Erik Grigoryan


Erik Grigoryan

“We Should be Both Optimistic and Ambitious”

Environment protection has become a central issue for all societies and states across the world, and Armenia is not an exception. Amulsar, Sevan, burning forests, and the global question of climate change: all these issues have been at the headlines of news for several months. Regional Post spoke with the Minister of Environment Erik Grigoryan to shed light on the approaches and views of the Ministry on these matters.

Interview : Arshak Tovmasyan    Photo : RA Ministry of the Environment


Globally speaking, recently, Armenia participated in the UN Climate Change Summit. What did we learn and what is the role of Armenia in the solution of these global issues?

First, I would like to mention that Armenia is actively engaged in the processes happening on the international climate and environment platforms. We signed and ratified the Paris Agreement setting the stage for climate action. Armenia is, perhaps, one of the pioneers when it comes to active engagement with large climate funds, such as the Green Climate Fund (GCF). The GCF is the largest climate fund, whose platform will play a key role in utilizing parts of the USD 100 billion – the financial commitment made by the developed countries under Paris Agreement from 2020. Armenia has a number of climate projects financed by the GCF including the National Adaptation Plan for the amount of close to USD 3 million, a USD 20 million project on retrofitting buildings for energy efficiency, as well as Readiness support. It is also important to note that Armenia is the first country in the region to have a national accredited entity under the GCF – which is the Environmental Project Implementation Unit. I am also happy to inform, that Deputy Minister Irina Ghaplanyan is a Board member of the GCF along with 11 representatives of developing and 12 representatives of developed nations.

Reflecting on bilateral engagements, our Ministry has a number of bilateral MoUs on cooperation in environmental sector with an extensive list of governments, most recent of which was signed with China and the United Arab Emirates.

Recently, I had the honor to represent Armenia in the Climate Summit of the United Nations. In our written statement delivered to the Summit we presented an innovative climate finance mechanism, which our government has worked on over a year and which offers a great opportunity both for developed and developing nations to meet their climate commitments under the Paris Agreement by means of utilizing the debt-for-nature swaps. This mechanism was also communicated to the President Macron of France and we have been working with his cabinet. This mechanism is not limited to Armenia and in case of success, it can become a scalable for the rest of the world.

Erik Grigoryan on UNESCO International Water Conference


Which three sectors in Armenia would you highlight in which we will see considerable changes in the future?

I can speak about where we already have significant changes. We have progressed with small hydro-power stations on sustainable water resource management, limitation of excess water abstractions and many other matters. With the previously operated hardware set up these stations have causing major environmental damage by depleting the water in the rivers. This is because the proper water flow meters were not set up and were not being overseen. We had also had positive changes in water use licensing, both from bureaucratic and content perspectives. We progressed in the forestry sector as well. Two days ago, during the government session at the National Assembly, I was accused of the depletion of firewood and that the costs for it have increased, to which I responded that there would be very limited qualities of fuelwood and that we would have to find alternatives for the heating and cooking needs of our rural communities. We are also continuing to review legislation on both water and forest sectors and intend to have substation legislative proposals for both. The processes are optimized. For example, previously, environment monitoring was the responsibility of our Ministry, the forest monitoring was the function of the Ministry of Agriculture, hydrometereological monitoring was conducted at the Ministry of Emergency Situations and Zvartnots Meteorological Monitoring was transferred part of the Transport Ministry. Now all these entities are incorporated under our Ministry’s umbrella, which will allow us to optimize, consolidate and innovate all of these crucial monitoring functions and services.


Now one of the most important question for today – mining industry. Where are we now and in which direction are we going?

Currently, 28 metal mines have received operation permissions but in fact only 6-7 of them actually operate. These mining sector activities together with the environmentally inadequate legal framework resulted in large-scale environmental pollution. The pollution prevention was not sufficiently regulated and the amount of compensation was not calculated properly, which created a situation where it is more beneficial for the mining companies to overuse the resources instead of conducting preventive activities. In many countries fines and penalties for air and water pollution and tailing dumps are quite high, so preventive measures operations are more financially sound and also required. In Armenia, many companies bypassed preventive measures as the fines for polluting the environment were extremely low.


Where are we in terms of Amulsar?

