On February 2023 the Government of Armenia, the Eurasian Development Bank and “Lydian Armenia” CJSC signed a trilateral Memorandum of understanding on the restart of mine development program at Amulsar auriferous crystal deposit.


We, the undersigned organizations, and individuals, hereby express our deep disappointment and discontent with the RA Government’s illegal, short-sighted, irresponsible, opportunistic and state-endangering decision regarding the mine operation at Amulsar.

The Government of Armenia has FAILED to:

  1. Conduct a fully-fledged environmental impact assessment; it disregarded the results and conclusions of the respective studies by ELARD and TLC international organizations in 2019, that had been paid $454 000 USD for their services from Armenia’s budget
  2. Take into consideration the negative impact on the water resources, such as Lake Sevan, basins of Arpa and Vorotan rivers, Spandaryan and Kechut water reservoirs, the underground waters and the long-term pollution of the surficial and underground waters caused by acid and metalliferous drainage.
  3. Consider the radioactive risks at Amulsar deposit, since it contains uranium, thorium, and radon; as well as the enormous masses of toxic dust that will rise and pollute the environment, should the mine be enacted. The cyanide technologies, banned in many countries globally, as well as the relevant risks, have also been neglected.
  4. Take into account the risk of losing Jermuk as a globally renowned spa and resort town. It's doomed to turn into a worker settlement, with the local population subsequently emigrating and the workers leaving it, too, upon the depletion of the deposit.
  5. Evaluate the health impact of the project. The minister of Health announced that the Amulsar project development is not hazardous for health and that the project had undergone the relevant expert assessments. This is not true, since either of the four environmental impact assessments conducted, contains any health hazard evaluation. This couldn’t have been feasible, since no respective methodology is available.
  6. Assess the negative impact of the project on “Jermuk” mineral water and consider Armenia’s commitment on preserving the biodiversity as per the Bern Convention on the Conservation of Wildlife and Natural Habitats.
  7. Take into account the continuous public resistance to the Amulsar project that the local community residents have been incessantly manifesting for years. In the fall of 2018 around 3 000 residents of the enlarged Jermuk community signed a public petition against metal mining industrial deployment in their territory.
  8. Consider or do the due diligence with regard to “Lydian Armenia” CJSC’s style of conduct in the past-with all the illegal actions, violence towards citizens, the malicious practice of prosecuting people in courts that the company accounts for. Thus, the public resources were trusted to an offshore-registered company with unknown owners and financially challenging state of affairs.
  9. Give consideration to Azerbaijani aggression, the penetration of Azeri troops to Armenia’s territory on September 13, 2022, and the missile strikes on the town of Jermuk. According to the Amulsar project, there will be thousands of tons of poisonous and hazardous chemical substances that take centuries to disintegrate as well as explosives accumulated near the town of Jermuk. In the event of military actions, not only will this endanger Jermuk itself, but may cause, due to the leakages, the pollution of Lake Sevan, the entire Vayots Dzor, Suiniq and Ararat regions, where Arpa and Vorotan are the main water resources. Gegharquniq marz is running the same risk, because of Arpa-Sevan tunnel pollution. The statements regarding international investments as a safeguard to Amulsar project implementation are manipulative and lack any factual grounds. We are witnessing regular attacks in the Sotq gold mine territory, which clearly shows that no international investments can retain the Azerbaijani aggression. As for the Amulsar project, there is no evidence that a similar scenario can be avoided, and that Armenia’s territory is going to be less vulnerable because of the project.
  10. For the purposes of funding the Amulsar mining project, the Eurasian Development Bank was involved. The Government of Armenia failed to evaluate the political and economic risks of EDB’s involvement given the Western sanctions against Russia- a major stakeholder of the bank. Kazakhstan and Belarus, the other two large stakeholders of the Eurasian development Bank, have manifested a clear pro-Azerbaijani position during the recent war between Armenia and Azerbaijan. So, any deals with a bank with such stakeholders, would present a threat to Armenia’s security.


The Government of Armenia, instead of adopting a policy to revitalize the once flourishing and now a borderline resort town of Jermuk, instead of restoring the normal life, empowering the community, and improving the borderline security, is now engaging in Amulsar mining project. In doing so, the government prefers to ultimately sacrifice Jermuk and its established social and economic systems for the sake of 10–11 years of revenues from the mining activity, for the sake of several billion drams to temporarily replenish Armenia’s budget, for the sake of prosperity of a few offshore entities.


Considering the Amulsar project risks are non-manageable, we are against its deployment.

We demand
from the President of the Republic of Armenia:

  • To comply with the Armenian Constitution and international norms and manifest an unbiased position regarding the economic, environmental, social and security risks for Armenia in the event of Amulsar mine operation. In doing so, we demand that the President of Armenia is guided solely by state and national interests.
  • To assist in struggling against a project that presents an Armenia-wide hazard, to disallow the violation of the RA Constitution, to ensure the national security and environmental protection.

from the Ministry of Territorial Administration and Infrastructure:

  • To terminate the mining and land use contract and rights provided to “Lydian Armenia” that were extended on May 25, 2022 due to the anti-constitutional and antidemocratic RA law “On Amendments and Changes to be introduced in the Mining Code”.

from the RA Ministry of Health:

  • To publicize the results of “relevant expert evaluations” that the Ministry of Healthcare carried out with regard to human health impact assessment for Amulsar project and other mines.

from the RA Ministry of Economy:

  • To publicize the trilateral Memorandum of Understanding signed between the RA Ministry of Economy, the Eurasian Development Bank and “Lydian Armenia” CJSC and the agreement on the transfer of shares from “Lydian Armenia” CJSC to the RA Government.

from the RA Ministry of Environment:

  • Deem to have lost force the environmental expert assessment of Amulsar project dated to 2016, considering the under assessment of risks and the newly emerged environmental factors.

from the RA Prosecutor General’s Office:

  • To initiate a criminal case and investigate all the responsible parties that permitted and/or were involved in compiling the compromised environmental impact assessment and expert opinions that laid foundations for an outrageous project of Amulsar and its advancement.

from the RA Government:

  • To renounce the Amulsar mine development project, before it is funded, before the investments are made, before the RA Government shoulders any financial liability for the indemnity of losses.

from the international organizations in Armenia:

  • To support the human rights protection and democratic processes for the sake of security of Armenia and its citizens.

1. Transparency International Anticorruption Center
2. “Center for Community Mobilization and Support” NGO
3. “Environmental Rights” NGO
4. “Democratic Platform” Foundation

5. “Human Rights Research Center” NGO
6. “Ecolur” Informational NGO

7. “Green Armenia” Environmental, Educational NGO
8. “Armenian Forests” Environmental NGO
9. “Armenian Environmental Front” volunteer organization
10. “For Equal Rights” Educational NGO
11. “Freedom of Information Center of Armenia” NGO
12. “Helsinki Association” human rights NGO
13. “Helsinki Group Spitak” human rights NGO

14. “Janus” legal NGO
15. “Vayots Dzor Evolution” NGO
16. “Dalma-Sona” Educational, Cultural, Social and Environmental Foundation
17. “Environmental non-governmental Society” NGO
18. “Journalists Club Asparez” NGO
19. “Helsinki Citizen’s Assembly- Vanadzor” NGO
20. Zaruhi Hovhannisyan, human rights advocate
21. Nikolay Davtyan, film director
22. Roza Julhakian, expert
23. Law Development and Protection Foundation
24. “Peace Dialogue” NGO

25. “Human Rights Power” NGO

The statement is open to join.