An Alternative Look at a Proposed Mine

In Tambogrande, Peru

Report Prepared by:

Robert E. Moran, Ph.D.
August 2001

Report commissioned by:

Oxfam America, Washington DC, USA
Mineral Policy Center, Washington DC, USA
Environmental Mining Council of British Columbia, Vancouver, Canada
15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Robert E. Moran, Ph.D.

Water Quality/Hydrogeology/Geochemistry
501 Hess Ave., Golden, CO 80401 U.S.A.
Phone: (303) 526-1405
Fax: (303) 526-2678
Internet: [email protected]

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

TABLE OF CONTENTS
Foreword ........................................................................................ iv

Executive Summary........................................................................vii

Introduction......................................................................................1

Findings...........................................................................................5

Related Observations ....................................................................13

Recommendations.........................................................................19

References ....................................................................................21

Editorial Note: This report refers to the town of Tambogrande in Peru. However, the name of the
mining project, which is derived from the name of the town, uses a different spelling, Tambo
Grande. In this report “Tambogrande” is used to refer to the town, and “Tambo Grande” to refer
to the mining project.

Cover photo: Ernesto Cabellos, Guarango Cine y Video.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

FOREWORD
The proposed Tambo Grande mining project in northern Peru offers a stark
illustration of the problems associated with large-scale mining operations in an
era of deregulation and globalization. The town of Tambogrande is poor, isolated
and in the heart of Peru’s “El Niño” zone. It sits directly atop a major gold, zinc
and copper deposit that Manhattan Minerals, a small Canadian mining
multinational, is seeking to develop into an open-pit mine. Projected impacts of
the mine could be severe. Construction of the mine would require the relocation
of an estimated 8,000 inhabitants of a total population of between 14,000 and
16,000 people and the diversion of a local river. The project could also have
significant impacts on agricultural production in the area. Tambogrande farmers
are Peru’s principal mango exporters and the area has become one of Peru’s
leading agricultural centers thanks to major investment in irrigation systems,
some of it provided by the World Bank.

Concerned by the proposed relocation and by threats to their agriculturally based

livelihoods, local populations have mounted significant resistance to the project.
On February 27 and 28, 2001, an estimated 10,000 people participated in
blocking road access to the exploration site. A recent initiative collected
approximately 28,000 notarized signatures of individuals in the Tambogrande
district, of approximately 37,000 eligible voters, who are opposed to the mine.
Tambogrande’s Mayor and local Archbishop have called for the project not to go
forward, citing not only the potential environmental impacts, but the mine’s
disruptive social impacts, already evident in the exploration phase due to the
tense environment of distrust and conflict that exists in the area. The archbishop
has called the project “socially unviable.” These actions represent significant
opposition to the proposed mine by affected citizens and community leaders.

Manhattan Minerals, a mining “junior” with no previous experience operating a

mine of this size, and no other current projects, rode into Peru on the wave of the
country’s recent mining boom. With the privatization of Peru’s mining sector in
the early 1990s, foreign investment in the sector has exploded over the past
decade. From 1992 to 1997, the volume of mining operations in Peru tripled
from 30,000 to 100,000 metric tons of minerals per day. Land area devoted to
exploration and extraction increased from 4 million to 18 million hectares
between 1992 and 1998. According to the Financial Times, Peru has had South
America’s highest rate of exploration success in recent years, driving Latin
America’s emergence as the most popular continent for new mining projects.
The Tambo Grande project is located in the department of Piura, a department
that up until now has not been known for mining, but rather agriculture.
Manhattan’s operation may open the door to the exploitation of hundreds of
thousands of hectares currently under concession in Piura. The impact on
traditional agricultural livelihoods, from which the vast majority of Piurans draw
sustenance and income, could be significant.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Peruvian legislation adopted in December of 1998 specifically forbids mineral

exploration or production in urban areas, such as the town of Tambogrande.
Under that legislation, current mining lease holders tenure holders had a two-
year window in which to apply for an exemption, providing that they could
demonstrate surface rights and had submitted an environmental impact study to
the satisfaction of the Peruvian Ministry of Energy and Mines. Manhattan
received an extension to that timeline as part of a Supreme Decree from the
government of then-President Alberto Fujimori. Since that time, however,
Manhattan has repeatedly pushed back the date for completing the
environmental impact study.

While rich in detailed knowledge about their environment, local communities

sometimes lack access to the scientific expertise needed to effectively evaluate
and respond to technical studies and claims put forward by mining project
proponents. This is particularly true in Tambogrande, where there is no prior
history of mining.

To support the ability of local communities to gauge potential impacts of the

Tambo Grande mine on their water, land and livelihoods, Oxfam America,
Mineral Policy Center and the Environmental Mining Council of British Columbia
supported a visit to the area by Dr. Robert Moran, a hydrologist and
internationally-recognized expert on the environmental impacts of mining. The
objective of Dr. Moran’s work was to provide an independent assessment of the
project’s potential impacts on water quality and quantity in the region, an issue of
particular concern given the importance of agriculture production to the regional
economy.

The results of Dr. Moran’s investigation are presented in the following report.
Among Dr. Moran’s conclusions is that there are fundamental inadequacies in
the environmental assessment work presented to date by Manhattan Minerals.
This information is essential for designing adequate impact prevention and
remediation measures. Additionally, Dr. Moran concludes that given the
geography and geology of the proposed mine site and given past history with
open-pit mining, negative environmental impacts are inevitable in the
Tambogrande region, despite claims to the contrary by Manhattan and Peruvian
government officials. Because of the potential for water, soil and crop
contamination from mine wastes, Dr. Moran also raises doubts that mining and
agricultural production can indeed co-exist without long-term environmental
impacts, as the company has claimed.

The Peruvian government and Manhattan Minerals have both said publicly that
they will not proceed with the project if local populations are opposed. We agree
that the project should not go forward without informed community consent.
Such consent and a rigorous environmental review are essential preconditions
for any mining project, whether in North America or Peru. Dr. Moran’s study,
taken together with demonstrated opposition to the project by thousands of local

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

citizens and their elected representatives and religious authorities, indicates that
in Tambogrande there is reason to doubt that either of these criteria can be met.

Oxfam America
Mineral Policy Center
Environmental Mining Council of British Columbia

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

EXECUTIVE SUMMARY
The findings of this report demonstrate that the proposed Tambo Grande open-
pit gold mine, if approved, is likely to have negative, long-term impacts on water
quality and quantity, the general environment, and possibly agriculture. Further,
claims that Manhattan Minerals and the Peruvian government have made
regarding the lack of impacts cannot be substantiated by the analysis and
information that the company has provided, to date.