When the Investigative Committee received the final report of ELARD – the company that undertook third party assessment of the Amulsar gold mine project – we received instructions from the government to examine the report and provide feedback. In this process we reached out to other relevant governmental bodies and scientific institutions and gathered respective data. As a result, we had several revelations which, at this moment, I would rather refer to as inconsistencies. Some of these will be clarified after the Inspectorate for Nature Protection and Mining Resources undertakes relevant inspection, and the rest – after the Investigative Committee concludes relevant investigations. The changes to the submitted plan of the mining project and the question of whether or not the respective official state bodies had been properly informed about these and some other matters will fall in the spectrum of the Inspectorate’s inquiry.

Kajaran mine


Consequently, we don’t know whether or not there’s a need for a new EIA, do we?

The relevant legislation of Armenia does not stipulate any legal provision whereby an EIA could be immediately revoked, with the exception of provision, which states that in case if a mining company does not proceed with any functioning activities ranging from opening and construction to mine operation for one year. However, even in this case the Inspectorate for Nature Protection and Mineral Resources must visit the site, check and document it. In all other cases, be it a change in the project, unaddressed violations, a new ecological factor, etc., the relevant legislation requires a series of actions to be taken before the EIA can be revoked. It can be inspections or an inquiry undertaken by the Environmental Impact Expertise Center state non-commercial organization. So legally it is not possible even if there are any inconsistencies in the EIA for a Minister to deem an EIA invalid immediately.


You’ve mentioned that only around six from 28 metal mines are active, but are there going to be any measures for the rest 22?

Yes, the Law on Environmental Impact Assessment and Expertise has a provision, which states that if in one year after having received the license, the mining company does not undertake any operations, then the permit can be deemed invalid. We have applied to the Inspectorate for Nature Protection and Mineral Resources with inquiry on the status of these mines and have received information that there are more than ten metal mines which do not operate and have reported this information to the Ministry of Territorial Administration and Infrastructure Development, which is the state body in charge of revoking their licenses.


Some people claim that in a long term perspective, mining is not beneficial for the country. In today’s Armenia, do we have an accurate strategic approach regarding how we view the mining sector in the long run?

At this moment, the mining strategy, which is to provide answers to all the questions you’ve mentioned, is in the development phase. This might sound strange but, in my opinion, the operations of small- and medium-sized mines should be eliminated, because although small or medium they still can cause substantial damage to the environment without appropriate benefits in terms of boosting the economy and providing sufficient employment and taxes. Nevertheless, several of our large mines, such as Zangezur Copper-Molybdenum Combine, must first and foremost comply with the principles of preventing pollution to begin with, as opposed to paying fines for polluting. All in all, mining should be a temporary activity, i.e. a mine is opened, the resource is utilized, then the mine is closed, recultivated, and the territory is returned to economic and environmental balance. Currently, we don’t have this practice in Armenia, but the Ministry is working towards this. In the long run, I think that mining is not a prospective sector for Armenia.

Sevan’s green surface, 2019


Let’s talk about Sevan because recently it has become another central issue for discussion. The story of environmental pressure and negative impact on Sevan goes back to early 1920s-30s. What is the state of the lake now?

