Sal de Vida is a lithium mining project located in the Province of Catamarca, Argentina, expected to produce 15,000 tons of lithium carbonate yearly, over a 40-year mine life. Brine containing lithium is extracted from Salar del Hombre Muerto, a high altitude wetland located in an arid region, where water is vital for local communities and biodiversity.
Allkem Ltd owns 100 percent of the operation and has partnerships with Toyota Tsusho Corporation, the Province of Jujuy, and the Province of Catamarca. Construction of the Sal de Vida mine is ongoing. Shallow ponds are already in use, evaporating brine, while the company estimates full production to start in mid-2024. Allkem has issued two contracts, one for the evaporation ponds and the project infrastructure, and another for the construction of the lithium carbonate plant.
Partner Organizations: Asamblea Pueblos Catamarqueños en Resistencia y Autodeterminación (PUCARA), Fundación Ambiente y Recursos Naturales (FARN), Fundación Yuchan
Environmental concerns
IFC has categorized the project as Category A, since the project has potential to generate significant irreversible environmental and social impacts, including ones to biodiversity and the local communities. Among the environmental risks are several that IFC’s project appraisal has failed to adequately address:
1. Impact area. The project's Environmental Impact Assessment (EIA) designates a 52 km2 area of “direct influence” where the camp, the processing plant, the extraction wells, and the evaporation pools are located, and also an area of indirect influence of 522 km2. The EIA provides no justification or a technical explanation for this delimitation. Given the hydrological and hydrogeological implications of brine processing, which will require 320 million liters per year of extracted groundwater over a period of 40 years, an area of indirect impact should be included in the EIA to cover the entire basin of the Salar del Hombre Muerto of 4,316 km2. By underestimating the project impact area, the company and IFC have failed to accurately identify and value many environmental and social impacts in accordance with Performance Standard (PS) 1, thus failing to consider the ecosystem and basin integrated management approaches.
2. Cumulative impacts. Cumulative impacts, per IFC’s PS1, refer to those resulting from the successive, incremental, and/or combined effects of an activity or project when added to the effects of other existing or planned ventures. In the Salar del Hombre Muerto, eight lithium brine mining projects have been registered and are in different stages. Cumulative impacts have not been considered in any of the EIAs of the eight mining projects. The most notable of these is likely to come from the projects’ extraction of fresh water from the Río Los Patos, a designated stewardship zone.
3. Long-term impacts of water evaporation. The extraction method adopted by the Sal de Vida project (evaporation in open pools) will require copious volumes of salt water and fresh water during the next 40 years. The sustained extraction of groundwater brines and underground waters over decades is likely to generate irreversible impacts on the wetlands’ hydrological balance, salinity, and unique biodiversity. The baseline information used to prepare the water balance and the hydrogeological models is insufficient.
4. Destruction of natural habitats. An independent study carried out by the Consejo Federal de Inversiones (CFI) in December 2021 identifies the complex interaction between surface and subterranean water levels given different extraction scenarios, and also acknowledges the likely future reduction in both levels. However, it does not analyze the implications of a reduction of surface water volumes and the possible impacts on critical riparian habitats. The EIA hydrological component fails to mention this whatsoever.
Social concerns
1. Social conflict and reports of official harassment. Some local Indigenous communities around the project have reported harassment as a direct consequence of their actions in defending their rights, territory, access to water, and cultural heritage. As an example, residents of Antofagasta were briefly apprehended by the police on charges of threats following a demonstration to resist the project in 2019.
2. Lack of information and weak consultation process. Since the beginning of Sal de Vida, the information about the project has been scarce, with limited access for local communities. Several requests of information issued to the provincial government remain unanswered. In October 2021, the company held informational talks and consultations in the town of Ciénaga Redonda, but the process did not meet standards for informed consultation and participation, and there has been no follow-up.
3. Lack of consideration of sacred ancestral sites. The EIA presented by Allkem has failed to start dialogue with the Indigenous communities regarding cultural heritage and sacred sites which may lead to damages or even their complete disappearance, in violation of PS8.
4. Legal actions at the national level against the company: Members of the Indigenous community Atacameños del Altiplano have pressed charges against Allkem and other companies for human rights violations. The Supreme Court of the province of Catamarca is considering a request for the immediate suspension of mining projects (Sal de Vida and others), presented on the grounds of the lack of an appropriate EIA and the violation of the rights of the Indigenous communities.
IFC’s Board approved a US$100 million loan in December 2022 with another US$100 million to be mobilized from commercial banks. IDB Invest is financing an additional $50 million for the project.