Consider these primary findings:

• The TamboGrande Baseline Study is completely inadequate, if judged by

the criteria of the British Columbia Environmental Assessment Office;
criteria that Manhattan Minerals would have to meet if it was proposing
such a mine in its home country (Canada) and province (British
Columbia). Nor would it be acceptable in the United States.

• The evidence provided by the company does not support the company’s
assertion that there will not be any detrimental environmental impacts.
Manhattan has not released any study describing potential environmental
impacts, such as an Environmental Impact Assessment (EIA). However it
is clear that residents have been led to believe that no such impacts will
occur, based upon public presentations by company representatives and
government officials.

• Water pollution at the site is likely. Whether highly acidic or highly

alkaline, the waters leaching from the tailings are likely to contain high
concentrations of many toxic constituents such as: metals (aluminum,
antimony, arsenic, barium, cadmium, copper, chrome, cobalt, iron,
mercury, molybdenum, manganese, nickel, lead, selenium, silver, thallium,
vanadium, zinc); non-metals (sulfate, nitrate, ammonia); cyanide and
related breakdown compounds (metal-cyanide complexes, cyanate,
thiocyanate); possibly radioactivity (uranium, radium, gross alpha and
beta); and organic compounds.

• There is significant potential for soil and crop contamination in an area of

highly valuable agricultural production. As noted above, solid wastes from
the mine will contain numerous chemical contaminants, and many will
exist as forms mobile in water, capable of contaminating local surface and
ground waters. In addition, these huge accumulations of waste rock and
tailings will be exposed to local winds, which will carry contaminant-laden
dust particles into nearby domestic areas, schools, surface waters, and
agricultural fields. These particles are potentially toxic to humans, animals,
fish, and crops—especially when released over many years.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

• The Peruvian government, with a 25 percent ownership stake in the

project, has an inherent conflict of interest. It is both the regulator and will
benefit from mine production, thus it might be tempted to avoid enforcing
environmental requirements that prove too costly. Such arrangements
have resulted in similar problems at other mines such as the Kumtor Mine
in Kyrgyzstan and the Aurul Mine in Romania.

• Discussions with local community leaders revealed strong opposition to

the project on the grounds of its likely environmental impacts. Local
communities are deeply concerned about the threat that potential
contamination from the project could pose to their livelihoods, based
primarily upon agricultural cultivation and production. They are cognizant
of environmental and social problems that have occurred in recent years
at other large mining projects in Peru and worry the same could occur at
the Tambo Grande mine.

Clearly, the proposed Tambo Grande mine will also have substantial impacts on
the social fabric of those living at, and near, the site of the proposed mine. Mine
operation would require relocation of numerous families because portions of the
mine would be excavated under the existing town. Some of the short-term
impacts could be viewed as positive, such as immediate improvements to local
infrastructure—assuming they were constructed as planned. However, it is the
long-term impacts to the community and environment that will be most
significant. It is imperative that all of the potential risks and impacts are fully
considered and weighed, by those living in and near the mine site, before any
decision is made to proceed.

Manhattan Minerals should not proceed without the prior informed consent of the
affected community. As a first step, Manhattan Minerals must provide a full
impact assessment, including a comprehensive and final baseline study, and
should provide community leaders with resources to conduct their own,
independent assessment of Manhattan’s conclusions. It is only on this basis that
those affected can make an informed decision about whether or not they wish to
accept the likely impacts of this mine on their environment, livelihoods and
community, in exchange for the potential economic benefits of a large-scale
mining operation.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

INTRODUCTION
Have you visited many active metal mining sites? If the answer is yes, you know
that most are located at a distance from large population centers, often in
mountainous areas. The reasons generally have to do with the way natural
mineral-forming and mountain-building processes work, and the settlement
history of the area. The citizens of most densely populated portions of the
developed world simply will not tolerate the noise, truck traffic, and potential
contamination that come with large, active metal mines. There are exceptions, of
course, but they are just that, exceptions. Even more unusual is to find a modern
and active metal mine located in a populated area, which derives its income
largely from agriculture. Once again, there are exceptions---but we shall discuss
those later.

Tambogrande is located in an agricultural area of Peru, about 100km inland from

the Pacific coast and about 50 km south of the border with Ecuador (see map).

Colombia
Ecuador

Piura ll

Brazi l
Tambogrande

Peru
Lima«
Cuzco
l

Pacific O cea n Bolivi a

Arequipa l

Chile

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Approximately 50 years ago, this area contained only a few farms and ranches
that obtained very limited amounts of water from the local rivers, which flowed
intermittently. Beginning about 1949, a multistage water diversion and irrigation
program began, which diverted water from the Quiroz River into the Piura River
basin, supplying the Tambogrande area. Funding for the initial stage came from
the Peruvian government, with later stages funded by the World Bank, the
governments of the U.S.A. and Peru, the U.S. Agency for International
Development, and the Peruvian Banco de Fomento Agropecuario (Details on the
irrigation project history come from Aste Daffos, 2001.) Thus, a significant
amount of international aid and development funding was invested in this area to
convert the land into irrigated farms, with results that are visible 50 years later.

These diversion and irrigation improvements have caused the Tambogrande

area to become one of the most successful and profitable agricultural areas in
Peru, producing significant amounts of mangos, lemons, rice, cotton, marigold,
and corn. Juan Aste Daffos, an economist with the NGO Grupo de
Investigaciones Economicas, ECO, estimates that the average annual lemon and
mango production alone contribute about $12.5 million and $ 83.5 million,
respectively to the local farmers, and about $41.0 million and 106.5 million,
respectively, to the national economy, largely in the form of exports (Written
communication, May, 2001).

While essentially a near-coastal desert (average precipitation about 60 mm per

year) located at about 5 degrees south of the equator, much of the Tambogrande
area contains “dry forests” composed of unusual accumulations of algarrobo
trees. These deep-rooted trees are able to tap ground water recharged by the
irrigation waters and rainfall from El Nino events. The algarrobo tree is a central
part of the local ecosystem in that it provides essential shade and moderates the
strong local winds thereby limiting the process of desertification. It also provides
wood (for construction and cooking/ heating), and the seedpods are a source of
“honey” (Torres G., 2001).

