On September 8, we sent a request (in Armenian, in Russian) about implementation of the 2025–2030 atmospheric air protection program. We asked for the results of each measure separately for 2025 and the elapsed part of 2026: deadlines, documents, expenditures, and further plans. The Ministry of Environment sent a response with an annex, signed on September 18. For easier reading, we prepared a Russian translation of the response as a PDF; the Armenian original is also available. Let us examine which questions it answers and what information is still missing.
Key points from the response
Work is under way, but on key questions the ministry reported on the process rather than a completed result. The most detailed part of the letter covers meetings, publications, and public outreach.
- The stations have been purchased but have not been officially launched. AMD 300 million was allocated to purchase two stations in 2025. Both have remained in testing since January 2026. The ministry did not say when testing would end or PM2.5 and PM10 data would become available. It did not provide a full answer about the four stations planned for 2026.
- Dust suppression requirements have been adopted. They apply to construction and mining. No report on the implementation of these measures was provided. Amendments on administrative liability have been submitted for government review.
- No completed result was presented on vehicle emissions. Proposals to reform measurements and inspections were due by September 2025. The response describes studies, discussions, and a review of regulations. Based on the information provided, we assess this item as unfulfilled.
- The ministry gave more detail on greening and public outreach. It reported work on 2.5 hectares in Yerevan and further planting. It listed meetings, videos, and publications against burning. In 2025, the inspectorate recorded 1,156 burning incidents; 111 persons were held liable, with penalties totaling AMD 2.7 million.
- No consolidated report or expenditure report was provided. The response also did not describe an action plan for winter 2026/2027 or the current procedure for warning residents about high pollution.
Meetings and information campaigns are covered in detail in the response. It still gives no dates for when residents will receive data from the new stations and no work plan for the coming winter.
| What we asked | What we received | How sufficient was the answer? |
|---|---|---|
| A report on the entire program, deadlines, supporting evidence, and reasons for delays. | An overview of completed and planned measures. | Partial. No consolidated report was provided. |
| Two stations under the 2025 plan, four under the 2026 plan, the goal of six stations in Yerevan, addresses, parameters, and commissioning dates. | The addresses of two purchased stations, their trial operation, and plans for new deliveries. | Answered, but the stations have not yet been officially launched. The two stations purchased in 2025 have remained in testing since January 2026. The ministry did not say when testing would end or the data would become available. |
| When PM2.5 and PM10 data will be made available, and how residents are warned now. | A description of future monitoring and public information rules. | Insufficient. There are no dates for making the data available and no current warning procedure. |
| Planned, allocated, and spent amounts, contracts, and funding sources. | AMD 300 million allocated in 2025 and the funding arrangement for three planned stations. | Partial. No expenditure report was provided. |
| Adopted acts, their implementation, and inspection results. | Order numbers and the dates when the requirements took effect. | Partial. No report on implementation of the measures was provided. |
| The status of the liability amendments. | The draft laws have been submitted to the government, and a link to the draft was provided. | Largely sufficient to establish their status; the submission date was not given. |
| The results of preparing proposals on vehicle emissions. | Studies of vehicle inspections and work on a new model. | Unfulfilled based on the information provided. The response did not present completed proposals. |
| Work against burning, documents, and indicators. | A list of meetings and publications, and enforcement results for 2025. | Substantive for 2025. |
| Coordination of programs, the winter schedule, and reporting. | General references to projects. | No substantive answer. The division of responsibilities, winter schedule, and reporting procedure were not provided. |
Implementation of the program
We requested the current version of the program, including amendments, and a consolidated report on every item in its annex: who is responsible, what should be ready by the deadline, what result has been achieved, and what evidence supports it. For unfinished measures, we asked for the reasons and a revised schedule.
