...This document is a critical analysis, with regard to the impacts on biodiversity, of the Environmental and Social Impact Assessment (ESIA) of the Amulsar Gold Project. It adds new circumstances that require resumption of the ESIA procedure. The analysis was prepared by experts of Balkani Wildlife Society (Bulgaria) as requested by and with the support of CEE Bankwatch Network and EcoLur Informational NGO in support of the implementation of Chapter 3 (Environment) of the Comprehensive and Enhanced Partnership Agreement between the European Union and the Republic of Armenia (CEPA)...

The analysis of the Environmental and Social Impact Assessment (ESIA) of the Amulsar Gold Project prepared by Balkani Wildlife Society (Bulgaria) adds new circumstances that require the permits of the project to be annulated and the impact assessment procedure to be started from the beginning. With regards to biodiversity the permissions to develop the project were granted by the Government of Armenia in violation of the Bern Convention and the Armenian legislation...

[W]e include evidence on the pollution of the Arpa river during construction, when many fish died in 2018. The ESIA did not predict these damages. In letter H/A-2018/59 from 19.06.2018 of Lydian and letter 16.1/111/511-18 from 02.11.2018 of the Inspection Body this pollution is proven.

Thus, the decision of the EIA Expertise and all mining permits were given in violation of the Bern Convention, the RA Subsoil Code, the Law "On Flora", the Law "On Fauna", the Law on EIA and Expertise and should be canceled.