In the last few years, the Canadian multi-national mining company, Manhattan
Minerals, has discovered ore deposits containing significant amounts of gold,
silver, copper, and zinc, much of which lie beneath the village of Tambogrande.
Yet, as the history and geography of the area demonstrates, the Tambogrande
area is quite an unusual choice for the location of a potential metal mine site for
many reasons. A considerable amount of international money was used to
convert the land into irrigated farms; now agricultural exports from this region
contribute significantly to the national economy. Manhattan Minerals is now
proposing that much of the village be relocated to make way for mine facilities,
which would operate for at least 20 to 30 years immediately adjacent to the
homes of about 14,000 to 16,000 people and some of the most productive
agricultural lands in Peru.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Manhattan Minerals is proposing to exploit the ore by constructing several open

pit excavations, one of which (referred to by the company as TG-1) would be at
the present location of the village. TG-1 would be approximately 250 meters
deep, and would require the relocation of an estimated 8,000 inhabitants out of a
total population of between 14,000 and 16,000. It should be noted that the
Manhattan website states about 1600 households will be relocated.

(Photo: Ernesto Cabellos,

Guarango Cine y Video.
Local youth activists
working on strategies to
resist the establishment of
the mine. The entire area
behind them would be in
the proposed pit, TG-1.)

Any proposal to develop large scale mining in a predominantly agricultural area is

guaranteed to cause controversy, especially when the local citizens are
unfamiliar with the expected impacts, question whether they will benefit from
such development and dislocation, and where they feel they are not being
adequately informed about the issues and potential consequences.

Local citizens are extremely concerned about the potential impacts to the local
water resources if such development occurs. Specifically, they fear that mining
activities will negatively impact the sources and volumes of waters used to
irrigate agricultural crops (mangos, cotton, limes, papayas, rice) which are the
lifeblood of the present economy. They worry that such mining development
would lower the local water table, causing domestic wells to dry up, and possibly
killing the algarrobo trees. Furthermore, the citizens are reasonably concerned
that mine development may contaminate their surface and ground waters, soils
and crops, via the development of acid, metal-laden wastes and the release of
potentially-toxic process chemicals such as cyanide. Such impacts have
resulted, in fact, in areas surrounding numerous mining sites, in Peru and
throughout the world.

There are hundreds of sites throughout the developing countries of the world
where international mining companies are operating or propose to operate such
huge projects. Almost all of the technical and environmental information and
data relating to these projects is paid for and prepared by representatives of the

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

(Photo: Ernesto Cabellos,

Guarango Cine y Video.
Mango trees outside
Tambogrande.)

mining companies. These environmental documents prepared by the

consultants to the mining companies and lending institutions normally fail to
consider potential impacts from the viewpoints of those most likely to be
impacted---the local citizens.

Mining consultant’s reports frequently fail to realistically discuss the unpleasant

impacts; it is not good for their future employment prospects, and it is easier for
the politicians to approve projects when no negative impacts are “foreseen.”
Less-than-candid consultant’s reports are often produced in both developed and
less-developed countries (Moran, 2000). This leads to a great deal of mistrust on
the part of the public, and frequently results in unforeseen environmental costs
which must later be paid for, often not by the companies, but by the taxpayers
(Moran, 2001). Such concerns have developed regarding the Tambo Grande
project.

The purpose of this report is to raise and begin to discuss critical environmental
and water-related issues from the perspective of those potentially affected, the
community. It is intended to provide an independent outside review of the quality
of the current publicly available environmental information for the Tambo Grande
mining project prepared by Manhattan or its consultants.

Various Peruvian government officials have stated that the Tambo Grande
mining project will have no negative environmental impacts. This report will also
comment on these assertions.

This report is not intended to instruct the local citizens and regulators as to what
to do. It is intended to provide independent technical support to the local citizens
and NGOs, and to assist them in determining their own choices regarding their
environment and its development.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

FINDINGS
My opinions and observations result from:

• Visits to the Tambogrande area, discussions with many local citizens, one
well driller, university laboratory personnel, and representatives of
numerous local and national non-governmental organizations (NGOs);
• A review of all publicly-available environmental technical information; and,
• A meeting with senior representatives of Manhattan Minerals in Lima.

All activities occurred between May 1 and May 14, 2001.

A discussion of the water-related and environmental aspects of the Tambo

Grande project is more meaningful if we first review some of the proposed mining
activities. Unfortunately, Manhattan Minerals has not released any studies (i.e.,
the EIA or any feasibility studies) that describe the specific locations of the
proposed facilities or which discuss the proposed process details.

The company website (www.manhattan-min.com/), supplemented by

conversations with the Manhattan project manager, indicate that the company
proposes to excavate several open pits, the first designated as TG-1, which is
likely to be about 1000 meters long by 650 meters wide by 250 meters deep.
Another deposit, TG-3, is located about 500 meters to the south of TG-1, and the
open pit is expected to be about 1400 meters long by 1000 meters wide by 350
meters deep. All anticipated pit dimensions are based on existing exploration
drilling information and metals prices; such information could change in the
future, as could the pit dimensions.

Construction of any deep open pit creates a huge, low elevation area, which
becomes a “sink” that collects local ground water, if it exists. Likewise, this sink
will potentially receive nearby surface waters, such as the Piura River, and other
tributaries. Hence, such pits have the potential to deplete existing river flows,
and to lower local and regional ground water levels if they are not very carefully
engineered and maintained. Pumping of pit-inflow water is often one of the most
costly and important aspects of mine operation. Thus, for TG-1 construction,

(Photo: Ernesto Cabellos, Guarango Cine y

Video.
Activist Ulisses Garcia reviewing the proposal
for the mine with a map showing the pit
locations. TG-1 would destroy part of the town;
TG-3 would require a river diversion. Ulisses’
father was an outspoken opponent of the
proposed mine, and was murdered last March.)

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Manhattan anticipates needing to divert one of the tributaries to the Piura River,
Carneros Creek, and creating a constructed channel for portions of the Piura
River. Manhattan expects that construction of the TG-3 pit would necessitate
diverting a significant length of the Piura River (Telephone conversation, June
12, 2001, Richard Allan, project manager).

The rocks to be mined are mineralized, and contain high concentrations of many
metals and non-metals. Once the pits are excavated the rocks will be exposed to
contact with air and water, which will initiate chemical reactions that form acid
and dissolve metals and other chemicals from the rock. These acidic,
contaminated waters (leachates), if not contained, can pollute local surface and
ground waters, and soils.

Clearly it is imperative for a company to thoroughly understand the details of the

chemical quality, presence, amounts, flow directions, and interactions of local
surface and ground waters before beginning a project. It is also imperative that
the local citizens understand these details before they can reasonably be asked
to analyze the options, or to support such a mining project.

