A few days ago, the civil society faction of the Multistakeholder Group (MSG) of the Extractive Industries Transparency Initiative (EITI) made a statement regarding the adoption of RA governmental resolution "On Approving Mining Sector Development Strategy and Action Plan Arising from It". The statement was followed by the response of RA Ministry of Territorial Administration and Infrastructure addressed to Sona Ayvazyan, Executive Director of Transparency International Anti-Corruption Center. Today Multistakeholder Group (MSG) of the Extractive Industries Transparency Initiative (EITI) made an additional statement, which says:
"On May 12, 2023, after the publication of the statement by the civil society faction of the Multistakeholder Group (MSG) on May 11, the response by RA Ministry of Territorial Administration and Infrastructure was received in response to our letter written on August 26, 2023, regarding which observations are presented below:
1. RA Ministry of Territorial Administration and Infrastructures stated in its response that it submitted to RA Ministry of the Environment all four versions of the strategy for the development of the mining industry, probably considering that thus it fulfilled the requirement of RA Law "On Environmental Impact Assessment and Expertise " on conducting strategic environmental assessment (SEA).
On August 20, 2022, in our comments on the fourth version of the strategy for the development of the mining industry, we suggested to the ministry that this document should still undergo SEA, but this was not considered.
It is obvious that the requirements of RA Law "On Environmental Impact Assessment and Expertise" have been ignored, moreover, RA Ministry of Territorial Administration and Infrastructure, as well as RA Ministry of Environment, which is the competent body of this law, have shown inaction.
The ministry notes that focus group discussions and round tables were held with the civil society in Syunik and Lori Regions. Although the range of invitees has not been specified, according to our information, organizations/groups active in the mining industry, representatives of scientific and educational institutions, other affected regions and affected communities, who could have made a significant contribution, were not invited to the discussions on the strategy development.
As for the public discussion of the draft strategy, we would like to inform you that it was only posted on the e-draft website, and no hearings were organized despite the public interest in the given topic.
Thus, at the session of the RA government on May 11, incorrect information was presented regarding the implementation of public discussions, misleading RA government, RA citizens, and partners of the World Bank.
3. We claim that in the process of developing the mining strategy, only the members of the civil society faction of the Multistakeholder Group (MSG) of the Extractive Industries Transparency Initiative (EITI) were invited, which, however, we do not consider to be effective enough.
4. Considering that the Ministry of Territorial Administration and Infrastructures has expressed readiness to meet with the representatives of civil society, we accept this invitation. We urge the discussion to be organized as inclusively as possible.
We are urging once again:
To annul the decision of RA Government adopted on May 11, 2023 on the grounds of contradicting the Aarhus Convention and RA Law "On Environmental Impact Assessment and Expertise" in accordance with Article 38 (1) of RA Law "On Normative Legal Acts" and again refer to the given document after the due process established by law;
To the Ministry of Territorial Administration and Infrastructure and the Ministry of Environment: to start SEA process, including within its framework, organizing appropriate public discussions with the participation of civil society interest groups and duly taking into account the opinions presented.
EITI MSG Civil Faction Members
Victoria Burnazyan, "EcoLur" Informational NGO
Oleg Dulgaryan, Center for Community Mobilization and Support
Nazeli Vardanyan, "Forests of Armenia" NGO
Anahit Simonyan, Human Rights Research Center
Suren Nersesyan, Yerevan State University
Sona Ayvazyan, Transparency International Anti-Corruption Center".
May 17, 2023 at 12:20