Mr. Prime Minister!

We, the undersigned civil society organizations operating in the Republic of Azerbaijan, address this letter to you expressing the deep concerns regarding the serious ecological crisis caused by the regional and global effects of the works carried out in the mining industry of the Republic of Armenia on the environment by grossly violating international environmental norms and standards.

Regarding the growing environmental problems in the country, we share their deep concern of the civil society organizations of Armenia, as well. Degradation of the ecosystem as a result of ongoing mining operations is not only a threat to Armenia's environment, but also a great threat to the neighboring countries. The transboundary nature of environmental damage puts the health and well-being of communities in the region and beyond at risk.

We demand the cessation of the mining industry, which violates international environmental norms and standards and the rights of the region's population.

We note that the Sustainable Development Goals (SDGs) of the United Nations provide a comprehensive framework for solving environmental, social and economic problems. UN member states have recognized clean air, safe drinking water and sanitation as environmental factors of health. At the same time, the UN recognizes a clean, healthy and sustainable environment as a basic human right. However, by committing these environmental crimes, Armenia violates the UN's Sustainable Development Goals, especially the 3rd on "Good Health and Well-being", the 6th on "Clean Water and Sanitation", the 12th on “Responsible Production and Consumption”, and 16th on the "Climate Change the 13th Goals on "combating the consequences of climate change" and the 15th Goals on "Protection of the Earth 's Ecosystem", and the 15th goal on “Protecting the Soil Ecosystem.

We call on the Republic of Armenia to immediately stop the activities of the following enterprises that seriously damage the ecosystem in the region:

1. Chromium, nickel, copper, molybdenum, zinc, aluminum, vanadium, lead and other heavy metal-containing mining wastes from the Zangezur Copper-Molybdenum Combine in Gajaran and the mining combine in Gafan are polluting the Okchuchay and Araz rivers. 60% of Zangezur Copper-Molybdenum Combine's shares are owned by Germany's “Cronimet Mining GmbH". An average of 20 million tons of ore is processed here during the year without following any environmental norms . The 270-million-square-meter Artsevanik reservoir, which is the mine tailings pool of the combine, is a big threat to the entire region;

2. Since 2019, the Gafan mining complex has been part of the British company "Chaarat Gold International Limited" and is currently called "Chaarat Kapan". During the year, an average of 1.3 million tons of ore is processed here. The Gutgum (Qeganush) mining waste deposit, which covers an area of 4.6 million square meters within the Gafan mining complex, poses a threat to the region;

3. Mining waste containing heavy metals from Akarak (Agarak) Copper-Molybdenum Combine also poisons the Araz River through Karchivanchay. The US company "Comsup Commodities" bought all the shares of the combine and became its full shareholder. During the year, an average of 4 million tons of ore is processed here. According to the information, approximately 36.8 million cubic meters of hazardous waste in the Davazam waste warehouse of the combine are collected. The water from the waste reservoir flows into the transboundary Araz river;

4. During the occupation, the Armenian authorities illegally put the Zod (Sotk) field of Kalbajar, located on the border with Azerbaijan, into the full exploitation of the "GeoProMining" company. In 2009, 320,500 tons, 490,000 tons in 2010, and 880,000 tons in 2011 were processed in Davali (Ararat) gold processing plant. As a result, the Zod (Sotk) River near the mine was polluted with heavy metals such as copper, iron, cadmium and molybdenum. Considering that the polluted Zod (Sotk) River flows into the Kur River, this is a great threat to the lives of millions of people. In 2018, the European Court of Human Rights issued a decision regarding the violation of ecological balance rights by Armenia for polluting the region by allowing the operation of this mine;

5. European Court of Human Rights issued six decision against Armenia on February 14, 2019, found the exploitation of illegal mining industry on the lands of the residents of the villages of Shinikh (Shnogh) and Tugut (Teghout), who appealed to the court, and in this regard, the Armenian government was requested to pay compensation in the amount of 69,400 euros to the affected villagers;

6. The Dashdam (Dashdam) Gold Mine in Goyce (Sevan) produces about 10,000 ounces of gold per year. Mining continuously pollutes the local water supply. A high concentration of heavy metals such as arsenic and mercury, harmful to human health and the environment, was found in the mine's wastewater. The mine's wastewater poisons nearby rivers, including the main source of fresh water, the Barghushad (Vorotan) River. Barghusad (Vorotan) river flows into Araz river. The mine is managed by the Canadian company "Lydian International";

7. Akhtala mine in Lori region of Armenia produces about 5 thousand tons of copper and lead per year. A high concentration of heavy metals such as copper, lead and zinc harmful to human health and the environment was found in the mine's waste water. The mine is managed by "Metal Prince" company. Wastewater from the mine pollutes the nearby Tona (Debed) river. That river flows into the Kur river. Akhtala mine was closed in 2017 due to environmental problems. However, in 2020, the mine was restored for the operation;