The program annex provides for the following measures in 2025–2026. Let us compare them with the ministry's response.
| Program item | What was planned | Deadline | Did we receive an answer? |
|---|---|---|---|
| 1.1. Fixed monitoring stations | Purchase 2 stations. AMD 300 million was budgeted for acquisition and AMD 60 million for maintenance and operation. | 2025 | Partial. The ministry reported the allocation of AMD 300 million and the purchase of two stations. They have been in testing since January 2026. No expenditure report was provided. No official commissioning date was given. |
| 1.1. Fixed monitoring stations | Purchase 4 stations. AMD 600 million was budgeted for acquisition and AMD 120 million for maintenance and operation. The overall measure provides for monitoring major pollutants, including PM2.5 and PM10, and promptly making data available to the public. | 2026; modernization from 2025 onward | Partial. The planned delivery of equipment for three stations under a Japanese grant was described. The ministry did not explain how this relates to the four stations in the program; it gave no complete status of procurement, expenditures, or the date when data would become available. |
| 2.1. Construction dust | Establish a dust suppression requirement, including the use of equipment, in construction standards. | For Yerevan: December 2025; overall deadline: September 2026 | Yes, regarding the adopted requirement. The ministry cited Order No. 02-Ն and the date the requirement took effect: May 24, 2026. No report on implementation of the measures was provided. |
| 2.2. Mining dust | Prepare an addition to the requirements for mineral extraction projects, including dust suppression supported by calculations. | For Yerevan: December 2025; overall deadline: September 2026 | Yes, regarding the adopted act. The ministry cited Order No. 43-Ն, in force since January 16, 2026, and a six-month transition period for existing subsoil users. No report on implementation of the measures was provided. |
| 3.1. Public outreach | Conduct interagency outreach in communities about the consequences of burning stubble, dry vegetation, industrial waste, and hazardous waste. | Continuously from 2025 | Yes, regarding activities held. There is a list of meetings, publications, and videos from 2025, along with some activities from 2026. |
| 4.1. Liability | Submit draft amendments to the Code of Administrative Offenses to the Prime Minister's Office on specific measures and the limits of liability for violations under Article 81.1. | September 2026 | Yes, regarding the preparation stage. The draft laws were reportedly submitted for government review. Neither the submission date nor a document confirming that the deadline was met was provided. |
| 5.1. Greening Yerevan | Increase green areas by 10 hectares; AMD 100–150 million was budgeted. | 2025 | No report for 2025 was provided. |
| 5.1. Greening Yerevan | Increase green areas by 7 hectares; AMD 70–105 million was budgeted. | 2026 | Partial. The ministry reported improvements, irrigation, and greening on about 2.5 hectares from March 1 to August 1; work on 8.5 hectares near Nubarashen Highway continues, with planting planned for autumn; another 3 hectares are planned near the northern entrance. |
| 5.2. Vehicle emissions | Prepare proposals on digitizing measurements during vehicle inspections, re-equipping inspection stations, and electronically monitoring emissions checks. | September 2025 | Unfulfilled based on the information provided. Instead of completed proposals, the response describes studies, discussion of a new vehicle inspection model, and work on regulations. |
Monitoring stations
According to the ministry, two fixed automatic stations were purchased in 2025. They are installed at 6/1 Yervand Kochar Street in Kentron and in David Anhaght Park in Kanaker-Zeytun. The stations have been operating in test mode since January 2026; official launch is planned after testing ends. No date for the end of testing was given.
The response separately describes a Japanese grant: Horiba equipment for three stations to measure SO₂, nitrogen oxides, CO, ground-level ozone, PM10, and PM2.5. The agreement sets a 2026 deadline. The grant covers the equipment, while Armhydromet is to pay for the pavilions and related facilities. Another two stations are included in an agreement with the European Commission that is under negotiation for 2027, and two more in a project application for 2028.
According to the ministry's response, neither of the two purchased stations has yet been officially commissioned: both remain in testing.
Open data and warnings
We asked when modernization of the information system would be completed, when measurements, including PM2.5 and PM10, would become available, and what procedure for warning residents about high air pollution is in effect now.
