The Ministry of Environment takes note of the open letter sent by a number of alleged “civil society organizations” operating in the Republic of Azerbaijan referring to an alleged “serious environmental crisis caused by the regional and global environmental impact of the activities carried out in the mining industry of the Republic of Armenia”.
The allegations in the letter are manifestly false. This is not the first time that Azerbaijan—whose own record on environmental issues is notoriously poor—has sought to use alleged “civil society organizations” to make false accusations against Armenia for public relations purposes.
Just last December, Azerbaijan organized and directed many of the very same types of organizations to hold so-called environmental “protests” blocking the Goris-Stepanakert highway, thereby cutting off the 120,000 ethnic Armenians of Nagorno-Karabakh from the outside world and causing serious consequences to the environment in Artsakh.
That such “protests” were pretextual and in reality led by Azerbaijan can be seen from the fact that the “protesters” dispersed as soon as Azerbaijan was able to replace them with a Government checkpoint impeding traffic along the same road.
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The claims made in the open letter are entirely without foundation and are unworthy of a response. The Ministry of Environment nonetheless wishes to briefly make the following points:
With respect to the alleged pollution of water resources (mentioned in the preface of the open letter and its points 1-3), the Ministry notes that there are water quality monitoring points in all transboundary sections of rivers in Armenia, where the monitoring of all water quality parameters, including heavy metals, is carried out at monthly intervals. According to the law, mining enterprises monitor water quality and atmospheric air and soil pollution, and the results are submitted to the Ministry in the form of quarterly and annual reports, which are then published. At the same time, Armenia is the only member country of the “Extractive Industries Transparency Initiative” in the Caucasus region, which proves the importance Armenia accords to open and accountable management of natural resources.
In response to point 4 of the open letter, the Ministry observes that the ”Sotk” gold mine was lawfully assigned to the Armenian Soviet Socialist Republic in 1964, and so it now belongs to the Republic of Armenia on the basis of succession. The open letter is simply wrong that the European Court of Human Rights has ruled that Armenia has violated “rights to ecological balance”; no such decision exists.
Point 5 of the open letter misrepresents the judgments of the European Court of Human Rights of 14 February 2019.
In those judgments, the Court accepted that the implementation of the Teghout copper‑molybdenum deposit exploitation project was in the public interest. It granted compensation to Armenian nationals only because their properties had been expropriated for this project. Contrary to what the open letter states, the Court did not consider the mining activities in question to be illegal.
The mine with the name mentioned in point 6 of the letter is neither located in nor operated by the Republic of Armenia.
As for the Akhtala Ore Processing Combine mentioned in point 7 of the letter, it is being operated with a new technology, which does not provide for the use of tailings.
The factory with the name mentioned in point 8 of the open letter is neither located in nor operated by the Republic of Armenia.
What is mentioned in point 9 of the open letter does not correspond to reality, because there is no factory engaged in the production of copper, zinc and lead in the Kotayk region of the Republic of Armenia.
Point 10 of the open letter is also not true, because there is no copper smelter in the Gegharkunik region of the Republic of Armenia.
As for the Eraskh factory, it fully complies with international environmental standards. On June 15, the Ministry of Environment issued a detailed explanation on this (http://www.mnp.am/news/yeraskh-15-06-2023).
As for the Amulsar mine, it has not yet entered the operational phase, so there is no question of any contamination. And when it begins operation, the highest international benchmark of environmental risk management will be followed, and its implementation will be strictly monitored, including by international organizations.
It should be noted that the water leaving the borders of Armenia corresponds to international norms. This was proven years ago, when the Center for Ecological-Noosphere Studies National Academy of Sciences, with the support of the North Atlantic Treaty Organization (NATO), conducted studies on 40 indicators at border points for 6 years, applying the same methodology adopted jointly with neighboring countries within the framework of the project.
