MAC: Mines and Communities

Complaint Concerning Minera Yanacocha, S.A.

Published by MAC on 2001-05-01

Complaint Concerning Minera Yanacocha, S.A.


This complaint is brought jointly by the Federation of Rondas Campesinas of Northern Peru (FEROCAFENOP) and Project Underground in March 2001.

Ubranizacion El Bosque, Manzana R, Lote 7
Cajamarca, Peru
Tel: (044) 826143

Project Underground
1916A Martin Luther King Jr. Way
Berkeley, CA 94704
Tel: (510) 705-8981
Email: or

FEROCAFANOP is the representative organization of campesinos, composed of affiliate organizations in the seven departments of northern Peru: Piura, Tumbes, La Libertad, Amazonas, Lambayeque, Cajamarca, and Ancash. Recognized in the Civil Code and the Constitution of Peru, FEROCAFENOP is a non-profit representative organization which administers Campesino Justice, undertakes capacity-building in environmental conservation, promotes indigenous culture, and works to improve the well-being of campesino communities.

FEROCAFENOP and Project Underground bring this complaint with the authorization of the people directly affected by MYSA. Attached as Appendix 1 to this complaint are authorizing declarations signed by members of the affected communities.

Project Background

Minera Yanacocha S.A. (MYSA) is a joint venture between Newmont Gold Corporation, Condesa and the IFC, which is a 5% shareholder and has loaned nearly $20 million and promised another $100 million. MYSA is a 25,000 hectare multiple pit heap leach mine located in the province of Cajamarca, approximately 18 kilometers from the city of Cajamarca. A number of rivers and tributaries flow from or through the mine site area, providing water for Cajamarca and outlying rural areas. Cajamarcans are entirely dependent on this watershed for drinking, bathing, irrigation and husbandry purposes.

In 1998, the Peruvian Ministry of Energy and Mines approved the La Quinua mine site within the existing Yanacocha mining district. The IFC has agreed to loan MYSA $100 million for the development of La Quinua.

Further background on MYSA can be found in "The Rondas Campesinas Defend Life", a December, 1999 report prepared by FEROCAFENOP and Project Underground. (See Appendix 2).

Project Impacts

The many serious environmental and social impacts have been thoroughly documented in "Las Rondas Campesinas Defend Life". (Appendix 2). Additional impacts observed since the publication of this report are discussed in a supplemental report filed in January, 2001. (See Appendix 3).

To summarize, the two reports document extensive problems with dewatering, water contamination, fish and frog die-off, air pollution, loss of medicinal plants, unjust and illegal land acquisitions, displacement, unemployment, alcoholism, prostitution, domestic violence, violence by mine employees and repression of mining opponents.

Non-compliance with IFC and World Bank Policies

IFC Standards

"It is IFC policy that all its operations are carried out in an environmentally and socially responsible manner. To this end, IFC projects must comply with applicable IFC environmental, social and disclosure policies. In addition, IFC applies World Bank Group environmental, health and safety guidelines to all projects...Furthermore, the project sponsor must ensure compliance with host country requirements." (IFC website). In July, 1998, IFC adopted its own environmental and social safeguard policies. The key provision in this set of policies is OP 4.01, Environmental Assessment. The following policies were listed as forthcoming: OP 4.10 on Indigenous Peoples, OP 4.11 on Safeguarding Cultural Property, and OP 4.12 on Involuntary Resettlement. It is anticipated that OP 4.10, OP 4.11 and OP 4.12 will resemble World Bank OP 4.20, OPN 11.03 and OP 4.12 on Indigenous Peoples, Safeguarding Cultural Property and Involuntary Settlement. IFC requirements apply to all projects with an Investment Review Meeting on or after September 1, 1998. (IFC website). Additional and applicable standards are found in two World Bank Operational Directives, OP 4.20 on Indigenous Peoples, OP 4.12 on Involuntary Resettlement and OPN 11.03 on Safeguarding Cultural Property. La Quinua EIS Violates IFC Policy on Environmental Assessment In 1998, MYSA proposed to develop the La Quinua mine site within the existing Yanacocha mining district. In October, 1998, MYSA prepared an Environmental Impact Study ("EIS") of the proposed La Quinua mine site. The EIS was approved by the Peruvian Ministry of Energy and Mines in October, 1998. In March, 1999, MYSA prepared an Environmental Impact Study Addendum ("Addendum") and an EIS Summary Report that summarizes the first EIS and the Addendum. Unless otherwise specified, the term "EIS", as used in this complaint, refers to both the initial EIS and the EIS Addendum collectively. OP 4.01(3) provides: EA takes into account the natural environment (air, water land); human health and safety; and social aspects (involuntary resettlement, indigenous peoples and cultural property); and transboundary and global environmental aspects. EA considers natural and social aspects in an integrated way. It also takes into account the variations in project and country conditions; the findings of country environmental studies; national environmental action plans; the country’s overall policy framework and national legislation; the project sponsor’s capabilities related to the environmental and social aspects, and obligations of the country, pertaining to project activities, under relevant international environmental treaties and agreements. IFC does not finance project activities that would contravene such country obligations, as identified during the EA. EA is initiated as early as possible in project processing and is integrated closely with the economic, financial, institutional, social, and technical analyses of a proposed project. To a limited extent, the Addendum takes into account the natural environment and human health and safety. Social issues such as involuntary resettlement, indigenous peoples and cultural property are not addressed at all. Global and transboundary environmental aspects are not taken into account at all. With the major exception of water quality, Peruvian legal requirements are identified and satisfied. The Addendum does not even purport to consider natural and social aspects in an integrated way. This omission is particularly egregious given the interrelated social and economic structure of campesino communities. A social scientist acting in consultation with the affected communities is needed to more carefully assess these kinds of interrelated aspects. Whether or not the EA was initiated as early as possible is difficult to determine, due to the veil of secrecy that protects MYSA from having to disclose information it considers proprietary. That said, it appears that, although exploration was initiated in December, 1996 (Addendum, p.39), the first public consultation did not take place until November, 1998, nearly two years later. (Public Consultation and Disclosure Plan, p. 3). This backwards sequence of events certainly does not satisfy the early EA initiation requirement. OP 4.01(4) provides, in part: For Category A projects that are highly risky or contentious or that involve serious and multidimensional environmental concerns, the project sponsor should normally also engage an advisory panel of independent, internationally recognized environmental specialists to advise on all aspects of the project relevant to the EA. Although Yanachocha is a Category A project that involved extremely serious environmental and cultural concerns, the authors of this report are not aware that MYSA has engaged an independent panel. OP 4.01(5) provides: IFC advises the project sponsor on IFC’s EA requirements. IFC reviews the findings and recommendations of the EA to determine whether they provide an adequate basis for processing the project for IFC financing. When the project sponsor has completed or partially completed EA work prior to IFC’s involvement in a project, IFC reviews the EA to ensure its consistency with this policy. IFC may, if appropriate, require additional EA work, including public consultation and disclosure. The Addendum addresses surface water and social issues in greater detail than the EIS. This raises the question of the extent to which the IFC informed MYSA of its EA requirements before MYSA undertook preparation of the EIS and whether IFC provided MYSA, in a timely manner, with a sufficiently detailed explication of its EA requirements. OPD 4.01(12) provides: For all Category A projects and as appropriate for Category B projects during the EA process, the project sponsor consults project-affected groups and local nongovernmental organizations (NGOs) about the project's environmental aspects and takes their views into account. The project sponsor initiates such consultations as early as possible. For Category A projects, the project sponsor consults these groups at least twice: (a) shortly after environmental screening and before the terms of reference for the EA are finalized, and (b) once a draft EA report is prepared. In addition, the project sponsor consults with such groups throughout project implementation, as necessary to address EA related issues that affect them. [emphasis added]. La Quinua is a Category A project. MYSA did not consult with affected groups twice. No formal consultation occurred until after the final EIS was submitted to the Ministry in October, 1998. A detailed analysis of MYSA’s failure to engage in public consultation is found on pages 11-17 of this report.

