More than 100 thousand waterbirds that inhabit or nestle on the lake Texcoco will be cast out to the of Bordo de Xochiaca area, in order to build the new Airport, in spite of the 250 protected species worldwide as well as other endemic ones present. The businessmen –who plan to urbanize 1,700 hectares of permanent lake area and 2,000 hectares of stationary shallow ponds- only saw a “desolate and abandoned” area-, according to the Environmental Impact Manifestation (EIM) that SEMARNAT (Secretaría de Medio Ambiente y Recursos Naturales, Secretary of the Environment and Natural Resources) hastily approved. Other endemic species of mammals and reptiles will also be forced either to relocate or to die. The countless mistakes of the “study” which the companies presented are so serious, that as a “measure of environmental mitigation”, they put forward the introduction of exotic and predator species among the local flora and fauna, clarify the scientists.

The construction of the new airport serving Mexico City, on the lake Texcoco puts in imminent risk at least 100 thousand or more waterbirds; of which 250 are enlisted within the Law for the Conservation of Neotropical Migratory Birds, 12 within the norm NOM-059-SEMARNAT-2010, one under the endangered category and 11 subject to special protection.

The partial or total loss of that habitat also threatens the lives of endemic mammals and reptiles. However the dependency in charge of taking care of life and security of the species -the SEMARNAT- granted its endorsement to the project.

The SEMARNAT authorized the construction and operation of the air terminal on the grounds of the former lake Texcoco, with 20 constraints and 34 observations made by governmental authorities and experts, and only 2 months ahead of receiving the Environmental Impact Manifestation (EIM) on the new international Airport of Mexico City.  The deliberate omission of information and technical deficiencies are a constant in the 900 pages bundle, claim nine scientists.

After a thorough revision of the document SGPA/DG RA/DG/09965 of the project of the Nuevo Aeropuerto International de la Ciudad de México, SA de CV (New International Airport of Mexico City), MIA-15EM2014, the analysis group on the EIM of the Unión de Científicos Comprometidos con la Sociedad (Union of Committed Scientists with Society, UCCS)- a non-lucrative association made up by Mexican scientists out of the natural and social sciences, and humanities- concluded that the project “should have been dismissed by the Dirección General de Impacto y Riesgo Ambiental (the General Impact and Environmental Risk Directorate, DGIRA)”.

On the 28th of November 2014 the Secretaría de Gestión para la Protección Ambiental (the Assistant Secretary-General for the Environmental Protection) through the DGIRA issued the notification SGPA/DGIRA/DG/099965 directed to Raúl González Apaolaza, the legal representative of Grupo Aeroportuario de la Ciudad de México, SA de CV (the Airport Group of Mexico City, GACM).

Based on the document, SEMARNAT authorizes for 48 years the conditioning and construction of the project with regard to impact and environmental risk in four phases: phase 1 from 2014 to 2018, phase 2 from 2018 to 2023, phase 3 from 2023 to2028, and phase 4 from 2028 until 2062.

The guarantee would have been issued 77 days after the GACM had submitted the EIM for its analysis and evaluation.

The authorization consisting of 133 pages bears the signature of the General Director of the Impact and Environmental Risk Directorate of the SEMARNAT, Alfonso Flores Ramírez. This public servant appears to be denounced before the supervisory body of the SEMARNAT in April 2012 by the environmental organization Greenpeace, for declaring himself incompetent to cancel the touristic complex Cabo Cortés, in charge of the Spanish firm Hansa Urbana, which threatened the Reef and Marine Park of Cabo Pulmo in the State of Southern Baja California.

Around 2 months were enough for the dependency to issue the warranty added with 20 constraints and 34 observations made by governmental instances and experts on this subject.

 “The DGIRA resolves very inadequately this issue and often accepts the developer’s proposals without any constraint. This proves to be absolutely unacceptable due to the magnitude of the project, and the environmental and social impacts that will be present on the medium and long term”, warn the scientists of the UCCS

Among the main observations of the UCSS Analysis Group, led by Fernando Córdova Tapia, is the sowing of 264,534 individuals of invasive exotic species, as one of the main measure of compensation for the recovery of the adjacent land of the area to be taken up by the new airport, in order to compensate the conditions derived of the change of land use.

The program intends to plant 134,011 individuals of Tamarix Aphylla, 125,290 individuals of Tamarix chinensis, 4,070 individuals of Lycium spp, 1,163 individuals of Casuarina equisetifolia and 290 individuals of Opuntia streptacantha in the proposed area for environmental compensation.

“It is extremely worrying that four out of five species to be planted are invasive exotic species, whose hazardous effects to the native flora and fauna have been widely studied and very much documented nationally and worldwide.”

Therefore they are considering that by no means this could be conceived as a measure of compensation, rather an activity which will bring along very serious environmental damage on the medium and long term for the ecosystem of the Valley of Mexico.

