An Independent Environmental and Social Assessment of the Camisea Gas Project - By: Patricia B. Caffrey

Commissioned by Peruvian indigenous organizations:
The Machiguenga Council of the Urubamba River (COMARU) and the Inter-Ethnic Association of the Peruvian Amazon (AIDESEP)


ACKNOWLEDGEMENTS:

Many individuals and their organizations with a broad array of experiences and knowledge have contributed to and enriched this independent review. I would like to thank the following people for their technical input into the analysis: the Machiguenga communities of the Urubamba Region, Janet Lloyd of Amazon Watch, Bahram Jafari an independent consultant in the design and development of gas projects, Amparo Herrera of Peru Verde a non-profit organization operating out of Timpia - Lower Urubamba and Meche Lu of E-Law. I would also like to thank the following people who reviewed and made suggestions for strengthening the report: Juan Carlos Riveros of WWF-Peru, Lily la Torre of Racimos de Ungurahui and Lelis Rivera of CEDIA. Thanks as well to the anthropologists Conrad Feather, Gregor MacLennan and Lev Michael. The translators also deserve special recognition for their good work: Violeta Villacorta, Alex Taylor and Roberto Espejo. There were several individuals who accompanied me throughout the entire process of producing this independent study and they deserve special thanks: Cathy Ross, Keith Slack and Javier Aroca of Oxfam America, Atossa Soltani of Amazon Watch and Jorge Agurto - the Co-coordinator of this effort. Finally, we would like to thank the Amazon Alliance for their coordination efforts and Global Green Grants, Oxfam America, Rainforest Action Network, and Tropical Nature for their financial support.

TABLE OF CONTENTS


ACKNOWLEDGEMENTS..................................................................................... 2
TABLE OF CONTENTS........................................................................................ 3
I. EXECUTIVE SUMMARY.....................................................................................4
II. INTRODUCTION................................................................................................7
III. PROJECT DESCRIPTIONS AND MAP.............................................................. 9
A. GAS TRANSPORT: DOWNSTREAM........................................................9
B. BLOCK 88 - EXPLORATION, EXTRACTION AND PROCESSING OF GAS:
UPSTREAM.............................................................................................. 11
IV. ANALYSIS AND OBSERVATIONS.................................................................. 14
A. INDIGENOUS PEOPLE LIVING IN VOLUNTARY ISOLATION.................... 14
2. International Legal Agreements on Indigenous Rights:................................17
3. Analysis of the Pluspetrol's Social Impact Study:............................................... 18
B. OTHER SOCIAL IMPACTS.............................................................................. 21
1. INTRODUCTION:...................................................................................... 21
2. Best Practices and International Standards: 23
3. Observations: Environmental Impact Assessments, Environmental Management Plans and Community Relations Plans: 25
C. BIODIVERSITY IMPACTS 28
1. Introduction: 28
2. Best Practices and International Standards: 31
3. Observations: Environmental Impact Assessments and Environmental Management Plans: 33
V. CONCLUSIONS AND DESIRED OUTCOMES 39
A. CONCLUSIONS 39
B. DESIRED OUTCOMES 44

I. EXECUTIVE SUMMARY

Peru's Camisea natural gas field (Block 88) and pipeline project will be constructed in one of the world's most environmentally and socially sensitive areas. A region of great biodiversity, Camisea is home to Machiguenga, Yine, Nanti, Nahua and possibly Kirineri peoples including indigenous populations living in voluntary isolation. The Cordillera of Vilcabamba and the Lower Urubamba Region are areas of global ecological importance. Conservation International has prioritized the Cordillera of Vilcabamba as one of twenty-five global "hotspots" for conservation because of its biological richness, high incidence of endemism and highly threatened status. World Wildlife Fund has designated the Southwestern Amazon, the Lower Urubamba located at its heart, as one of their "Global 200" ecoregions prioritized for conservation efforts because of its high biodiversity and globally important ecological functions.

This review provides an independent assessment of the most significant potential environmental and social impacts of the Camisea natural gas field and pipeline project on the Urubamba River Valley. The assessment devotes particular attention to analyzing concerns raised by local indigenous peoples' organizations and by national and international environmental and development organizations working to support indigenous peoples in the area. The review was commissioned by the Consejo Machiguenga del Río Urubamba (COMARU), the Asociación Interétnica de Desarrollo de la Selva Peruana (AIDESEP) with support from the cooperating organizations - Amazon Watch, Oxfam America and the Centro para el Desarrollo del Indígena Amazónico (CEDIA). The technical review was conducted by an independent group of experts who worked closely with the Grupo de Interes and the local stakeholders to research, analyze and finalize this report. The technical experts included independent consultants in addition to voluntary input from experts from the following organizations - Racimos de Ungurahui, AIDESEP, World Wildlife Fund Peru, COMARU, CEDIA, Oxfam America, Peru Verde, ELAW Peru, and Amazon Watch.

