February 21, 2002
Letter to AMEC Urging Retraction of Faulty Environmental Assessment
Re: AMEC-CIDA assessment of the
I am writing to follow-up on our Feb. 6 meeting about the flawed AMEC-CIDA assessment of the proposed Chalillo dam project in Belize. Please find attached a summary of key unresolved concerns, noting your Feb. 6 responses, and additional details for your attention.
In our Feb. 6 meeting, you agreed to investigate the accuracy and reliability of your company’s geological assessment, following written complaints from independent geologists in Belize that AMEC’s geological assessment is incorrect and should not be used as a basis for the Chalillo dam’s design and construction. You agreed that as an engineering consultancy providing services to the public of Belize, AMEC has a responsibility to immediately notify the public in Belize of any mistakes and omissions in its report.
Any mistakes in the geological assessment of the dam site will not only affect the dam’s design and structural integrity, but also the project’s costs and overall economic viability. Therefore, AMEC has a responsibility to resolve this matter urgently. Furthermore, independent geologists in Belize, who have been publicly maligned by AMEC’s client, Fortis, for pointing out mistakes and omissions in the geological assessment, deserve a prompt and public apology in Belize. We have yet to receive your response.
As you are no doubt aware, the EIA work that Canada has funded since June 2000 is now the subject of a lawsuit brought against the Belize government by a coalition of environmental and business groups in Belize. The coalition has filed for a judicial review of the government’s “conditional clearance” granted to Fortis-Belize Electricity Company on the basis of the AMEC-CIDA assessment of the project. The groups in Belize argue that the Canadian EIA is incomplete, contains errors, and was not subject to public hearings in accordance with Belizean environmental law.
Prior to this, Probe International has urged Canada’s minister responsible for CIDA, Susan Whelan, to recall the AMEC report immediately, suspend all disbursements to AMEC, and issue a public statement assuring Canadians that no more public funds will be used for the Chalillo project. We have yet to receive the minister’s response.
Neither CIDA nor AMEC appear willing to ensure that their EIA work for the Chalillo dam project meets the highest international standards of practice, and be held accountable for complaints that the Canadian report is so flawed it cannot serve as a basis for a decision to build.
Canada’s approach to EIA work for this major infrastructure project in Belize has been sloppy and negligent:
· In our Feb. 6 meeting, you agreed that the EIA is incomplete in terms of its information about wildlife impacts but you said that AMEC is not responsible for what the dam’s proponents do with this report or the fact that it has been used by Belize authorities to rush approval of the dam’s construction without public hearings and adequate planning. AMEC’s geological assessment is wrong; its report on wildlife impacts is incomplete. Incredibly, only eight percent of CIDA’s total EIA budget for the Chalillo dam went to assess the dam’s impacts on rare and endangered wildlife populations in the project area. Aquatic ecology, vegetation, and forestry studies commissioned by CIDA in June 2000 were not completed. The project management plan, also commissioned by CIDA in June 2000, which was to include an evaluation of environmental risks, mitigation measures, and a budget for environmental monitoring and project management, was not included in the EIA.
· CIDA claims that it cannot comment publicly on the Chalillo EIA until it receives all documents from AMEC, the deadline for which CIDA has extended four times since June 2000 to February 2002. CIDA also claims that it cannot comment publicly on the EIA until it completes its internal review of the AMEC report, a process that, according to CIDA, has been ongoing for the last six months.
· In our Feb. 6 meeting, you said that CIDA has not passed on to AMEC hundreds of pages of technical comments on its EIA report, which were submitted last October by various experts and organizations to the Belize authorities, and to CIDA via Probe International. For the record, most of these comments have been available via our web site since last November and we have tried since last October to meet with AMEC and Fortis to discuss the EIA but both companies refused.
Meanwhile, bulldozers started work on the access road to the dam site this month, and the Canadian EIA, a document you admit is incomplete and could contain errors, has been used by Fortis and its Belize partners to justify construction of the dam this dry season.
We look forward to your response.