8. Gafan Manganese Plant is one of the largest manganese plants not only in Armenia, but also in the world. The plant produces manganese ore, manganese dioxide and other manganese products, with an annual output of about 1.5 million tons of ore. During the extraction and processing of manganese ore, heavy metals, dust and other pollutants are released into the air and water. These pollutants cause a number of health problems, including respiratory problems, neurological diseases and cancer. The plant also significantly pollutes the nearby Barghushad River, an important source of drinking water for the South Caucasus region;

9. Eller (Gotayq) plant is a metallurgical plant that produces copper, zinc and lead. The factory contaminates Arpachay river with heavy metals such as copper, lead and cadmium that have a negative impact on human health. The plant produces large amounts of air pollution, including sulfur dioxide, nitrogen oxides and particulate matter. This pollution adversely affects human health, causing respiratory problems, heart diseases and other serious diseases. The factory discharges its waste water to Arpachay, the main source of drinking water. A large amount of solid waste rich in heavy metals generated in the factory pollutes the soil and seeps into the groundwater;

10. Goyche (Gegharkunik) Copper Smelting Plant is one of the main copper smelting plants in Armenia. It produces about 100,000 tons of copper per year. The plant belongs to "GeoProMining" company of Armenia. The plant emits large amounts of sulfur dioxide and other pollutants into the atmosphere, causing air pollution and acid rain. The factory discharges its waste water to Arpachay, the main source of drinking water. Arpachay, in turn, carries pollutants to Araz. Sewage water destroys aquatic life in Arpachay. Goyce (Gegharkunik) Copper Smelting Plant is a source of great danger to the environment and human beings;

11. The construction of a new metallurgical plant in Arazdeyan (Yeraskh), which is being built against the requirements of environmental norms and international conventions, should also be stopped. The potential impacts of toxic chemical waste from this metallurgical plant on the local ecosystem could be enormous. The discharge of waste into the Araz River means a tragedy for the creatures living in the river and for the large farms that use the Araz water for irrigation. This impact on drinking water supplies can also lead to the spread of infectious diseases in border areas. This will create a serious public health crisis for both Azerbaijan and Armenia;

12. Mining wastes containing heavy metals formed as a result of the operation of the Amuldagh (Amulsar) gold deposit, whose activities have been protested many times by international organizations, are also being discharged into the Bargushad (Vorotan) River and polluting the Araz River through the Hakari River. The gold mining industry has caused environmental pollution that transcends national borders. Thus, the mine leaves behind a large amount of waste rock and waste piles, which pollutes the soil and leads to a high acceleration of the erosion process in the mountains. Such exploitation of the Amuldagh (Amulsar) gold deposit is a serious threat to the region surrounded by the Caucasus mountains and its population;

Amuldag field is located 13 kilometers away from the city of Istisu (Jermuk) which is a natural mineral water. The deposit is also located in the area between Arpachay and Bazarchay. Both rivers pass through the territory of Azerbaijan and flow into the Araz river. The use of toxic substances, which have been banned for a long time in the exploitation of the Amuldag field, which pose a high threat to the environment, destroys nature, causes acidification of river waters and water poisoning. In addition to gold mining polluting the waters of this river, it also has a negative impact on the ecosystem of Lake Goycha (Sevan), which is the largest freshwater lake in Armenia, located near the area.

At the same time, this industry poses a serious threat to the Caspian Sea basin. Arpachay and Bazarchay, which flow from the territory of the Nakhchivan Autonomous Republic of the Republic of Azerbaijan, flow into the Araz River and from there into the Caspian Sea. Thus, it seriously damages the ecology of not only Azerbaijan, but also Iran, as well as other Caspian countries.

The gold deposit is operated by "Lydian Armenia" company. The full shareholder of this company is "Lydian International" of Great Britain. The main shareholders of the company are "Orion Mine Finance" (USA), "Resource Capital Funds" (USA), "Merk Investments" and "Tocqueville Asset Management LP".

The 12 facts listed above are only a visible part of the environmental disasters that have occurred, there are so many cases that we are aware. It is known that some times ago, more than 60 civil society organizations operating in Armenia addressed to you and warned that the work of the Amuldagh (Amulsar) mine will cause a great damage to the environment, and therefore the Armenian authorities should cancel the decision to resume its activity, the prosecutor's office should check the results of the expertise regarding the impact of the mine on the environment.

Mr. Prime Minister!

Transboundary Rivers Convention, which entered into force in 2014, are grossly violated by the Armenian government. The purpose of the Convention is to ensure fair and sustainable use of transboundary watercourses. This Convention envisages working closely with and taking into account the views of affected communities if water resources pose a risk to social, economic and environmental development. However, the Armenian government has not taken into account the concerns of Azerbaijanis and even Armenians living in neighboring villages in the organization of the mining industry, which may affect the fresh water resources of the region, and has not involved them in the environmental assessment process.