The technical experts reviewed the current Environmental Impact Assessments, Environmental Management Plans, biodiversity assessments and other key project-related documents for both the upstream and downstream projects. These documents were compared with (a) similar documents prepared for the Shell-led Camisea consortium of 1996-98 and (b) relevant World Bank standards and (c) similar documents. The preliminary analysis was presented, discussed and finalized during a series of workshops held with interested stakeholders of the Urubamba River Valley.

Two consortia will implement the Camisea Gas Project. The transport or downstream part of the Project will be implemented by Transportadora de Gas del Peru (TGP) - a consortium of several companies: Pluspetrol (Argentina), Hunt Oil (USA), SK Corporation (Korea), Sonatrach (Algeria), G y M (Peru) and Tecgas (Argentina - chief operator of the Project and subsidiary of Techint). The major characteristics of the transport part of the Project are:

· Gas pipeline - two pipelines to be buried side by side (natural gas and liquid natural gas), 700 kilometers from lowland rainforests to the coast (25 meters in width right of way - ROW) with the capacity to transport 250 million cubic feet of natural gas per day and 70,000 barrels of LNG per day.
· Pumping and pressure stations: 2 pumping stations in the sensitive rainforest area.
· Two campsites cleared and established in the sensitive rainforest area with 500 to 1000 workers.

Pluspetrol (Argentina - lead operator), Hunt Oil (USA), SK CORPORATION (Korea) and Hidrocarburos Andino S.A.C (Peru) will implement the exploration and extraction part of the Project that will take place in Block 88. The major characteristics of this part of the Project are:

· Seismic testing - paths of 1.5 meters. in width will be opened approximately every 300 meters, north-south and east-west, and will produce explosions in an area of 800 kilometers², 66 heliports and various campsites will occupy 8.5 hectares, and there will be 6,400 unloading zones that will occupy 23 hectares.
· Extraction - platforms and wells, 4 platforms (1 to 3 hectares) and 12 wells now, and up to 9 more in the future.
· Transportation - pipeline network between platforms and processing plant within Block 88, 64 kilometers, 25 meters ROW.
· In Las Malvinas: a gas separation and condensation plant, related infrastructure, airstrip, port facilities, storage tanks and a campsite in an area of 72 hectares with between 500 and 1000 workers.

The analysis, observations and conclusions in this report are detailed and extensive. The major observations and conclusions are as follows:

Irreversible Negative Impacts and Compliance:
The Project will have negative irreversible impacts on the biodiversity of this area and on indigenous groups living in isolation regardless of the implementation of the strictest mitigation measures. In addition, there is concern that even if the consortia were to plan the strictest measures that in reality the companies will not adhere to and comply with plans and targets. There are no financial incentives or strict enforcement in place to ensure compliance with plans over the life of the Project. The Peruvian government's capacity to enforce compliance is weak. None of the companies involved in the consortia have a history of applying best social and environmental practices. In the case of TGP, mitigation targets and measures are deficient. Project plans do not include truly independent and transparent monitoring processes and lack mechanisms for ensuring independent technical and advisory oversight.

Neither component of the Project meets World Bank standards. Exploration, extraction and transport activities will destroy primary tropical humid forests and will lead to degradation and conversion of critical natural habitats. Special analysis of impacts on indigenous groups - particularly indigenous groups living in voluntary isolation is deficient. Corresponding plans to prevent and mitigate negative impacts to these groups is lacking. Both companies are in violation of the ILO Convention 169. Local stakeholders were not given appropriate information or sufficient time to study and respond to the environmental impact assessments. Current compensation negotiations and practices do not allow for free and informed decision-making on behalf of the indigenous groups. They have not been involved in decision-making over issues that will affect them.

Recognition of Induced Impacts and Control of Access:
Both EIAs include extensive sections on analyzing potential direct impacts. However, analysis of indirect induced impacts and corresponding environmental management measures to mitigate them are deficient. The EIA for the upstream component does analyze indirect induced impacts however, the environmental management plan is weak when it comes to measures for preventing or mitigating induced impacts. The EIA for the downstream component does not recognize indirect induced impacts therefore, the environmental management plan does not address them. Both components were studied separately so there is no recognition of the combined impacts of both components. For example, Pluspetrol plans to prohibit the construction of roads to hinder access however, no mention is made of the fact that the other component - the gas pipeline, will open up access to the Cordillera of Vilcabamba, Lower Urubamba and Block 88. For such a complex Project that will be implemented in an extremely sensitive area this is a significant shortcoming. The local communities, human rights and conservation groups are very concerned about indirect impact issues such as improved access which will lead to increasing colonization, deforestation, environmental degradation, health hazards, loss of cultural integrity and social conflict. The companies must be required to implement measures to control access.

