On June 3, 2015, Armenian Prime Minister Hovik Abrahamyan declared the formation of a working group tasked with studying the potential that caves in Armenia have in terms of tourism.

Abrahamyan, however, is not the first to think along these lines. One year ago, Armenia’s Ministry of Culture declared a tender bid for the commercial operation of the Magil Cave in the Vayots Dzor village of Areni. As to why the potential of “cave tourism” is to be studied after the announcement of the tender is a question that can only be answered by the prime minister and the minister of culture. Nevertheless, this decision by Abrahamyan affords the chance to resolve the confusion started by the ministry of culture last year.

A Tender That Never Happened: A Participant Demands that the Committee Corrects the Mistake

The tender bid to operate Magil Cave one of the caves in Armenia for commercial pursuits was the first attempt of its kind regarding caves in Armenia. But the attempt was a failure due to a lack of bids.

Armenia’s Ministry of Culture announced that two bids had been submitted, one of which did not meet the stated requirements. As for the other bid, the attached affidavit stating that operating the cave would not damage the local environment was deemed past due. After the tender was announced, one of the members of the selection committee (Sevak Baloyan, Head of the Ministry of Nature Protection’s Animal Resources Management Division), gave a press interview and stated that none of the tender participants had submitted environmental impact documents.

Cave specialist and representative of Inkar Ltd. Smbat Davtyan told Hetq that he submitted one of the two bids. Davtyan says he filed an environmental impact review that was favorable in terms of possible damage and that the document was filed on time.

Sevak Baloyan had the positive environmental review submitted by Inkar Ltd. in his possession at the time of the tender bid. Later, as a specialist with the Ministry of Nature Protection, Baloyan announced a one year deadline for filing impact conclusions. Since Inkar Limited’s document was issued in 2011, it was declared invalid.  

According to the Environmental Impact Assessment Law, only the activity examination has a one year time limit. The document submitted by the company was a positive conclusion of the project, not of its operation. The same law stipulates time limits for activity examinations are not specified. Sevak Baloyan believes this shouldn’t have caused any confusion. He told Hetq that the company’s submitted bid was an activities examination. “Let’s say it was the title of the project, but its entire essence was about the planned for operation,” Baloyan said.

Several of the current experts on the committee, according to speleologist (cave specialist) Smbad Davtyan, claim that Sevak Baloyan is incorrectly interpreting the issue. However, the committee president, Deputy Minister of Culture Arev Samvelyan has decided that he is correct.

“The absurdity reached such a degree that even the explanation given by Samvel Shahinyan, President of Armenia’s Cave Specialists Union, wasn’t heard. The reason I place importance on this matter is because Shahinyan was the President of the Commission on Environmental Matters of Armenia’s Supreme Council. It was during his tenure that the “Law Regarding Impact Assessments on the Environment” was adopted, and he was knowledgeable of all the nuances of that law,” says Smbat Davtyan.

The document cannot be an operation examination because it is noted in it that the operation examination must still be submitted.

“Prior to the implementation of activities it s necessary to draft preliminary documents according to the protocol defined by RA law and, pertaining to the architectural/construction portion (with corresponding solutions), and with an environmental impact assessment, submit an evaluation of the impact on the environment to the Ministry of Nature Protection.”

 Since last year, Smbat Davtyan has petitioned the Ministry of Culture eight times, asking when the mistake will be corrected. His lat inquiry (the 9^th) was entered as received on March 19, 2015. While the deadline for a response was March 26, according to the document, no answer has yet been received.

The ministry remains silent. Sevak Baloyan and Deputy Minister of Culture Arev Samvelyan are included in the working group formed by the prime minister. Baloyan notes that if a decision is made to hold another tender bid he will submit the same assessment, because he is not prepared to spend more money due to ‘illiteracy’. The company spent some 3 million AMD for the study. In addition, payments are made to the Ministry of Nature Protection’s appropriate SNOC (state non-commercial organization. If that amount was 150,000 AMD according to the old environmental impact assessment law, it is 400,000 AMD based on the new law.

The Tourist Project of Inkar Ltd

After announcing the tender, environmentalists and sector specialists split into two groups. This was the first attempt to use the cave for commercial pursuits and the public response was intense. One group claimed that bats, listed in the Red Book of Endangered Species, would be threatened. Others felt that tourists would finally visit Armenia not only to see churches but caves as well.

None of these two views was used to substantiate viewing the tender as not taking place. Smbat Davtyan believes that the reason for the obstacle among the departments was the expectation of receiving bribes. He says that if he has struggled for so many years without “giving a dime”, he will continue to do so and, if needed, will take the matter to the courts.

Inkar Ltd. wants to transform the Magil Cave into a tourist site for cavers. According to the operational plan, 260 meters of the cave’s 1,720 meter length would be cleaned of fallen rock and soil and that a lighted cement path 1 meter in width would be built.

 As a result, as Davtyan notes, the cave would be accessible to all and visitors escorted by guides would be able to learn about the cave, its geology and history.

 “The project has been prepared on the basis of documents drafted by international and organizations and   national safety organizations of countries with a rich experience in the commercial utilization of caves,” says Davtyan.

 The project, according to the conclusion granted by the Ministry of Nature Protection, has undergone   environmental impact and geological examinations and has received a positive determination by the Institute of Geological Sciences and the Institute of Archeology and Ethnography of Armenia’s National Academy of Sciences and Armenia’s Center of Speleology NGO