Following a Hetq report on how construction waste from the COP17 venue—Yerevan’s Meridian Expo Center—was being dumped into the Hrazdan Gorge, Armenia’s Environmental Protection and Mining Inspection Body (EPMIB) initiated administrative proceedings. 

However, the agency soon dismissed the case, claiming that trees had not sustained damage severe enough to halt their growth, that calculating the damage was impossible, and that there had been no alteration to the riverbed.

After the proceedings were dismissed, Hetq  revisited the site. We observed that, because of the construction activities deemed "harmless" by the EPMIB, several trees had already snapped, while others were leaning and at risk of toppling at any moment.

The EPMIB acknowledged that excavated soil from construction sites had been dumped on the slopes of the Hrazdan River and among the trees. However, the inspectorate terminated the administrative proceedings based on a peculiar interpretation of the law: since the trees had not yet withered and the riverbed had not changed, there was no "measurable damage," and therefore, no violation.

Article 98 of Armenia’s Water clearly stipulates that the owner or user of land adjacent to a water resource is obligated to prevent any threat to the ecosystem; furthermore, ecosystems interconnected with water bodies are subject to protection.

According to Article 99, conducting any type of work within the water area of ​​a water resource or its water protection zone is prohibited, except in cases specifically provided for by legislation. Such areas must also be protected against pollution and littering.

 In its decision, the EPMIB cites Article 5 of the Law "On Rates of Compensation for Damage Caused to Flora and Fauna as a Result of Environmental Violations," under which damage is calculated based on the diameter of the tree stump (applicable when the tree has already withered or been destroyed).

However, it appears that the inspection agency is overlooking Article 4 of the same law. That article stipulates that the impairment of the water- and soil-protecting functions of vegetation cover, as well as the creation of a risk of damage to the ecosystem, also constitute violations.

In other words, the fact that the trees had not yet withered at the time does not mean that dumping construction waste into the gorge was lawful.

The inspection agency should have first determined whether dumping waste into the gorge was permissible, rather than waiting for the action to cause irreversible damage to the gorge's vegetation and the Hrazdan River. 

A second visit to the Meridian Expo Center reveals that trees in the area adjacent to the Hrazdan Gorge continue to suffer damage due to construction work.

Water is pooling in a section of the Hrazdan River. At the same time, the grounds cited for terminating the administrative proceedings—namely, that the trees were not damaged to the point of halting their growth and that the riverbed remained unaltered—do not absolve the developer of liability, as mandatory legal requirements regarding the protection of water and plant resources have been violated.

After watching Hetq’s video and seeing the situation firsthand, only one question remains: have EPMIB employees even visited the site?