14. For meaningful consultations between the project sponsor and project-affected groups and local NGOs on all Category A and as appropriate for Category B projects, the project sponsor provides relevant material in a timely manner prior to consultation and in a form and language that are understandable and accessible to the groups being consulted.

The only material provided was a copy on exhibit in City Hall, which was not in a form or language that was understandable or accessible to most campesinos. 69% of women and 43% of men in Cajamarca and surrounding areas are illiterate. In addition, many have visual impairments which, due to lack of access to optometry services, prevent them from being able to read. A number of campesinos affected by the mine, particularly older individuals, speak only Quechua or are more proficient in Quechua than Spanish. However, none of the materials were translated into Quechua. Even campesinos who can read Spanish are unlikely to be capable of comprehending the highly technical and formal language and format of the materials.

Moreover, City Hall is not an accessible repository for campesinos. Transportation and cultural issues make it difficult if not impossible to travel to Cajamarca and to review the EIS in a comfortable and culturally familiar setting conducive to comprehension and reflection. Roads leading over mountainous terrain to the municipality are bad. Buses cost money which most campesinos are unable to spend on non-essential items. Moreover, the cost of being away from the farm in terms of lost production is in itself a significant barrier.

OP 4.01(15) provides:

For a Category A project, the project sponsor provides for the initial consultation a summary of the proposed project’s objectives, description, and potential impacts; for consultation after the draft EA report is prepared, the project sponsor provides a summary of the EA’s conclusions. In addition, for a Category A project, the project sponsor makes the draft EA report available at a public place accessible to project-affected groups and local NGOs. For FI operations, the FI ensures that EA reports for Category A subprojects are made available in a public place accessible to affected groups and local NGOs. From what the researchers for this Report could tell, neither an initial summary of the project nor a draft EA was prepared. The final EIS was lodged with City Hall which is not accessible to many affected individuals for the reasons discussed above. OP 4.01(18) provides:

During project implementation, the project sponsor reports on compliance with (a) measures agreed with IFC on the basis of the findings and results of the EA, including implementation of any EAP, as set out in the project documents; (b) the status of mitigatory measures; and (c) the findings of monitoring programs. IFC bases supervision of the project's environmental aspects on the findings and recommendations of the EA, including measures set out in the legal agreements, any EAP, and other project documents.

MYSA reports annually to the IFC. Given the extreme deficiencies in MYSA’s public consultation plan, discussed below, more frequent reporting is necessary in order for the IFC to exercise appropriate oversight.

OP 4.01 Annex B(1) provides:

An environmental assessment (EA) report for a Category A project focuses on the significant environmental issues of a project. The report's scope and level of detail should be commensurate with the project's potential impacts. The report submitted to IFC is prepared in English, French, or Spanish, and the executive summary in English.

OP 4.01 Annex B(2) provides:

The EA report should include the following items (not necessarily in the order shown): …

b. Policy, legal, and administrative framework. Discusses the policy, legal, and administrative framework within which the EA is carried out. Explains the environmental requirements of any cofinanciers. Identifies relevant international environmental agreements to which the country is a party.

The EIS does not mention any international agreements to which Peru is a party. Relevant treaties and international agreements include the Convention on Nature Protection and Wild Life Preservation in the Western Hemisphere, Salvador Convention on the Protection of the Archeological, Historical and Artistic Heritage of the American Nations, International Plant Protection Convention, International Covenant on Economic, Social and Cultural Rights, Convention concerning Indigenous and Tribal Peoples in Independent Countries, Convention on Biological Diversity, Indigenous and Tribal Peoples Convention (ILO No. 169) and Occupational Cancer Convention (ILO No. 139).

c. Project description. Concisely describes the proposed project and its geographic, ecological, social, and temporal context, including any off-site investments that may be required (e.g., dedicated pipelines, access roads, power plants, water supply, housing, and raw material and product storage facilities). Indicates the need for any resettlement plan or indigenous peoples development plan (see also subpara (h)(v) below). Normally includes a map showing the project site and the project's area of influence.

Section 6.2 of the EIS concerning fauna and flora contradicts the findings of Dr. Homero Bazán Zurita. This issue is discussed in the report found in Appendix 2, page 3.

The EIS does not mention resettlement or indigenous peoples. The Addendum goes to great lengths to avoid use of the word "indigenous" and to deny the indigenous roots of the campesinos in and around Cajamarca. No indigenous development plan is referenced.