Community Relations:
Local stakeholder relations with the companies are troublesome. Although some of the initial consultations went well - especially those conducted by ERM, the public involvement in the EIA reviews have been woefully inadequate. The local stakeholders have not had any input into the Project design, environmental management plans or proposed compensation measures. Compensation negotiation practices have served to divide, confuse and weaken the Machiguenga community. The companies are negotiating exclusively on their terms and communities are faced with having to negotiate with one to three different companies over related issues. There has not been any effort to integrate approaches between companies. Different "deals" are being presented to each community. What appears to the communities' as a chaotic and divisive process is also not addressing their concerns. Instead, it is generating mistrust between the companies and the local people. The local communities are very aware of the potential social and environmental problems and they realize that the divided and partial compensation deals will not address these issues. The companies need to combine efforts and resources to work with the communities to effectively address their concerns regionally and in an integrated fashion. The companies should work with the communities collectively - not individually.

Indigenous Peoples Living in Isolation:
The magnitude of the Camisea Gas Project demands a thorough and accurate assessment of the needs and wishes of peoples living in voluntary isolation and a rigorous and full analysis of project impacts on their lives. Methods proposed to mitigate social impacts on isolated peoples are deeply deficient, though it should be noted that improved mitigation methods would only partially reduce the substantial risks of serious social impact on isolated indigenous peoples presented by the Project. The Nanti, Nahua and Kirineri peoples will be affected to varying degrees and in different ways. The Camisea Gas Project repeatedly violates the indigenous people living in isolations' internationally recognized rights as human beings and indigenous peoples. Even though the companies may discourage contact it is extremely likely that during the 33 year period of implementation of the Project that contact will occur against the will of some of these groups. The boundaries of the Reserva del Estado al Favor de las Poblaciones Nativas Nomade Kugapakori y Nahua have not been respected by allowing gas exploration and extraction in the Reserve. Three of the four platforms and most of the seismic activity will take place in the Reserve. Respecting the boundaries of the Reserve and the rights of the isolated peoples would entail prohibiting development of three of the platforms (Cashirairi 1 & 3, San Martin 3) and reducing seismic exploration so that it will not take place in the Reserve. Finally, no independent oversight mechanism has been proposed to ensure adequate development of measures and strict compliance to company policies, codes of conduct and contingency plans related to indigenous peoples living in isolation.

Safety of Local Communities:
Local communities have never been exposed to an industrial project. Extreme care should be taken to safeguard their health and safety. During the workshops that were held in the area the local communities expressed a high level of understanding and concern over potential health and security risks. It is likely that the EIA consultation process contributed to this awareness. On the other hand, despite the thoroughness of the consultation analysis, the Project design and plans have not taken several major local concerns into account. The current design has the gas pipeline running precariously close to human populations and civil structures. Workers camps will present a significant intrusion on the local native population. They pose serious potential threats to the local peoples health and culture. Any relationship between the workers and the local communities could lead to negative social impacts.

II. INTRODUCTION

Peru's Camisea natural gas field (Block 88) and pipeline project will be constructed in one of the world's most environmentally and socially sensitive areas. A region of great biodiversity, Camisea is home to Machiguenga, Yine, Nanti, Nahua and possibly Kirineri peoples including indigenous populations living in voluntary isolation. Indigenous peoples in the project area are gravely concerned about the potential impacts of the project on their natural environments and their ability to live off their natural environment. Their livelihood is intimately linked to the natural forest and freshwater habitats of the eastern Andean foothills and Amazon River basin within which they live. Degradation or conversion of these natural habitats would significantly alter their livelihoods, health and way of live. For this reason, they have requested international assistance to review project-related environmental impact documents prepared for the consortium's two consortia, Pluspetrol (upstream) and TGP (downstream). The review strives to strengthen the local stakeholders efforts to guarantee that the serious impacts related to the project are addressed within the environmental management processes to be established.

The Cordillera of Vilcabamba and the Lower Urubamba Region are areas of global ecological importance. Conservation International has prioritized the Cordillera of Vilcabamba as one of twenty-five global "hotspots" for conservation because of its biological richness, high incidence of endemism and highly threatened status. World Wildlife Fund has designated the Southwestern Amazon, the Lower Urubamba located at its heart, as one of their "Global 200" ecoregions prioritized for conservation efforts because of its high biodiversity and globally important ecological functions. A rapid ecological assessment conducted by the Smithsonian Institution and Conservation International confirms that the Cordillera of Vilcabamba is a region of global biodiversity importance and recommends that gas pipelines be routed around, construction of roads be prohibited and immigration to the area be controlled. A series of biodiversity studies conducted in the Lower Urubamba region by the Smithsonian Institution states that few areas of the planet remain unexplored and intact, untouched by human activity and with their full complement of biodiversity like the Lower Urubamba. It goes on to state that the transitional forests of the Lower Urubamba are among the most biologically diverse in the world.

