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Letter to Minister of Energy of Argentina, Jose Aranguren
The New Mining Policies of Argentina Deepen Violations of the National Glacier Protection Law
Three Mining Projects to Come Confirmed to Destroy Periglacial Environments
by Jorge Daniel Taillant
Executive Director, Center for Human Rights and Environment (CHRE)
August 17, 2016
Dear Mr. José Aranguren, Minister of Energy of Argentina
The recent announcements regarding the arrival of US$20 billion in investments to reactivate mining activity in Argentina, to take place between 2016 and 2021, work against the protection of glaciers and periglacial areas, as three of the projects that are slated to move forward are located in areas protected by the National Glacier Protection Law in the provinces of San Juan and Catamarca. The glacier law, as you know, clearly prohibits mining in glacier and periglacial areas.
El Pachón, owned by Glencore Xstrata in San Juan, is the first of these projects listed to advance thanks to the new mining policies adopted recently. Los Azules, owned by the Canadian company McEwen Mining, also in San Juan Province is also one of the projects deemed ready to move forward as is Agua Rica, owned by Yamana Gold and Glencora Xstrata in Catamarca Province.
Between these three projects is the majority of the new investments you have cited for the mining sector. The fundamental problem we have with this announcement is that each of these projects is to a greater or lesser degree, in the middle of periglacial areas which are today protected by federal law and by provincial laws that would make these projects ilegal if the proper impact studies were carried out to determine glacier and periglacial environment risks. If the mining sector is to operate as you suggest, in a transparent, sustainable and just way, none of these projects should move forward.
Perhaps you do not know the history of these projects in regards to the National Glacier Protection Law, but each of them and the companies that currently own them, have received international complaints against them in Australia, in Canada, and in Switzerland, due to their impacts on glaciers and rock glaciers as well as other periglacial environmental resources that exist at their location. Some of these impacts have already occurred in the exploration phases of these projects, while others would occur if the projects were to move forward as planned. The impact that has already occurred, in fact, is perfectly visible with commonly used programs such as Google Earth. The information regarding the impacts of these projects to glacier and periglacial environments is publicly known, and is also known by the National Government which you represent, as well as by the provincial governments where the projects are located. It is also obviously known to the companies that own these projects. In fact, it is because of projects like these that we saw in Argentina so much debate over the proposed glacier law in 2008 through 2010, before it was finally adopted. I will recall, that it was the mining sector and the provinces where these projects are located that so staunchly opposed establishing legal protections for glaciers and periglacial areas.
The governments of Argentina, Australia and Canada received, evaluated and admitted legitimate complaints that were well substantiated against these projects, and each government tried unsuccessfully to mediate the conflict that arose between these mining companies and civil society actors in Argentina that were carrying forth and continue to carry forth a campaign to protect Argentina’s glaciers and periglacial areas against mining impacts.
El Pachón (31°45’04.17″ S 70°25’40.23″ W) is a project located in San Juan Province, near the locality of Calingasta on the border with Chile. You can visit the project for yourself at the cited GPS location on Google Earth. On Google Earth, you will immediately notice numerous mining exploration roads erratically crisscrossing the terrain. If you look closely and if someone points them out to you, you will also see numerous active rock glaciers at the site. According to a glacier inventory prepared by the organization I represent, the Center for Human Rights and Environment (CHRE), founded by the former Secretary of Environment of Argentina, Romina Picolotti, El Pachón has some 200 rock glaciers in the area concessioned to Glencore Xstrata (formerly Xstrata Copper). Several of these rock glaciers, rich in hydrological content and luckily today, protected by the National Glacier Protection Law, are located squarely inside the projected pit area, and in the waste dump destined site for sterile rock.
These rock glaciers, protected by law, would be irreparably destroyed if Glencore Xstrata, were to move forward with El Pachón as planed. I met personally with the Minister of Mining of the Province of San Juan, Mr. Felipe Saavedra when we presented our 2011 report on periglacial impacts at El Pachón due to Glencore Xstrata’s past and planned work. Minister Saavedra received me again when we presented our complaint to the Australian Government, against Xstrata Copper’s violations of the OECD Guidelines for Multinational Enterprises and due to Xtrata Copper’s disregard for Argentina’s National Glacier Protection Law.