With respect to resettlement, the Addendum makes a semantic argument against the need for resettlement by claiming that former land owners are temporary or seasonal and, therefore, in need of "relocation" rather than "resettlement". The distinction, however, is a false one. World Bank OP 4.12 on Involuntary Resettlement covers "(i) relocation or loss of shelter; (ii) loss of assets or access to assets: or (iii) loss of income sources or means of livelihood, whether or not the affected person must move to another location;…" [emphasis added]. Thus, the EIS fails to indicate the need for a resettlement plan for displaced persons.

The Addendum further notes that individuals who sold land in the highlands own other land at lower elevations. While this may be true for some former land owners, it is far from universally true. Moreover, it is crucial to understand that campesinos conduct different types of agricultural activities depending on the elevation. At higher elevations suitable for grazing, sheep, cattle and alpacas are kept. At lower elevations, smaller animals and crops are tended. Thus, campesinos whose high elevation land was expropriated lost an important asset necessary for their ranching activities.

The Addendum does include the requisite maps, but they are difficult to read, particularly by campesinos with the literacy issues discussed above.

d. Baseline data. Assesses the dimensions of the study area and describes relevant physical, biological, and socioeconomic conditions, including any changes anticipated before the project commences. Also takes into account current and proposed development activities within the project area but not directly connected to the project. Data should be relevant to decisions about project location, design, operation, or mitigatory measures. The section indicates the accuracy, reliability, and sources of the data.

Although the EIS describes relevant conditions, there is no indication of the accuracy, reliability or sources of the data. The accuracy of all of the data is called into question by the blatant inaccuracy of the description of flora and fauna, as discussed above. Another inaccuracy is in the characterization of vast stretches of lands as unsuitable for grazing or agriculture. (See EIS, Sec. Though MYSA’s high-priced consultants may view this land as unusable, the fact is that campesinos farm and have farmed this steep and rocky land for hundreds of years, because they have no choice.

The EIS sets forth various community development projects, several of which MYSA takes credit for. It should be noted that MYSA’s rural development officer, Jose Chang, is an engineer with a forestry background and no community development experience. Chang’s relationship with the campesino communities is extremely poor, due to a pattern of unfulfilled promises made by Chang.

With respect to the socioeconomic conditions, the data is very general limited. For example, in the section in the EIS Addendum on Education, no figures are provided on literacy rates or the number of schools. Access to higher education is not mentioned. Under the section on Health, there is no data on such basic indicators as infant mortality, life expectancy and access to emergency medical facilities. MYSA’s failure to set forth adequate baseline data relates to its apparent decision to not hire a local social scientist to develop sociocultural profiles of the people in the impacted area, as recommended in the Good Practice Manual (p.19).

e. Environmental impacts. Predicts and assesses the project's likely positive and negative impacts, in quantitative terms to the extent possible. Identifies mitigation measures and any residual negative impacts that cannot be mitigated. Explores opportunities for environmental enhancement. Identifies and estimates the extent and quality of available data, key data gaps, and uncertainties associated with predictions, and specifies topics that do not require further attention.

The EIS does not address the uncertainties associated with the predictions. This is a critically deficient aspect of the EIS, one that calls into question the reliability of any of MYSA’s predictions concerning environmental and social impacts.

The EIS does not adequately address the critical issue of acid mine drainage (AMD).

f. Analysis of alternatives. Systematically compares feasible alternatives to the proposed project site, technology, design, and operation—including, the "without project" situation—in terms of their potential environmental impacts; the feasibility of mitigating these impacts; their capital and recurrent costs; their suitability under local conditions; and their institutional, training, and monitoring requirements. For each of the alternatives, quantifies the environmental impacts to the extent possible, and attaches economic values where feasible. States the basis for selecting the particular project design proposed and justifies recommended emission levels and approaches to pollution prevention and abatement.

The only alternative mentioned is the "without project" scenario under which, of course, MYSA concedes, the described disturbance would be avoided. (EIS 8.3). The EIS does not compare any design, technology or operations alternatives. Given the pressing issue of water contamination, the lack of any mention of alternative methods of heap leaching and hazardous waste disposal or design alternatives for the processing plant or excess water treatment plant is extremely problematic.

g. Environmental Action Plan (EAP). Covers mitigation measures, monitoring, and institutional strengthening; see outline in OP 4.01, Annex C.

This element is discussed under Annex C below.

h. Appendices

iii. Record of interagency and consultation meetings, including consultations for obtaining the informed views of the affected people and local nongovernmental organizations (NGOs). The record specifies any means other than consultations (e.g., surveys) that were used to obtain the views of affected groups and local NGOs.

No such information is included within or appended to the EIS. The absence of such a record points to the central defect of the entire project, which is discussed under the Public Consultation and Disclosure Plan below.

v. List of associated reports (e.g., resettlement plan or indigenous peoples development plan).

Such a list is not included, due to the non-existence of such reports.

OP 4.01 Annex C (Environmental Action Plan) provides:

2. The EAP identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels. The plan includes compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient. Specifically, the EAP

    identifies and summarizes all anticipated significant adverse environmental impacts (including those involving indigenous people or involuntary resettlement);

    describes—with technical details—each mitigation measure, including the type of impact to which it relates and the conditions under which it is required (e.g., continuously or in the event of contingencies), together with designs, equipment descriptions, and operating procedures, as appropriate;

    estimates any potential environmental impacts of these measures; and

    provides linkage with any other mitigation plans (e.g., for involuntary resettlement or indigenous peoples) required for the project.

In March, 1999, MYSA prepared an Environmental Action Plan (EAP). The EAP does not mention indigenous peoples or involuntary resettlement, despite the fact that both issues were minimally flagged in the EIS Addendum. The EAP does not discuss potential environmental impacts of mitigation measures. The EAP does not provide linkage to socio-cultural mitigation plans, because there are none.

The EAP does not address storage, disposal and transport of mercury. If, as MYSA has claimed in the wake of the Choropampa spill, it has suspended all sales of mercury in Peru, the question remains as to what it will do with the mercury produced at the mine.

3. Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures. Such information enables the project sponsor and IFC to evaluate the success of mitigation as part of project supervision, and allows corrective action to be taken when needed. Therefore, the EAP identifies monitoring objectives and specifies the type of monitoring, with linkages to the impacts assessed in the EA report and the mitigation measures described in the EAP. Specifically, the monitoring section of the EAP provides

    specific description, and technical details, of monitoring measures, including the parameters to be measured, methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and definition of thresholds that will signal the need for corrective actions; and

    monitoring and reporting procedures to (i) ensure early detection of conditions that necessitate particular mitigation measures, and (ii) furnish information on the progress and results of mitigation.