Given the highly sensitive social and ecological nature of these areas, the local stakeholders expect that processes and proposed safeguards meet at least the standards established by the previous Camisea consortium leader Royal Dutch Shell and by the World Bank. The original Environmental Impact Assessment (EIA) conducted by Shell Oil indicated that the Camisea gas field and pipeline project could cause the loss of food resources, loss of habitat and biodiversity, contamination of drinking water supplies and an increase in the incidence of sickness and disease. When Shell Oil conducted preliminary exploration in the region in the 1980's, 42% of the Nahua population died as a result of diseases contracted from loggers (Shepard, 1999: 38). Loggers used the seismic trails to penetrate deeply into the forest. Before eventually withdrawing from this project, Shell made a strong commitment to minimize the project's impacts on biodiversity and local communities in the region.

This review provides an independent assessment of the most significant potential environmental and social impacts of the Camisea natural gas field and pipeline project on the Urubamba River Valley. The assessment devotes particular attention to analyzing concerns raised by local indigenous peoples organizations and by national and international environmental and development organizations working to support indigenous peoples in the area.

The review was commissioned by the Consejo Machiguenga del Río Urubamba (COMARU), the Asociación Interétnica de Desarrollo de la Selva Peruana (AIDESEP) with support from the cooperating organizations - Amazon Watch, Oxfam America and the Centro para el Desarrollo del Indígena Amazónico (CEDIA). The technical review was conducted by an independent group of experts who worked closely with the Grupo de Interes and the local stakeholders to research, analyze and finalize this report. The technical experts included independent consultants in addition to voluntary input from experts from the following organizations - Racimos de Ungurahui, AIDESEP, World Wildlife Fund Peru, COMARU, CEDIA, Oxfam America, Peru Verde, ELAW Peru, and Amazon Watch.

The technical experts reviewed the current Environmental Impact Assessments, Environmental Management Plans, biodiversity assessments and other key project-related documents for both the upstream and downstream projects. These documents were compared with (a) similar documents prepared for the Shell-led Camisea consortium of 1996-98 and (b) relevant World Bank standards and (c) similar documents and current practice in the Bolivia/Brazil and Bolivia/Cuiaba pipeline projects, including the independent monitoring system, indigenous peoples development plan, environmental management plans, and programs to compensate for loss of biodiversity.

The preliminary analysis was presented, discussed and finalized during a series of workshops held with interested representatives of the indigenous communities of the Urubamba River Valley. This document presents brief project descriptions, the technical analysis, conclusions and desired outcomes. A great deal of time and effort was invested by many interested people and institutions to prepare this independent assessment and it is their sincere desire that the sponsors and managers of the Camisea Gas Project make use of the report to achieve the desired outcomes. The assessment will provide guidance to the community-based stakeholders for evaluating the Project implementers' practices and performance and ultimately, the impact of the Project on their lives and cultural survival.

III. PROJECT DESCRIPTIONS AND MAP
A. GAS TRANSPORT: DOWNSTREAM

The Project will be implemented by Transportadora de Gas del Peru (TGP) - a consortium of several companies: Pluspetrol (Argentina), Hunt Oil (USA), SK Corporation (Korea), Sonatrach (Algeria), G y M (Peru) and Tecgas (Argentina - chief operator of the Project and subsidiary of Techint). Three, thirty-three year, contracts were signed with the Government of Peru on the 9th of December, 2000: 1) a contract to build, own, operate and transfer (BOOT); 2) a contract for BOOT of liquid natural gas (LNG) via pipeline from Camisea (Las Malvinas) to the coast of Peru (Lurin) and 3) a contract for BOOT of distribution of natural gas via pipelines in Lima and Callao. TGP is responsible for the design, administration of goods and services, construction and operation of the system of gas transport, leasing of transport services and maintenance and repair of the system. The estimated cost of the Project is US $1.45 billion. The natural gas pipeline will be approximately 700 kilometers long and the "poliducto" to transport the LNG will be 650 kilometers. Both will begin at Las Malvinas in Camisea. The natural gas pipeline will end at the City Gate of Lima and the LNG pipeline will end at Pampa Clarita in Canete. The Project is designed to transport 250 million cubic feet of natural gas per day and 70,000 barrels of LNG per day. While, initial use will be for approximately 125 million cubic feet of natural gas per day, production can be expanded to 730 million cubic feet per day. The diameter of the natural gas pipeline will vary between 18", 24" and 32" and the diameter of the "poliducto" pipeline will vary between 14", 12 ¾", 10 ¾", and 8 5/8". Both pipelines will be buried along the entire route with the possible exception of the Acocro River crossing. The depth the pipelines will be buried will depend on the characteristics of the soil. For example at road crossings they will be buried 2 meters however throughout most of the route they will be buried at a depth of .6 to .9 meters. The pipelines will cross thirty steep valleys and rivers and the crossings will generally be constructed conventionally with the possible exception of the Urubamba and Apurimac Rivers, which may involve construction via guided horizontal perforations. The Acocro River may require an aerial crossing. A twenty-five meter right of way will be cleared for the pipeline with the exception of a possible reduction of 15 meters as it crosses through four ecologically sensitive areas (Vol. I R, pg. 64).

