From 19–30 October, Armenia will host the 17th UN Biodiversity Conference (COP17) in Yerevan. This year, the official slogan is ‘Taking action for nature’.
Yet just nine days before the conference opened, on 10 October, the Armenian government officially launched mining operations at the Amulsar gold mine. Prime Minister Nikol Pashinyan himself attended the opening ceremony near the spa town of Jermuk, claiming that the absence of protests around the opening proved that public concerns had been resolved.
Civil society organisations and environmental activists, however, have accused the Pashinyan administration of deliberately keeping the ceremony out of public view, arguing that the event had not been announced, so no one could gather to protest.
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At the same time, they have criticised the government’s heightened support for the Amulsar project, especially in the run-up to COP17, arguing that promoting mining in a sensitive ecological region contradicts Armenia’s international biodiversity commitments.
Indeed, while the government promotes a green agenda globally, local communities and environmental experts warn that the mine threatens endangered wildlife and vital water systems.
Removing ‘biodiversity obstacles’ by government decision
In March 2020, a coalition of Armenian and international environmental organisations, including Bankwatch, filed a complaint with the Secretariat of the Bern Convention on the Conservation of European Wildlife and Natural Habitats. They argued that the Amuslar mine directly threatened endangered wildlife and affects three candidate sites of the Emerald Network (a network of areas of special conservation interest set up under the Convention): Djermuk Area, Gorhajk Area, and Sevan National Park. The complaint notes that the area affected by the mine is home to a number of species listed as ‘strictly protected fauna’ under the Bern Convention, including the Persian leopard, bezoar goat, brown bear, Eurasian otter, and Eurasian lynx, and that mining would lead to habitat destruction and fragmentation of wildlife populations along the Amulsar mountain corridor.
Despite initial promises to abide by the findings of an independent, state-commissioned environmental audit, Pashinyan’s administration has repeatedly and actively promoted the Amulsar mine, disregarding any critical findings which highlighted flawed data on flora and fauna and the lack of biodiversity action and monitoring plans.
By late 2024, the government had acquired a 12.5% stake in Lydian Armenia, the company operating the mine, and in early 2025, it approved a $150 million state guarantee for loans from a local bank. In the meantime, Pashinyan’s administration disregarded the results of a government-commissioned international environmental audit. The 13-point document officially drafted in 2019 by the Ministry of Environment outlined instances of non-compliance and gaps in the Amulsar environmental impact assessment.
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Yet the environmental setbacks began over a decade ago. In one of the most important instances, in July 2014, the Armenian government adopted a decision to allow developers to relocate endangered plant species. Some critics have suggested this was designed to clear the way for the Amulsar gold mine by sidestepping domestic biodiversity conservation law. Although the Armenian Mining Code explicitly prohibits mining on land that is home to plant or animal species listed in Armenia’s Red Book, the decision authorised the relocation of Red Book plants such as Potentilla porphyrantha, which grows in the project area.
The timing of the decision was highly suspicious: it was adopted less than a month before the public hearing on the project’s environmental impact assessment. Without this legal loophole, the Amulsar mine may not have been able to proceed. By allowing endangered species to be moved to artificial ‘plant zoos’, the government undermined its own domestic laws as well as international treaties such as the Bern Convention, which protect the habitats of threatened species, not just individual plants.
Notably, the company itself pointed to the decision as a way around these legal barriers.
During a public hearing in the village Gndevaz in August 2014, the company responded to my question about Red Book plant and animal species by stating that the government had adopted a decision the prior month allowing such plants to be relocated from the Amulsar mining zone. As I argued at the time, I believe the decision was passed specifically to help the company bypass environmental protection laws and clear the area for mining infrastructure.
Offsetting on paper, not in practice
At the same time, both the government and COP’s formal agenda have highlighted biodiversity offsetting and market instruments such as private ‘nature credits’ as a method to protect biodiversity. In reality, however, these efforts risk legitimising efforts by corporations and banks to greenwash the loss of endangered habitats rather than halting ecological destruction at the source. Indeed, Target 19 of the Kunming-Montreal Global Diversity Framework, which calls for more finance from all sources, explicitly encourages ‘innovative schemes’ such as biodiversity offsets and credits. Armenia’s own experience shows how such schemes can play out in practice.
In December 2016, Lydian Armenia and the Ministry of Nature Protection signed a Memorandum of Understanding to establish Jermuk National Park as an offset for permanent ecosystem damage on Amulsar mountain, with the company pledging more than $5 million over five years. But the park’s boundaries were later redrawn to exclude the mine.
In October 2023, the Armenian government reported to the Bern Convention that the initiative to establish Jermuk National Park had been postponed due to ‘prevailing state priorities and regional instability’.
Then there is the Djermuk Area candidate Emerald site, which featured proposals to protect the whole area on the basis of a 2012 World Wildlife Fund-backed feasibility study. Now, once again, the government is proposing to cut Amulsar mountain out of that site too, so that it matches the smaller park.
In the case of the Teghut open-pit copper and molybdenum mine in northern Armenia, compensation for lost nature also failed. The mine required the felling of 357 hectares of rich forest, including 128,000 trees. Under the original project terms, the developer, Vallex Group, pledged to plant twice as many trees in adjacent areas to offset the ecological loss. Rather than carrying out the planting and long-term care itself, its subsidiary Teghout CJSC set up a tender committee to outsource the work. Environmental watchdogs and local groups long contended that the afforestation efforts fell short or failed. In 2019, the Prosecutor General’s Office opened a criminal case after state forest monitoring found that most of the trees planted on 132 hectares had not survived, even though officials of the state forestry agency Hayantar (ArmForest), which was contracted to do the work, had recorded it as complete. The case also found that the responsible ministries had failed to supervise the restoration.
All of these approaches are at odds with Article 9 of the Bern Convention, which sets out the only exceptions allowed from the protection of species — for example, in the interests of public health and safety, air safety, or other overriding public interests — and only where there is no other satisfactory solution. Offsetting the damage done by a gold mine is not one of them.
In April 2025, the Bern Convention’s monitoring committee reiterated its request for a new environmental impact assessment that considers all the species and habitats present in the area and asked the authorities to ‘suspend any permits for the exploitation of subsoil’ until the new assessment had been completed. The Armenian government disregarded the requests, maintaining in its September 2026 report to the Convention that the existing environmental impact assessment’s conclusion and national permits remain legally valid.
Notably, it is only now, on the eve of COP17, that the Jermuk National Park concept has been revived, with the government announcing at the mine’s launch that Lydian would put $5 million towards it — the same sum the company pledged a decade ago.
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In August 2026, Lydian and the government also signed a community development agreement for the Amulsar project. Under it, the company will pay $7 million or $9 million a year to affected communities, depending on the price of gold, through a new foundation. The arrangement goes beyond the social contributions mining companies are legally required to make, and risks becoming a new instrument that makes communities dependent on the company’s money.
At COP17, several events in the official negotiation venue will focus on the Bern Convention, bringing together country delegates, the Convention Secretariat, and accredited experts to discuss how to protect wild flora and fauna and their natural habitats. It is worth asking the Armenian representatives how they plan to address their persistent disregard for their Bern Convention commitments while simultaneously ‘taking action’ to protect biodiversity during their two-year COP presidency.