Gráinne Ryder, Policy Director
AMEC-CIDA Assessment of the Chalillo dam project, Belize
1. Geological assessment of the dam site
PROBE INTERNATIONAL: AMEC geological assessment is wrong, it must be redone, and the public in Belize must be notified (supporting documents submitted to AMEC and available on our web site at <www.probeinternational.org>). Without an accurate assessment, the dam’s design could be faulty, there may be unexpected bedrock movement, subsidence, and leakage after the dam is built; problems and increased costs during construction can be expected based on world-wide experience.
AMEC: In response to complaints from geologists in Belize and Probe International that the company’s geological assessment is wrong, AMEC Vice President, David Paterson, tells the St. John’s Telegram on Feb. 5 that AMEC “stands by its report.” In our Feb. 6 meeting, AMEC Chairman and CEO, Peter Janson, agreed to investigate the allegations of mistakes and promptly notify Probe of its findings. Janson and Paterson said the company continues to advise Fortis and its Belize partners on geology and sent technical people down to Belize the week of Feb. 11. We have received no further updates from AMEC. In Belize, the decision to go forward with the dam stands and, to our knowledge, AMEC has not yet advised the government of the errors in its geotechnical evaluation of the dam site.
ADDITIONAL INFORMATION PROVIDED BY PROBE FOR THE RECORD:
· November 2001: AMEC engineers insisted that their bedrock evaluation was correct in meetings and conference calls with Belize’s technical committee, despite independent review of the core samples by experienced geologists who pointed out that the dam site is made up of sandstones and shales, not granite as AMEC claims.
· January 2002: Fortis-Belize Electricity Limited sent a second set of core samples to Corelab in Houston and the Department of Geology, University of West Indies, after geologists Brian Holland and Andre Cho disputed the rock descriptions provided by AMEC. That sample analyses reportedly came back confirming that the rocks at the dam site are sandstones and shales, not granite as AMEC and Fortis-BEL claim. AMEC has yet to admit to these findings publicly.
· AMEC insists there are no significant geological faults in the project area. The Cooma Cairn Fault is less than one kilometre from the dam site and it is not known whether the fault is active or if it can be reactivated since no one has studied this. Another fault, the Northern Boundary Fault Zone of the Maya Mountains, which intersects with the Cooma Cairn Fault, is active and tremors are felt regularly within the fault zone and within the Mountain Pine Ridge area. Based on this, the Comma Cairn Fault poses a potential risk and should be evaluated.
· Geologist Brian Holland tried to have his concerns about the geological assessment addressed by the authorities in Belize last year without going public. He was hired by BEL and advised senior BEL staff of the problems but when he got no response he contacted John Woods, former Chairman of the Board of BEL who, in turn, advised the BEL Board and management of the problems. Woods’ response to Holland was that “the Canadians say you are wrong.” It was at that point that Holland decided to go public with his concerns.
· Canadian geologist Robert Johnston advised BEL of the flaws in the AMEC report, i.e., inaccurate geological maps and a flawed testing program on Nov. 19, 2001 and Jan. 2, 2002.
· On Nov. 13, 2001, Holland was hired by BEL, and accompanied by BEL CEO Lynn Young, to examine Chalillo drill cores, along with Andre Cho of the Belize Department of Geology and Petroleum. Holland’s core description and report with recommendations were sent to BEL on November 16, 2001.
· On Nov. 12, 2001, Mr. Sukhnanadan of BEL contacted Mr. Holland for a copy of his technical review of the AMEC report and received it on the same day.
· Geologist Brian Holland submitted his technical review of the AMEC report to BACONGO and the National Environmental Appraisal Committee in October 2001.
2. AMEC has downplayed wildlife impacts and ignored key recommendations from its wildlife consultants that the dam should not be built.
PROBE: “Based on the rarity of the habitat to be inundated, and the dependence on this habitat by several endangered species,” the Natural History Museum states in its report to AMEC, “the ‘No Build’ option is highly recommended as the most suitable and appropriate option for the long‑term viability and conservation of wildlife in Belize.” In a follow‑up letter to the Belize authorities, Lieutenant Colonel Alistair Rogers, a senior scientist and contributor to the Natural History Museum report, writes: “It is absolutely clear that constructing a dam at Chalillo would cause major, irreversible, negative environmental impacts of national and international significance – and that no effective mitigation measures would be possible.”