The monitoring plan is extremely general and lacking in the specific requirements set forth in Section 3(a) above. Instead, the EAP refers to a forthcoming site-specific Environmental Monitoring Manual (EMM). The IFC policy, however, does not permit the project sponsor to withhold monitoring plan specification until it publishes an EMM. Among the more egregious omissions is the lack of threshold definitions that will signal the need for corrective action.

Although the EAP indicates that water quality samples will be collected on a quarterly basis, such an infrequent schedule will certainly not ensure early detection of water quality problems as required under the IFC policy.

La Quinua Public Consultation and Disclosure Plan Violates the IFC Good Practice Manual, "Guidance for Preparation of a Public Consultation and Disclosure Plan (PCDP)"

MYSA prepared a Public Consultation and Disclosure Plan in May, 1999 (two and a half years after commencing exploration and a year and half after preparing the EIS). Both the PCDP itself as well as the manner in which it was executed violate the letter and spirit of the IFC’s public consultation and disclosure requirements.

Annex C of the Good Practice Manual provides as follows:

1. Project sponsors are required to consult meaningfully with stakeholders on preparation and findings of the Category A EA and to disclose to the public the results of the EA process. Ongoing consultation is also required during the construction and operation phases of the project.

According to the PCDP, two public hearings were held in Cajamarca during November, 1998. The November 17, 1998 was organized by the Municipality and MYSA only participated as an invited guest. This is not the project sponsor-initiated public consultation contemplated by the IFC. The other meeting was held at the Laguna Seca, Cajamarca’s only four-star hotel, with no campesinos invited or in attendance. FEROCAFENOP was unaware of this meeting. At this meeting, MYSA presented the EIS. Although OP 4.01(12) requires project sponsors to commence public consultation as early as possible and at least once before preparation of the EA, MYSA did not undertake any public consultation until after preparation of the final EIS. Obviously, presentation of a final document does not allow for anything resembling the "meaningful consultation" required by the IFC. At the meeting, the Cajamarca NGO Ecovida presented a detailed technical critique of the EIS and, to date, has received no reply. Moreover, no formal consultation has occurred since 1998, despite changes to project design due to input from the Municipality and the IFC. The PCDP also mentions as a consultation event for La Quinua a site visit by the Mayor of Cajamarca and councilors. Again, while it is important for elected officials to see for themselves the potential impacts of devastating projects such as La Quinua, it does not seem that this is the type of "meaningful consultation" the IFC had in mind when it developed this policy. A bilingual Quechua-Spanish man served as an informal translator at a consultation event. This man was not requested to translate. He did so because he knew there were individuals present who did not understand Spanish. He was not paid for his services.

2. A PCDP should: (i) describe local requirements for consultation and disclosure; (ii) identify key stakeholder groups; (iii) provide a strategy and timetable for sharing information and consulting with each of these groups during various phases of the project; (iv) describe resources and responsibilities for implementing PCDP activities; and (v) detail reporting and/or documentation of consultation and disclosure activities. [emphasis added].

The PCDP includes two lists of participants with whom it claims to have engaged in public consultation (p.5). The two lists appear to constitute a hierarchy, in which the First Group consists of high government officials, and the Second Group includes lower level government officials and others. The only group that includes campesinos is Rural Community Mayors which, needless to say, is in the Second Group. Amongst the groups listed are "NGOs" and "stakeholders". These vague references do not fulfill the documentation requirements of the PCDP. The PCDP states that "opportunistic" and "informal" meetings occur frequently and are held ‘as-needed’ or approximately every four months with various First Group participants, and with the Mayor of Cajamarca on a monthly basis. A separate, informal process exists between MYSA and rural communities and other Second Group participants (pp. 5-7). There is some confusion here, because there are no rural communities or community groups listed as Second Group participants. Informal meetings are a culturally inappropriate and ineffective mechanism for receiving community input. Campesinos’ tendency toward formality, politeness and deference to authority makes it highly unlikely that they would raise controversial issues in an informal setting. Rather, an informal setting would dictate a mere exchange of pleasantries, and voicing a complaint would be considered very rude. The PCDP does not indicate how many such informal meetings have occurred nor the anticipated frequency of future meetings. On the contrary, the PCDP states that these meetings will continue to "not be scheduled events, rather opportunistic events..." (pp. 6-7)--This haphazard approach is neither a strategy nor a timetable and cannot possibly satisfy IFC public consultation requirements. The PCDP also mentions that formal public meetings will be held and will be advertised in newspapers, radio and television (p.8). The absence of a schedule, even a tentative one, for these public meetings, is glaring. Moreover, the media outlets MYSA plans to use for advertising these meetings are totally inappropriate and ineffective for campesinos, most of whom do now own televisions or radios and who, even if literate, do not enjoy home delivery of the daily newspaper. The PCDP does not describe the resources available for implementing PCDP activities.

3. The plan submitted by the sponsor to IFC must define a technically sound and culturally appropriate approach to consultation and disclosure. The goal is to ensure that adequate and timely information is provided to project-affected people and other stakeholders, and that these groups are given sufficient opportunity to voice their opinions and concerns. Important considerations include:

No information has been communicated in Quechua. No provision has been made for the illiterate or the fact that even many literate campesinos can’t read because they have sight problems and no access to optometry services. Moreover, the EIS format is extremely technical and highly alienating for poorly educated campesinos.

As mentioned above, the only public meeting so far was in Cajamarca with no transport provided to campesinos, and the EIS was made available only at City Hall. The PCDP states MYSA’s intention to continue holding centralized public meetings. MYSA’s stated plan to evaluate the need for providing transportation to various individuals or groups from outlying areas is absurd as the need for transportation to Cajamarca is apparent. This, however, begs the question of whether rural residents should be required to make a long and difficult trip to Cajamarca, one that would take them away from their homes, families and farms, in order to engage in the public consultation process. With respect to the unscheduled informal meetings, campesinos are unlikely to raise contentious issues in an informal setting where doing so would violate cultural norms of politeness and deference.

The PCDP fails to address this issue. No such methods have been employed.

The PCDP fails to address this issue. The investigators for this report collected anecdotal evidence that white mining executives and consultants frequently express their view of the campesinos as dishonest, stupid, inbred and alcoholic. Such racist attitudes are, needless to say, inconsistent with respect for local traditions.