The response lists adopted resolutions on new air assessment criteria and monitoring procedures. The ministry writes about a future official air quality index and a clearer presentation of data to the public. But Resolution No. 1142-Ն and Resolution No. 1958-Ն take effect on November 1, 2027.
The response gives no dates for completing modernization or making the data available. It does not describe the current warning procedure.
Funding
The ministry reports that AMD 300 million was allocated to it in 2025 for monitoring modernization and that two stations were purchased under this funding. For the three stations under the Japanese grant, the equipment and pavilions are to be paid for separately by the grant and Armhydromet.
No expenditure report was provided.
Dust suppression
For construction, the ministry cited Order No. 02-Ն: the requirement to use dust suppression systems, including dust suppression equipment, has been in effect since May 24, 2026. For subsoil use, it cited Order No. 43-Ն, which took effect on January 16, 2026. Subsoil users who had obtained their rights earlier were given a six-month transition period to organize dust suppression or use water mist systems.
In our request, we specifically mentioned the December 2025 deadline for Yerevan and the overall September 2026 deadline. No report on implementation of the measures was provided.
Liability, transport, and work against burning
Administrative liability
The ministry reports that amendments to the Law on the Protection of Atmospheric Air and the Code of Administrative Offenses have been drafted and submitted for government review; a draft project page has been published. The amendments concern, among other things, liability for dust at construction and industrial sites. The question about their preparation stage was answered. The submission date was not given.
Vehicle emissions
According to the ministry, studies of the current vehicle inspection procedure have been carried out, the Information Systems Management Council has considered a new model, and regulations are being revised in light of EU directives. We asked for the results of preparing proposals on measuring vehicle emissions, which the program scheduled for September 2025. Based on the information provided, we assess this item as unfulfilled: the result required by the program—completed proposals—was not presented in the response.
Burning and public education
This is the most detailed part of the response. The ministry listed meetings with residents, developers, and local authorities; publications; public appearances; two videos; and 21 information reminders about the ban on burning. It provided links to some of the materials. The inspectorate reported that in 2025 it recorded 1,156 incidents involving the burning of waste, leaves, stubble, and other plant residue. 111 individuals and legal entities were held administratively liable, with imposed penalties totaling AMD 2.7 million.
Coordination and preparation for winter
We asked how the national program is coordinated with Yerevan's four-year program and EU4Clean Air in Armenia, who is responsible for what, and what actions are scheduled before and during winter 2026/2027. We also asked where consolidated reports would be published.
There was no substantive answer. The division of responsibilities among the programs, the winter action plan, and the procedure for publishing reports were not provided.
What this means
Work is under way: dust suppression requirements have been adopted, two stations have been purchased, and greening is in progress. But the stations have remained in testing since January, no date has been given for making their data available, and no report on the implementation of the dust suppression requirements was provided. On vehicle emissions, instead of the completed proposals due back in September 2025, the ministry describes studies and discussions.
The most detailed part of the response covers meetings, publications, videos, and public outreach. Here there are lists, dates, and links. The agencies are able to provide this level of reporting. Their answers about launching equipment, expenditures, and implementing the program are noticeably weaker.
Ahead of winter 2026/2027, we received a detailed account of outreach work, but still no schedule for launching the stations and making data available, and no winter action plan. We hope the next report will be equally detailed about a working monitoring system and completed measures to reduce emissions.
See also
- New air quality standards in Armenia — a separate examination of Resolution No. 1142-Ն: PM2.5 and PM10 standards, information and warning thresholds, and the stages of the transition in 2027 and 2035.
- WHO air quality guidelines — WHO recommendations, Armenia's current standards, and how they differ from the new system.
- Winter 2025/26: Yerevan air quality report — what we have already written about the 2025–2030 air protection program, the adoption of the state monitoring procedure, and the promised stations.
- Why complaints about smoky garages are not enough — the ban on burning under Article 11 of the Law on the Protection of Atmospheric Air and the problem of pollution from heating.