A group of civil society organizations and individuals have condemned the operation of the Amulsari mine, issuing a statement on the matter. The statement is below.

 

 A statement by representatives of civil society in Armenia 

 

THE STATEMENT

 

On the eve of COP17: The start of the Amulsari mine's operation 

and the failure to meet Armenia's international obligations

We, the undersigned representatives of civil society organizations and concerned citizens, we condemn the start of gold mining at Amulsar, in the absence of any realistic and substantiated rebuttal to the fundamental environmental and socio-economic concerns that have been raised for years.  

On October 10, 2026, on the occasion of the 17th Conference of the Parties to the UN Convention on Biological Diversity to be held in Yerevan, Just a few days before COP17, the official announcement and grand ceremony by the Government of Armenia for the opening of the Amulsari mine is a highly audacious and irresponsible move. The ceremony, attended by Armenian Prime Minister Nikol Pashinyan, was accompanied by a display of a gold ingot, the product of the entire industrial cycle. This display directly struck the entire COP17 process and the reputation of Armenia as the country presiding over COP17. As the presiding country of COP17, Armenia is trying to present itself to the international community with a green agenda, while at home, the start of an ecological disaster is being set in motion, grossly violating the commitments undertaken under international conventions and calling into question the sincerity of the government's environmental goals and declarations.

For years, we have been repeating and trying to bring to the attention of the Government of Armenia and various funding partners the main legal and ecological risks associated with the Amulsar mining project. Some of them are listed below:

• Failure to fulfill international obligations: The European Convention on the Conservation of Wildlife and Natural Habitats (Bern Convention) The Standing Committee and the Bureau of the Convention on European Wildlife and Natural Habitats (Bern Convention) have, in numerous resolutions, called on the Government of Armenia to halt all work at Amulser and to conduct a new environmental impact assessment for the mine's operation. (EIA), revise and approve the list of areas of special conservation value of the Emerald Network and designate the "Jermuk" National Park as biodiversity conservation areas. The Committee's position clearly states that this is possible as long as the mine is not in operation. In communication with the Secretariat of the Bern Convention, the Ministry of Environment of Armenia has stated, that remedial work is underway on the Amulsari project and stressed that the findings of the ELARD and TRC organizations have been provided to the relevant state institutions to provide a professional assessment.  The start of the mine's operation undermines any dialogue with the Government of Armenia within the framework of the Bern Convention and damages our country's international reputation.

• Ignoring officially recorded violations: The Government of Armenia is intentionally ignoring a key official document it developed on its own initiative— the 2019 report by ELARD and TRC on the impacts of the Amulsari gold mine on water resources and geology, biodiversity, and air quality, which systematically identified dozens of major omissions, miscalculations, and inaccuracies in Amulsari's current EIA documents, relating to the mismodeling of water resources, miscalculations of acid drainage, disregard of seismic risks, biodiversity assessments, and other critical issues. Furthermore, this study and all documents related to the associated criminal case have been removed from official websites.

• An irreversible ecological disaster. Many domestic and foreign experts believe that, that the cyanide method used for gold extraction at Amulsar is one of the most dangerous chemical processes, and that in the event of a spill from an accident or any other cause, the ecology of the Arpa River will be endangered. They have also convincingly argued that the operation of the Amulsari mine will create an extremely high and long-term risk of acid rock drainage, threatening the Arpa and Vorotan rivers, through the Vorotan-Arpa-Sevan tunnel, to the entire Lake Sevan ecosystem, as well as to the mineral waters of Jermuk and other groundwater in the region. 

• The resort city of Jermuk is in danger. Jermuk will be transformed from a sustainably developing resort into a temporary mining settlement. The city's ecology is already deteriorating due to the construction and blasting work being carried out for the mine's operation. After the mine's reserves are depleted and the short-term profits cease, we face the fate of having another abandoned and deserted settlement (like Dastakert and Sotk).

The Armenian government is increasingly losing touch with the public and an understanding of the public interest. As early as 2019, when Prime Minister Pashinyan first tried to persuade the public to accept the opening of the Amulsar mine, the public's reaction was clear. Subsequently, civil society has repeatedly voiced its protest, including over the fact that 12.5% of the shares of the Lydian Armenia company were "gifted" to the Government of Armenia.  

The government's actions on the Amulsari issue—a blatant disregard for public opinion and human rights, The unaccountable conduct demonstrates that public authorities have adopted the same behavior characteristic of their predecessors, which led to the delegitimization of power and sparked a widespread wave of public protest. 

Armenia's environment, water resources, and the future of its communities cannot be jeopardized without proper justification for public accountability and safety.

We consider the disregard of these public-interest risks to be unacceptable. Within the framework of COP17 and other international forums, we will present this declaration and the supporting documents to the relevant international organizations and partners— demanding that they take practical steps within their authority to prevent possible severe and irreversible environmental damage.

We demand:

1. Immediately halt the mining operation and related activities, while maintaining necessary measures for site safety and pollution prevention, and review the decisions that permitted the operation. 

2. Ensure the proper implementation of the recommendations of the Bureau of the Bern Convention, namely: conduct a new environmental impact assessment and suspend all mining permits until the new EIA process is completed. 

3. Justify the list of Emerald Network candidate areas and report on the progress of establishing the Jermuk National Park within its originally approved area, which includes Amulsar. Any change to the borders can be justified only on scientific, not economic or political, grounds and in accordance with internationally permissible procedures. 

4. Publish the measures taken regarding each significant issue recorded by ELARD, TRC, and government bodies, and the resulting changes made to the project documents or reports, which, in the opinion of the Government of Armenia, "mitigated" the risks.

