Civil Society Representatives Call for Suspension of Amulsar Mine

Civil Society Representatives Call for Suspension of Amulsar Mine

Representatives of Armenian civil society and citizens concerned about environmental issues have issued a statement condemning the launch of operations at Amulsar gold mine.

The statement says:

Ahead of COP17: Launch of Amulsar Mine and Undermining of Armenia’s International Commitments

We, the undersigned representatives of non-governmental organisations and citizens concerned about the state of the natural environment, condemn the launch of operations at Amulsar  gold mine in the absence of any realistic, evidence-based response to the significant environmental and socio-economic concerns raised for years.

On 10 October 2026, just days before the 17th meeting of the Conference of the Parties to the UN Convention on Biological Diversity (COP17), to be held in Yerevan, the Armenian Government officially announced the opening of Amulsar mine and held a ceremonial event. This was an extremely brazen and irresponsible step. Prime Minister Nikol Pashinyan attended the ceremony, which featured the display of a gold bar produced through the full industrial processing cycle. This display dealt a direct blow to the entire COP17 process and to Armenia’s standing as the country presiding over COP17. While Armenia seeks to present itself to the international community as a country committed to a green agenda, the launch of an environmental disaster is being set in motion at home, blatantly violating obligations undertaken under international conventions and calling into question the sincerity of the Government’s environmental goals and statements.

For years, we have repeatedly raised and sought to draw the attention of the Government of Armenia and various financing stakeholders to the key legal and environmental risks associated with Amulsar  mining project. Some of these are outlined below.

Failure to honour international commitments. Through numerous decisions, the Standing Committee and Bureau of the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) have called on the Government of Armenia to halt all work at Amulsar, conduct a new Environmental Impact Assessment (EIA) for the mine, review and approve the list of Emerald Network sites of special conservation value, and establish Jermuk National Park as a biodiversity conservation area. The Committee’s position clearly states that these measures can be implemented while the mine remains non-operational. In its communications with the Bern Convention Secretariat, the Ministry of Environment of Armenia reported that work was under way to improve Amulsar  project and noted that the expert assessment findings of ELARD and TRC had been submitted to the relevant state institutions for professional evaluation. The launch of mining operations undermines any dialogue between the Armenian Government and the Bern Convention and damages Armenia’s international standing.

Disregard for officially documented deficiencies. The Armenian Government is deliberately disregarding a key official document commissioned by the Government itself: the 2019 report by ELARD and TRC on the impacts of Amulsar  gold mine on water resources, geology, biodiversity and air quality. The report systematically identified dozens of major omissions, miscalculations and inaccuracies in the existing EIA documentation for Amulsar, including errors in water resource modelling, miscalculations of acid rock drainage, failure to account for seismic risks, deficiencies in biodiversity assessments and other critical issues. Moreover, this study and all documents related to the associated criminal case have been removed from official websites.

Irreversible environmental disaster. Numerous Armenian and international experts believe that the cyanide-based method used to extract gold at Amulsar is one of the most hazardous chemical processes, and that any accidental or other release could endanger the ecology of the Arpa River. They have also presented compelling evidence that operating Amulsar  mine would entail an extremely high and long-term risk of acid rock drainage, threatening the Arpa and Vorotan rivers, the entire Lake Sevan ecosystem via the Vorotan–Arpa–Sevan tunnel, Jermuk’s mineral waters and other groundwater resources in the region.

Threat to the resort town of Jermuk. Jermuk risks being transformed from a sustainably developing resort destination into a temporary mining settlement. The town’s environment is already deteriorating as a result of construction and blasting activities carried out for the mine. Once the mineral reserves are depleted and short-term profits cease, the town faces the prospect of becoming another abandoned and depopulated settlement, like Dastakert and Sotk.

The Government of Armenia is increasingly losing touch with the public and with an understanding of the public interest. The public response was clear as early as 2019, when Prime Minister Pashinyan first attempted to persuade the public to accept the opening of Amulsar  mine. Civil society has repeatedly voiced its opposition since then, including in response to the transfer of 12.5% of Lydian Armenia’s shares to the Government of Armenia as a “gift”.

The Government’s actions concerning Amulsar—including its blatant disregard for public opinion and human rights, and its lack of accountability—indicate that public authorities have adopted a pattern of behaviour reminiscent of previous administrations, which led to their loss of legitimacy and triggered a broad wave of public protest.

Armenia’s natural environment, water resources and the future of its communities must not be put at risk without public accountability and an adequate demonstration of safety.

We consider the disregard for these risks of public importance unacceptable. Within the framework of COP17 and other international forums, we will submit this statement and the supporting documents to relevant international organisations and partners, calling on them to take practical steps within their mandates to prevent potentially severe and irreversible environmental damage.

Our Demands

We call for the following measures:

1․ Immediately suspend mining operations and all work aimed at developing the mine, while maintaining the necessary measures to ensure site safety and prevent pollution, and review the decisions authorising the mine’s operation.

2․ Ensure proper implementation of the recommendations of the Bern Convention Bureau, including conducting a new Environmental Impact Assessment and suspending all subsoil-use permits until the new EIA process has been completed.

3․ Justify the list of Emerald Network candidate sites and report on progress towards establishing Jermuk National Park within its originally approved boundaries, which include Amulsar. Any changes to the boundaries must be justified solely by scientific, rather than economic or political, considerations and must comply with internationally accepted procedures.

4․ Publish the measures taken in response to every significant issue identified by ELARD, TRC and state authorities, along with any resulting changes to project documentation or reports that the Government of Armenia considers to have “eliminated” the risks.