AMEC failed to include the NHM conclusions in its main report but shunted them into an appendix with an advisory: “Opinions contained in the report are those of the Natural History Museum. Readers . . . are advised to read it with the knowledge that it is a DRAFT REPORT and that they should formulate their conclusions accordingly.”
AMEC: According to Peter Janson, AMEC has not tried to downplay the project’s impacts on wildlife but is not satisfied with the NHM report because it failed to study the Scarlet Macaw nesting sites outside the area that would be flooded by the Chalillo dam. As such, AMEC was not able to conclude whether the dam will wipe out the Scarlet Macaw or whether the birds will be able to survive outside the area flooded.
ADDITIONAL INFORMATION PROVIDED BY PROBE FOR THE RECORD:
· NHM set up 32 monitoring stations in the watershed but all nests found were in the area that would be flooded by the dam. All Scarlet Macaw biologists agree that a thorough study of Scarlet Macaw nesting sites would require at least two to three years of monitoring to identify where the nests are and which are active, whereas AMEC scheduled a few weeks of dry season study and failed to schedule any wet season work.
· NHM agrees with AMEC that further studies are needed to identify the total number of Scarlet Macaw nests in the watershed, and should focus on areas inside and outside the watershed. However, NHM was given neither the time nor the funding by AMEC to complete this work before the Belize government granted its “conditional” clearance to Fortis-BEL to begin construction in January 2002.
· AMEC claims that the NHM failed to meet the terms of reference and provide a final report for inclusion in the EIA. However, a September 5, 2001 letter from the NHM to the Belize government states: “NHM believes that this report constitutes the best body of data currently available on the wildlife of the area. . . .”
· In its EIA report, AMEC omitted approximately 20 pages from the NHM report which included summaries of mammal and other species sighted in the Macal River Valley during NHM’s dry season study in the project area.
· NHM received approximately C$40,000 for its wildlife impact assessment out of C$73,314 allocated by CIDA to AMEC for this work. This amounts to about eight percent of the total CIDA budget of C$466,234 for AMEC’s project justification and EIA.
3. AMEC’s ongoing conflict of interest
PROBE: CIDA hired AMEC to produce a project justification and environmental impact assessment report. AMEC’s Executive Summary highlights the alleged benefits of the project, and downplays the severe impacts of the project, contrary to the original data prepared by scientists contracted by AMEC. AMEC’s contract with CIDA clearly stipulates that AMEC has an interest in pursuing project implementation, pending approval of the EIA. According to CIDA records obtained by Probe International using the Act, AMEC’s conflict of interest position is built right into its contract with CIDA, which states: “The Firm [AMEC] shall seek to interest the client [BECOL] in assigning implementation of the Project to the Firm [AMEC], or to interest the partner in continuing its cooperation in implementing the Project.” Clearly, AMEC has a conflict of interest conducting an EIA for a project it hopes to benefit from. The primary purpose of this contract is not to inform government decision-making process in Belize, as claimed by CIDA, but to help AMEC win Chalillo-related contracts.
AMEC: AMEC claims no conflict of interest because it has no intention of bidding on the design and build contract. However, AMEC continues to provide geotechnical advice to Fortis in Belize and may pursue environmental mitigation-related contracts.
The company is still working on two reports for CIDA as part of its revised June 2000 contract. AMEC’s client for these reports is CIDA, not the Fortis-owned Belize Electricity Company. These two reports, a risk assessment, and a final report No. 2 are due to be completed in February 2002. The risk assessment report is an estimate of environmental mitigation costs and may be used by Fortis-BEL to prepare its environmental compliance plan for the Chalillo dam. The environmental compliance plan is the subject of ongoing negotiations between the Belize government and Fortis-BEL, and must be completed prior to final clearance to Fortis by the Belize government. AMEC is not directly involved in the preparation of the environmental compliance plan but may bid on future environmental mitigation work. AMEC is also preparing the tender documents for the design and build contract on behalf of Fortis.
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