“The Tamarix breed as well as the Casuarina breed are recognized by the CONANP (Comisión Nacional de Áreas Naturales Protegidas, National Commission for Protected Natural Areas) as being the main threat to native flora and fauna in protected natural areas nationally”.

According to the CONANP, the sow of these invasive exotic species should be avoided without exception within the Mexican territory. “It is absolutely unacceptable that the resolution issued by the DGIRA doesn’t mention nor takes into account the seriousness of the introduction of invasive species, and furthermore approves its sowing without any restriction, as a measure of compensation to the construction of the airport.”

The change in land use

The new airport shall be constructed on 4,431 hectares of land of the municipalities of Atenco and Texcoco in the State of Mexico, within an area of non-developable land use, as it states in the Environmental Impact Manifestation.

Regarding the analysis of the land-use regulation, the group of scientists of the UCCS point out that according to the Programa de Ordenamiento Ecológico General del Territorio (the General Ecological Land-use Program of the Area, POEGT), the ground of the project matches with the Unidad Ambiental Biofísica (Biophysical Environmental Unit, UAB) 121, in which the guidelines are the social and touristic development, and as contributory are the forestall-industrial activities, as well as the preservation of flora and fauna.

The scientists also indicate that in the Municipal Plan of Urban Development of Texcoco, the area of the basin of the former lake Texcoco is considered as Natural Protected Area, since it constitutes one of the areas of major environmental value within the municipality. The municipal plan establishes the environmental policies of land not intended for building, among which stands out the strict control on urban development inside the area of the basin of the former lake Texcoco and the promotion and the stimulus of agricultural activities, discouraging any human settlements.

Hereby this is a project of high impact, which intends to implement urban development in an area of recharge of the ground water level, an archeological area, with floodable zone and foreseeable risk of sinkholes and flooding. “The development of the airport should have been denied by the DGIRA; however the decision omits this legislation, arguing that in the zonation there is no mention of whatsoever ban of construction sites, nor any related activities in regard with this project, so henceforth no contravention has been identified with the regional urban development plan of the Valley of Cuautitlán-Texcoco, nor with the municipal urban development plans of Atenco or Texcoco, that may constrain the development of the project.”

The construction site: a desolated and abandoned area

For the authors of the EIM –Especialistas Ambientales SA de CV (Environmental Specialists Ltd) in collaboration with Proyectos de Ingeniería, SC (Engineering Projects) and the Colegio de Biólogos de México, AC (the Public School of Biologists of Mexico) – “from the point of view of ecology the former lake Texcoco is solely a desolated and abandoned area”.

The Especialistas Ambientales SA de CV Group -whose director and associate as well as current Undersecretary for Planning and Environmental Policies of the SEMARNAT is Rodolfo Lacy Tamayo-, explains in the mammothreptus, that the desiccated lakebed of the former lake Texcoco has ceased to have any use due to the extreme conditions of salinification and high levels of sodium, that prevent the natural development of the vegetation and that have caused the desiccation of the area, turning it unfit for  any urban purposes.

Thereby and without “any human settlements implied in the project”, the developer considers the building and operation of an airport for 100 years feasible, in the region 68 of the remnant of the lake complex of the basin of Mexico, with an extension of 2,019 square kilometers in which lies the lake Texcoco with an area of 15,106 hectares, listed as an Important Area for the Conservation of birds.

The endemic, migratory and endangered birds off to the Bordo de Xochiaca Area

After 5 days of field work –two in November (21st and 25th), two in December (10th and 23rd) of 2013 and one in January (9th) of 2014- in which Texcoco and other six waterbodies were visited: Lake Texcoco, the Ecological Park of Xochimilco, the Cienega of Tlahuac, the Guadalupe Dam, the Zumpango Dam, the Cuevecillas Dam. In this task, which the specialists of the UCCS described as poor and insufficient, the developer accounted 74 species of water and inland birds.

Four of these species are found to be under the protection by the Official Mexican Norm NOM-059-SEMARNAT-2010, 13 under some category of the International Union for the Conservation of Nature (IUCN) and finally four are included in the Appendix II of the Convention on International Trade of Endangered Species of Wild Fauna and Flora.

The UCCS Group also reveals that in this section the developer solely refers to the species that they found on the premises and omits all the other species registered within the Important Area for Conservation of Birds, identified with the code AICA-01 by the Comisión Nacional para el Conocimiento y Uso de la Biodiversidad (the National Commission for the Knowledge and Use of the Biodiversity, CONABIO).

The fact sheet available on the website of the Commission, whose General Coordinator is the former Rector of the National Autonomous University of Mexico (UNAM) José Sarukhan Kermez, clearly states that “the site maintains a population of over 100 thousand waterbirds in winter, is also the most important area of the two or three areas for hibernation of waterbirds of the Valley of Mexico. It represents an area of 1,700 hectares of permanent lakes and 2,000 hectares of stationary shallow ponds, which favor the establishment of big colonies for nesting and resting of waterbirds”.

