Does the MARN environmental license replace prior consultation?

No. The environmental instrument (Government Agreement 137-2016, the Regulation on Environmental Evaluation, Control and Monitoring) classifies projects into categories A (high impact, full environmental impact assessment),… B1 and B2 (moderate impact), C and the CR registry (minimal),… over an exhaustive list of 14 sectors. The 'public participation' in the environment ministry (MARN) procedure, hearings, objections to the EIA, is a documentary requirement; the C169 consultation is a state-run process with a rights-holding collective counterpart. Escobal, Fénix and El Tambor had licenses and EIAs and were suspended for the defect the environmental instrument does not cover; Cerro Blanco also shows that an approved EIA can be annulled administratively for flaws in the file. Confusing the two is the most expensive way to learn Guatemalan law.