In 2017, a 20-year concession was granted to COHIDRO, a Chinese-led consortium to improve navigation along 2,687km of the Amazon, Ucayali, Huallaga and Marañón rivers in the Peruvian jungle. In 2015, free, prior and informed consent discussions had been held with the indigenous communities affected.

Now the Environmental Impact Assessment (EIA) has been completed and presented to SENACE, the government agency charged with its revision and eventual approval. As part of that process, two of the four public hearings about the EIA were held in Iquitos on 5-7 August. They generated some strong criticisms.

Even before the hearings began, the Comptroller General issued a report (Informe de Hito de Control No. 001651-2019-CG/APP-SCC) questioning changes made to the project without explanation as to the works required. These involved the construction of two limnimetric stations (which measure water levels in rivers), without taking into account the protocols of the Peruvian weather bureau as to their location or the technical specifications approved by the transport ministry.

The Peruvian biologist, Mercedes Lu, member of ELAW has published a report in which she argues that the project, as envisaged in the EIA report, would sorely test the technical and institutional capacities of the Peruvian state.

She argues that the EIA’s terms of reference have important gaps: the lack of a definition of the methods to be employed for measuring quantitatively the project’s impacts; the lack of a definition of the areas of influence of the project; the lack of an analysis of the effects of the project over time on the morphology and dynamics of the rivers; the lack of a methodology to evaluate the alternatives; and the lack of an evaluation of the effects of the project on the ecosystems, as well as the accumulative and synergistic effects on the health and food security of the local communities.

In other words, she argues, the EIA lacks technical information of fundamental importance for analysing the impact of the project and defining measures for environmental and social management.

Furthermore, Dr. Lu argues that Peru lacks regulations that govern dredging or the management and disposal of dredged material. She also notes that the lack of technical information in the EIA creates great uncertainty about the effects of the project on the quality and diversity of fish, ecosystems, protected areas and communities.

Finally, she notes the project will only create 164 jobs, of which 39 over 20 years would be for local workers.

For its part, the Wildlife Conservation Society reports that the hearings generated negative reactions from diverse sectors in the region because of the lack of information about the real benefits of the project for the communities and the Loreto region in general.

It argues that, due to the lack of technical and scientific clarity in the EIA, it fails to provide clear and transparent specifications about the project’s true impacts on the population, the rivers and the forests. There are no specific data of possible fish loss during the twenty years of the project, nor on the alterations that dredging could make to annual fish migration for spawning.

Other issues raised in the hearings by the general public present included the areas where dredged material would be deposited, the possibility that dredging would release contaminated material, the increase in toll prices, the access to drinking water, and the impact of waves generated by heavier river traffic on crops traditionally cultivated on sand banks during the dry season.

The Centre for Water Research and Technology (CITA) of the Engineering and Technology University (UTEC) has also issued a report identifying eight technical deficiencies in the report which would justify its rejection by SENACE.

These are the following: the areas studied in the report are not continuous and do not take into account the longitudinal and lateral connectivity of the rivers; the field measures and the periods analysed do not include critical high water periods; the movement of sediment on the river bottoms has not been measured; the protocols established by the Brazilian environmental agency CONAMA were not followed to decide the number of points where fluvial sediments were measured; the determination of the areas where dredged materials would be deposited did not include the evaluation of the three dimensional water flow; the analysis of lateral erosion did not consider the different sediment strata along the river banks; the possible effects on the Pacaya Samiria National Reserve were not considered; and the report does not anticipate possible changes in the courses of the rivers, a common phenomenon in the Amazon.

On 24 July, the Culture Ministry (Oficio No. D000248-2019-DGPI/MC) sent over 100 observations and recommendations on the EIA to SENACE requesting that the agreements reached during the consultation process with the indigenous communities be respected.

The proposed project has thus generated widespread concern about its possible environmental and social impacts, particularly in the light of the limited research and information about the history and behaviour of the Amazon and its tributaries. The number of detailed observations from a wide range of organisations pointing out the lack of detailed scientific and technical information in the EIA and raising issues that the EIA does not address will present a challenge to SENACE and the Peruvian government if it wishes to push ahead with the project.