...In their response, the company's representatives claim that APIB's publication presents "factual errors and misleading assumptions about the project and the company's performance". However, as will be demonstrated in this reply, the criticisms of Belo Sun Mineradora S.A.'s Volta Grande project are not mere speculations, but findings based on scientific studies, technical opinions and court decisions.

...[The]...project has been questioned by multiple bodies such as the Federal Public Prosecutor's Office (MPF), the Public Defender's Office of the State of Pará (DPE/PA) and the Federal Public Defender's Office (DPU), the National Council for Human Rights (CNDH), FUNAI and Ibama, as well as academics and researchers from the Federal University of Pará (UFPA) and more than 800,000 signatories who signed a shared petition against the mining company. ...[T]he United Nations Working Group on Business and Human Rights signalled in its report on its visit to Brazil that the case was worrying....

...[T]he Belo Sun project "should not be considered if there is potential for similar impacts [to Belo Monte] or if the affected indigenous peoples have not expressed their free prior and informed consent following participatory social, environmental and human rights impact studies and good faith consultations".

...[T]he entire overlapping area of the project is owned by INCRA....

...[The]...National Human Rights Council (CNDH)...[pointed out]...that even before obtaining the Preliminary Licence, Belo Sun had already carried out the illegal purchase of plots and houses from agrarian reform settlements - driving families out of the region....

...[D]efenders and organisations have suffered verbal and physical abuse because of their opposition to the project....

...In recent years, it has been documented that the mining company has also failed to establish positive and constructive relations with the indigenous and riverine peoples in its sphere of influence. Moreover, not all peoples potentially affected by the project have been consulted, nor do they support the project or wish the mine to be built or operate in the region....

...[T]he absence of an impact assessment and potential cumulative damages from Belo Sun to Belo Monte demonstrates that the company is not committed to minimising the risks of the project in the region.

...The mining company recognises in the EIA24 the following potential risks: ...impacts on groundwater quality as a result of tailings infiltration...[,]...Disruption of natural flow patterns of surface runoff and tributaries of the Xingu River...[,]...Deposition of airborne pollutants from mining operations. ...[,]...Increased social problems due to the presence of local communities and/or an influx of labourers and job seekers, including domestic violence, alcoholism, prostitution and sexually transmitted infections; Conflicts over land and natural resources....

...Contrary to the Brazilian standard, the company did not include in its studies an analysis of local seismicity nor did it simulate the response of the structure to a hypothetical seismic acceleration...No risk analyses were made of the geological faults mapped in the vicinity of the project site...With a speed of 20 km/h, the flood from the Belo Sun dam would reach the Xingu in only seven minutes...

...In light of all of the above, we reinforce our position that Belo Sun's mining project, which aims to install Brazil's largest open-pit gold mine in the heart of the Amazon rainforest, is patently unviable...[I]t has been proven that Belo Sun's operations have not been in full compliance with Brazilian laws and regulations in several aspects of its business, including licensing and land acquisition. In addition, the consultations carried out by the company with local indigenous peoples, due to various factors, did not meet the standard of free, prior and informed consent set out in Convention No. 169 of the International Labour Organization (ILO)...[T]he impacts of a mine on the environment and the local population are imminent risks and the absence of an impact assessment and potential cumulative damage from Belo Sun to Belo Monte demonstrates that the company is not committed to minimising the risks of the project in the region....

...[T]he APIB and the other organisations that make up the Volta Grande do Xingu Alliance demand the immediate withdrawal of Belo Sun's Volta Grande Project proposal....

(Translated by the BHRRC)