1. Strengthen the Environmental Impact Assessment.
● Reassess the extent of the area of direct and indirect influence of the project: The IFC should require Allkem to review the current EIA and determine the area of direct and indirect influence considering the full hydrological and ecosystem impacts.
● Strengthen the water pressure analysis: The water pressure analysis should be strengthened to address the methodological mistakes and use proper and sufficient data pertaining to the project's scale, duration, and relation to other projects.
● Develop a cumulative impact assessment and make it public by sharing it with provincial authorities and project-affected communities: The current EIA does not include the assessment of cumulative impacts. Identifying cumulative impacts is key to understanding the water pressure in the Salar del Hombre Muerto where Sal de Vida is located, and IFC should consider this during project appraisal. The eight lithium brine mining projects in the Salar del Hombre Muerto all are located in the same endorheic basin, using the same fresh water source.
2. Strengthen the consultation process and engagement with Indigenous Peoples and local communities.
● The IFC should require that the company carry out a consultation process not only open to Indigenous and non-Indigenous Peoples, but also to inhabitants of the social impact area identified by a revised EIA. The consultation process should be meaningful and robust, accessible, culturally appropriate, and implemented in compliance with all relevant Performance Standards and international standards.
● The consultation process should guarantee the participants' security and avoid harassment of local leaders and/or members of local communities who oppose or raise questions about the project or the consultation process. Allkem and its subsidiary Galaxy Lithium S.A. must guarantee a safe environment to conduct consultations that protect those who oppose the project or have raised concerns about it.
● IFC should see to it that the company is effectively disclosing complete information about the project risks, impacts and benefits with project-affected communities, and assure that the views of stakeholders are taken into account in the Environmental and Social Management Plan. The company should publish information about all project risks and impacts in a timely and culturally appropriate manner accessible to project-affected communities.
● The information provided by the company must be objective and account for all potential impacts of the project, including negative impacts on cultural heritage and sacred sites, such as the Indigenous gravesite, Tumba del Hombre Muerto.
3. Strengthen environmental and social appraisal and supervision.
● The IFC should strengthen environmental and social appraisal and supervision, including by requiring the company to conduct and publicly disseminate a participatory contextual risk assessment that uses a full range of sources and tools, including stakeholder engagement, to evaluate external risks of the operating environment, such as legacy issues, unresolved land disputes, the role of private and public security forces, internal social conflict, etc. All these risks, including potential unresolved legacy issues, must be factored into decision-making and overall risk management.
The Supreme Court of the Province of Catamarca ordered the government of the province not to grant new authorizations for the mining project Sal de Vida until the completion of a cumulative impact assessment to understand the impacts and risks of the 7 different lithium projects in the Salar del Hombre Muerto 590 sq. kilometer basin. In addition, it prohibits the government of Catamarca from issuing authorizations to “any other lithium project located in the Salar del Hombre Muerto basin” until the completion of a cumulative impact assessment in the area.
The project is being developed by Livent and Galaxy Lithium (now Allkem after the merger between Galaxy Resources and Orocobre in 2021). More recently, Livent formed a joint venture with Australia's Allkem under the name Arcadium.
In 2021, a member of the indigenous group Atacameños (Comunidad Originaria Atacameños), one of the Sal de Vida project-impacted communities, filed for an injunction requesting a halt of the mining projects “Expansion of the Fenix'' and “Sal de Vida.” Upholding a provincial court's ruling, the Supreme Court of Catamarca partially granted this request, establishing that the authorizations already granted for exploitation for Sal de Vida can continue. However, new permits for Sal de Vida and new projects cannot be granted until a cumulative and comprehensive environmental impact assessment is carried out on the Los Patos River and Salar del Hombre Muerto in Antofagasta de la Sierra.
Catamarca’s Supreme Court also acknowledged flaws in the projects’ participatory process and ordered that the “affected indigenous community” be granted access to all relevant information and that the authorities enable its participation.
The indigenous community also asked the courts to develop an environmental baseline and guarantee public hearings for mining projects, as required by Argentina’s environmental regulations. Atacameños also requested the involvement of the Federal Council of Environment and the national Undersecretary of Infrastructure and Hidric Policy, which are responsible for interprovincial water and environmental management.
Only hours after the ruling was published, Arcadium issued a statement saying the court would not hurt its operations. It noted that “The court ruling does not impact Arcadium Lithium's existing mining operations and expansion activities at its Fenix and Sal de Vida projects. The company's existing permits and Environmental Impact Assessments (EIAs) remain valid.”
The ruling of this provincial Supreme Court could be appealed before the national Supreme Court under exceptional circumstances.