In our investigation on the predicament of the El Pachón project regarding impacts to periglacial environments, we came across a periglacial inventory map carried out by a consulting firm by the name of URS, hired by Xstrata Copper to map out periglacial areas. (see photo above or click active link). URS identified at least 100 rock glaciers (shown as brown polygons on the map) and extensive periglacial environment–permafrost (blue areas) at El Pachón, including an active rock glacier inside the projected pit area as well as in projected waste sterile rock pile dump sites. When presented with the company’s own evidence that there were indeed rock glaciers and periglacial environments present at El Pachón, San Juan’s Mining Minister had no alternative but to recognize that we were right about our claims, and that there were in fact rock glaciers present at the project site and in sensitive areas of the project. He did not indicate however, what the province would do about this problem, but he did assure me that if there was ice in those rock glaciers, they’d protect it as is called for by the law. Meanwhile, Xstrata’s Project Manager for El Pachón, Xavier Ochoa, incredibly, was declaring to national media, that there were no “ice glaciers” at El Pachón.
CHRE’s Glacier and Periglacial Inventory at El Pachón reveals the presence of rock glaciers at key activity areas at the El Pachón’s pit site.
Following the adoption of the National Glacier Protection Law in 2010, Xstrata Copper hired glaciologists working at the Argentine National Glacier Institute (IANIGLA) to study the periglacial environment at El Pachón. It is at least curious that Xstrata’s Project Manager, Mr. Ochoa hired glaciologists to study rock glaciers with active ice, when according to him, they didn’t exist at the project site!
San Juan’s provincial authorities in charge of overseeing mining projects and assigned to study the glacier situation, incredibly stated numerous times, that there were no glaciers anywhere near mining operations in San Juan, a statement that was clearly false for anyone working on glacier issues or involved with mining operations at high elevations in the area. One only needs to explore the area on Google Earth to verify that this region is very rich in glacier resources and that there are signs of mining exploration happening in numerous glacier and periglacial rich areas. These glaciers and periglacial environments are all protected by the National Glacier Protection Law.
The hired work contracted by Xstrata Copper (now Glencore Xstrata) to look at glacier and periglacial impacts at El Pachón, also aimed at developing a remediation plan to fix past impacts that are visible still today, as well as contemplate ways to avoid or remediate impacts in future operations. We asked the company numerous times for the results of these studies, but the company never chose to release this information or share with us any of its findings. During the former federal government administration under Fernandez de Kirchner, the Australian Government transferred our complaint (presented by CHRE, FuCI and El Algarrobo) against Xstrata and its El Pachón and Filo Colorado projects, to the Argentine Foreign Ministry, which took on the task of acting as a mediator between these Argentine NGOs and the company. The foreign diplomat in charge of this mediation practically had to force Xstrata Copper to engage in the mediation as they had agreed to do but were constantly delaying.
We at CHRE had taken on a reasonable position in the mediation, calling for appropriate studies and remediation actions for already existing impact as well as ensuring no future impacts to rock glaciers or periglacial areas, essentially, ensuring company compliance with the law. We were not asking for the company to leave or to cancel the project, but rather that it protect glaciers and periglacial areas, and that it adhere to Argentine Law. The Argentine Foreign Ministry found that CHRE/FuCI’s and El Algarrobo’s requests were reasonable, and tried numerous times to convince Xstrata Copper’s Legal Council and CEO of Operations, Julian Rooney, to come to the dialogue table, but ultimately the company chose to ignore the complaints presented by these civil society organizations.
In the case of the Los Azules project (31°06’23.49″ S 70°13’21.94″ W), also a copper project in San Juan Province, owned by the Canadian company McEwen Mining, as El Pachón, the project is surrounded by rock glaciers and periglacial terrain. You can see in the image below, the project map and the multiple rock glaciers mapped in blue polygons that exist within the project limits. The project is located near the colossal Calingasta Rock Glacier, one of the most magnificent and emblematic rock glaciers in the region, attesting to the fact that the project is located in a very rich rock glacier zone.
Los Azules is also the subject of an international complaint that we filed along with our partner FuCI, due to the company’s failure to take rock glacier and other periglacial impacts into account during project preparation and development and due to its disregard for the National Glacier Protection Law. In 2012 CHRE and FuCI presented this complaint to the Corporate Social Responsibility Counsellor of the Canadian Government, then, a recently created office to address international complaints against Canadian mining companies. In this case, we had a similar experience as with Glencore Xstrata. There was an initial interest in dialogue and mediation, until the company realized that we had very solid evidence that their project was squarely located in lands that were protected by Argentina’s new glacier protection law and that mining was in fact prohibited in these areas.
