[take action to support these organizations by sending your own letter]
Dec. 4, 2020
Ms. Candace MacGibbon,
Re: Respond to Ecuadorian organizations’ request for access to critical technical information: make Loma Larga´s EIA public
We the undersigned write to you today in reference to a request that was recently made to your company by several organizations in Southern Ecuador who are affected by INV Metals ongoing work on the Loma Larga project (attached here for your reference).
It has come to our attention that lately your company has been making statements to the Cantonal Council of Cuenca, Ecuador, wherein you say that the Loma Larga project will produce no impacts on the ecologically sensitive highland hydrological system, páramo, upon which hundreds of thousands of people depend for clean drinking water. The unique soils and complex hydrology of the páramo also provide critical habitat and or nesting grounds for hundreds of species, many of which are endangered or critically endangered and endemic i.e., specifically adapted and restricted to the Andean highlands of Ecuador.
The Loma Larga project will require constant dewatering to achieve workable conditions. Yet, no information has been provided as to how these significant alterations will affect Azuay’s biodiversity and its functions, nor how INV plans to ensure that the well-being of these sensitive species is not jeopardized. At least 4 amphibian species classified as Critically Endangered or Endangered are known to occur in and around the project area. These species play an essential role within a complex web of biological interactions that maintain Azuay’s water quality.
In their letter, organizations in Cuenca and the surrounding communities express concerns regarding a dearth of technical information about the Loma Larga project, and a complete lack of access to the primary studies upon which the company’s feasibility studies depend. They also note that despite the fact that the company has announced the completion of the Environmental Impact Study for the Loma Larga project and “began permitting”, they have not seen any results of this study, nor have they been given the opportunity to analyze its contents independently.
As a Canadian company who has operations abroad, it is important to note that the Government of Canada “expects Canadian companies operating abroad to meet or exceed widely-recognized international standards for RBC. Where host country requirements differ from the international standards listed below, the Government of Canada expects Canadian companies to meet the higher, more rigorous standard.” According to the government, one of such standards is the OECD Guidelines for Multinational Enterprises which states that companies should “provide the public and workers with adequate, measurable and verifiable timely information on the potential environment, health and safety impacts of the activities of the enterprise” . Another such standard recognized by the Canadian government is the IFC Environmental & Social Performance Standard, where Standard #1(ii) “establishes the importance of (ii) effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them.”
We too are of the opinion that having access to transparent information is a basic condition for communities to be able to make informed decisions about the future of their lands and water. As the organizations note in their letter, they have their own professionals and have their own local capacities to make assessments based on information that is provided to them. It is important that they are given the opportunity to exercise their capacities as informed citizens.
As the organizations also point out, your company has also made explicit commitments to transparency and providing communities with access to information.
As such we expect you to uphold these obligations and commitments and respond to the organizations’ legitimate request for access to information. If the company is convinced that the project will not impact the páramos watershed, then there should be no reason to continue to withhold technical information from those who have the most at stake.
We expect your swift and positive response on this matter,
- Animal Alliance of Canada
- Animal Protection Party of Canada
- Barnard-Boecker Centre Foundation, Canada
- CATCA Environmental and Wildlife Society
- Center For Biological Diversity
- Christian Peacemaker Teams, Canada
- Committee for Human Rights in Latin America (CDHAL), Canada
- Defend them All, United States
- Earthworks, United States
- Global Law Alliance for Animals and the Environment
- Institute for Policy Studies - Global Economy Program
- Interamerican Association for Environmental Defense - AIDA
- KAIROS: Canadian Ecumenical Justice Initiatives
- MiningWatch Canada
- Mining Injustice Solidarity Network (MISN), Canada
- Mining Justice Action Committee, Canada
- People's Health Movement - Canada
- Rainforest Action Group, Australia
Ms. Sunny Lowe, CFO, INV Metals
Ms. Sylvie Bédard, Ambassador, Canadian Embassy in Ecuador