Days before COP17 opens in Yerevan, the reopening of the Amulsar gold mine brings the Bern Convention’s recommendations and Armenia’s biodiversity commitments into focus. With the Bern Convention’s requests for a new environmental impact assessment, a Jermuk National Park and revised Emerald Network boundaries still unmet, the question for Armenia, as the country presiding over COP17, is whether its commitments to nature will be matched by action.
Amulsar Reopens on the Eve of COP17
On 10 October 2026, just days before the 17th meeting of the Conference of the Parties to the UN Convention on Biological Diversity (COP17) in Yerevan, the Armenian Government officially announced the opening of the Amulsar gold mine and held a ceremony. Prime Minister Nikol Pashinyan attended the ceremony, which featured the display of a gold bar produced through the full industrial processing cycle. This display dealt a direct blow to the entire COP17 process and to Armenia’s standing as the country presiding over COP17.
The Bern Convention Complaint
In 2020, Bern Convention Secretariat received the complaint “The Amulsar gold mine project and its impacts on Emerald Network sites” submitted by the EcoLur Informational NGO, the Armenian Forests NGO, the Green Armenia NGO, and the CEE Bankwatch Network. According to the complaint, the project affects an area of 1,946 hectares, three Emerald Network sites, three Important Bird Areas, a Ramsar wetland of international importance, and 24 species listed as threatened or near-threatened on the IUCN Red List.
The complaint lists the main risks for biodiversity: habitat destruction, dust and water pollution, the killing of animals and plants, fragmentation of the Amulsar Mountain wildlife corridor, and disturbance and poaching. Species at risk include the Persian leopard, grey wolf, bezoar goat, Eurasian otter, Eurasian lynx and brown bear.
The complaint review process spanned six years, during which both the Government-represented by the Ministry of the Environment-and the complainants submitted annual reports.
Bern Convention Requirements and the Ministry’s Responses
In 2026, the Standing Committee of the Bern Convention argued for concrete requirements for the Ministry of Environment:
Regarding the new EIA on Amulsar, the Ministry answered that the current EIA conclusion and related national permits on Amulsar remain in force.
Regarding the Emerald Network, the Ministry answered: Armenia continues the revision of its candidate Emerald Network sites and duly notes the Bureau’s request to conclude consultations and submit an updated database, including the revised boundaries.
Regarding the Jermuk National Park, the Ministry answered: “The Jermuk national park process is in an active phase.”
Environmental Assessment: Questions That Remain
The Amulsar project also highlights serious risks identified in previous expert assessments. The 2019 ELARD–TRC independent review questioned the reliability of the project’s environmental assessment, particularly its treatment of acid rock drainage, groundwater conditions, contaminant pathways and potential impacts on the Arpa, Vorotan and Darb rivers and Kechut Reservoir.
The project’s scale makes these unresolved issues particularly significant. The project’s scale makes these unresolved issues particularly significant.
According to the State environmental expertise conclusion, the project involves the extraction of approximately 89,376,300 tons of ore containing 73,733 kilograms of gold (at a reported grade of 0.78 g/t) and 294,367 kilograms of silver (at a reported grade of 9.29 g/t). The document also reports an overburden volume of 106,490,056 cubic metres. However, earlier sources suggest that the total mass of overburden could reach 250–300 million tons.
Cyanide heap leaching, acid rock drainage, dust emissions, seismic hazards, and possible contamination of surface and groundwater pose potential long-term risks. The project may also affect protected wildlife and habitats, disrupt ecological connectivity and undermine Jermuk’s health-resort economy, which depends on the region’s natural environment and water resources.
A separate 2019 letter from Environment Minister Erik Grigoryan to the Prime Minister’s Office identified 13 issues requiring attention, including inconsistent water-quality modelling, inadequate hydrological calculations, underestimated climate extremes, seismic assessment gaps and concerns about radiation-related information. Despite these findings, the Government has not required a new EIA before extraction (the letter is the Annex 1 of the Complainant report, September 2026).
The Government’s reliance on post-approval monitoring cannot replace a preventive assessment of environmental impacts before extraction begins. Without a new EIA, scientifically justified Emerald Network boundaries, and effective protection of the Jermuk area, the full consequences of the project remain insufficiently assessed, particularly the risks of environmental degradation, biodiversity loss, water and soil contamination by cyanide and toxic metals, potential radiation pollution, and damage to Jermuk’s spa resort and health tourism.
Public Participation and the Road to Reopening
Amulsar is also a case study in the relationship between mining policy, environmental governance and public participation in Armenia. Legislative amendments adopted in 2022 enabled the extension of the project’s subsoil-use rights without a new EIA, despite years of suspension caused by public protests. The project has generated sustained resistance from residents of Jermuk and neighbouring communities, as well as legal actions against activists, journalists and residents.
In 2018, residents of Jermuk and Gndevaz staged protests against the Amulsar gold mine project, blocking all roads leading to the mine. “Amulsar must remain a mountain!” demanded the defenders of Amulsar.
Lydian has initiated legal action against activists-defenders ofof Amulsar seeking the retraction of their statements (which the company alleges constitute defamation) and claiming compensation of 1,000,000 – 6,000,000 drams-an amount that, in most cases, exceeded the defendants' income.
In January 2024, the Government of Armenia received a 12.5% stake in Lydian Armenia as a donation from the company, further deepening its involvement in the project. In 2025-26, Lydian Armenia reopened its activities at Amulsar.
Looking Ahead: Amulsar and the COP17 Agenda
The Amulsar case has evolved from a local environmental conflict into one of Armenia's most significant environmental and social governance cases. What began as community opposition to a proposed gold mine developed into sustained civil disobedience, legal and administrative challenges, international complaints, and scrutiny by international financial institutions and the Bern Convention.
The Bern Convention must not remain isolated in its demands upon the Armenian government. International organizations making decisions within the framework of COP17 must focus on a key issue: the genuine protection of remaining natural areas across the globe. Armenia is one such place - a region where endangered species must receive protection. Parties, observers and the CBD Secretariat should raise Amulsar openly with the host government during the conference, and the Bern Convention Standing Committee’s recommendations should serve as a benchmark for Armenia’s COP17 commitments.
Civil Society Calls for Suspension
On 12 October 2026, two days after the ceremony, more than 60 representatives of Armenian NGOs and concerned citizens, including EcoLur, Transparency International Anti-Corruption Center, the Environmental Law, Green Armenia, Armenian forests NGOs issued the statement “Launch of Amulsar Mine and Undermining of Armenia’s International Commitments”. They describe the timing of the opening as “brazen and irresponsible” and argue that the Bern Convention steps, including a new EIA, the review of Emerald Network sites and the establishment of Jermuk National Park, can go ahead while the mine is not yet operating. They also warn of risks from cyanide-based extraction and long-term acid rock drainage to the Arpa and Vorotan rivers, Jermuk’s mineral waters and regional groundwater.
The signatories demand that the Government:
The signatories plan to submit the statement and supporting documents to international organizations and partners during COP17 and other forums.
As COP17 opens in Yerevan, the host government’s response to the Bern Convention’s three requests will show whether Armenia’s commitments to nature extend beyond the conference hall.
The struggle for Amulsar continues.
The content of the publication is the sole responsibility of the authors and can in no way be taken to reflect the views of the Heinrich Böll Foundation Yerevan Office – South Caucasus Region.