The PCDP fails to address this issue. No women attended the one public meeting that was held.

No such mechanisms are in place. As mentioned above, MYSA has still not responded to a critique lodged at the November 1998 public meeting.

FEROCAFENOP and campesinos generally have made their concerns clear at meetings concerning the nearby Cerro Quilish project but, despite promises, have never received a reply of any kind to their concerns.

The PCDP states that a formal grievance mechanism will be established, which will require comments, inquiries and questions in writing. The requirement that the comments be in writing excludes illiterate or sight-impaired individuals.

4. The sponsor must submit to IFC a Public Consultation and Disclosure Plan (PCDP). The contents of the plan should include the following:


Briefly describe the project, including design elements and locational aids (eg, site and area maps)

The Introduction has no locational aids and makes no mention of any design elements. The project is not described, even briefly.

c. Review of any previous Public Consultation and Disclosure

Summarize all public consultation and information disclosure undertaken to date, including:

No information dissemination is mentioned, presumably because none occurred. Public meetings are mentioned, but details on the nature of the presentations given at these meetings are not provided.

Such description is not set forth in the PCDP.

This overview is not set forth in the PCDP.

This description is not set forth in the PCDP.

Such explanation is not set forth in the PCDP.

d. Stakeholders

Provide an inventory of key stakeholder groups who will be informed and consulted about the project. Stakeholders are persons or groups who are affected by or can affect the outcome of a project. These can be affected communities, local organizations, NGOs, and government authorities. Stakeholders can also include politicians, commercial and industrial enterprises, labor unions, academics, religious groups, national social and environmental public sector agencies, and the media.

The inadequacies of the two-tier list are discussed above.

e. Public Consultation and Disclosure Program

Disclosure of information: The draft Category A EA report must be made available in the project country as early as possible and not later than 60 days prior to the proposed Board date. The sponsor should proactively disseminate a non-technical summary of the EA findings, in a form and language meaningful to those being consulted, to local stakeholders prior to consultation activities.

As mentioned above, the EIS was exhibited in City Hall but, to the knowledge of the authors of this report, no non-technical summary was even available, let alone "proactively disseminate[d]".

Consultation: The PCDP should set out a program for public consultation and information disclosure during the following stages: (i) during the early scoping phase, before the terms of reference for the Category A EIA are finalized; (ii) once a draft of the Category A EA report has been prepared; and (iii) during the construction and operation phases.

The PCDP fails to set out a program but says a schedule will be established. There was no consultation during the early scoping phase or for a draft EIS. Again, the only meeting took place after the EIS had been finalized.

The absence of a plan for ongoing consultations during construction and operation phases is particularly disturbing in light of MYSA’s horrific track record for failing to consult during the operation of its existing mines. For example, when MYSA began draining water from the Plateros Lagoon, at no time did it discuss this activity with the campesinos downstream who rely on water flow from the lagoon for agricultural activities. (See Appendix 2, page 4). Given this pattern of contemptuous conduct, MYSA can hardly be expected to consult with the campesinos during the construction and operation of La Quinua.

This section should:

The stated goal of the program is "to improve and facilitate decision making and build an atmosphere of understanding that will actively involve individuals, groups and organizations that can affect or be affected, in some way, by the development of the project." This is a generic statement of the goals of any public consultation program and does not state the goals, if any, of MYSA’s specific plan.

Although communication methods are discussed, they are, as explained above, barriers rather than vehicles for campesino participation.

The PCDP mentions only informal meetings and the occasional formal public meeting. Thus, it appears that MYSA will not take advantage of any of the other consultation tactics mentioned above. Moreover, of the 25 suggested techniques for public consultation and disclosure set forth in Annex E to the Good Practice Manual, MYSA has used only four—reports, newspapers, radio/tv and targeted briefings.


Provide a set schedule detailing when consultation and disclosure activities will take place for each stage of the process and each stakeholder group identified

No timetable is set forth in the PCDP. Stages and stakeholders are not even differentiated with respect to consultation and disclosure.

g. Resources and Responsibilities

Indicate what staff and management resources will be devoted to undertaking the PCDP. Who within the company will be responsible for carrying out these activities? IFC encourages the sponsor to hire a Community Liaison Officer (CLO) to arrange and facilitate these activities. Effective consultation and information disclosure may require assistance from specialized consultants. The sponsor, however, should be involved in all consultations related to the project. Appointment of a CLO is a good way to ensure and sustain this involvement.

No Community Liaison Officer has been appointed.

h. Grievance mechanism

Describe the process by which people affected by the project can bring their grievances to the sponsor, in a culturally appropriate manner for consideration and redress.

The PCDP sets forth a highly inappropriate written grievance procedure that is discussed above.

i. Reporting

Identify where and when the results of public consultation and information disclosure will be reported. This should include:

As the PCDP was prepared after the EIS was finalized, it does not address the logistics of reporting on the draft EIS consultations.

La Quinua Project Violates World Bank Policy on Involuntary Resettlement.

The policy objectives of World Bank Draft OP 4.12 on Involuntary Resettlement are as follows:

(a) Involuntary resettlement should be avoided where feasible, or minimized, exploring all viable alternative project designs.

(b) Where involuntary resettlement is unavoidable, resettlement activities should be conceived and executed as sustainable development programs, providing sufficient investment resources to give the persons displaced by the project the opportunity to share in the project benefits. Displaced persons should have opportunities to participate in planning and implementing resettlement programs.

(c) Displaced persons should be assisted in their efforts to improve their livelihoods and standards of living or at least to restore them, in real terms, to pre-displacement levels or to levels prevailing prior to beginning of project implementation, whichever is higher,

It is not possible to quantify the total number of campesinos displaced by MYSA, because none of the assessment documents provide this information, a significant deficiency. It is estimated by FEROCAFENOP that approximately 2,500 campesinos have been involuntarily displaced over the life of the project.

According to the EIS Addendum, MYSA has purchased 2,462.75 hectares of land from 26 families. These purchases took place without any consideration of alternative project designs and in the absence of any resettlement program at all, let alone one that involved the participation of displaced persons and promoted sustainable development that improve actual living standards. Moreover, many owners sold their land without informed consent, as discussed in December, 1999 report. (Appendix 2, pp. 12-13). MYSA’s abuse of its unequal bargaining power reared its ugly head again in the summer and fall of 2000, when it pressured hundreds of victims of the June, 2000 mercury spill into quick, small cash settlements.

