On February 22, 2023, the RA government signed a tripartite memorandum of understanding with the Eurasian Development Bank and 'Lydian Armenia' CJSC to resume the exploitation of the Amulsar gold-bearing quartzite mine.
We, the representatives of the undersigned organizations and individuals, express our deep disappointment and displeasure over the RA government's illegal, short-sighted, irresponsible, adventurous, and dangerous decision to operate a mine in Amulsar.
The RA Government:
Failed to ensure the completion of a comprehensive environmental impact assessment, disregarding the 2019 results and conclusions of studies conducted by ELARD and TRC international companies, which cost $454,000 from the state budget.
Ignored the detrimental effects on water resources, including Lake Sevan, the Arpa and Vorotan catchment basins, Spandaryan and Kechut reservoirs, and underground water, leading to potential long-term pollution of surface and underground water due to acid drainage.
He ignored the risks associated with the radioactive elements present in the Amulsar mine, such as uranium, thorium, and radon, as well as the environmental pollution from dust laden with large amounts of toxic elements arising from the mine's operation. He also disregarded the dangers of using cyanide technology, which is banned in several countries.
It did not consider the detrimental impact on the city of Jermuk, a resort of international importance. Jermuk risks being transformed into an industrial town, leading to the emigration of its natives and leaving it deserted once the mine ceases operation.
The Minister of Health announced that the restart of the Amulsar project is not hazardous to health and has undergone appropriate examinations. This is not true, as 4 EIAs of the Amulsar project were not carried out in the examination processes, and examination could not be carried out in practice, as there is no appropriate methodology.
It did not take into account the possible negative impact on "Jermuk" mineral water, the international obligations undertaken in the field of biodiversity protection due to the Bern Convention.
It did not consider the resistance of the affected communities' population and the public's long-standing opposition to the Amulsar project. In the fall of 2018, around 3,000 residents from the extended community of Jermuk expressed their opposition to metal mining through a petition.
It either ignored or failed to evaluate the prior due diligence of 'Lydian Armenia' CJSC, the history of illegal activities, violence against citizens, legal prosecutions of citizens, and the repeated entrustment of public resources to a company registered in an offshore zone with unknown owners and in financial crisis.
It did not take into account the aggressive actions of Azerbaijan, including the September 13, 2022, invasion of the territory of the Republic of Armenia and the bombing of the city of Jermuk. According to the Amulsar plan, tens of thousands of tons of toxic and dangerous chemicals and explosives, lasting for hundreds of years, should be stored and used in the vicinity of Jermuk. In the event of military operations, these would pose a danger not only to Jermuk but also to Lake Sevan, the entire regions of Vayots Dzor, Syunik, and Ararat, and the Vorotan rivers, due to the pollution of catchment basins and the flow of polluted waters through the Arpa-Sevan tunnel towards Gegharkunik region. Claims that the implementation of the Amulsar project and the attraction of international investments guarantee security are baseless and manipulative. The area of the Sotk gold mine is regularly targeted; thus, international investment does not ensure curbing Azerbaijan's military ambitions. In the case of the Amulsar project, there is no guarantee that the same scenario will not be repeated, thereby increasing the targeting of Armenian territories.
By involving the Eurasian Development Bank for the purpose of financing the Amulsar project, he failed to assess the economic and political risks to the Republic of Armenia under the conditions of Western sanctions against Russia. The other major shareholders of the Eurasian Development Bank, Kazakhstan and Belarus, demonstrated a pronounced pro-Azerbaijani stance during the Armenian-Azerbaijani war. Engaging with a bank with such shareholders poses a direct threat to Armenia's security.
Instead of adopting a policy to restore the once-prosperous border resort town of Jermuk, to strengthen the resilience of the communities, and to secure the borders, the RA government prefers to sacrifice Jermuk and its well-established socio-economic system for the sake of 10-11 years of mining exploitation with the Amulsar development plan. This decision leads to several billion drams temporarily entering the state budget and the enrichment of several dubious offshore companies.
Considering the unmanageability of the risks of the Amulsar project, we are against the implementation of the Amulsar project.
We condemn to the President of RA
Guarantee the observance of the Constitution of the Republic of Armenia and international norms, and express an impartial position regarding the economic, environmental, social, and security risks threatening Armenia as a result of the Amulsar project's implementation, being guided exclusively by national and nationwide interests.
Support society in the fight against the dangerous program for the Republic of Armenia, prevent the violation of the RA Constitution, and ensure the protection of national security and the environment.
to the RA Ministry of Territorial Administration and Infrastructures
Terminate the subsoil use contract and the rights granted to 'Lydian Armenia' company, which were extended on 25.05.2022, due to the adoption of the anti-constitutional and anti-democratic RA Law 'On Making Additions and Amendments to the Subsoil Code'.
to the RA Ministry of Health
Publish the results of 'all examinations' carried out by the RA Ministry of Health on the impact of the Amulsar project and other mines on human health.
to the RA Ministry of Economy
Publish the tripartite memorandum of understanding signed between the Ministry of Economy of the Republic of Armenia, the Eurasian Development Bank, and 'Lydian Armenia' CJSC, as well as the agreement on the transfer of a part of the shares of 'Lydian Armenia' CJSC to the RA government.
to the RA Ministry of Environment
Repeal the environmental due diligence given for the Amulsar project in 2016, taking into account the incompletely assessed risks and emerging environmental factors.
to the RA General Prosecutor's Office
Initiate a criminal case to identify all individuals responsible for participating in and permitting the environmental impact assessment and expertise failures that laid the foundation for the problematic advancement of the Amulsar project.
to RA government
Abandon the Amulsar mine development project until financing is received, investments are made, and the Republic of Armenia has not assumed the financial burden of paying for the losses.
to international organizations accredited in RA
To support the implementation of human rights and democratic processes in Armenia for the sake of the Republic of Armenia and the security of its citizens.
Transparency International Anti-Corruption Center
"Community Consolidation and Support Center" NGO
"Ecological Law" NGO
"Democratic Platform" Foundation
"Human Rights Research Center" NGO
"EcoLur" information NGO
"Green Armenia" environmental, educational NGO
"Forests of Armenia" environmental NGO
Armenian Environmental Front Volunteer Initiative
"For Equal Rights" Educational Center NGO
Freedom of Information Center
"Helsinki Association" human rights NGO
"White Helsinki Group" human rights NGO
"Janus" Legal NGO
"Vayots Dzor Evolution" NGO
"Dalma-Sona" educational, cultural, socio-environmental fund
"Ecological Public Union" NGO
"Club of Journalists "Asparez"" NGO
"Vanadzor Office of the Helsinki Civil Assembly" NGO
Zaruhi Hovhannisyan, human rights defender
Nikolay Davtyan, director
Roza Julhakyan, expert
Law Development and Defense Fund
"Peace Dialogue" NGO
"Strong of Law" NGO