5․ Review, through established procedures, the AMD 150 million guarantee provided by the Republic of Armenia to Ameriabank to finance the operation of Amulsar  mine, and terminate the state’s participation in this disastrous project.

6․ Reconsider Armenia’s mining policy, ensuring that future decisions are based on meaningful public participation, a robust EIA process, water security, biodiversity conservation and the long-term well-being of communities.

Signatories: Organisations, Initiatives and Citizens

  1. Sona Ayvazyan — Transparency International Anti-Corruption Center NGO; member of the Multi-Stakeholder Group (MSG) of the Extractive Industries Transparency Initiative (EITI) in Armenia
  2. Artur Grigoryan — Environmental Law NGO; EITI MSG member
  3. Viktorya Burnazyan — EcoLur Informational NGO; EITI MSG member
  4. Oleg Dulgaryan — Community Mobilization and Support Center NGO; EITI MSG member
  5. Hripsime Kocharyan — Successful Woman NGO; EITI MSG member
  6. Arsen Arsenyan — Healthy Environment NGO; EITI MSG member
  7. Inga Zarafyan — EcoLur Informational NGO
  8. Tehmine Yenokyan — Green Armenia NGO
  9. Garegin Miskaryan — “+374 Political Self-Determination Club” NGO
  10. Levon Galstyan — Armenian Environmental Front volunteer initiative
  11. Anna Shahnazaryan — Armenian Environmental Front volunteer initiative
  12. Ani Khachatryan — Armenian Environmental Front volunteer initiative
  13. Arpine Galfayan — Armenian Environmental Front volunteer initiative
  14. Arax Melkonyan — Protection of Rights Without Borders NGO
  15. Genya Petrosyan — Law Development and Protection Foundation
  16. Levon Barseghyan — Asparez Journalists’ Club
  17. Shavarsh Margaryan — Citadel NGO
  18. Federation of Green Councils environmental activist movement
  19. Healthy Hrazdan civic initiative
  20. Zaruhi Hovhannisyan — New Culture of Justice NGO
  21. Anahit Simonyan — Human Rights Research Center NGO
  22. Varduhi Tsolakyan — Founder of ORBIS NGO; Federation of Green Councils
  23. Hayk Abrahamyan — Federation of Green Councils
  24. Anna Maralyan — Law Center NGO
  25. Karine Margaryan — Helsinki Association for Human Rights NGO
  26. Zhanna Aleksanyan — Journalists for Human Rights NGO
  27. Natalia Martirosyan — Armenian Committee of the Helsinki Citizens’ Assembly
  28. Gayane Abrahamyan — For Equal Rights Educational Center NGO
  29. Varduhi Ananyan — Cinemart Youth NGO
  30. Vigen Mnatsakanyan — Beekeeping Development and Training Center NGO
  31. Arpine Khachafyan — Koriz Aygezard Youth and Community Development Center NGO
  32. Ani Sargsyan — Impulse Youth NGO
  33. Naira Nahapetyan — Safe Corner Social and Educational NGO
  34. Angela Stepanyan — Regional Sustainable Development NGO
  35. Tigran Matevosyan — Armash Rural Communities Support and Development Center NGO
  36. Ruzanna Ghazaryan — Citizen of the Republic of Armenia, legal expert, Class II Civil Service Counsellor; Dalma-Sona Educational, Cultural, Social and Environmental Foundation
  37. Gevorg Kotanjyan — Direct Democracy NGO
  38. Maya Barkhudaryan — Civil Society Institute NGO
  39. Mher Karagozyan — Public Oversight NGO
  40. Shushanik Harutyunyan — Armenian Climate Justice Initiative
  41. Arpine Yeritsyan — Civic Youth Center NGO
  42. Amalia Hambardzumyan — Khazer Environmental and Cultural NGO
  43. Henrik Mkrtchyan — Citizen of the Republic of Armenia
  44. Gayane Shagoyan — Citizen of the Republic of Armenia
  45. Lala Aslikyan — Citizen of the Republic of Armenia
  46. Nina Mamajanyan — Citizen of the Republic of Armenia
  47. Gor Hakobyan — Citizen of the Republic of Armenia
  48. Artsrun Andreasian — Farmer
  49. Seryan Yenokyan — Citizen of the Republic of Armenia
  50. Hermine Martirosyan — Citizen of the Republic of Armenia
  51. Anna Hovsepyan — Citizen of the Republic of Armenia
  52. Varduhi Barseghyan — Citizen of the Republic of Armenia
  53. Mariam Mkrtchyan — Citizen of the Republic of Armenia
  54. Harutyun Babajanyan — Citizen of the Republic of Armenia
  55. Nina Martirosyan — Citizen of the Republic of Armenia
  56. Lusine Galstyan — Citizen of the Republic of Armenia
  57. Hrach Gevorgyan — Citizen of the Republic of Armenia
  58. Ani Avetisyan — Citizen of the Republic of Armenia
  59. Elena Amiryan — Citizen of the Republic of Armenia
  60. Gevorg Aslanyan — Citizen of the Republic of Armenia
  61. Husik Martirosyan — Citizen of the Republic of Armenia
  62. Roza Julhakyan, expert
  63. Satik Badeyan, " “Center for Territorial Development and Research” NGO
  64. Mariam Yeganyan, Founder of “Loreni” tea house
  65. Nazeli Vardanyan, "Forests of Armenia" NGO.

October 12, 2026 at 17:18