In negotiating sales price, MYSA relied on Ministry of Agriculture valuations rather than replacement price. This is analogous to an insurance company offering to pay market value instead of replacement value for a stolen car. The outcome is that many displaced campesinos have been unable to buy equivalent land.

Cash compensation for lost assets does not constitute a resettlement policy under World Bank policies. For displaced persons whose livelihoods are land based, resettlement must include replacement land with productive value and locational advantage at least equivalent to the advantages of the old site. (OD 4.12(9). MYSA has not demonstrated that the new land acquired by some of the former land owners is of equal value to their old lots.

MYSA claims that 70% of "relocated" land owners have at least one family member working for the mine. The inaccuracies in MYSA’s reporting of employment statistics is covered in the December, 1999 report. (Appendix 2, pp. 12-13).

It would be difficult, indeed, for MYSA to demonstrate that displaced persons are faring the same or better, because MYSA neglected to gather adequate baseline data from which to compare. Moreover, none of the former land owners interviewed by the authors of the report found in Appendix 2 has been contacted by MYSA since the sale. Thus, it is unclear what techniques MYSA is using to compile its data on the status of former land owners.

OP 4.12 requires that borrowers prepare a resettlement plan that ensures that displaced persons are informed about their rights, are consulted on their resettlement options and are provided with housing and other forms of economic assistance above and beyond the compensation paid to them for their lost assets. As with the guidelines for the Environmental Assessment, there are numerous requirements for resettlement planning, implementation and monitoring. MYSA has failed to comply with any of the required measures, choosing instead to entirely ignore the issue of resettlement.

La Quinua Project Violates World Bank Policy on Indigenous Peoples

The objective of World Bank OD (Operational Directive) 4.20 on Indigenous Peoples is as follows:

6. The Bank’s broad objectives towards indigenous people, as for all the people in its member countries, is to ensure that the development process fosters full respect for their dignity, human rights, and cultural uniqueness. More specifically, the objective at the center of this directive is to ensure that indigenous peoples do not suffer adverse effects during the development process, particularly from Bank-financed projects, and that they receive culturally compatible social and economic benefits.

Borrowers must prepare an indigenous peoples development plan that is consistent with the Bank’s policy. (OD 4.20, § 13). The development plan must include various components, including a strategy for local participation and descriptions of proposed education, training, health, credit and legal assistance services. (OD 4.20, §15). Borrowers are supposed to be informed of the policy for indigenous peoples during project identification. (OD 4.20, § 16). In addition, as discussed earlier, IFC policies require the identification, in the Environmental Assessment, of the need for an indigenous people’s development plan.

Under OD 4.20(5), indigenous peoples can be identified by the presence of the following characteristics:

(a) a close attachment to ancestral territories and to the natural resources in these areas;

(b) self-identification and identification by others as members of a distinct cultural group;

(c) an indigenous language, often different from the national language;

(d) presence of customary social and political institutions; and

(e) primarily subsistence-oriented production.

The campesinos of Cajamarca have all of these characteristics. They self identify as indigenous people and are recognized as such under the Constitution of Peru. The goals of FEROCAFENOP include the promotion of indigenous culture and the administration of campesino justice. They are subsistence farmers. Many of them speak the indigenous language Quechua. There is, in fact, no question that the campesinos are indigenous, other than in the contrivances of MYSA to avoid this inconvenient reality.

The La Quinua EIS does not acknowledge the presence of indigenous people and does not reference any indigenous people’s development plan. It is unclear whether the IFC failed to inform MYSA of the World Bank policy for indigenous peoples or if MYSA simply ignored the requirement. It does appear from MYSA’s contrived efforts to avoid use of the term "indigenous" in its EIS Addendum that MYSA was aware of the requirement and willfully attempted to skirt it.

Minera Yanacocha Violates IFC Policy on Natural Habitats

OP 4.04 expresses the IFC’s strong policy in favor of protecting natural habitats and their functions and the IFC’s expectation that project sponsors will apply a "precautionary approach to natural resource management." "Natural habitat" is defined as "land and water areas where (i) the ecosystems’ biological communities are formed largely by native plant and animal species, and (ii) human activity has not essentially modified the area’s primary ecological functions."

Though the EIS seeks to portray the area as a barren wasteland, it is, in fact, of an area of high biodiversity, with 250 plant and 50 vertebrate species. (See Appedix 2, pp.3-4). The EIS does concede that the marshes in the project area are sensitive ecosystems that support productive habitats. (EIS 4.2.3).

OP 4.04(4) provides, in part:

IFC does not support projects involving the significant conversion of natural habitats unless there are no feasible alternatives for the project and its siting, and comprehensive analysis demonstrates that overall benefits from the project substantially outweigh the environmental costs. If the environmental assessment indicates that a project would significantly convert or degrade natural habitats, the project includes mitigation measures acceptable to IFC. Such mitigation measures include, as appropriate, minimizing habitat loss (e.g. strategic habitat retention and post-development restoration) and establishing and maintaining an ecologically similar protected area. [emphasis added]

OP 4.04(6) provides:

In projects with natural habitat components, project appraisal and supervision arrangements include appropriate environmental expertise to ensure adequate design and implementation of mitigation measures by the project sponsor.

It is difficult to conceive of a more "significant conversion" of a natural habitat than the operation of four open pit mines and three heap leaching facilities therein. Yet, MYSA has done so without designing appropriate mitigation measures. The only tangible measures MYSA proposes are the construction of wildlife fences, reclamation of land (with the significant exception of the open pits) and the creation of a tree farm to mitigate the loss of 100 hectares of pine forest. A much more detailed description of proposed mitigation measures is needed in order to assess the extent to which such measures have the potential to minimize habitat loss. Moreover, MYSA has taken no steps to ensure that personnel with appropriate environmental expertise oversee the implementation of mitigation measures.

OP 4.04(8) provides:

IFC expects the project sponsor to take into account the views, roles, and rights of groups, including local nongovernmental organizations and local communities, affected by IFC-financed projects involving natural habitats, and to involve such people in planning, designing, implementing and monitoring such projects. Involvement may include identifying appropriate conservation measures, managing protected areas and other natural habitats, and monitoring projects. IFC encourages the project sponsor to provide such people with appropriate information on the protection of natural habitats.