Findings on Baseline Study conducted by Manhattan Minerals

From May 1999, when recent exploration drilling began, until May 2001 when my
project review took place, Manhattan had made public only one “substantive”
environmental document concerning Tambogrande--the Environmental Baseline
Study, released in July 2000. The title of this document called it a “preliminary
report”; unfortunately it has never been finalized. It is common practice for
mining environmental reports to be designated “preliminary”, and, unfortunately,
for no final report to be released. Nevertheless, the language of the report
implies that it was intended to provide an indication of the “baseline” conditions of
the project area.

What is a baseline study in the context of mining? With respect to water

resources, it is a study intended to define, characterize, and quantify the water
resources of an area prior to commencement of actual mining and mineral
processing activities. Such studies normally define, in considerable detail, the
amounts and quality (chemical and biological) of all surface and ground waters
present in a study area. Because both water quantity and quality often vary
markedly from month to month (and often from day to day), such studies must be
quite detailed, and usually involve sampling throughout at least one entire
calendar year. Water quantity and quality (both surface and ground waters) can
also vary markedly from place to place. Thus, baseline sampling must also be
conducted at a significant number of locations, especially those likely to be
impacted by future mining activities. In order to be usable, such sampling must
yield statistically valid results.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Baseline water resource studies at mining sites routinely include sampling of

aquatic life, such as fish and bottom-dwelling organisms. In addition, these
studies are usually integrated with sampling of the geologic materials that will be
mined. In this way it may be possible to foresee impacts to water quality, such
as the development of acid conditions, or for example, the likely contamination
due to elevated arsenic concentrations.

When adequately conducted, a baseline study allows users to perform the

following tasks:

• to estimate how much water is available for various uses prior to project
initiation;
• to compare the pre-mining water quality (and quantity) with future water
quality (and quantity), so that one can understand the causes for future
changes, and to determine whether changes have been significant;
• to anticipate the development of many future impacts to water resources;
• to determine who, or what group was responsible for the changes.

Decision-makers and regulators must have such information in order to truly

enforce regulations and to quantify penalties or financial assurance bonds.

Without an adequate baseline study, it is frequently impossible to demonstrate

technically or legally which party is responsible for any future impacts.

Baseline Study Details

The Baseline Study describes several possible aquifers, or water-bearing units,
but details about the actual presence of ground water are largely lacking,
especially for the deeper zones. Most of the discussion is speculative and
theoretical. Because the open pits are anticipated to be at least 250 to 350
meters deep, it is imperative that deep test wells be constructed and tested.
There is no evidence in the report that such detailed testing has been conducted,
and no actual well data are cited to explain the ground water conclusions. It
appears that no long-term aquifer tests were performed in any wells. No maps
depicting water levels or ground water flow directions (based on actual
measurements) are shown in the Study.

Map 3.9 in the Baseline Study shows the positions of all the ground water
monitoring locations in the Study. While the map is difficult to read, it appears
there were only 7 total wells for all water-bearing units in the entire study area.
All were located south of the Piura River and all appear to be relatively shallow.
Most of the discussion suggests that these wells had low yields. However, these
conclusions are open to question because no details are presented on the
drilling methods, fluids employed, or completion and well development
techniques used. In fact, a discussion with a driller for one of the Piura-based
NGOs (Hector Otero Aviles, of CIPCA---Centro de Investigacion y Promocion del

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Campesinado) who was present when several Manhattan wells were drilled
suggests that there may have been little or no development of these wells. That
is, it appears the drilling contractors never conducted activities necessary to
remove fine-grained sediments from the wells prior to testing them. Thus, it is
unlikely that we can learn much about the water-yielding characteristics of these
rocks from the existing well data.

Discussions with Mr. Otero and local citizens indicate that the wells Manhattan
drilled to augment the water supplies in some outlying villages also were not
developed. Hence, it seems unreasonable to assume that reported low well
yields are representative.

Table IV. 4, in Annex IV of the Baseline Study, shows the ground water quality
analyses. Only five actual samples were analyzed, and only one included
metals. In fact, the list of metals and non-metals that were determined is very
incomplete when compared to the Canadian criteria documents (see website
http://www.eao.gov.bc.ca/PUBLICAT/PRO_guide2001/appendices/a_4/2.0.htm#
3.0). Some of the few metals reported were from unfiltered samples, while
others were from filtered samples. No analyses are from the deeper geologic
zones that will actually yield the majority of the ore.

Table IV.7 of the Baseline Study presents a comparison between water quality
samples analyzed at the ASL lab in Canada versus those analyzed at the IHHIS
lab at the Univ. of Piura (all collected February, 2000). Most of the samples are
from surface water sites. Unfortunately, the analytical agreement between the
determinations for many of the duplicate samples is extremely poor. Also, the
list of constituents is extremely incomplete. Lastly, there is no indication that
holding times were adhered to, for either lab. No total cyanide was determined.
It is obvious that these water quality data, together with the other water quality
data Manhattan has made public, are totally inadequate to provide a reasonable
baseline data set.

Pages 127-128 state that bedrock water quality samples from nine sites were
airlifted, and that samples were then taken to the laboratory (University of Piura)
for analysis. Only measurements for pH, EC, and temperature were made on
these samples—back at the lab. However, since airlifting would alter the water
chemistry of these samples, these measurements would be largely useless.

The Baseline Study fails to report any studies that would indicate that Manhattan
has evaluated the potential impacts of dramatically increased rainfall that occurs
during El Nino events. While average local rainfall may be about 60 mm per
year, about 4,000 mm of rainfall is reported to have fallen during the 1998 El
Nino event. Will roads and bridges, and the various mine waste facilities be
able to withstand the next El Nino event? Such facilities could easily fail leading
to release of highly contaminated wastes into the rivers, ground water,
agricultural fields, and into the village. Such events could generate massive

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

contamination, health and economic problems, together with possible deaths.

Clearly, all facilities and operations decisions must take El Nino rainfall into
account.

Between May 1999 and the end of May 2000 alone, Manhattan had drilled more
than 400 exploration and feasibility holes (verbal communication, G. Clow, May
14, 2001). Nevertheless, the Baseline Study contains no environmental data
from the roughly 400 holes drilled before the end of May 2000. Samples from
these holes were obviously analyzed for sulfide content, otherwise the various
cross sections showing the oxide – sulfide ore boundaries could not have been
constructed.

While the Baseline Study contains little actual environmental data related to
water resources, the sections describing the Peruvian environmental legislation,
regulatory agencies, guidelines, and various environmental enforcement
processes covers about 40 pages!