As had occurred with our complaint to the Australian government, the Canadian government found that CHRE’s/FuCI’s claims were perfectly legitimate and merited mediation with the company. We had found 79 rock glaciers (see picture) at Los Azules, and extensive periglacial environment inside the project area. The CSR Counsellor admitted the complaint and tried to conduct mediation with McEwen.
CHRE traveled numerous times to meet with Canadian authorities, in an attempt to convey our concern that this project had issues with the Argentine National Glacier Protection Law. Without the necessary studies to look at glacier and periglacial impacts of mining operations, without the inventories that should have been completed by the IANIGLA, without the impact studies to glaciers that should have been summoned by the province of San Juan, and also without any opinion from the federal Environment Secretariat, this project should not move forward.
Given that the national and provincial authorities evidently did not want to publish information that could be construed to indicate that these priority mining projects were in conflict with glaciers or periglacial areas, CHRE chose to publish its own information on Los Azules’ glacier and periglacial locations and past as well as likely future project impacts. Using GPS tools such as Google Earth and with guidance from professional glaciologists as we have in all of our reports, CHRE published a report on periglacial impacts at Los Azules. We noted that images readily available on Google Earth show mining exploration roads cutting through legally protected active rock glaciers. (see photo below). This, claimed CHRE and FuCI, was illegal under national law.
Mining exploration roads at Los Azules cut through protected active rock glaciers.
But just like Glencore Xstrata, McEwen Mining, owner of the Los Azules project, when confronted with the undeniable evidence that their project was in conflict with the Argentine Glacier Protection Law, and that the project could be deemed illegal, refused to participate in the Canadian government-sponsored mediation offered through the CSR Counsellor. Further, McEwen was receiving a clear message from the provincial government in regards to how it would react to glacier conflicts by mining projects. With Barrick Gold’s Veladero and Pascua Lama, the mining authorities in San Juan superficially overlooked the presence of glaciers and periglacial areas in Veladero’s and Pascua Lama’s area of impact, giving the company a green light despite evident and documented conflicts with the National Glacier Protection Law. Surely McEwen must have thought that the San Juan Provincial authorities would ensure that any conflict with the glacier law would be swept under the rug, just as the province had already done with Barrick Gold’s projects. Due to McEwen’s unwillingness to engage in mediation on Los Azules, the Canadian government dropped the mediation efforts and nothing came of the CSR Counsellor’s process. That office was subsequently closed due to its inability to offer effective mediation in conflict situations. Evidently McEwen’s gamble produce results, since the San Juan authorities seem set to ensure that any conflicts with the National Glacier Protection Law will be hidden from the public eye.
Agua Rica (27°21’54.90″ S 66°17’01.63″ W), the project in Catamarca Province, and near to the locality of Andalgalá, a community which is staunchly opposed to the investment, is in an area that is adjacent to periglacial environments. The Aconquija Mountains, where the project is located are rich in periglacial resources and have hundreds of active rock glaciers and other periglacial forms that are rich in hydrological content. All of these are protected by Argentina’s National Glacier Protection Law. Nevertheless, provincial authorities in Catamarca have consistently denied public access to information to society regarding the province’s glacier and periglacial resources. One can still see the impacts to rock glaciers left by Xstrata Copper when it explored, and then abandoned, the Filo Colorado project (27°22’04.99″ S 66°12’18.81″ W), next to Agua Rica. The Catamarca government never requested that Xstrata Copper clean up its mess at Filo Colorado and repair visible damages to rock glaciers (which is what CHRE, FuCI and El Algarrobo were requesting) and yet the province is very keen on inviting further investments by Glencore Xstrata to Mina Alumbrera or at Agua Rica.
CHRE published an extensive extensive report in 2012, mapping periglacial areas and rock glaciers in the Aconquija Mountains, and analyzing possible and probable impacts from mining activity (including the Agua Rica Project) to glaciers and periglacial features protected by the National Glacier Protection Law. It should be noted that Agua Rica is actually adjacent to and seemingly not directly in periglacial environment, however it is close enough to warrant studies to ensure that periglacial resources are not harmed by mining operations at the location. These studies should be transparent and public. Today no information is shared with the local community or with concerned stakeholders. On the contrary, no government official from Catamarca or from the federal government published any opinion or information whatsoever about glacier and periglacial risks from mining activity in the Aconquija Mountains.