As extensively documented in the preceding section of this report, MYSA has utterly failed to fulfill its responsibility to consult with local communities and NGOs.

Minera Yanacocha Violates IFC Policy on Natural Habitats

Under OPN 11.03, the Bank’s general policy regarding cultural properties is to assist in their preservation, and to seek to avoid their elimination. Cultural property is defined by the Bank to include unique natural environmental features. OPN 11.03 calls for the study of cultural property during the scoping phase and careful planning to avoid damage.

OPN 11.03 provides:

Deviations from this policy may be justified only where expected project benefits are great, and the loss of or damage to cultural property is judged by competent authorities to be unavoidable, minor, or otherwise acceptable. Specific details of the justification should be discussed in project documents…

Before proceeding with a project, however, which prima facie entails the risk of damaging cultural property (e.g., any project that includes large scale excavations, movement of earth, surficial environmental changes or demolition), Bank staff must:

(1) determine what is known about the cultural property aspects of the proposed project site. The government’s attention should be drawn specifically to that aspect and appropriate agencies, NGOs or university departments should be consulted; (2) If there is any question of cultural property in the area, a brief reconnaissance survey should be undertaken in the field by a specialist.

As discussed in the December, 1999 report, medicinal plants traditionally used by Cajamarcan campesinos have all but disappeared from the area surrounding the mine. (Appendix 2, p.13). These plants were not treated as cultural resources in the EIS. Also in the area of the mine site are an array of archeological resources of cultural significance. (Appendix 2, p. 14, EIS 4-42). The EIS denies the significance of these resources on the ground that they are of pre-Hispanic origin. However, the World Bank policy is not limited to pre-colonial cultural resources. MYSA and/or the IFC should have consulted with the community concerning the appropriate mechanisms for preserving their archeological and traditional medicine resources.

Attempted Resolution

FEROCAFENOP and Project Underground have made extensive efforts to communicate these environmental and social problems to MYSA and the IFC.

In June, 1999, Julio Marin Rodriguez and Segenda Castrejon Vallejo of FEROCAFENOP, along with the director of Project Underground, met with Maurcio Athie, Takuro Kimura, Doug Lister and Martyn Riddle of the IFC. Mr. Marin and Ms. Castrejon provided the IFC with a detailed account of the environmental and social problems in their community caused by the mine.

In July, 1999, Project Underground wrote to Meg Taylor to introduce itself and the problems surrounding MYSA.

In August, 1999, Project Underground requested a copy of the Public Consultation and Disclosure Plan (PCDP) and annual environmental monitoring reports. The IFC first refused to provide the PCDP but later relented. The IFC refused to disclose any monitoring reports but stated that it was discussing with MYSA the appropriate means of communicating monitoring activity in the future. To date, the IFC has not provided any such monitoring reports.

In December, 1999, Project Underground provided the IFC with a copy of "Las Rondas Campesinas Defend Life: A Study on Mining Contamination in Cajamarca".

In December, 1999, Project Underground wrote to James Wolfensohn to inform him of the problems caused by MYSA and the community’s opposition to its proposed expansion. This letter referenced the December, 1999 report mentioned above. Mark Constantine, an IFC public relations officer, responded to this letter to Mr. Woflensohn. Mr. Constantine’s letter displayed a shocking degree of ignorance concerning the issues raised in the letter and in the report. He noted that the water contamination allegations could not be addressed without more specific sampling information. Mr. Constantine concluded his letter by encouraging periodic consultations between MYSA and municipal authorities, despite the fact that communication between these entities was not even flagged in the report as a problem nor a desired outcome.

In January, 2000, 8000 people demonstrated against the La Quinua expansion. Project Underground wrote to Mr. Athie and Mr. Kimura and other IFC representatives to inform them of this protest and of the police’s brutal response. The IFC did not respond.

In a March, 2000 letter, Shawn Miller, another public relations officer, assured Project Underground that the IFC was trying to defuse tensions between MYSA and the community, but said that he would not and could not, pursuant to IFC policy, disclose the specific details.

In a March, 2000 phone call, Shanna Langdon from Project Underground advised Mr. Athie and Mr. Miller that, if the IFC wants to independently verify reports of water contamination, it should allow FEROCAFENOP representatives to show them the contamination sites during its upcoming supervision mission. Mr. Athie admitted that the public consultation process had been flawed and assured Project Underground that the IFC would contact FEROCAFENOP upon arrival and would visit several impacted villages and contamination sites. During this call, Mr. Athie informed Project Underground that it is the IFC’s belief that the water contamination pre-dated and is not caused by the mine.

On May 4, 2000, representatives of the Rondas Campesinas participated in Newmont’s annual shareholder meeting in Denver, Colorado. They subsequently met with several vice-presidents of the company to discuss the impacts of the Yanacocha mine on communities in the project area and explained that the communities were demanding no further expansion of the mine. They were told that the company would address these issues, and respond to them in writing. Project Underground sent two follow up letters to Newmont management in May and July of 2000, and as of March 2001 have had no response.

In May 2000, the IFC conducted its supervision mission in Cajamarca. The team, in a hastily arranged meeting, spent only four hours with FEROCAFENOP and declined FEROCAFENOP’s offer to take them on a tour of contaminated sites. Shanna Langdon wrote a letter to Mr. Athie expressing Project Underground’s concerns about the missed opportunity to engage in consultations with the affected community. Mr. Constantine responded to Ms. Langdon’s letter, proclaiming that the IFC team did engage in meaningful consultation and berating Ms. Langdon for suggesting otherwise.

In January 2001, Project Underground and FEROCAFENOP provided the IFC and the CAO with the supplemental report found in Appendix 3. In March 2001, at James Bond’s suggestion, the report was also provided to Newmont. In response, Mr. Bond informed Project Underground that, in the IFC’s view, the information in the supplemental report "does not provide significant new material that would warrant a change to our supervision work." Mr. Bond referred to a "thorough evaluation" of MYSA performed by the IFC. The IFC, however, has refused to disclose this evaluation, making further discussion of the disputed facts an impossibility.


From the time La Quinua was conceived until the present, MYSA has flagrantly flouted the IFC and World Bank policies that ostensibly govern the development and implementation of this project. Although MYSA has gone through the motions of some of the most rudimentary requirements, such as the preparation of an EIS and EAP, its performance makes a mockery of the very IFC and World Bank policies it purports to fulfill.

