30art 05 02

There are few industries that are bound to have as significant an impact on the future of Armenia as mining. From opportunities for economic growth and job creation, to foreign investment and regional development, mining has the potential to play a significant role. However, current gaps in legislation, and a poor track record of assessment, monitoring and enforcement, present many risks too. Armenia is a highly urbanized nation with a small land area, so the impacts on the environment, society, economy and the rights of workers are multiplied and potentially catastrophic. 

When developing mining policies in Armenia there are several challenging questions that should be addressed. Are there reasons that compel Armenia to resort to mining? What are the environmental, economic, social and workers’ rights impacts of mining? Have the legacies of genocide, a centralized soviet economy, the Artsakh war, natural disasters, poverty and corruption driven Armenia to boost the economy through mining and is this justifiable? Does Armenia have some ‘responsibility’ to mine natural resources for the global and Armenian markets? Are there other industries that could substitute for mining and generate even greater economic and social outcomes without impacting the environment?

These are just some of the foundational issues that Armenian government policy makers should be considering as they forge a comprehensive mining policy. To its credit, the new government has taken some steps to improve financial transparency in the mining sector. It has also embarked upon a two year review of it’s mining sector policies and is currently running three simultaneous processes to further shape the future of mining in Armenia. 

  • An independent study on the economic impacts of the mining sector in Armenia (already contracted)

  • An independent study on the environmental and social impacts of the mining sector in Armenia (at proposal review)

  • The Extractive Industries Transparency Initiative (EITI), Armenia’s roadmap for responsible mining (a two-year process which has not yet commenced)

While these efforts are encouraging, there are urgent and pressing issues around which more immediate actions are required – and two years is a long time to wait.

As the Armenian government inches forward in assessing its policies on mining, the Mining Legislative Reform Initiative (MLRI) [1] has, in recent years, commissioned several independent international and domestic experts to review and assess the environmental, economic, social and workers’ rights related impacts of mining in Armenia.

Many of these studies can be accessed on the MLRI website. These together with other major studies including by the World Bank provide a strong foundation for solid, scientifically backed and responsible mining policies in Armenia. However, there is one missing piece which is an essential ingredient for the development of comprehensive public policy; a substantial, transparent and inclusive stakeholder consultation process.

Since October 2018, MLRI has initiated a civil society consultation process with the aim of developing comprehensive mining policy recommendations. The process is transparent and inclusive of all relevant and interested civil society representatives, academics and local community groups. It is designed to allow all participants multiple opportunities to contribute, influence and shape a consensus-based responsible mining policy.

Many leading civil society groups in this area, including the Armenian Environmental Front, Civil Voice and EcoRight, as well as experts such as Yerevan State University’s Dr. Harutyun Movsisyan, and the American University of Armenia Center for Responsible Mining’s Alen Amirkhanian have already provided significant input into the ongoing development of the MLRI’s responsible mining policy.

Their contribution has brought to our attention a tidal wave of legitimate concerns, some of which are captured below:


  • Due to inconsistencies in geographic information system (GIS) measuring techniques, some mining license holders lay claim to land that is dually reserved as Armenian national park land;

  • While the law requires that Environmental Impact Assessments (EIAs) be prepared before mine operations commence, the guidelines for preparing them are weak and they are not undertaken independently, but rather by the mining companies themselves; and

  • Some tailings dams in Armenia are not built to international best practice, and the rules for designing, building and assessing dams are inadequate.


  • The potential economic demise of the agricultural and tourism industries in areas close to mine sites is not appropriately assessed;

  • Compensation currently received by mine operators for environmental damages caused by mining operations in Armenia is insufficient; and

  • There is currently no sovereign wealth fund in Armenia for state revenues generated through mining operations.


  • There is an increased risk to public health caused by heavy metals and high levels of toxicity in the air, soil and water making their way into the food chain; and

  • While required by law, Health Impact Assessments (HIA) are often not undertaken by mining companies in Armenia as there are no implementation guidelines.

Workers’ Rights

  • Workplace injuries in Armenia are substantially more frequent in areas and regions which have significant mining operations;

  • Safety practices, training and compliance have not proven to result in substantial reductions in workplace injuries; and

  • Local staff hold fewer senior positions in Armenian mining companies and are less frequently promoted to managerial positions, stunting career progression.

This is just the tip of the iceberg when it comes to concerns held by civil society about mining operations in Armenia. In the coming weeks the MLRI will be running its final round of consultations to further consolidate this input, before launching and pitching its civil-society-led and scientifically-backed responsible mining policies to the Armenian government.


State Governance Failures in Mining and Lessons for Armenia’s Future

In his first piece for EVN Report. Alen Amirkhanian writes about the current state of the mining industry in Armenia. He argues that mining governance, from decision-making process on granting mining licenses, monitoring performance to ensuring compliance with laws and standards, is defective and in need of determined reform.

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Without doubt, many of the legacy issues in the mining sector are the result of policies adopted by previous governments. They were developed in close association with business, with little public consultation, and were driven by short term economic gain. For instance, from August 2015 to December 2017 the Armenian government placed a moratorium on environmental inspections of mine operations, preventing a proper and genuine assessment of the environmental harm resulting from the Teghut mine in Lori, where the mine’s catchment basin was overflown into the adjacent area. Reportedly, the moratorium was put in place to remove administrative and bureaucratic obstacles to business.

Earlier, in November 2014 the Amulsar mine was approved by the Ministry of Energy and Natural Resources of Armenia despite community concerns that sufficient studies were not undertaken to determine the mine’s impact on water quality at Jermuk and Lake Sevan.

The flow-on-effect of the government’s approach is that the public do not trust policy makers to act in their best interests when it comes to mining. The Pashinyan administration’s recent removal of Artur Grigoryan as Head of the Environmental Protection and Mining Inspection Body further raised public concerns. Grigoryan, with an education in law and a background in environmental activism was a strong proponent for responsible mining. He was due to reveal the results of the Inspectorate’s assessment of Armenia’s largest mine at Kajaran, before his dismissal in January 2019. The government cited Grigoryan’s performance in the role as it’s justification.

Whatever the real reason, building public confidence in the government’s mining policies may prove to be a herculean challenge for the Pashinyan administration. The advice that the government receives from business on mining, will inevitably need to be counterbalanced with the will of civil society and the expectations of the public, if the Pashinyan administration is to deliver a responsible mining policy and live up to its promise of building a new Armenia.


[1] The Mining Legislation Reform Institute (MLRI) seeks to ensure that mining in Armenia provides sufficient benefits to the country and local communities. It’s main activities include research, stakeholder consultation, policy development, public education, communications and advocacy. The MLRI is based at the American University of Armenia’s Center for Responsible Mining. 

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