The nine scientists indicate that information is being left out, by failing to mention many of the 250 species, which can be found in the Neotropical Migratory Bird Conservation Act (NMBCA), an initiative for subsidies to support conservation projects of habitats in the USA, Canada, Latin America and the Caribbean islands.

Furthermore, out of the 250 species, 12 are listed in the NOM-059-SEMARNAT-2010 norm, one in the category of endangered species and 11 more under special protection. Three species are included in the list of the IUCN, two in the category of nearly endangered and one is considered as vulnerable. “(The study also) skips completely the state of endemism of the registered species”.

Additionally they point out that information referred to the Red Hemisférica de Reservas Para Aves Playeras (Hemispheric Beach Birds Reserve Network, RHRAP) is being left out, whereby lake Texcoco is classified since 2007 as a site of Regional Importance. This category was designed due to the fact that the area is used by at least 20,000 beach birds, both residential and migratory ones. Inasmuch the lake Texcoco is considered a paramount site for the distribution and conservation of beach birds and is located in the 21st position nationally. According to the RHRAP the lake Texcoco contains 47 species of beach birds of prioritized conservation as a whole, among them 26 with high conservation concern, and 21 with moderate conservation concern. In addition to this, 12 of them have a low population and nine have become vulnerable due to loss of habitat.

The EIM “underestimates the birdlife of the region” and despite the fact that the information about which ones are residents or migratory, is public and can be made available from online databases of the CONABIO, the developer says to be ignorant of which of them are resident species and which are migratory.

In accord with Especialistas Ambientales, SA de CV, the species will be chased away of the construction area of the project or moved to similar places nearby, and during operations of the aerodrome the presence of birds will be minimal around the take-off and landing airstrips.

“In the event of drying out the waterbody both the resident and migratory species will spread to neighboring water bodies, like the Lake Nabor Carrillo, the Recreativa Lagoon, the Churubusco, Xalapango and Facultativa Lagoon, among others”, claims without greater detail the EIM.

In an interview with Contralínea, Fernando Córdova of the UCCS stresses out that “the developer assumes that once the birds are chased away, they will not return within the next hours or days to that same spot”, and adds that it remains unclear how the operations will take place, with which staff and whether they have some special training on how to deal with the bird population.

The EIM speaks openly about the possibility of extinction of species of birds, reptiles and mammals:” There is a probability directly as indirectly of such mortality among wildlife. The sole human presence and the use of machinery in the area itself, could bring about the mortality of wildlife”, nonetheless it considers that the impact will be moderate.

In line with the scientists, the vacuum of information should have been taken into account by the DEGIRA; on the contrary the scientists accuse that entity to accept the arguments provided by the developer, where it doesn’t question how the birds will be chased away or whether it is the most appropriate method; neither does it question itself on how the developer ensures that the contiguous waterbodies, as well as the De La Compañía River and the Bordo de Xochiaca area are in fact favorable places for the chased-away birds to remain, nor do they question the effects caused to the birdlife while occupying the spots, as well as the possible death due to the amount of waste found in the Bordo de Xochiaca area and to the settlement of great number of bird flocks.

The UCCS concludes that the management program of the birdlife is being poor in its actions, in the description, support and in their justification, with unsatisfactory skills which aren’t considered in the resolution. “The DGIRA simply limits itself to requesting a monitoring program hence it doesn’t warranty the protection of the birds of Texcoco”.

Inside the property the developer also has taken into account 24 species of vegetation, as a result of governmental reforestation and grass sowing programs and of the natural development of vegetation, which will utterly be removed. In the process of excavation and clearance, in accordance with the authors of the EIM, 900 thousand cubic meters of organic soil and clay will be removed.

So it states: “For the waste generated by the clearance and excavation, as well as by the construction itself, it will be necessary to count on a waste depot that should be located far from the waterbodies and in areas that lack vegetation coverage (…) like the Bordo Xochiaca Area which is located approximately 6 km away from the construction site.”

Also seven more species of herpetofauna were identified (four amphibious, three reptiles, which based on their aquatic habits and slow movement will be affected, underlines the EIM); five species of mammals (2 rodents, the white-footed mouse and the Mexican meteor), as well as two leporidae reported in the area (the black-tailed jackrabbit and the Castilian rabbit), also herds of domestic dogs of six to eight individuals each.

The LEDD-Certification, the sustainable farce

Facing the laxity whereby the authority evaluate and authorize the EIM, the UCCS throughout an analysis group are working since 2011 in the revision of the documents.

The analysis group which is performing technical-scientific dictates of the project, that potentially could impact the environment, has identified some of the factors that weaken the efficiency of the EIM both on the local and federal level.

