The following is a copy of the letter sent by non-
governmental organizations in Mato Grosso and
Mato Grosso do Sul, Brazil to the heads of
the Inter-american Development Bank (IDB), the
United Nations Development Programme, and the
Inter-governmental Committee on the Hidrovia.
In it, they demand participation in, and access to
information concerning the engineering, economic,
and environmental studies for the Parana/Paraguay
Hidrovia, an industrial shipping channel
proposed by the governments of Brazil, Bolivia,
Paraguay, Argentina, and Uruguay. Preliminary studies
have shown that the engineering works required for
the Hidrovia could destroy the world's largest wetlands
area -- the Pantanal -- and other unique ecosystems,
and threaten the survival of traditional populations of
Indigenous people and fisherfolk in the region.
(For more information: International Rivers Network
1847 Berkeley Way, Berkeley CA 94703, USA
tel: (415) 243-4146 fax: (415) 243-0661
email: glenirn)
Cuiaba and Campo Grande, Brazil, October 24, 1994
Mr. Enrique Iglesias
President, Inter-american Development Bank
1300 New York Ave. NW
Washington, DC 20577
fax: (202) 623-3614
Mr. Gustave Speth
Administrator, United Nations Development Programme
One United Nations Plaza
New York, NY 10017
fax: (212) 906-6947
Mr. Jesus G. Gonzalez
Executive Secretary
Inter-governmental Committee on the Hidrovia
Av. Espana 2221-4 piso
1107 Buenos Aires, Argentina
Fax: (541) 362-9046
Dear Sir:
The Environment and Development Forums of Mato
Grosso and Mato Grosso do Sul, composed of 72
organizations from different segments of society,
including non-governmental organizations, scientific
research groups, professional associations, advisory
groups, labor unions, and popular movements wish to
express our extreme concern with the possibility of
the IDB's financing the Paraguay-Parana Hidrovia Project
as now projected, especially as it affects the region of
the Pantanal of Mato Grosso.
This project will cause large-scale changes in the
drainage of the Paraguay River, and in land-use patterns
in the basin, which could result in enormous
environmental, social, cultural, and economic impacts
throughout the region; impacts which will be irreversible.
Besides, the project supports a type of development
which is unsustainable, socially perverse and outdated,
where the State "commands" the economy. Even from a
narrow economic-financial point of view, it is an unviable
undertaking, a fact which is demonstrated by independent
studies recently carried out.
Therefore, we feel that the Environmental Impact
Studies to be financed and monitored by the IDB,
through a consortium chosen in conjunction with
the UNDP and CIH, must have scientific consistency
and be effectively carried out. These studies are
extremely important and should precede any decisions
on investment in Hidrovia or in other development
projects in the region. In order for these studies to
be successful, it is fundamental that the public be
informed and participate during the entire process,
from its beginning to its conclusion.
Aware that the contracts for the Environmental Impact
Studies are in the final phases, and should begin in the
next few months, we wish to put forward some points
which we consider fundamental, in order that the Studies
meet their objectives, and facilitate the participation of
local society.
# Changing of the designation of the Project from
category III to category IV, for purposes of carrying
out the Studies. A project which involves engineering
works on such a large scale, within a river and an area
so intricate and sensitive as the Pantanal of Mato Grosso,
as is indicated in "Module B" of the Operational Plan
(Project no. TC 91-05-02-5-RE), cannot be considered to
have only "moderate environmental impacts".
# Inclusion of river modification and other engineering
works on the Parana River, already undertaken by
the governments of the Hidrovia project area, in Module A,
so that they may be included in the Environmental Impact
Studies, and so that the results of these studies may be
preceeded by an extensive debate. These measures are
essential to ensure consistency in the Studies, and should
take place before any decisions on construction of the
project are made.
# To make available to the public all existing information
relating to the terms of reference, preliminary studies,
reports, evaluations, including agreements, contracts,
conditionalities, commentaries, decisions, and financial
commitments assumed by the Governments, which should
be already available in preliminary versions, so that they
may be analyzed and commented upon by interested local
populations, and so that the final documents may also reflect
their concerns and recommendations. The public must
have access to this information and to all documents
relating to the Project in the languages of the region
(Portuguese and Spanish).
# In accordance with Annex V of the Terms of Reference
of the EIA, the RIMA (Environmental Impact Report) should
be made public in language accessible to the general public,
as well as in public meetings. We feel this is not sufficient.
Before beginning the studies, public meetings should be held
so that the content and methodology of the studies be made
known. The agenda for these meetings should be publicized
with sufficient lead time, and in translation where
necessary. Written minutes of the meetings should be
distributed to the participants. Decisions taken by the
governments, IDB, UNDP, and Consultants or changes in
aspects of the Studies or in the Project, as well as
agreements on the rights of affected populations should be
clearly documented. It is important that the participation
of NGO's in the meetings be facilitated, and that a
preliminary meeting be carried out to discuss and to
define mechanisms for public participation in the EIA.