The Agua Rica and Filo Colorado projects in Catamarca are in Periglacial Areas protected by Argentina’s National Glacier Protection Law.
Unfortunately, despite having completed (internally but not publicly) the national glacier inventory called for by the National Glacier Protection Law which located rock glaciers and glaciers, in the mining provinces of San Juan, Catamarca, Salta, Jujuy and La Rioja, the National Environment Minister Sergio Bergman does not want to publish (or is not allowed to publish) these glacier inventories which are already available from the national glacier institute the IANIGLA, and which are already in the hands of provincial and federal government authorities.
CHRE has tried numerous time to contact the National Environmental Ministry offering our own information produced to date to highlight mining conflicts with glaciers and periglacial environments. We have this information and we know they have seen it. The environmental authorities however, do not formally respond. Instead, incredibly, they refuse to give CHRE access to updated satellite imagery available through the national space program at the CONAE which is available at no charge to NGOs. The CONAE rejected our request for images due to intervention by the Environment Ministry disallowing our access. They claimed that it is unnecessary for an NGO like CHRE to do a glacier inventory since the IANIGLA is already doing one!!! The National Environmental Ministry also fails to publish any reports informing on the present mining risks to glaciers. In fact, despite being the national authority of implementation of the National Glacier Protection Law, there isn’t even a glaciologist amongst its staff. We know for instance, and despite your claims to the contrary, Mr. Minister, that the mining authorities are not collaborating with the environmental authorities, that the IANIGLA has NEVER received any information whatsoever about the location of mining projects, in which case they would have produced the mandatory priority inventories at sites of potential conflict. Mining authorities are not collaborating with environmental authorities as you suggest.
The CHRE, founded and presided by Romina Picolotti, the former Secretary of Environment who resigned precisely because President Cristina Fernandez de Kirchner vetoed the unanimously approved National Glacier Protection Law in 2008, to favor mining investment (this favoritism is not a supposition since it was stated as such in the justification of the veto by the President). This veto favored projects like El Pachón, Los Azules and Agua Rica, which could have been stalled or canceled if the glacier law survived–which eventually, it did.
Because national authorities and provincial authorities working on mining, on glaciers and on environmental protection do not want to publish information about glacier vulnerability due to mining, CHRE carried out its own inventories, analysis and reports highlighting mining impacts to glaciers and periglacial environments on numerous projects. They are easily available online, and focus on projects such as Veladero, Pascua Lama, Cerro Amarillo, Famatina, Filo Colorado, El Pachón, Altar, and Los Azules. All of these reports reveal undeniable evidence that there is mining occurring in glacier and periglacial areas, that there is impact to glaciers and to periglacial environments by mining operations, particularly exploratory operations, but also extraction phases, and that impacts will deepen and expand should many of these projects move forward. We also have additional evidence for other projects which could also move forward in the coming years under more favorable mining investment climates like those being announced today. Vicuña, Josemaria, Las Flechas, del Carmen, are all in glacier and periglacial environments, and would likely have irreparable conflicts with the National Glacier Protection Law. In fact, CHRE also carried out another study, detailing the general situation of the mining sector with regards to periglacial environment–you Mr. Minister, should read this report to learn of the situation.
Of the projects that are closer to implementation, El Pachón and Los Azules, there is extensive periglacial environment present in practically all of the project area, and there has been or will be damage caused by these projects that would be in violation of the National Glacier Protection Law. In the case of Agua Rica, which seems to be adjacent to but not directly in periglacial environment, there could be impacts and specific studies would need to be carried out to determine the feasibility and legality of this project. None of the mentioned companies has carried out the necessary studies detailing these risks (or they have not published any such studies), nor have government authorities (provincial or federal) taken it upon themselves to ensure that these project do not violate the National Glacier Protection Law. On the contrary, we know that the authorities are withholding the information they have, and they are violating the ethical and moral character that you Mr. Minister suggest should imbue the national mining sector in order to be transparent, responsible and sustainable.