The Project will also include the following infrastructure as part of the transport system:

For transporting natural gas:

2 pressure control stations at kilometer 0 and kilometer 482

1 launching scraper pig in Las Malvinas and 1 receiving pig in Lurin and intermediary scraper pigs every 140 kms.

27 regulating valves, every 35 kms.

4 feeder pipelines to provide natural gas to generate electricity for the pumping stations for the LNG at kilometers 0, 70, 173 and 199.

For transporting LNG:

1 initial pumping station at kilometer 0.

3 intermediary pumping stations at kilometers 70, 173 and 199.

2 pressure reduction stations at kilometers 421 and 482.

1 launching scraper pig in Las Malvinas and 1 receiving pig in Pampa Clarita and 7 intermediary scraper pigs.

18 regulating valves and stations, approximately every 30 kilometers.

Other related infrastructure:

A SCADA system - a centrally controlled computerized system that monitors and alerts of changes in pressure throughout the pipeline system.

11 temporary camps occupying 40,000 - 60,000 m2 each one

Construction of access roads and improvement of existing roads (the EIA does not indicate where.)

Construction of heliports (the EIA does not indicate where.)
B. BLOCK 88 - EXPLORATION, EXTRACTION AND PROCESSING OF GAS: UPSTREAM
A consortium of companies comprised of Pluspetrol (Argentina - lead operator), Hunt Oil (USA), SK CORPORATION (Korea) and Hidrocarburos Andino S.A.C (Peru), will implement the Project. After following a legal tendering process the contract was awarded to these companies by the Peruvian Government on December 9, 2000. The contract stipulates that gas should be delivered to Lima by August 2004. The Project will involve developing four drilling sites on four existing platforms (San Martin 1 & 3, Cashirairi 1 & 3 - previously constructed by Shell Int.), the construction of a natural gas separation and condensation plant (plant and related facilities will occupy 72 has.) in Malvinas, installation and operation of pipelines from the platforms to the plant (64 kms.) and a 3D seismic survey of a 800 km2 area. The Project will be located in the Peruvian Amazon, near the Camisea River approximately 20 kms. from the right bank of the Urubamba River. The area is undeveloped and is recognized for its high biodiversity. There are native inhabitants in the area - some settled and others nomadic. A brief description of each component is as follows:

3D seismic survey:
Transport for seismic surveying will be done by helicopter. A base camp (2 has.) will be temporary and will be located in Malvinas near the Urubamba River with a capacity for 100 people which will include housing, offices, workshops, generator, heliport, river port and other related facilities. According to the EIA, three sub-bases will also be constructed temporarily in the area and will each cover approximately .05 has. Roaming camps, which accommodate 20 to 40 people, will be located temporarily at the sub-bases (primarily near the platforms) and other areas as needed, throughout the forest, occupying areas of approximately .04 has per camp. Receiver lines/trails (1.5 m. width) will be opened up North to South every 300 m. and source lines/trails (1.5 m. width) will be opened up East to West every 400 m. Drilling teams of approximately 20 people will drill blasting holes (3"x 15m.) and detonate explosives along the source lines with portable equipment. Recording teams of approximately 150 to 200 people will record results along receiver lines. The survey will also include 50 speed tests, which involve drilling and blasting at 60 m. depths throughout the area. One heliport (70 m. x 50 m.) will be constructed for every 4 km2 and 2.5 drop zones (6m. x 6m.) will be cleared and constructed for every km2. All lines, heliports and roaming camps will be cleaned, restored and revegetated.

Drilling construction and operations: San Martin 1 (SM1) & 3 (SM3) and Cashirairi 1 (CR1) & 3 (CR3):
It is projected that 21 wells will be developed in both fields - San Martin and Cashirairi. Initial development will include 12 wells. 4 gas injection wells are foreseen in the two fields for re-injection of gas. The EIA deals with the development of four drilling sites (clusters) on four existing platforms: San Martin 1 & 3 and Cashirairi 1 & 3. Clearings including the platforms will cover 1 to 3 hectares - sufficient space for the platform, dwellings, sludge pits, water storage, other waste, chemical and equipment treatment areas and storage and helicopter landing and take off. Roads will be constructed for transport between wells in a given field and will not be constructed externally. Heavy transport and drilling equipment will be transported by barge and/or helicopter to the site. Chemical substances used for drilling will be packed, transported and stored in pits on site. A closed circuit system of drainage and containment will be used during drilling operations. The previous drilling campaign did not help identify the best means for treatment of sludge and different problems were encountered therefore, options must be explored further for each of the sites. The depth of the wells will vary from 100 m. to 2,800 m. with diameters varying from 8 ½" to 26".

