Announcement
Announcement
International organizations should stop supporting the false agendas of the RA Ministry of Environment, thereby ending their participation in the processes of ecosystem degradation.
This statement is addressed to all those international organizations that provide support to the RA Ministry of Environment, believing that this way they contribute to the processes of nature protection and sustainable management of natural resources, when in fact they participate in the opposite - the deterioration of the natural environment. The international organizations that provide financial and other support to the Ministry of Environment should realize that with their actions they partake in the reduction of forested areas in Armenia, the elimination of biodiversity, the inefficient use of water resources, soil degradation, etc. The international organizations should not ignore their own participation and contribution to the degradation of the natural environment, thus contradicting their proclaimed sustainable goals. For years, representatives of civil society, communities have been fighting to preserve the natural environment, to protect their right to live in a clean and healthy environment, but the short-sighted activities of the Ministry of Environment and the support provided by the international institutions nullify these goals of the public and nature protection of the entire region and the world. We are constantly following not only the actions of the Ministry of Environment, but also the steps of international organizations and we expect that the international support for false agendas of the Ministry will finally cease.
Specifically with the example of forests, although the problems exist in conservation and management of all ecosystems, below we present the mechanisms by which the Ministry of Environment of the Republic of Armenia fails to fulfill its obligations, and the international organizations willingly or unwillingly participate and support these failures.
It should also be noted that we are ready to discuss all the bases of the information presented below in the framework of a separate meeting.
1. Distortion of primary/robust data regarding forests and planning of activities (sanitary /yet in fact a commercial logging/ and maintenance cutting) with subjective interests.
The forest management plans developed with the state budget and international funding contradict the requirements of the Republic of Armenia’s (RA) legislation (in particular, the Forest Code, the Law on Specially Protected Nature Areas (SPNA), the Law on Local Self-Government, etc.) and the internationally accepted principles and standards of sustainable forest management, as well as the requirements of biodiversity protection, climate change and a number of other key international conventions. In most cases, forest assessment descriptions given in forest management plans do not correspond to reality, while the planned measures contradict the requirements of the relevant guidelines for sustainable forest management, as well as the requirements of the relevant regulatory legal acts, the implementation of which will lead to the degradation of forest ecosystems. Thus on the one hand we deal with the waste of state and international support funds, on the other hand, there is a continuous process of degradation and destruction of forest ecosystems.
In those management plans, important information is missing, in particular, information on the study and evaluation of measures taken in the past 10 years prior to their development, or this information is given in a distorted version, in particular, information about logging and reforestation/afforestation measures. This information should have been the basis for one of the most important functions authorized by the state authorized body, i.e. state census of forests/forest accounting, for the purpose of evaluating and analyzing the qualitative and quantitative changes in forest management, also for the evaluation of the effectiveness of management and use of financial resources. Yet, after adopting these documents, the Ministry of Environment decided to organize an operation at the expense of the state budget and through another organization/company that will try to "conceal" the gaps caused by the Ministry’s fault, despite the fact that the function of census is completely within the authority of the relevant institutional units of the Ministry and thus should be implemented by the latter.
2. Institutional degradation and disintegration of the forest management system.
Without proper institutional analyses, sectoral reforms are being implemented that have nothing to do with internationally accepted procedures. Legal, technical and financial justifications are missing, processes of institutional degradation are clearly identified. The financial burden of the state is gradually increasing, instead, measures destroying forest ecosystems continue and have even gained stronger momentum...
3. Illegal alienation and rent of forests and forest land, ongoing arbitrary as well as illegal commercial logging disguised as sanitary cutting.
Expropriation of forests is carried out by changing land for other purposes and forms of ownership. In the last few years, particularly in Tsaghkadzor, forested lands have been expropriated with gross violations of RA legislation for the purpose of building multi-functional complexes and hotels. Information on these areas is missing from the newly developed forest management plan and its maps. Instead of returning those forested lands as authorized with its powers, the Ministry of Environment refuses to provide the newly developed maps of those areas, moreover, it gives positive conclusions to the Environmental Impact Assessment (EIA) documents provided by the companies that initiated construction in those areas. Arbitrary, commercial logging disguised as sanitary logging continues in forested areas of the Republic of Armenia.
4. Subjective changes in sectoral policies, strategies and legal acts, particularly at the level of strategic planning, setting agendas that pursue subjective interests, facilitating requirements for the lease of forests, forest and Specially Protected Nature Areas land, to the detriment of the forests.
Within the framework of the fake agenda of doubling the forested areas under the framework of the Paris Agreement, with the state budget, international funding and the support of local organizations, the Ministry continues to implement afforestation and reforestation measures, most of which do not exist.