You, Mr. Minister of Energy, José Aranguren, stated in a recent gathering of the National Argentine Mining Chamber (CAEM):
“Let me reaffirm our common objective to work for the responsible development of the Argentine mining industry … In many regions of the country, mining is the only viable alternative for Argentines to achieve sustainable development, … there are those that talk to us about mining from prejudiced positions and with lack of knowledge … [we want] to invite you so that economic, environmental development and social justice are the vertices of a single triangle where mining is at the center … we are working with the Ministry of Environment and in coordination with the provinces of Argentina on an integrated plan to address all of the concerns of society. We are committed to improve the institutional capacity of the public sector in the environmental control and management of mining. Above all, in each of these efforts, we promise to always tell the truth and to be transparent in our actions, because there is no other way to generate confidence in society of the political sphere in all of Argentina’s territories … we must take advantage of our natural resources and develop them responsibly”.
The problem with these statements, Mr. Minister, is that they are full of contradictions with the way that the mining sector actually operates and with the way it controls (or fails to control) its’ environmental impacts. We know already that several mining projects that the federal and provincial governments want to reactivate are in direct violation to the National Glacier Protection Law. The National Government, despite what you say, does not share the extensive information that is available already, produced by the IANIGLA, about the presence of glaciers and rock glaciers in San Juan, in Catamarca and in La Rioja provinces as well as in other provinces where there is also mining activity in conflict with glaciers and periglacial areas. You speak of collaboration of the mining and environmental authorities and yet, reality is quite different. Mining and environmental authorities are not collaborating, they are not articulating and they do not work in complementarity to one another, except to hide information about the risks of mining. You should personally consult the IANIGLA and ask the glacier institute if the mining authorities have ever requested that the IANIGLA carry out a glacier mapping at a mining site they wished to promote–this is what should have occurred immediately after the passage of the glacier law. We know the answer to that question, NEVER. We know this to be true because the glaciologists of the IANIGLA have shared this information confidentially with us. But no one in government dares reveal that this is the case, because the priority of the mining authorities prevails over environmental responsibility.
The reality is that there is no intention of the mining authorities nor of mining companies for society to know if there are glaciers or periglacial environments where they want to extract minerals because if it did, the projects would be stalled. If the mining sector followed through with its empty rhetoric vis a vis the National Glacier Protection Law, it could not move forward with several of the mining projects it wishes to develop. Projects such as El Pachón or Los Azules–and many others in the Central Andes, or in the Famatina or Aconquija Mountains could not move forward. What is ironic about this situation is that the places of conflict between mining and glaciers have more than been identified. We’ve known of them for several years. Anyone working on glaciological issues in Argentina or in mining at high altitudes knows very well which are the problem projects. The issue is that no-one wants to say it formally or in writing, so as not to obstruct the priority mining investments you are talking about today.
We, CHRE, have extensive information about this conflict and our reports are in the public domain. The information exists, and we know that both the mining sector and the environmental and mining authorities have seen our reports. And so, we ask you Mr. Minister, you speak of transparency and the importance of answering the concerns of society. We have concerns. So why hence is the sector not transparent and why does it not share the glacier inventories that we know are in the possession of authorities? Why isn’t the government acting on its confirmed knowledge over the presence of mining in glacier and periglacial areas in provinces like San Juan, La Rioja, Catamarca and Jujuy? Why isn’t government and the mining sector transparent (as you suggest) about conflict areas pitting mining projects with glaciers and with periglacial environments? We could have a rational debate about the decisions being taken to advance mining in these regions, and analyze the legality of these propositions. Instead, the mining sector and the mining and environmental authorities, provincial and national, sweep this knowledge under the rug.
Minister Aranguren, I ask you, can we as a country be against mining when it violates the National Glacier Protection Law? … or is that not an option? This is a very valid question. Just as you suggest that some actors take on categorical positions against mining and that being against mining is “irrational”, isn’t it also irrational to deny that in some places mining should not be allowed?
Is the promotion of mining, which your Ministry is strongly behind, a categorically absolute position of government despite any and all costs? Would the French place a mega mining project at the foot of the Eiffel Tower because it found gold there? Or would it be more prudent to prohibit large-scale mining in a tourist city like Paris simply because some areas are not apt for mining activity even if it could produce some economic gains? In the same way, shouldn’t we prohibit mining where there are glaciers and periglacial environments, as is established by law? Or on the contrary, are we simply going to ignore this law and move forward with projects like El Pachón, Los Azules, Del Carmen, Las Flechas, Vicuñas, Josemaria, Pascua Lama and others and destroy glaciers and periglacial environments because it brings some jobs and financial resources? I think this is a reasonable question to ask, and it is by no means a dogmatic or extremist position to take.