Malvinas Gas Treatment Plant:
The Plant will be located on the right bank of the Urubamba River, approximately 50 kilometers from the production fields. The Plant will include a water compressor facility where turbo expansion will cool, condense and ultimately separate the liquid natural gas (LNG) from the natural gas. The LNG will be stored in horizontal cylindrical tanks to be transported later via pipeline to Pampas Clarita. The Plant will initially produce 11.3 MMm3 per day and 165 m3 of LNG per hour eventually to be expanded to 22.6 MMm3 per day and 330 m3 of LNG per hour. It is estimated that the power plant will produce 140,000 HP by the year 2005. The installation will also include an airstrip (1,800 m.), heliport, jetty, roads, workshops, living quarters, fuel depot, ancillary services, fire fighting system, offices and a lighting system which will occupy 72 has. It is estimated that 500 people will be involved in the construction phase and 100 in the operation phase. Equipment and construction materials will be transported in by barge and sand and rock for construction will be obtained from the riverbank. The Plant will include the following units: liquid separator, condensate stabilization, dehydration by molecular screen and glycol system, cryogenics through turbo expansion, sales and injection compression, pumping installations and storage of LNG condensate and twelve general service units (torch venting system, fire fighting system, drainage and liquid waste treatment systems, electric power generation, hot oil system, fresh water system, compressed air system, fuel/lubricant storage, chemical injection system and diesel injection system).

Map of the Project Area


System of Gas and LNG Transport:
A gas tubing system constructed of carbon steel or a corrosion resistant alloy (Cr13 carbon steel) will be constructed along a 64 km. network to transport the gas from the clusters of wells to the Plant in Malvinas and includes a re-injection system that will re-inject gas from the Plant to the fields. A continuous injection system will be used to prevent corrosion in the duct system. The design includes three lines: gas, liquid gas and re-injected gas. The height of the collection system will vary between 425 and 650 meters. The lines will go from SM3 to SM1 and from CR3 to CR1 and after running an additional 6.1 to 14.7 kms. respectively, will couple at the main line, which will run 16.3 kms. to the Malvinas Plant. The outside diameter of the tubing will vary from the initial drilling site to the second site, the second site to the main line and the mainline to the Plant accordingly: 16", 20/24", 28" for the gas tubing, 4.5", 6.625", 8.625" for the liquid gas tubing and 8.625", 10.75" to 16" for the gas re-injection tubing. Maintenance of the line will include pigging, cleaning of drip trays, removal of liquids from the drainage sump and venting strainer, maintenance of actuators and duct valves, cathotic protection system, paint and vegetation along the right of way. Intelligent pigs will be installed at pipe junctures where the width changes, scrapers will be launched periodically and blocking and retention valves will be installed. The width of the right of way will be cleared to a maximum of 25 meters and the right of way will be kept clear of vegetation and used for transport of people and equipment and construction. Depth and width of the ditches where the tubes will be buried will vary and comply with ASME B31.8 Standards.

IV. ANALYSIS AND OBSERVATIONS
A. INDIGENOUS PEOPLE LIVING IN VOLUNTARY ISOLATION

1. Introduction:

The Camisea gas development project will impact three indigenous peoples known to be living in voluntary isolation within the Nahua Kugapakori Reserve in the Camisea region. Each of these peoples has their own distinctive identity, language, culture, socio-economic practices and geographic territories. Based on documentation by the NGO CEDIA, the Pluspetrol EIA states that there are 450 Nahua and 950 Kugapakori (Nanti) in the Reserve although figures are approximations (chap 4, pg. 35).

These different peoples and family groups engage in different degrees of contact, but all chose to live in isolation. Though many Nahua and Nanti people live in stable settlements and have regular contact with health workers, missionaries and anthropologists, their status is considered to be semi-contacted, as they continue to shun generalized contact with the outside world. Moreover, they continue to subsist almost entirely from natural resources found throughout their territory, and migrate seasonally to varying degrees to access the full range of resources needed for survival. Each will be affected in varying degrees and in different ways by gas development according to their location in the Reserve. Whether semi-contacted or uncontacted, all three isolated peoples will be affected by the Camisea gas project through the depletion of the natural resource base on which they depend for survival and through other impacts explored below.

The Nahua Kugapakori Reserve, created in 1989, covers 443,000 hectares. The Reserve was created to guarantee the territory of its isolated peoples Nanti and Nahua and to protect them from outside disturbance. The specific territories of each of the groups Nanti and Nahua were not demarcated separately within the Reserve. Even so, in accordance with ILO Convention 169 and the Law of Native Communities, these groups will get their own land titles once they fulfill the following two conditions: the development of a sedentary population or a pattern of seasonal migrations.

The Nahua (also known as Yora) are hunters and gatherers who live in the headwater regions of the Mishagua and Sepahua Rivers, the Lower Urubamba basin and along some tributaries of the Manu River in the Madre de Dios basin. The need to escape diseases and slavery that accompanied the early twentieth century Peruvian rubber boom concentrated Nahua populations around these remote headwaters. Though living in voluntary isolation, competition for natural resources brought many Nahua groups into contact with other indigenous peoples, loggers, traders and oil company representatives. After contact with logging workers, who used trails established by Shell's exploration crews in 1984, 42% of the population died of introduced respiratory diseases (Shepard, 1999: 38). Researchers estimate that between 220 and 250 semi-contacted Nahua people live in a settlement at the confluence of the Mishagua and Serjali rivers. Observers disagree about the presence of Nahua beyond the settlement, though some argue that a small number live in total isolation migrating around the Serjali and Caspajali headwaters within in the Nahua Kugapakori Reserve.