# The decisionmaking process needs to be transparent
and clearly laid out and documented. Comments received
from interested parties (NGOs, social movements,
governments, business sectors, universities, etc.) should be
documented and distributed so that all may be kept informed.
It is fundamental that the governments and project
proponents refrain from spreading misinformation and
that they make accurate information regarding all
phases of the project available to local populations.
# To assure the integrity of the process, it is essential
that an independent evaluation of the Environmental
Impact Studies, Viability Studies, and other decisions
relating to the project begin immediately. There must
also be clear mechanisms established for monitoring,
and for sanctions in the case where agreements, decisions,
and conditions of the Studies are not followed. All
these measures must be clearly explained and documented
from the beginning of the process.
# We understand that the IDB plans to develop an
Independent Audit to evaluate the process and content
of the Studies. We understand that this is an important
initiative, and we support it. Nevertheless, we feel it
is necessary that the Terms of Reference of this Audit
be made available for public comment before they are
finalized, so that NGOs and affected populations can provide
their observations. It is also important that the name of
the group or persons chosen be known beforehand and there
exist clear mechanisms to guarantee adherence to the
agreements, decisions, and conditions of the studies.
Mr. President, besides the above points which we consider
fundamental, we have the following questions, for which
we would like to have a response:
1. Will all the information generated by the IDB, UNDP,
and CIH be available in all the offices of the IDB in the
countries of the La Plata Basin in Portuguese and Spanish?
2. Will the IDB make all the reports and other documents
sent to it by the Executive Secretary of the CIH publically
available upon receipt of same?
3. What is the initial date of the Contract between the
IDB and UNDP and how much time remains before the 27
months foreseen are completed?
4. How much has each Government of the La Plata Basin
already spent, within the $1,350,000 forecast in the
Contract, and on what were these resources spent?
5. Taking into account the high costs of the Engineering
Studies, would it not be logical to prioritize economic-
financial analyses before investing so much money?
If an economic viability study demonstrated the
inviability of the Project, would this be sufficient to
trigger the provisions of Section 3.1.1 p.8 of the cited
Contract?
6. The studies of "Module A" are to last five months.
>From what we know, the Brazilian company Hidroservice
is already carrying out these studies. What is the current
situation? When should they be completed? Was any
accompanying report already produced? May we have
immediate access to these reports? What is the process
of the IDB, UNDP, and CIH for consultations with affected
populations in the region regarding these Studies?
7. The Terms of Reference for Module B limit the direct
and indirect area of influence of the HPP to the
hydrographic basin of the Paraguay River. But, it is very
probable that the project will result in significant
alterations to the model of occupation of lands in the
region, with implications in the Central Planalto, and in
areas within the Amazon Basin. Should this limitation
of the TOR of the EIA not be lifted, in order to allow
the preliminary studies themselves to define the limits
of the area of influence?
8. We understand that the objectives of the EIAs is to
determine whether the Project is viable from the point
of view of environmental impacts, compared to other
Alternatives. If viable, they would then define how to
mitigate these impacts. The TOR always speak of
"mitigating" environmental impacts, instead of "avoiding"
these impacts from taking place. In order for the studies
to have real significance, is it not necessary that, from
the beginning, to recognize that they may redefine the
Project?
9. We would like to know the names, addresses, and
curriculum vitae of consultants that have been chosen
by the IDB, UNDP, and CIH to carrying out the EIA and
the Engineering and Economic Feasibility studies.
10. Has the committee been named to accompany the EIA?
Will only governments have a seat on this Committee
(and is there an opportunity for representatives of NGOs
and civil society to sit on this committee)?
These are the initial points and questions which we are
putting forward. We are working together with diverse
NGOs, social movements, scientists, and research
organizations, with the objective of protecting the
Pantanal and contributing to the search for sustainable
development alternatives. In this sense, our priority is
to deepen our understanding of the Hidrovia Project, as
well as to inform the civil society about the possible
consequences of its eventual implementation.
We attach as an annex the Final Document of a meeting
which took place in Chapada dos Guimaraes-MT "Letter
from Chapada dos Guimaraes" which, in a general way,
tells our positions regarding the Hidrovia. Expecting that
we can count upon responses to our requests, we place
ourselves at your disposition to discuss these questions.
Without anymore for now, we hereby sign.
Attentively,
Mato Grosso Forum for the Environment and Development
Permanent Forum for Development and the Environment of Mato Grosso do
Sul