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Why the Ministry of Energy and Natural Resources of RA is concerned about the demand of civil society to hold discussion on the problems in the field of underground mining?

Environmental Public Alliance
From the Members of the Environmental Public Alliance and the Armenian Aarhus Centers


     We, a number of NGOs of Environmental Public Alliance and private members concerned with the nature conservation, representatives of the Armenian Aarhus Centers, have sent a letter in12.05.2014 congratulating Yervand Zakharyan on the occasion of assuming high position of the Minister of Energy and Natural Resources at the RA Government, and expressed willingness to meet and interact, being sure that the newly appointed minister could not remain indifferent to the intense and indiscriminate use of the natural resources becoming tradition in recent times in Armenia, as well as to the gross violations in the field of mining legislation and created environmental catastrophic situation. But our action of sense of civic duty, which was aimed at protecting the country’s national wealth, and coming out of the situation, remained unanswered. Up to date has not been given response to our letter, it has just disappeared.

In the letter addressed to the newly appointed minister Yervand Zakharyan was stated: “Today, at this responsible moment, we consider necessary to meet with you and present our concerns, offer our participation and support in anticipation of further joint work for the sake of country’s prosperity.”

We want to say at once that we are not sure that our proposal on cooperation has been ignored by Yervand Zakharyan. We tend to think that the issues that have been brought up in the letter, was not pleased the State Mining Inspectorate and Subsoil Concession Agency of the same ministry, as in our letter enumerating the main flaws at the same time we have pointed out, that for the emerged situation is responsible the Subsoil Concession Agency, where are formed and approved legislation bypassing documents.

The fact that not reaching our letter coincides exactly with the assumption of high government positions by Hovik Abrahamyan, Prime Minister of the RA and minister Yervand Zakharyan we consider as a good indicator for us, as during the reign of the former government and the Minister Armen Movsisyan have not been lost any letter, but simply due to the efforts of the Subsoil Concession Agency and indifference and inaction of the Minister Armen Movsisyan, we always received evasive answers to our questions and legal violations were qualified as a misunderstanding.

As a result, nothing had been changed.
Here is the incomplete list of illegalities and irregularities, which we presented in our letter addressed to the Minister Yervand Zakharyan:
- Mineral extraction without a draft, lack of inspections
- Neglect and violations of contractual obligations,
- Re-registration of mining license for the companies previously failing to comply with the contractual obligations
- Granting mineral prospecting licenses for industrial purpose which dates are going out the limit permitted by law
- Gross violation of working draft and contract on mining exploitation; opencast mining instead of underground mode of operation in accordance with the contract
- Existence of unrecultivated tailing dumps, lack of tailing dumps security certificates.

We reiterate one more time that all of this leads to an unacceptable violation of landscapes, contamination of soils and waters as a result of spreading heavy metals and toxic elements from the mine, destruction of arable lands, natural ecosystems, decline of soil fertility and loss of national wealth.

Honorable Mr. Yervand Zakharyan we are once again forced to appeal indirectly, in the form of a statement.
Mr. Minister, for re-establishing the legality in the field of the mining industry, preservation of subsoil-our national wealth and for the sake of prosperity of our country, we hope that under your leadership the ministry will be reorganized, will be identified and resolved the previous illegalities and the exploitation of the natural resources of the Republic of Armenia will be proceed in a new way.

Silva Adamyan
Coordinator of Environmental Public Alliance
Yerevan 09.06.2014
Translated by Anush Beybutyan