The Nanti settlements in the Upper River Camisea are of the Arawakan ethno linguistic group who migrated to the area in the 1950s after community conflicts in the Timpia region. Since the late 1980s, some Nanti individuals and families have come into gradual contact with other indigenous communities such as the Machiguenga, and more recently since the arrival of oil companies in the region, with a small number of missionaries, health and education workers and social scientists. By the mid 1990's, approximately 220 Nanti people settled in two communities Malanksiá (known as Marankiato to the Machiguenga) and Montetoni. According to some observers, a larger number of up to 600 individuals of semi-nomadic Nanti live in total isolation in numerous small family groups mainly on the Timpia and Ticumpinia rivers. Some investigators estimate that the total Nanti population reaches 800.

While researchers disagree as to their number and origin, the Kirineri people are thought to live in total isolation on the upper Paquiria and Serjali rivers. (It should be noted that the term "Kirineri" is a Machiguenga misnomer meaning 'assassins' or 'savages'.) The Kirineri are not Nanti. They are often erroneously referred to as "Kugapakori" (Nanti). Limited knowledge suggests that they are a distinct Arawakan people possibly of Machiguenga origin who number around 200 individuals. There is evidence to suggest that the Kirineri have been present in the region for decades, and some individuals have had sporadic contact with Machiguenga communities. In addition, investigators speculate that there are small groups of Machiguenga and/or Nanti peoples living in total isolation in the Megantoni reserve region between the Timpía and Ticumpinia Rivers.

Camisea's semi-contacted and uncontacted peoples currently control the extent and nature of their interaction with the outside world and chose to keep contact to a minimum. The issue of control over contact is all-important. All cultures change and evolve - isolated peoples are not 'pre-modern' cultures 'frozen in time'. They are not passive 'victims' of wider forces. Able to shape their own participation in wider society and the economy, peoples in voluntary isolation actively manage the pace of change within their cultures.

While they subsist almost entirely from the forest, some Nahua and Nanti engage in the market economy by voluntarily trading forest goods to acquire medicines, outboard motors and other products. The acquisition of non-indigenous products can strengthen their social and economic position vis-à-vis the outside world and should not alone be interpreted as dissolution of 'tradition'.

However, for both semi-contacted and uncontacted peoples, when the outside world begins to intrude aggressively upon their territories and reduce their natural resource base, the pace of socio-economic and cultural change spins out of control leaving isolated peoples suffering the effects of cultural dislocation and visible social problems such as introduced illnesses and malnutrition.

It is clear that the Camisea Gas Project will bring factors into play that will set off such consequences. At the root of any analysis of the social impacts of the Project lies the question of the unequal distribution of political power and economic resources between multinational energy companies, the Peruvian government and indigenous peoples living in voluntary isolation. These peoples are excluded from the nation's political processes. State presence in their lives is non-existent. The political and economic influence of the energy companies driving the Camisea Project forward is immense.

Despite their remote location, such peoples are part of the wider political and economic dynamic that shapes the Camisea region and the Peruvian and global economies. Outsiders - missionaries, teachers, health workers- who engage with isolated peoples all too frequently seek to use them as a political football to advance their own distinctive agenda. The fundamental inequalities underlying isolated peoples' experiences of this wider dynamic are exacerbated by the presence of energy companies. When debating the price of their forest products with local mestizos, individuals from indigenous groups in initial contact are often at a disadvantage due to their lack of fluency in Spanish and inexperience with a currency based economy. Due to their lack of understanding of western concepts related to industrial development, land rights, resource rights, when debating the impacts of the Camisea Gas Project with company representatives, this power disparity is magnified.

Analysis of the social impacts of the Camisea Gas Project on peoples living in voluntary isolation contained within the Environmental Impact Assessments of both Pluspetrol Peru SA and Transportadora de Gas de Peru is grounded in this pervasive imbalance of power. Deficiencies within both EIAs in assessing and addressing the potential impacts of the upstream and downstream gas operations on the isolated peoples of the region, breaches their human and indigenous rights as laid out in international law.
2. International Legal Agreements on Indigenous Rights:

As regards the historical rights of semi-contacted and uncontacted indigenous peoples, the International Labour Organisation (ILO) has one binding instrument focusing exclusively on indigenous rights, Convention 169 of 1989 . A comprehensive and progressive draft UN Declaration on the Rights of Indigenous Peoples is presently under discussion by the UN Human Rights Commission. The draft Declaration has yet to be ratified but in summary, establishes that indigenous peoples can legally assert their rights to live according to their own cultures and maintain their ways of life; to full participation in decision-making; to free and informed consent; to apply and enforce customary law; to represent themselves through their own traditional authorities and institutions; to own, control and manage ancestral communal lands (see section B2 for further discussion of international legal recognition of indigenous rights).

