To: GIZ Armenia Country Office (Deutsche Gesellschaft für Internationale Zusammenarbeit) Swiss Agency for Development and Cooperation (SDC) Ministry of Territorial Administration and Infrastructure of the RA (MTAI) Copy to: Cadastre Committee of the Republic of Armenia Ministry of Environment of the Republic of Armenia Delegation of the European Union to Armenia Embassy of the Federal Republic of Germany to Armenia Embassy of Switzerland to Armenia OFFICIAL OBJECTION AND URGENT INTERVENTION Regarding gross inaccuracies in the "Interactive Map of Territorial Reforms of the RA" and the resulting ecological disaster Dear Partners, I am writing to formally raise a grave concern regarding the critical inaccuracies found in the "Interactive Map of Territorial Reforms of the Republic of Armenia," hosted on the official platform of the Ministry of Territorial Administration and Infrastructure (https://www.mtad.am/pages/geo). Given that this platform was developed with the active support of GIZ and SDC, I believe that such misrepresentation of data severely undermines the reputation of both the state institutions and the international partners involved. 1. Documentation of Gross Mapping Inaccuracies The attached comparative map (Image 1) clearly demonstrates that in the area of the Nerqin Hand settlement (Kapan consolidated community), approximately 370-380 hectares of sovereign territory belonging to the "Shikahogh" State Reserve have been excluded from the RA state border (indicated with purple markings and arrows). This territory is de-jure part of Armenia, as also confirmed by the maps of the newly developed Management Plan for the "Shikahogh" State Reserve for 2026-2030. Although these boundaries were already corrected and restored in the Cadastre Committee's maps following the 2020 44-day war, the current interactive platform once again depicts an incorrect boundary. This error directly legitimizes the illegal incursions by Azerbaijani armed forces and has resulted in the factual occupation or fire-control of more than 3,000 hectares of land. 2. Context of the COP 17 Conference As Armenia prepares to host the COP 17 Biodiversity Conference in 2026, it is unacceptable to have such gross errors on official platforms. The international community must be informed of Azerbaijan's ongoing occupation of sovereign Armenian territory, which is currently being "omitted" from the state border on this map. Correcting these maps is a fundamental step in addressing the aggression and environmental damage. Proposals and Demands: To the Ministry of Territorial Administration and Infrastructure: Immediately review the data on the mtad.am/pages/geo platform and correct the state border line in the Nerqin Hand and Shikahogh Reserve sections. The boundary must correspond to de-jure realities, following the mountain watershed ridge, which is non-negotiable. Failure to do so will result in the formal abandonment of a significant forested area of the Shikahogh Reserve. To GIZ and SDC: Conduct a thorough technical and content audit of the project you support. It is imperative to ensure that international donor funds are not used to disseminate misinformation that endangers the territorial integrity and ecological security of the Republic of Armenia. To the COP 17 Agenda: Include the facts regarding forest destruction and ecocide in the occupied territories of the Shikahogh Reserve in international reports as a gross violation of the Convention on Biological Diversity. Attached Evidence: Image 1: Comparative mapping analysis. Draft Government Decision: Regarding the approval of the "SHIKAHOGH" STATE RESERVE Management Plan for 2026-2030 and Annex 2 (https://e-draft.am/projects/9147/about). I expect immediate and consistent steps to be taken, along with an official clarification regarding this matter. Sincerely, Ayser Ghazaryan June 16, 2026
