The Bern Convention Bureau Calls upon the Armenian Government to Halt Construction of the Gold Mine on Mt. Amulsar and Revise the ESIA 

The Standing Committee of the Bern Convention (on the Conservation of European Wildlife and Natural Habitats) convened its 43rd session from November 27 to December in Strasbourg. One of the agenda items of the session was regarding Amulsar. The Bern Convention is one of the most important international conservation instruments, which is a binding document for all member states of the Council of Europe. The Convention is ratified by Armenia and obligations on the part of the government set out by the convention have a legal force. 

We would like to hereby bring the results of the session and the recommendations and observations of the Standing Committee to public attention.

1. The Armenian authorities should halt the construction of the Amulsar gold mine which could negatively affect the habitats and species protected under the Convention, whether pertaining to an Emerald Network site or not, also highlighting the recent evidence of the remerging presence of the Persian Leopard which is critically endangered in the region, as well as other recent biodiversity findings. 
2. The Committee invited the Armenian authorities to revise the existing ESIA for the gold mine, in light of the recent biodiversity findings, and expertise of the local scientific and civil community, and possible transboundary impacts. 
3. The Armenian authorities were asked to speed up the declaration process of Jermuk National Park which was planned back in 2012 and included Amulsar mountain. In 2015-16 “Jermuk Area” and “Gorayk Area” Emerald sites were proposed. The Committee expressed its concern that the processes to drastically reduce the territory of the Emerald Network in Armenia, including the protected area where the Amulsar mine is located, were ongoing. It called for Armenia to consider this process very carefully, as such reductions in territory could be very detrimental for the sufficiency of the pan-European Network of Protected Areas. 
4. The Committee urged strong efforts to involve civil society more closely in the processes related to Amulsar and Emerald Network rather than leading processes behind closed doors. 
5. The Committee is also concerned with an unprecedented number of strategic litigations against public participation (SLAPPs) against independent experts, lawyers and journalists who opposed the project.

1. The Committee recalled its Recommendations No. 208 (2019) and No. 157 (2011, revised 2019) regarding Emerald Network sites, and encouraged the authorities to remain in close contact with the Secretariat during this process and if need be to ask for technical assistance.
2. The Committee took note of the request of the complainant to mandate an on-the-spot appraisal (OSA) to the site. However, due to the ongoing processes and assurances of the Armenian government, decided to postpone a decision on this until 2024. Meanwhile, the Government of Armenia and the complaintants were invited to send progress reports to the Spring Bureau in 2024 with information on the two separate issues of the Amulsar Gold mine, and the Revision of the candidate Emerald sites in Armenia.

The full list of decisions and texts adopted by the Standing Committee during the 43rd Session are available on the website of the Council of Europe, with sections pertaining to Armenia and Amulsar to be found on page 20, Clauses 181-189.  

To read more on the history of the complaint brought to the Bern Convention Body and the plans of the Armenian government to reduce the territory of the Emerald Network, please read the public stance of the Armenian Environmental Front disseminated in March 2023. 

The struggle for Amulsar has now reached a phase, when the Armenian Government is obliged, by force of international law, to stop any mining activities on Mt. Amulsar and to conduct a new, accurate, science-based environmental and social impact assessment, something the company holding mining licenses failed to do previously.

 

The full list of documents pertaining to the complaint can be found here. 

Yerevan, December 7, 2023 

Armenian Environmental Front volunteer initiative