At the most basic level, Manhattan has failed to adequately investigate and
describe the following:

• the availability of shallow and deep ground waters;

• the quality of surface and ground waters; and
• the chemical composition of the rocks to be mined and impacted (this
would include the soils / overburden, ores, waste rock, future tailings).

In short, there is no basis for compiling a statistically valid baseline data set for
ground water or surface water quality. Also, there is little useful information on
the presence of ground water. As a result, it would not be possible to distinguish
when water levels had declined, or whether pump yields had been reduced.
Information presented in this Baseline Study is inadequate to allow the public to
detect future impacts and to assign responsibility for these impacts, if they were
to occur.

The Environmental Baseline Study (July 2000), is an extremely poor quality

study, and would not be acceptable as the baseline portion of an Environmental
Assessment (EA) in Manhattan’s home country, Canada, in the U.S.A., or in
western Europe.

Manhattan Minerals argues that the Baseline Study was preliminary, and thus
does not represent their final product. However, Manhattan has released no
revisions to this report, nor have they released any other environmental studies
during the almost two years since their drilling program was initiated.
Furthermore, Manhattan representatives have stated that numerous other
studies are ongoing, but that none will be released until finalized (G. Clow, former
CEO, May 14, 2001 meeting; subsequent telephone conversations with project

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

manager, R. Allan). This position is reasonable, but the same policy clearly was
not followed for the Baseline Study.

Representatives of international mining companies are fond of saying that they

operate in developing countries using the same environmental practices and
criteria they use in their home countries. Because Manhattan Minerals is based
in British Columbia, it is informative to refer to the B.C. environmental guidance
documents to learn what information would be required when submitting a
comparable study there. The major information requirements for the
“environmental setting” are presented on the website of the B.C. Environmental
Assessment Office (http://www.eao.gov.bc.ca)

As part of the Environmental Assessment (EA) process, the same B.C. agency
also prepares project-specific reports that list data and information
requirements, and makes them public on the internet. For example, the
environmental information requirements for the Prosperity Gold Mine in British
Columbia are presented at:
http://www.eao.gov.bc.ca/PROJECT/MINING/Prosprty/finalreport/secB6.htm

Clearly there are many differences in the environmental details between the
proposed Prosperity Mine and Tambo Grande. Some of the proposed monitoring
activities in the much wetter B.C. setting would not be applicable, however a
comparison is very instructive in demonstrating deficiencies of the Manhattan
baseline program.

For example, the table below compares a few of the environmental requirements
for the Prosperity Gold Mine from the B.C. Environmental Assessment Office with
what was done for the Tambo Grande project.

Table: Comparison Between Publicly-Available Tambo Grande Information

and Selected B.C. Environmental Assessment Office Requirements for the
Prosperity Gold Mine, British Columbia

Prosperity Gold, British Columbia Tambogrande, Peru

Comparison 1
Provide results of a hydrogeological study which No studies of facilities seepage rates or flow
determines seepage rates and direction into or from direction are presented.
the pit, waste rock dump and tailings impoundment
areas, and any impacts on surface stream flows and
surface water quality. Groundwater data is required
to assess the extent and likelihood that the pit will
flood at abandonment, and that groundwater will
contribute to the tailings impoundment and waste
rock dump water balance

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Prosperity Gold, British Columbia Tambogrande, Peru

Comparison 2
Taseko Mines is required to provide a detailed water No water balance studies are presented.
balance for the mill, pit, tailings impoundment and
any other associated infrastructure, during pre-
operational, operational, closure and post-
operational phases of the project, for each of the wet
case, dry case, and expected case scenarios.

Comparison 3
Existing monitoring wells as shown in Figure 8 No facilities locations have been sampled by
must be sampled. While not required for the Project designated monitoring wells. Analyses from other
Report, Taseko should note that prior to site ground water sites are not representative of a
development, groundwater wells should be complete hydrologic year.
established to sample aquifers in both surficial
deposits and bedrock below at the following
locations:
Downgradient from the pit
• Downgradient from the waste rock piles
• Downgradient from the tailings impoundment
• Upgradient from the pit
• In Groundhog Creek, downgradient from the
tailings impoundment.
The locations of these monitoring wells must be
selected so that they are not disturbed by future
development. One year of sampling must be
completed prior to site disturbance (section 6.3.1.2).

Comparison 4
The following are minimum requirements for None of the frequency and duration criteria have
frequency and duration of monitoring. Streams-- been met for either surface or ground water quality
minimum of monthly for one full year, plus: samples.
• Weekly for five consecutive weeks starting
with early spring freshet on the rising limb of
the hydrograph for each stream as indicated by
stream hydrology monitoring;
• Weekly for five consecutive weeks during low
flows identified from stream hydrology
monitoring. The lowest flows accessible for
each stream should be monitored to represent
base flow conditions most closely.
Ground water—all wells must be sampled quarterly
for one year as a minimum (section 6.3.1.3).

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Prosperity Gold, British Columbia Tambogrande, Peru

Comparison 5
Surface and ground water samples must contain the None of the analyses presented in the baseline study
following variables: temperature (field), dissolved contained all, or even most of the constituents listed
oxygen (surface samples only), pH (field and lab), above. In many cases the detection limits used did
specific conductance (field and lab), total suspended not meet those mentioned in the B.C. criteria (see
solids, turbidity (field and lab), alkalinity (total), section 6.3.1.4, table 3).
sodium (ground water only), sulphate, fluoride,
dissolved organic carbon, ammonia, nitrite, nitrate,
total nitrogen (lakes only), ortho phosphorus (D),
total phosphorus (D), chloride, hardness, aluminum
(D), antimony, arsenic, barium, beryllium, boron,
cadmium, chromium, cobalt, copper, iron, lead,
manganese, molybdenum, nickel, selenium, silver,
titanium, uranium, vanadium, zinc –all D and
T(section 6.3.1.4). (D=dissolved; T=total)
Comparison 6
Predict the ARD/ML (acid rock drainage / metal No data from whole rock geochemical analyses,
load) potential of all materials (bedrock and static tests or kinetic tests have been presented in
surficial) to be disturbed or created (i.e. tailings) the baseline report or any other publicly available
during all phases (construction, operational, post- reports.
closure) of the proposed project, and reduce the
level of uncertainty to one at which the potential
risk can be identified, and effective impact
prevention strategies can be selected (section
6.4.3.1).

(Reference:
http://www.eao.gov.bc.ca/PROJECT/MINING/Prosprty/finalreport/secB6.htm).