The UN Guiding Principles on Business and Human Rights set out a framework for promoting responsible behavior in business, including the mining industry. These principles emphasize the need for companies to protect human rights, prevent negative environmental impacts, and communicate with affected communities in a transparent, inclusive manner.

With the exploitation of the above-mentioned mines, the Armenian government clearly ignores the provisions of the UN Economic Commission for Europe Convention on Environmental Impact Assessment in a Transboundary Context (Espoo Convention). The Espoo Convention acknowledges that environmental matters transcend national borders and emphasizes the necessity of international discourse when multiple states are involved in specific cases.

The Aarhus Convention plays an important role in ensuring access to information, public participation and justice in environmental issues. As a signatory to this convention, Armenia must fulfill its obligations by ensuring that the population of the affected region has access to information on mining activities, participation in decision-making processes, and ways to eliminate environmental damage.

We call on the government of Armenia to create an enabling environment for civil society organizations and local communities to actively participate in dialogue and decision-making processes related to mining. As Canadian professor Steven Emerman says, “The truth is that all sulfide mines cause water pollution. Wherever there is a mining industry, there is a danger of constant pollution of water with waste.

We call on all stakeholders, including foreign companies engaged in mining in Armenia to adapt their activities to these principles and integrate them into their operational practices. We invite those who invest in field exploration and production to be aware of the environmental disaster they are creating and to act responsibly.

Mr. Prime Minister!

As it is known from the above-mentioned facts, Armenia's mining industry has caused a serious environmental disaster in the South Caucasus region.

We appeal to you to open the doors of all mining industry facilities of Armenia to experts specialized in the field of ecology and health, civil society organizations of Azerbaijan specialized in this field, taking into account the international standards and principles listed above, to allow them to inspect the facilities, evaluate and create full conditions for monitoring, taking appropriate samples, and measuring.

We also recommend that you create appropriate platforms for dialogue and consultation to strengthen trust, inclusion and shared responsibility. Demonstrate political will and leadership to ensure transparency and accountability in the mining industry, implement necessary reforms, and ensure the disclosure of timely, reliable and comprehensive information on the extractive industry.

We call on the Armenian government for responsible management, to immediately stop the work in the mining industry that threatens our region and our planet, and to make decisions that ensure sustainable development and a healthy future for the people of the region.

Signatures:

1. Executive Director of “Saglamliga Khidmat” Public Association - Parvana Valiyeva

2. Vise-chair of “Experts in the Field of Water Use” Public Association - Amin Mammadov

3. Chairman of “Ecologist-2010” Environmental Awareness Public Association - Salim Balayev

4. Chairman of “Biosphere” Public Association - Gorkhmaz Ibrahimli

5. Chairman of “Shafag” Ecotourism Public Association - Vamig Babayev

6. Chairman of Patient Organizations’ Union and Hemophilia Patients’ Public Association - Ayaz Huseynov

7. Chairperson of Environmental Education and Monitoring Public Association - Gamza Yusubova

8. Chairperson of Pediatric Cardiology and Rheumatology Public Association - Sveta Rafiyeva

9. Director of “Towards TB free World” Public Association - Chingiz Ramazanli

10. Chairman of “Green World” Public Association of Environmental Awareness - Elman Jafarli

11. Chairperson of “Socioeconomic and Ecological Development” Public Association - Rahila Mehdiyeva

12. Chairman of Ecological Information Public Association - Musa Muradli

13. Chairman of “Towards a Healthy Life” Public Association - Sadig Hasanov

14. Chairperson of “Woman Initiative for Development” Public Association - Ziba Nabiyeva

15. Chairperson of Social Aid to the People with Hearing and Speech Disabilities Public Association - Jamila Abdulova

16. Chairperson of “Fight against Leukemia” Public Association - Mehriban Bagirova

17. Director of “Ecoleks” Environmental Law Center Public Association - Sevil Isayeva

18. Chairperson of “Support for the Development of Sustainable Tourism" Public Association - Narmina Garibova

19. Chairperson of “Health and Healthy Life” Public Association - Alizada Cahangir

20. Chairman of “Eco-TES” Environmental Research and Education Public Association - Chingiz Nazarov

21. Chairman of “Mother Kura” Public Association of Support for the Study of Environmental Problems - Rustam Malikov

22. Chairperson of “For Development and Welfare” Public Association - Zamina Safarova

23. Executive director of “Fight against Infectious Diseases” Public Association - Amina Karimli

24. Chairperson of “Sky and Eco” Public Association of Support for Social Economic Development - Irada Hasanova