Even more disturbing is the closed and secretive manner in which MYSA has developed the La Quinua project, a far cry from the kind of meaningful consultations touted as the IFC’s goal. MYSA’s failure to engage in consultations with the community is the inevitable byproduct of the racist attitudes of mining executives toward the indigenous people of the area. The authors of this Complaint posit that this racism, coupled with the desire to maximize profits, is the root cause underlying MYSA’s exploitation of the land and people of Cajamarca.

FEROCAFENOP and Project Underground have made numerous efforts to communicate the problems caused by MYSA to the IFC. The IFC’s response has been to downplay the impacts and to hide behind the shroud of secrecy provided by its (non)disclosure policy. Thus, we are left with no choice but to file this complaint and to make the demands set forth below, in the hope that the CAO will encourage the IFC to address these problems in an appropriate and effective manner.

Community Demands

With respect to all demands that call for the retention of experts or the establishment of a commission or program, FEROCAFENOP demands full participation in the process of selecting the experts or developing the program.

A. Dewatering and water contamination

    No further expansion of MYSA operations.

    No use by MYSA of the waters of Cerro Quilish, Cerro Negro, La Shacsha, El Hotel, El Pencayoc, Laguna de Totora and the seven lagoons of San Jose upon which the centro poblados of Cumbayo, Rio Grande, Tual and Huacataz rely.

3. Retention of hydrology experts to consult with the CAO on the following:

Protection of flow and quality of rivers, streams, lagoons, canals, cuencas, ojos de agua and other water bodies, including waters with sacred value;

Improved treatment system for drinking water;

Reduction of sedimentation in Rio Colorado, Rio Grande, Rio El Sufre, Rio Shacsha and the subcuencas Machcon, Chonta, Llaucano and Jequetepeque.

    Bi-monthly testing of water flow and quality by independent commission, under the auspices of the CAO, using U.S. standards and protocols.

5. Publicizing of water testing results in writing and via door-to-door presentations in Spanish and/or Quechua.

    Creation of fund to clean up water employing workers from impacted communities on a rotating basis.

    Access to and reconstruction of the canal that serviced agricultural production in

Yagamarca and Puruay (covered over by the mine to prevent community access).

8. Import sufficient quantities of potable water to each caserio.

B. Air Pollution

1. Cessation of all explosions.

2. Study by commission of independent experts, under the auspices of the CAO, on the air quality of areas within 25 km of mine.

3. Retention of experts to advise CAO on air quality improvement techniques.

C. Ecosystem

1. Reclamation and preservation program, funded by MYSA but under the auspices of the CAO, for medicinal plants.

2. Development of wildlife conservation program, funded by MYSA but under the auspices of the CAO.

3. Fish and frog repopulation programs, funded by MYSA but under the auspices of the CAO.

D. Displaced persons

1. No further purchases of land at prices below US $500 per square meter.

2. No threats or other forms of pressure to sell land.

3. Negotiation of land sale by representative of FEROCAFENOP or equivalent campesino community-based organization.

4. Compensation for former landowners in form of equivalent land and funds to reestablish farms.

5. Recognition of FEROCAFENOP’s administration of campesino justice in cases of unauthorized sales of land.

6. Development of resettlement plan pursuant to World Bank guidelines.

E. Indigenous Peoples

1. Recognition by MYSA and the IFC of the Rondas Campesinas as indigenous people.

2. Development of an Indigenous Peoples Plan pursuant to World Bank guidelines.

F. Social Impacts

1. Establishment of MYSA-funded programs in the following areas: microcredit, health education, domestic violence prevention and shelter, alcoholism treatment, prostitution prevention, vocational education, including training for employment at the mine and schooling of veterinarians.

2. Provision of basic services by MYSA, including rural health clinics, education, including dormitories for post-secondary studies, improved two-lane roads, free bus service, electricity, legal assistance, veterinary care and potable water.

3. Development of local hospitals’ expertise in cancer treatment and heavy metals detoxification, with funding from MYSA.

4. Provision of office equipment and supplies to NGOs, such as FEROCAFENOP, who represent the local indigenous population, with funding from MYSA.

G. MYSA Personnel

1. No employment of individuals with criminal records or who have complaints against them on file with the police or with FEROCAFENOP. This applies to MYSA and all contractors and subcontractors.

2. Employment of locals at mine and with MYSA subcontractors.

H. Human Rights

1. MYSA and police agencies must immediately cease their practice of collecting information on and threatening MYSA’s opponents and landowners who refuse to sell.

2. Appointment of local human rights ombudsperson who can serve as liaison between FEROCAFENOP and the CAO.

3. Community trainings on human rights laws and procedures with funding from MYSA but conducted by NGOs.

I. Consultations

1. FEROCAFENOP calls for a provincial-level referendum on the continued operation of the mine. This referendum would provide for a direct and secret vote by the citizens of each of the twelve districts of Cajamarca. An electoral committee to oversee this referendum should include representatives of the following:



Provincial Fiscalia

Each professional college

University of Cajamarca


    Public consultations first with the caserios and then with the centro poblados affected by the mine. The meetings in the caserios would coincide with the regular monthly meeting of each caserio.

    Public hearings convened by FEROCAFENOP with the mandatory attendance of the IFC, MYSA, local mayors, environmental and social agency officials and the Rondas president of each caserio.

    Redo the environmental assessment based on the community participation described above. The EA should be produced in writing and in the form of a video that would be shown at the monthly meetings of the caserios.

    Monthly consultation meetings at the caserio and centro poblado levels.

J. Mercury Spill

    Establishment of a sustainable economic development fund for the communities affected by the spill, with emphasis on the agricultural, small business and artisan sectors.

    Compensation for the damage caused by the spill, including illness, loss of livelihood and loss of home and personal belongings.

    Construction of health clinic specializing in heavy metal detoxification.

    Lifetime health insurance for spill victims and their families.

    Community administered infrastructure projects for affected villages, such as road improvements, schools, canals, potable water and electricity.

    CAO scrutiny of MYSA’s "Plan de Contingencia Para El Transporte de Cianuro de Sodio", "Spill Prevention, Control and Response Plan" and "Incident Management Plan".

K. Other

    Reopening of and free access along road from Herradura Rural de Cajamarca to Chanta Alta and Bambamarca.

    Payment of MYSA’s taxes directly to municipality of Cajamarca.

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