The entire Environmental Issues section for the Prosperity Gold Mine is 43 pages
long, and defines all EA information requirements, in addition to specific baseline
requirements. However, after only a few minutes reading through this guidance
document, the average reader would realize that the Tambo Grande Baseline
Study is totally inadequate, if judged by these standards.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

RELATED OBSERVATIONS
The following observations draw lessons from the authors experience at other
mine sites relevant the Tambo Grande project.

“Zero Discharge Facilities”

The mining industry often says that there will be no leakage from modern tailings
facilities because they will be lined with synthetic liners. Thus, they are often
called “zero discharge facilities”—implying to the average citizen that there will be
no leakage. Unfortunately, this is an obvious exaggeration; all liners leak to
some extent. This leakage can be very significant if the liners were not installed
correctly. Even when correctly installed, small amounts of leakage can produce
significant impacts if they occur over long periods of time, such as the decades
proposed for the operation of this mine. The management of potential leakage
becomes even more difficult once the mine closes. It may require that some
form of water management activities continue in perpetuity after mine closure.

Manhattan has made the same claims about “zero discharge” at the Tambo
Grande project, implying that there will be no release of waste contaminants to
the environment.

Water Quantity
Most mining operations require massive quantities of water for processing and
other uses. Hence, the competition for local water resources almost always
increases where open-pit mining occurs. There will be an obvious increase in
competition for surface and ground waters between Manhattan and the various
present water users if the Tambo Grande project is developed.

Processing Chemicals
Modern mining is a chemical process, not simply a physical one. Metals are
extracted from the rock using numerous potentially toxic chemicals, such as:
sodium cyanide, lime, soda ash, kerosene, various inorganic and organic acids,
sodium sulfite, copper sulfate, sodium metabisulfite, sulfur dioxide, sodium
silicate, numerous flocculants, thickeners and collector compounds of undefined
chemical composition, etc. These chemicals are disposed of in the tailings along
with the other metal residues. Most or all of the chemicals mentioned above will
be used by Manhattan if the project becomes operational.

Solid Waste
Mining produces tremendous amounts of solid waste (waste rock, tailings) which
contain process chemicals, waste metals, and other toxic components. The U.S.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

EPA states in its Toxics Release Inventory (TRI) for 2001 that the mining industry
is the largest source of toxic pollutants in the USA (U.S. EPA, 2001). In 1999, it
released approximately 3.98 billion pounds of toxic materials, more than half of
all the toxic pollution (7.8 billion pounds) released in the United States that year.

Previously, Manhattan has refused to make public detailed geochemical

analyses of the rock to be mined, but it is obvious from the information that has
been released that the sulfide and metal concentrations are extremely high;
these deposits are referred to as a massive sulfide deposits for a reason.
(Tegert, et. al., 2000, page 324, states: “The TG1 and TG3 massive sulphide
deposits consist of 85 to 99 percent pyrite,….”) Thus, the waste rock will likely
form acidic (pH probably between 2.5 and 3.5), high TDS, high sulfate, metal-rich
leachates after weathering. Such leach waters would be toxic to most plants,
aquatic life, and many organisms.

Based on the preliminary information presented in the AGRA Simons (2000)

report, it seems likely the tailings will initially be alkaline (initial pH may be greater
than 9.5) due to the high concentrations of process chemicals added to the ore.
Eventually, however, the tailings would likely become acidic as the high alkalinity
declines and the sulfide oxidizes. Whether highly acidic or highly alkaline, the
waters leaching from such tailings are likely to contain high concentrations of
many toxic constituents such as: metals (aluminum, antimony, arsenic, barium,
cadmium, copper, chrome, cobalt, iron, mercury, molybdenum, manganese,
nickel, lead, selenium, silver, thallium, vanadium, zinc); non-metals (sulfate,
nitrate, ammonia); cyanide and related breakdown compounds (metal-cyanide
complexes, cyanate, thiocyanate); possibly radioactivity (uranium, radium, gross
alpha and beta); and organic compounds.

Chemical Spills and Process Waste

Mining sites typically have spills of chemicals and of the process wastes. Such
spills can have serious impacts given the massive volumes of wastes and
reagents involved. There is little reason to believe that Manhattan can operate
without experiencing unforeseen spills that are normal practice in the mining
industry. However, in this case, they could occur in proximity to productive
agricultural fields.

Potential Contamination of Waters, Soils and Crops

As noted above, the Tambo Grande solid wastes will contain numerous chemical
contaminants, and many will exist as forms mobile in water, capable of
contaminating local surface and ground waters. In addition, these huge
accumulations of waste rock and tailings will be exposed to local winds, which
will carry contaminant-laden dust particles into nearby domestic areas, schools,
surface waters, and agricultural fields. These particles are potentially toxic to
humans, animals, fish, and crops—especially when released over many years.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Long Term Impacts

Some mining impacts do not become visible for many years. For example, acid
discharges from mining wastes may not produce obvious negative impacts for
many years, or even decades. As a result, some modern mining situations may
appear to be without impacts, when in fact it may simply be too early to judge.
Once such impacts do develop, however, they may continue for centuries if not
adequately and continuously managed.

One of the greatest shortcomings in most mining studies, and in the existing
Manhattan work, is to underestimate the length of time the public should consider
when attempting to evaluate future impacts. For example, acid drainage has
continued for hundreds and even thousands of years at sites originally mined in
ancient Scandinavia, Spain, and Greece. Also, it is an unproven assumption that
buried wastes will remain “contained” even a hundred years in the future. As
evidence of these concerns, the State of New Mexico (USA) recently
recommended that mining companies provide financial bonds adequate to pay
for treatment of contaminated waters for a period of 100 years following mine
closure (Moran, R.E. and McLaughlin Engineers, 2001).

Agricultural Resources
There are very few examples where large metal mining and agriculture operate
next to each other. Manhattan has repeatedly mentioned the example of the
Martha Mine in New Zealand as one example. It is true that this gold and silver
mine, operated by Waihi Gold (a subsidiary of the Australian company,
Normandy Mining) is situated within an agricultural and dairy area. However, the
comparison is interesting. The open pit operations were not begun until 1987.
Thus, the history of these activities co-existing is quite short-lived. Also, the mine
is located in an area that receives about 2,300 mm of rainfall per year—quite
different than the Tambogrande setting.