Sevan is a strategic water resource not only for Armenia but also for the region. Due to decades of unsustainable management of the lake today Sevan is experiencing a significant volume of pressure on its ecosystem, ranging from human-induced pollution to climate change. Given the immense pressure on the lake, we are currently working on devising an integrated water resource management plan for the lake, the first goal of which targets reducing the pollution inflow into this strategically vital water body. However, simply not polluting the lake is no longer sufficient, because the accumulated nutrient volume in the lake, which was built up over the decades of inflow of untreated community waste water is already putting an immense and unsustainable pressure on Sevan, and on top of preventing pollution, we also must work in the direction of eliminating new inflows of nutrients as well as removing, where possible, all the existing point source of nutrient inflow. At the moment, the Ministry is working on finalizing a road map for reducing this pressure. This plan involves detailed activities ranging from meticulous cleaning the coastal areas to suggestions on capturing farming and agricultural run off into the lake. Last year, our staff worked on clearing visuals captured via satellite and drone imagery to identify the areas located at the forecasted increase of Sevan’s surface, currently standing at the elevation of 1901.5 meters above the sea level. It is planned to clean up to 800 hectares of potentially swamping coastal area of the lake in the next three years. In 2020 we have allocated the required funds for the state budget to undertake the coastal cleaning activities and what is important to note here is that since we have increased the total area subject for cleaning the unit cost per cleaning has decreased. For example, if in the previous year the Ministry undertook activities to clean up to 100 hectares of coastal area, in the coming year we plan to clean up to 280 hectares of already swamping coastal area for almost the same budget. We strongly believe that with more hands on approach we will have a significant improvement in efficiency of conducted cleaning and mitigation measures. In addition to these measures we have also initiated a series of field work activities to collect data for calculation of potential costs of building sustainable sewage management systems for the coastal communities and what would be the potential financing options for placing biological wastewater treatment systems in at least three coastal and near-coastal towns. We have communicated our findings to the government, and the Prime Minister’s office has instructed the Ministry of Territorial Administration and Infrastructure Development to assess the financial and technical estimates for these measures to be undertaken. This year we succeeded in not only reducing the volume of water discharge from the lake by around 30 million cubit meters as compared to previous years, but also in discharging even less than indicated in the submitted permission. In addition to that we succeeded to stream significantly larger volumes of water into Sevan via Arpa-Sevan hydro tunnel. We have to further expand these measures as we are observing change in climate patterns which has led to increase in evaporation by around 100 million cubic meters as well as reduced inflow from the rivers. We have to realize, that we can’t continue doing “business as usual”, we not only have to reduce the pressure on the lake but start actively remediating it.


What about environmental pollution by different businesses and companies? We have the example of the storks in Hovtashen. Generally speaking, what is the approach of the Ministry in such cases?

Look, in the post-Soviet countries the concepts underlying the policies of environmental protection are based on the principle of “polluter pays”, meaning that when a business causes pollution it pays fines for the damage. However, unfortunately the fines for pollution are usually too low and certainly not enough for remediating the loss and damage caused to a given ecosystem. At the moment we are working on developing new legal provisions that will fundamentally change changing the approach towards environmental management thus transition from the concept of “polluter pays” to preventing pollution to begin with. This approach would require upfront measures to ensure that the right mitigation measures are put in place, but in the mid to long term perspective this model is actually more economically beneficial for businesses. In the scope of this undertaking we have already brought forward some new legislative measures. For example, we have enacted stricter provisions for criminal and administrative charges for offence related to illegal logging. We also have introduced legal amendments pertaining to more sustainable operation of hydro-power stations as well as prevention of illegal water wells. This is just the start. In the next few years we foresee introducing up to 250 legislative proposals. While the goal is to produce more rigorous environmental policies, we also aim to ensure that we maximally simplify various administrative procedures.

Hovtashen storks, victims of the pollution


Environment protection has become an important topic for society, especially for youth. Take the example of Greta Thunberg. Do you think that this active involvement of young people has a positive effect on decision-makers?

Yes, absolutely, and not just positive, but I also believe that the youth can have a much larger impact by being demanding. Moreover, on different international platforms we always emphasize that youth has the most power to bring significant change. Young generation is becoming increasingly demanding from governments to make real commitments and take action to ensure that they are left with sustainable and thriving planet. Youth today is aware and well informed and always poses poignant questions.

Today, Greta Thunberg is the most vocal proponent of climate action but this young activism is not new. Back in 1992 during the Rio Conference Severn Suzuki, a 12 year old girl shook the world by her poignant speech, raising sharp questions about biodiversity, water management and other environmental issues. This triggered a number of processes and I would attribute it both to Rio as a major undertaking but also to Severn and her passionate speech.


So, we can be optimistic about the world and Armenia, in particular?

In case of Armenia, we should be both optimistic and ambitious. For example, now we have a project aiming to double the forest cover of Armenia by 2050, which is a large-scale and very ambitious undertaking, but I believe that despite the imminent challenges we must pursue its implementation. The mechanism I talked about earlier suggests combining the commitments of developed countries taken under the Paris Agreement together with the debt-for-nature swaps. This potentially will streamline the much needed large-scale finance for the measures that need to be undertaken for the increase of the forest cover. This will have lasting and positive impact not only from environmental but also social-economic perspective, as many communities will get involved in large-scale afforestation operations.

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