On August 1, 2024, RA Environment Ministry issued a negative opinion to the environmental impact assessment application submitted by "Ord" LLC of Karmirsar limestone marl (pumice stone) mine in Ararat Region.
As a rationale for rejection, the opinion states:
There was a discrepancy in the information in the EIA related to the realization of extracted raw materials. According to the report, the mineral is planned to be mined on site, but during the public discussion it was revealed that it is planned to build a cement factory next to the mine and transport all the mineral there. Many of the residents expressed their displeasure since vehicles transporting extracted and later processed raw materials will pass through the territory of several settlements, causing social impacts, and the construction of an alternative road is not planned in the EIA report.
During the expert examination, opinions were received regarding the presence or absence of the habitat of red-listed plants and animal species in Armenia in the requested area. According to the letter received WWF Armenia and the opinion received by the Environmental Protection Department of Environment Ministry, the mentioned area of Karmirsar, Ararat Region, is the habitat of a number of endangered plant and animal species, which are red-listed in Armenia, and some of them are red-listed in the International Union for Conservation of Nature (IUCN) (a total of 14 plant species and 16 animal species).
To verify the information regarding the presence or absence of red-listed species, the EIA package was sent to Takhtajyan Institute of Botany of NAS RA, where conflicting opinions were received. In the letter dated on June 11, 2024, it was noted that there are no data on the growth of rare red-listed plant species in the area proposed for the mine. Whereas the letter dated on June 19 says that the institute conducted a botanical survey in the areas between 18.08.23-23.08.23, the same letter also noted the need for additional botanical research in the early spring (April, May) based on the region from the early vegetation period of plants.
In its letter dated July 23, 2024, "Ord" company submitted to the expert examination information that as a result of the research conducted by the researchers of Takhtajyan Institute of Botany of NAS RA, no rare red-listed plant species were found in the area of Karmir, Ararat Region, but 16 red-listed plant species grow in Yerakh (Boz-Borun) mountain range, but the period of research was not mentioned in the letter.
The institute's opinion cannot be considered valid and reliable, because the flowering and fruiting period of some plant species is in May-June, therefore, only their root systems or seeds could have been preserved in the soil during the observations made in August. Taking into account the abovementioned, it should be noted that any activity that will lead to the reduction in the number of species red listed in Armenia and the deterioration of their habitats is prohibited, in accordance with Article 18 of RA Law "On Fauna" and Article 17 of RA Law "On Flora".
During the examination, 16 complaints were received in the form of a petition (with around 1150 signatures on behalf of the residents of Aygezard settlement of Artashat community), which also served as a ground for drawing up the expert opinion. The petition states that the mine area is located in the immediate vicinity of agricultural lands and the operation of an open pit mine can cause damage and contain environmental risks both for the environment and for agricultural activities in the surrounding areas, and residents have expressed their opposition to the implementation of mining operations in the area. The dissatisfaction of the residents and the interested public was also expressed during the 4th public discussion."
August 06, 2024 at 16:07