The area in New Zealand had much earlier metal mining, beginning at the end of
the 19th century, which was done by underground methods, and was conducted
on a much smaller scale. These activities had contaminated local waters such
that many of the “baseline” pH measurements were less than 4.0, prior to the
open-pit operations. As early as late 1993, incidents of contaminated (low pH,
metals, sulfate) runoff from mine wastes were reported at the site. Since that
time, the company has been required to construct encapsulated waste rock cells
and ground water cut-off drains, and to operate a full time water treatment plant.
All surplus water is treated prior to discharge in the river. At present, the Martha
Mine operates on 400 hectares of prime agricultural land, and is negotiating for
more.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

The Marta mine is anticipated to operate until 2007. After mine closure, the site
will have to be remediated, and it is possible that the treatment plant may need to
continue operating for an indefinite period of time. I was unable to locate
information on the amount of any financial assurance that the company was
required to present to the government. The above information comes from
website locations sponsored by Waihi Gold and one of their consultants:
www.ameef.com.au/publicat/groundwk/grnd998/gcase3.htm and
www.waihigold.co.nz/com

It is interesting to note that an extensive internet search revealed numerous

sources of information on the Martha Mine, but all were, either directly or
indirectly from company sources. No company-independent sources of
information or data could be located on the internet.

Manhattan has also taken Tambogrande residents on at least one trip to visit
mining sites near Copiapo, Chile. These sites operate near vineyards. While I
did not review specific data on these sites, it is clear that these locations are also
quite recent, and the long-term impacts are not likely to be visible.

Impacts of Modern Mining

It is not true that there will be no environmental impacts. Manhattan has not
released any study describing potential environmental impacts, such as an EIA.
However, it is clear that their representatives have been implying, in public
presentations, that no impacts will occur.

In addition, the Ministry of Energy and Mines (MEM) is encouraging this opinion.
In a statement released on May 2, 2001 (see www.mem.gob.pe for original in
Spanish), the Minister of MEM said that: “…modern mining applies up-to-date-
technology and complies with present laws, co-existing perfectly with agriculture
and other economic activities, and it is completely respectful of the environment;
there being no reason to generate concern and worry among the people.”

Unfortunately, this is simply not true. Modern mining practices are much
improved over older methods, but nevertheless, there are usually some negative
impacts to water resources (both surface and ground waters), often resulting in
degradation of water quality and/or some reduction in water quantity. In addition,
there is almost always some contamination of nearby soils, and some negative
impacts to local aquatic life. In roughly 30 years of experience in water and
environmental chemistry issues, much of it associated with mining, I have never
seen a site that did not have some negative environmental impacts (see Moran,
2001, and http://www.cipma.cl/hyperforum/index.htm).

Additional evidence of the pervasive impacts associated with mining sulfide ores
can be found by reading Todd and Struhsacker (1997). This study was
commissioned by the mining industry in an attempt to favorably influence mining

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

legislation in the State of Wisconsin (U.S.A.). It was intended to show “…that a

mining operation has operated in a sulfide ore body in the United States and
Canada for at least 10 years without polluting groundwater or surface water from
acid drainage at the tailings site or at the mine site or from release of heavy
metals.” It was also intended to show “….that a mining operation that operated in
a sulfide ore body in the United States or Canada has been closed for at least 10
years without polluting groundwater or surface water from acid drainage at the
tailings site or at the mine site or from the release of heavy metals.” Data from
hundreds of mine sites from the U.S. and Canada were investigated. A careful
reading of the details in this paper shows that the authors were unable to locate
any sites that totally complied with the criteria at the time the paper was
published.

It is possible that the reclaimed McLaughlin Mine in northern California may now
comply with the criteria of the 1997 study. Nevertheless, the basic conclusion of
the study remains the same: that very few sulfide-rich sites have been closed
without generating acid drainage problems.

The Cost of Monitoring

Chemical monitoring and analysis are very costly. Citizens cannot normally
afford to conduct such activities. Thus, it is often not done. As a result, only
company technical information, data, and viewpoints are available to the public.

During my Tambogrande visit in May 2001, we provided some basic training in

water quality sampling techniques to representatives of one Piura-based NGO,
and a few samples were collected and analyzed. However, because the basic
analytical costs are more than $200 per sample, it is not possible for this or most
local groups to provide their own data. As a result, conclusions about baseline
concentrations and existing or future impacts are routinely made using only the
data provided by the mining company. Such company data often provides a very
limited and biased picture of the most important issues facing the local
communities.

Community Role in Decision-Making

The desires of the local citizens are important in the decision-making process, in
addition to the studies prepared by the mining company or their paid consultants.
While the Ministry of Energy and Mines (MEM) has said that the mine will not be
developed without the support of the local people, it is clear from some of their
written announcements that this is doubtful. A careful reading of MEM’s
announcement of May 2001 (see www.mem.gob.pe) shows that they have all but
decided that the project should be approved, despite the obvious negative
opinions of thousands of the local citizens. Alejandro Silva Reina, an attorney
with an NGO supported by the Catholic Church in Piura, reports that about
28,000 notarized signatures were collected from voters within the Tambogrande

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

district (out of about 37,000 eligible voters) protesting continued development of

the mine.

Frequently the desires of the citizens are dismissed as simply the wishes of
poorly informed folk, and it is posited they should instead be guided by technical
studies. Unfortunately consultants who receive most of their income from mining
and related industries normally conduct these studies. Also, their studies are
often far less objective than is claimed. It is common for these studies to revolve
around water-related predictions involving the use of computer models that
appear quite sophisticated. Frequently they are not. The results are often found
to be very inaccurate and overly optimistic when compared to actual events.
Unfortunately, such comparisons are seldom made. Reasonable decision-
making requires actual data, collected by independent parties, rather than simply
relying on computer simulations.

Financial Guarantees for Closure

Adequate financial assurance measures are imperative to prevent the public
sector from having to fund long-term environmental cleanups. Such measures
often include financial bonds held by the State or possibly environmental liability
insurance. Several international mining companies have now been required to
provide bonds greater than $100 million for mine remediation and operation of
water treatment facilities. Manhattan has claimed that they are willing to provide
financial assurance, but no details regarding financial assurance have been
publicly discussed. While such issues need to be made public early in the
decision-making process, the presently available Manhattan environmental data
are far too inadequate to make reasonable evaluations of either environmental
impact assessments or reasonable estimates of bond calculations for
environmental liability.