Regarding the false agenda of doubling forests, it should be noted that taking into account the internationally accepted (IUCN ROAM) methodology, the results of the assessment of "suitable" areas for afforestation based only on the ecological factor show that this measure can be implemented on a maximum of 60 thousand hectares, instead of the announced 265 thousand hectares (still not taking into account other factors, including social, in particular, whether the communities will agree to provide their agricultural land - pastures and meadows for this purpose...).
It should be noted that the Federal Ministry of Environment, Nature Conservation and Nuclear Safety of Germany (BMU) through the German KfW bank (the latter continues to provide serious financial support to the Ministry of Environment of Armenia particularly within the framework of the project for the creation of a biosphere reserve in the Syunik region) in 2011 developed the Strategic guidelines for responding to impacts of global climate change on forests in the South Caucasus (Armenia, Azerbaijan, Georgia) (Figure 1, link: https://shorturl.at/pACM3), in which, based on the projected climate change scenarios, possible scenarios of forest surface changes, including tree species, were also calculated. Two possible scenarios were calculated and analyzed: the scenario prediction based on the A2a model is particularly interesting - Modeled Present vs. A2a Model, according to which areas of forests with mesophilic/humidity-loving tree species will decrease. Main part of our forests is located in Tavush and Lori regions; these forests in the northern slopes are predominantly composed of moisture-loving beech and hornbeam. In Annex 1 (Figure 2) of the above guideline, it is noted that the predicted reduction for beech is about 67.11%, and for different tree species the average is 60.76%. In case of this scenario, part of the existing forests will be destroyed or become sparse forested areas. Yet the RA will try to double the area of forests by 2050...
This means that the state chooses long-term false targets and (re)declares the commitment to double the forests, "ignoring" the problems the forests face, specifically the continuous degradation processes of ecosystems, the glaring problems of forest management and the seriousness of predicted challenges. As a result, financial resources and time will be wasted on false targets...
5. Duplication/overlapping of international projects and lack of effective monitoring.
The Ministry of Environment, together with organizations with which it implements international projects, continue operating in an allegedly transparent manner, not providing the relevant information requested by NGOs and individual experts. Even during the discussion of newly developed and approved projects, they try to bypass the experts in the field and their professional opinion. The Armenian office of the World Bank acts exactly in this manner specifically regarding the development and discussion of the draft grant agreement of the project "RESILAND: Armenia Resilient Landscapes". As a result, this project has quite serious overlaps/duplication with the "FISP-1" and "FISP-2" projects previously implemented by the World Bank and the Swedish Development Agency: turns out that the Republic of Armenia will double spend/waste relevant loan and grant funds. Another example of an international project with non-transparent practices is the current EU4Sevan project "Environmental Protection of Lake Sevan", where the results of independent monitoring with "other approaches" regarding possible impact of some key results are of concern.
6. Lack of transparent management/implementation of projects.
In response to the letter submitted by the "Green Armenia" NGO to the Ministry of Environment, in which the NGO asked to present the list, budgets and results of the projects implemented with international and state funds in recent years, the Ministry presented incomplete and fragmentary information. Additionally, civil society reps. asked in another letter to present the newly developed forest management plans and information on afforestation/reforestation measures implemented after 2021; the latter request was mostly rejected, citing that the main part of those documents has not been approved yet, while the information on afforestation/reforestation was presented in very general terms.
7. Corruption
As an example, we present the UNDP-GEF "Mainstreaming Sustainable Land and Forest Management in Mountain Landscapes of North-Eastern Armenia" program, where particularly the results of an independent expert analysis of the developed forest management plans with the justifications mentioned in point 1 clearly state that these plans should not have been accepted and should not have received a positive conclusion of the EIA, and yet they did. We learn from international platforms about corruption scandals of a number of programs implemented with these financial sources: https://foreignpolicy.com/2019/08/14/greed-and-graft-at-un-climate-program-united-nations-undp-corruption/ , which demonstrate the consequences of the worst impact of similar programs, in particular, in terms of deepening the degradation of ecosystems and the activation of corruption processes in the field. These and other similar examples are fully compatible with the mechanisms and structure of corruption presented in the UNODC document “Rooting out Corruption” /link: https://www.unodc.org/documents/corruption/Publications/2023/Rooting_Out_-_Introduction_to_addressing_corruption_fuelling_forest_loss_2023.pdf /.
The above mentioned correspondence, as well as more detailed information can be presented during a separate discussion and/or a press conference.
“Green Armenia” Educational Environmental NGO
“Sustainable Forest Management” NGO