5. Review, through established procedures, the $150 million budget guarantee provided by the Republic of Armenia to Ameriabank for the financing of the Amulsari operation and terminate the state's participation in this disastrous project. 

6. Review Armenia's mining policy, making proper public participation, a quality EIA process, water security, biodiversity conservation, and the long-term well-being of communities the basis for future decisions.

Signing organizations, initiatives, and citizens:

1. Sona Ayvazyan, Transparency International Anti-Corruption Center NGO, Member of the Extractive Industries Transparency Initiative (EITI) Multi-Stakeholder Group (MSG) in Armenia

2. Arthur Grigoryan, "Ecological Law" NGO, Member of the EITI Multi-Stakeholder Group (MSG)

3. Victoria Bournazyan, EkoLur Information NGO, Member of the EITI Multi-Stakeholder Group

4. Oleg Doulgarian, Community Mobilization and Support Center NGO, Member of the ACHTN Multi-Stakeholder Group

5. Hripsimé Kocharyan, "Successful Woman" NGO, Member of the ACCM Multi-Stakeholder Group

6. Arsen Arsenyan, "Healthy Environment" NGO, Member of the ACCM Multi-Stakeholder Group

7. Inga Zarrafyan, "Ekolur" Information 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. Araks Melkonyan, "Human Rights Protection Without Borders" NGO

15. Zhenia Petrosyan, "Foundation for the Development and Protection of Rights"

16. Levon Barseghian, "Asparentz" Journalists' Club

17. Shavarish Margaryan, "Citadel" NGO

18. "Alliance of Green Councils" eco-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, Alliance of Green Councils

23. Hayk Abrahamyan, Alliance of Green Councils

24. Anna Maralyan, "Center for Law" NGO

25. Karine Margaryan, Helsinki Association 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, "CinemaMart" youth NGO

30. Vigen Mnatsakanyan, "Center for Beekeeping Development and Training" NGO

31. Arpine Khachatryan, "Koriss" Aygezard Youth and Community Development Center NGO

32. Ani Sargsyan, "Impulse" Youth NGO

33. Naira Nahapetyan, "Safe Corner" Social-Educational NGO

34. Anzhela Stepanyan, "Regional Sustainable Development" NGO

35. Tigran Matevosyan, "Armash" Center for Support and Development of Rural Communities NGO

36. Ruzanna Ghazaryan, citizen of the Republic of Armenia, lawyer, 2nd class consultant of the civil service, "DALMA-SONA" educational, cultural, social, and ecological foundation

37. Gevorg Kotanjyan, "Direct Democracy" NGO

38. Maya Barkhudarjan, "Civil Society Institute" NGO

39. Mher Gharakhoyan, Public Control NGO

40. Shushanik Harutyunyan, Armenia Climate Justice Initiative

41. Arpine Yeritsyan, "Civil Youth Center" NGO

42. Amalia Hambardzumyan, "Khazers" eco-cultural NGO

43. Ashen Babayan, "Spitak Helsinki Group" human rights NGO

44. Artur Sakunts, Vanadzor Office of the Helsinki Citizens' Assembly

45. Nazeli Vardanyan, "Forests of Armenia" NGO

46. Henrik Mkhitaryan, "Green Change" NGO

47. Satik Badeyan, "Regional Development and Research Center" NGO

48. "Pink" Human Rights NGO

49. "Blejhan" NGO

50. Henrik Mkrtchyan, citizen of Armenia

51. Gayane Shagoyan, citizen of Armenia

52. Lala Aslikyan, citizen of the Republic of Armenia

53. Nina Mamajanian, citizen of the Republic of Armenia

54. Gor Hakobyan, citizen of the Republic of Armenia

55. Artsrun Andriasian, farmer

56. Seryanz Yengoyan, citizen of the Republic of Armenia

57. Hermine Martirosyan, citizen of the Republic of Armenia

58. Anna Hovsepian, citizen of the Republic of Armenia

59. Varduhi Barseghyan, citizen of the Republic of Armenia

60. Mariam Mkrtchyan, citizen of the Republic of Armenia

61. Harutyun Babajanyan, citizen of the Republic of Armenia

62. Nina Martirosyan, citizen of the Republic of Armenia

63. Lusine Galstyan, citizen of the Republic of Armenia

64. Hrach Gevorgyan, citizen of the Republic of Armenia

65. Ani Avetisyan, citizen of the Republic of Armenia

66. Elena Amiryan, citizen of the Republic of Armenia

67. Gevorg Aslanian, citizen of the Republic of Armenia

68. Houssik Martirosyan, citizen of the Republic of Armenia

69. Arman Karagulyan, citizen of the Republic of Armenia

70. Azat Hovhannisyan, citizen of the Republic of Armenia

71. Mary Khachatryan, citizen of the Republic of Armenia

72. Mary Poghosyan, citizen of the Republic of Armenia

73. Anush Sargsyan, citizen of the Republic of Armenia

74. Mariam Yeganyan, citizen of the Republic of Armenia

75. Liana Harutyunyan, Associate Professor, Researcher

76. Anush Sargsyan, researcher, Mesrop Mashtots Institute of Ancient Manuscripts (Matenadaran)

77. David Matevosyan, "Pakhra" NGO

78. Seda Grigoryan, director

79. Ani Kojoyan, specialist in women's rights research

80. Susanna Gulamirian, Director of the Laboratory of Art and Cultural Studies

81. Zaruhi Muradyan, Member of the Artists' Union Council, Artist

82. Svetlana Galstyan, Institute of Consciousness, specialist in consciousness development programs