Government Conflict of Interest

The Peruvian government has an inherent conflict of interest in regulating the
Tambo Grande project. Because the government stands to receive 25 percent
ownership in the project if it goes forward, it is conflicted in enforcing
environmental laws and criteria. Adequate enforcement of environmental
regulations may be viewed as detrimental to the collection of revenues. This
form of shared government ownership has resulted in numerous examples of lax
regulatory oversight and severe environmental damage, as can be seen from
recent events at the Kumtor Mine in Kyrgyzstan, the Aurul Mine in Romania, and
the Ok Tedi Mine in Papua New Guinea.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

RECOMMENDATIONS
All ongoing studies (baseline, feasibility, etc.) intended to culminate in the Tambo
Grande EIA should continue. However, independent consultants should
participate in and review all such studies and environmental issues. The citizens,
or the regulators should make no judgments or decisions concerning project
approval, until such complete, detailed, and independent studies are made
publicly available

At the present date, Manhattan Minerals has not released any studies (i.e., the
EIA or any feasibility studies) that describe future impacts, the specific locations
of the proposed facilities or which discuss the proposed process details. Also,
the present baseline study is inadequate and should be revised in such a way
that it would be able to comply with the general data and information
requirements set out in the B.C. Environmental Assessment Office guidelines
(see section 2.0). At present, concerned citizens have no technical or scientific
basis on which to judge the claims Manhattan has made about future
environmental impacts.

Local citizens would be much more likely to trust statements about future
impacts if an “independent” study of the Tambo Grande data and information
was performed. Thus, it is recommended that Manhattan provide community
leaders with resources to conduct their own, independent assessment, of
Manhattan’s conclusions.

Such activities would be generally guided by the B.C. criteria presented in

section 2.0, and would be conducted by expert consultants selected by
representatives of the citizen’s groups involved. These consultants would be
allowed to oversee the Manhattan environmental activities intended to define the
baseline information and describe potential impacts. These independent
activities would also include the ability to accompany Manhattan representatives
during all environmental field activities, and to receive and analyze split
environmental samples.

These activities would be directed by the consultants themselves, and would be

independent of influence from all outside sources, including Manhattan, the
Peruvian Ministry of Energy and Mines, and citizen’s groups and NGOs.

Data collected by this independent group and by Manhattan’s representatives

would be openly shared in a timely fashion, and could be interpreted as each
side saw fit in their respective reports.

The Ministry of Mines should be required to consider the technical findings of

both sides, as well as the wishes of the affected public, in making their rulings
about whether the Tambo Grande project would proceed.

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Manhattan should not go forward with the Tambo Grande project without the
free, prior and informed consent of the potentially affected populations. The
current level of opposition to the project suggests that this consent does not exist
at present. Such informed citizen consent is now considered fundamental to
project approval by the World Commission on Dams (2000). The entire report by
this Commission can be found at www.dams.org. However, the most relevant
portion is Chapter 7: Enhancing Human Development: Rights, Risks and
Negotiated Outcomes, which can be found at:
http://www.damsreport.org/docs/report/wcdch7.pdf.

The EIA should discuss possible long-term impacts to agriculture. Such a

discussion should include collection of specific baseline data for soils and crops.

Manhattan should be required to present detailed information and data on a

population of sites from around the world where comparable mining and
agriculture have successfully coexisted. Such information should be presented
in the EIA, or in some other document made public prior to the release of the
EIA.

(Photo: Ernesto Cabellos, Guarango Cine y Video.)

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

REFERENCES CITED
AGRA Simons, 2000 (Sept.), Tambo Grande Project, Progress Report [Only
Portions of Report Available to Author].

Aste Daffos, Juan, 2001(January 31), Consideraciones Economicas y

Ambientales para Evaluar la Sostenibilidad del Proyecto Minero Tambogrande—
Informe Economico y Ambiental: Preliminary report prepared by ECO, Grupo de
Investigaciones Economicas, Lima, Peru.

Klohn Crippen-SVS S.A., 2000 (July), Proyecto Tambo Grande, Estudio de Linea
Base Ambiental, Informe Preliminar: prepared for Manhattan Sechura Compania
Minera S.A, Lima, Peru.

Manhattan Sechura Cia. Minera, 1999 (Sept.), Evaluacion Ambiental de las

Actividades de Exploracion de la Categoria “C” Para la Zona Urbana de
Tambogrande Por Decreto Supremo No. 038-98-EM, Piura, Peru.

Manhattan Sechura Cia. Minera, 1999 (Dec. 27), Proyecto Tambo Grande, Lima,
Peru.

Moran, Robert E., 2000, Is This Number To Your Liking? Water Quality
Predictions in Mining Impact Studies, p. 185-198, in Prediction: Science,
Decision Making and the Future of Nature. D. Sarewitz, R. Pielke, Jr., and R.
Byerly, Jr., eds., Island Press, Washington, D.C., 405 pg.

Moran, R.E., 2001, More Cyanide Uncertainties: Lessons from the Baia Mare,
Romania, Spill---Water Quality and Politics. Mineral Policy Center Issue Paper
No. 3, Wash. D.C., 15 pgs.

Moran, R.E., 2001, Aproximaciones al Costo Económico de Impactos

Ambientales en la Minería. Algunos Ejemplos en Estados Unidos y Canadá:
Ambiente y Desarrollo. Vol. XVII, Nº1, March 2001, CIPMA, Santiago, Chile,
pg.59-66.

Moran, R.E. and McLaughlin Engineers, 2001, A Review of Cost Estimates for
Collection and Treatment Systems—Chino Mine: prepared for the New Mexico
Environment Department.

Tegert, Peter, G. Allen, and A. Carstensen, , Regional Setting, Alteration, and

Mineralization of the Tambo Grande VMS District, Piura Department, Northern
Peru: http://www.manhattan-min.com/s/RelatedArticles.asp?ReportID=14863

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15 August 2001 An Alternative Look at a Proposed Mine in Tambogrande, Peru

Todd, J.W. and D.W. Struhsacker, 1997, Environmentally Responsible Mining:

Results and Thoughts Regarding a Survey of North American Metallic Mineral
Mines: Society for Mining, Metallurgy, and Exploration Preprint 97-304, Littleton,
Colorado.

Torres G., Fidel, 2001, Desarrollo de Piura: Agro, Mineria y Desertification—

Decisiones Ante Altos Riesgos, Piura, Peru.

Universidad de Piura, 1998 (January), Estudio Preliminar de los Pozos Ubicados

en el Valle Del Rio Piura Entre las Localidades de Tambogrande y Chulucanas,
Piura, Peru. [A proposal of future activities].
Universidad de Piura, 1999, Monitoreo de Aguas en el Area de Tambogrande
Para Mario Alvarado, Informe de Muestreo (signed Apr. 12, 1999), Piura, Peru.

U.S. Environmental Protection Agency, 2001,, Toxics Release Inventory. 1999

data and results can be found at:
http://www.epa.gov/tri/tri99/press/execsummary_final.pdf

World Commission on Dams (Nov., 2000), Dams and Development—A New

Framework for Decision-Making: World Commission on Dams,
www.dams.org

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