Or is it tabu for your Ministry and for the Mining Sector in general, to speak of no-go zones for mining because projects like Pascua Lama or El Pachón are simply to big to pass up? Why can’t we have a serious debate and not sustain false claims that are no longer possible to sustain in a world with free flow of information? Why don’t you, as you say, answer the concerns of society that worries about the impacts that these mega projects bring to many communities and to delicate natural resources? We are not uninformed. We are very informed and this is why we are legitimately worried.
We agree that we should utilize our natural resources responsibly, and so, why don’t you follow your own recipe when it comes to protecting glaciers and periglacial areas when it is in conflict with the promotion of mining investments or when you are considering building a mega sized dam in glacier territory, as you are now in Santa Cruz Province, placing dozens of the colossal glaciers of Argentina’s Glacier National Park at risk?
Just as the former government, this government, the government you represent, is showing once again that the State does not want to uphold the protection of the glacier law to protect glaciers and periglacial environments if that protection involves stopping a mining project. We already know the position of the Provincial Government of San Juan that has advanced with mining operations at all costs irrespective of its environmental implications. To avoid any type of problem with environmental impacts, San Juan removed the jurisdiction of the environmental ministry over mining projects and created a sub ministry of environmental control of mining under the mining ministry. That means the the environmental control agent of mining operations answers to the mining minister, the person most interested in promoting mining. We have seen how this absurd arrangement played out with the terrible contamination caused by the Veladero mining project and the failure of authorities to adequately address this environmental catastrophe.
The Glacier Inventory carried out by the IANIGLA with the collaboration of the provinces in areas where there is mining has already been completed several years ago. By law, priority areas (where mining is occurring in glacier or periglacial zones), should have been inventoried during 2011 (at most 180 days after the adoption of the law). We are already in 2016 and no information has been published on this topic. We ask you Mr. Minister, you speak of transparency of the mining sector and of the administration of mining, why does this occur? What is the sector hiding? The question is a rhetorical one, since we know exactly what it is hiding, that there is mining occurring in glacier and in periglacial areas and that this is illegal by law! The reality is that despite your rhetoric, the mining sector has no intention of having a rational debate about this conflict, nor is it interested in reforming or stopping projects that should not be allowed to move forward.
At this point, this is no longer a technical question, nor is it a matter of time to finish the glacier inventory at the IANIGLA. This has been done and everyone knows it. This is simply a question of priorities of the federal and provincial governments, and whether you are willing to destroy glaciers and periglacial areas and violate the National Glacier Protection Law to promote mining investments where they really should not occur. I note that neither the federal government nor the provincial governments of mining provinces wanted the glacier protection law and they both worked avidly to stall it and later lobbied the President to veto the law, which she did the first time it came around. And when the President did veto the law it was because she was protecting mining investments. This is not a personal opinion Mr. Minister, this is what is actually written in black and white in the justification of the veto. The current government that you represent, has merely carried on this position.
The dynamics are simple, it is evident that there is no real political will by the governors of the mining provinces or of the federal authorities to protect glaciers and periglacial areas if it means stopping mining. If you were, you’re actions and your public policy would be quite different. If as you say, you are governing with different criteria, that you really do want to be transparent, just and promote sustainable policies, then you really do need to change course on this issue. The announcements made recently to reinvigorate and move forward with projects like El Pachón, Los Azules, and Agua Rica, without considering their legality or illegality under the National Glacier Protection Law, is an indication that nothing has changed, and that the mining sector is actually much more dogmatic and inflexible with its promotion of mining at all costs, than the environmentalists you criticize as being uniformed and prejudiced.
If you’d like more information about the reports we have produced, and the information we have about the conflicts between current mining projects and glaciers and periglacial areas, we are open to engagement. But we realize despite your rhetoric, Mr. Minister, that you probably won’t call.
For more Information:
Jorge Daniel Taillant
+1 415 713 2309
Report on Glacier/Periglacial Impacts by El Pachón
Complaint to Australian Government Against Xstrata for El Pachon Impacts to Periglacial Environment
Report on Periglacial Impacts at Los Azules
Complaint Against McEwen Mining for Glacier Impacts of Los Azules filed in Canada
Report glacier and periglacial presence at Agua Rica
The Periglacial Environment and Mining in Argentina
Argentine National Glacier Protection Law