“The EIM has been overrun, it is absolutely inefficient; instead of being a tool to evaluate it has become a formality” says Fernando Córdova member of the UCCS in an interview.

The biologist explains that it is a structural problem: the authorities first grant the concession and then evaluate the environmental impact of the construction site: “The government being the promotor of the project, those who are in charge of the instances to safeguard the natural resources have acquired both parts, being the judge and the defendant.” He points out that from the perspective of the UCCS, the classification system LEED of the US Green Building Council (USGBC) which establishes the criteria for sustainability which the federal government often has expressed to seek, does not take into account the context in which the aforementioned project will be built, and according to Fernando Córdova  it shouldn´t apply for projects to be built on areas with environmental value such as the former Lake Texcoco: “The recovery of the lake is of major social benefit”, he concludes.

For the accomplishment of this research an interview has been requested to the Secretary of Environment and Natural Resources and the National Commission for Knowledge and Use of Biodiversity. Up to the closing of edition no response has been received.

Birds could bring down planes

In accord with the Analysis Group of the UCCS a clear example of the issue of attraction for birds (waterbodies) such as the Bordo de Xochiaca Area, is the Colombian 3 de Mayo Airport, which is approximately 2,4 kilometers away from a sanitary landfill, thus having carrion birds making up to 20 individuals overflying at different altitude the airport and its surroundings, therefore creating high risk for air navigation.

During the period of public consultation one of the observations put forward is referred to that issue. On page 14 of the resolution it is expressed: “Considering that the location of the runways is along a north-south axis and that the planes will cross through the area where the new waterbodies will be created, how will (those responsible for the project) warranty that the birdlife which will be relocated south of the project (site) will not be disturbed?”

The DGIRA responds to the objection in conformity with the statements of the developer, whereby the altitude of the birds of the place is reported to be between 30 and 40 meters within short-distanced flight patterns, meanwhile the airplanes at the crossing point with the Lake Nabor Carrillo will be flying at other altitudes.

The nine scientists of the UCCS that reviewed the EIM presented by the company, as well as the resolution of the DGIRA, assert that key information has been left out, i.e. the fact that the registered species (leaving out the Important Area for Conservation for Birds Register) don’t exceed 30 and 40 meters of altitude in their flight, but in agreement with the list of species drafted by the CONABIO, some of them specially the migratory birds of prey that commonly fly at considerable altitude (game birds or birds of prey with diurnal and nocturnal habits) such as the Cathartes aura, Leucophaeus pipixcan and the Buteo swainsoni, which reach flight altitudes exceeding 300 up to 450 meters (among them the two first species are registered in the list of the EIM).

Furthermore the carrion species Coragyps atratus and Pandion haliaetus are both to be found on the register of the EIM, which are reported by the Centro de Estudio y Conservación del Patrimonio Natural (the Center for Research and Conservation of Natural Heritage) to reach low and high flight altitudes, thus representing a large variety of patterns, therefore increasing the probability of collision between birds and airplanes.

Several studies show that approximately 87% of the collisions between wildlife and airplanes occur within o near the airport, while the planes are at less than 600 meters. These impacts at such altitudes are very dangerous as the pilots don’t dispose of much time to recover the control over the aircraft.

In the EIM is also found the Pluvialis dominica specie, which has been reported in the study Basic Concepts about Neotropical Migratory Birds of Mary Deinlein, published 2008 by the National Zoo of Washington, D.C., travelling at an altitude of 1,500 meters and occasionally above 3,600 meters. The same study states that the Anas platyrhynchos collided with an aircraft at an altitude of 6,400 meters.

“In this regard no register about maximum flight altitude of each of the species listed is presented. Neither is there any bibliographic revision of the history of collisions of listed species in the area”, consents the Analysis Group of the UCCS.

Despite the fact that for the developer “the birdlife that will inhabit the new waterbodies, which will be created as a mitigation measure, will not be disturbed since they will not compete for air space with the aircrafts when landing or taking off, and the creation of new habitat south of the area of the project (site) will meet internationally recognized standards, established in all airports in order to control the risk of encounter of birds and aircrafts…” the experts of the UCCS  clarify that all performed studies for airports mention the competition, that will always be for air space.

“There is no airport which is immune to risks of fauna. Therefore it seems of great importance to understand the nature of the birds that inhabit both in the area of the project (site) as well as its surroundings. It requires a classification that takes into account the level of danger that it represents according to the seasonality, month, year and hour of the day with peak activity, the climatic conditions and the focuses of attraction (vegetative cover, food, water). All of these factors can increase the wealth and abundance of birds in the airport area. None of the latter was evaluated by the EIM, neither was it part of the resolution of the project.

Source: Analysis Group of the UCCS


Elva Mendoza

(Translated by: Axel Plasa)




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