However, international legislation does not address all the unique rights of semi-contacted and uncontacted peoples. In recognition of this fact, other actors have developed policies to protect the rights of uncontacted peoples, particularly in Brazil. The Brazilian government indigenous affairs agency FUNAI founded federal and state departments that focus exclusively on uncontacted peoples issues. A decade of policy analysis within FUNAI led to the adoption in the 1990s of an isolated peoples' policy grounded in the principal of 'no forced contact'. In recognition of isolated peoples wishes and as a result of a series of cases of 'forced contact' which ended in fatalities amongst isolated groups through sickness and conflict, FUNAI now actively prevents outside actors from seeking contact with semi-contacted and uncontacted peoples.

The Colombian government has also taken unique steps to protect the rights of semi-contacted and uncontacted peoples by creating permanent protection zone covering the ancestral lands of the Nukak Maku people of the Amazon Region.

Debate on semi-contacted and uncontacted peoples' rights within the Peruvian government is nascent. However, in its work to defend the rights of indigenous peoples in the Madre de Dios department, the Peruvian indigenous organization FENAMAD has developed internationally acclaimed policies on semi-contacted and uncontacted peoples' rights. (In 1997 FENAMAD was awarded the Bartolome de las Casas prize for its work with semi-contacted and uncontacted peoples threatened by oil development on their lands by the Mobil, Exxon y Elf consortium). FENAMAD bases its policy on recognition of the inalienable right of semi-contacted and uncontacted peoples to remain without contact. The fundamental right of such peoples to define and chose the terms and extent of contact is clearly established. FENAMAD advocates a policy of 'no forced contact' meaning that any contact must be initiated by such peoples. FENAMAD establishes that:

"el contacto de foráneos con estos pueblos significaría un grave atentado contra el derecho fundamental a la salud, identidad cultural, integridad moral, su libre desarrollo y bienestar, y a la posesión sobre la tierra de estos pueblos al someterlos a condiciones que afectarían sus derechos posibilitando su extinción definitiva como individuos y como pueblo indígena con una identidad cultural propia."

("contact by outsiders with these peoples would constitute a serious threat to their fundamental right to health, cultural identity, moral integrity, control over development, well-being and possession of land by subjecting them to conditions that would affect their rights and make possible their extinction as individuals and as indigenous peoples with their own cultural identity.")
3. Analysis of the Pluspetrol's Social Impact Study:

Poor Baseline Data and Methodology
World Bank Indigenous Peoples Policy (OD 4.20) specifies that adequate baseline studies must be carried out to identify key indigenous issues and concerns at the project identification stage. Baseline data of ERM's Social Impact Study (EIS) on peoples living in voluntary isolation is insufficient, partly due to weak data acquisition methodologies. There is a glaring difference between the relatively extensive quantity of data accumulated for the baseline study of main river Machiguenga communities and data on peoples living in voluntary isolation.

The study recognizes the existence of peoples living in voluntary isolation in the Camisea area. A short history of the Nanti people and some information on their natural resource use is given. Reference is made to Nahua peoples living near the mouth of the Serjali River and to "nomad groups" living both within and outside "the State Reserve for Nahua and Kugapakori" (chap 4, pg 22). Their lifestyle is briefly described as "in a state of equilibrium with their hill forest"(chap 4, pg 30).

Recognition is also given to the existence of "several nomad groups in relative isolation with little or early contact" who are assumed to be Machiguenga (chap 4, pg 21). However the short discussion of the Megantoni Sanctuary makes no reference to the isolated Machiguenga peoples who almost certainly live there (chap 4, pg 31).

To improve its data acquisition for the baseline study, Pluspetrol could have tapped into the body of knowledge about the Reserve's isolated peoples that exists amongst local experts, NGOs and social scientists. It should be noted that helicopter flights over semi-contacted and uncontacted peoples' settlements (conducted by Pluspetrol according to local witnesses) are not an accurate means of estimating population sizes or land use patterns. Furthermore, such flights have the effect of terrifying and dispersing isolated groups.

Contrary to FENAMAD's recommendations on semi-contacted and uncontacted peoples, Pluspetrol admits that company representatives entered the Nanti communities of Montetoni and Malanksiá to conduct interviews. This action clearly counters established 'no forced contact' policies for such peoples. While these two Nanti settlements have some links with outsiders through sporadic visits from health workers and social scientists, their desire to remain in isolation is evidenced by their own practice of not initiating contact except in rare cases for trade purposes. The threats that such visits pose are outlined in FENAMAD's statement above.

In addition, it appears that the interviews in the Nanti communities were conducted without a methodology to guide engagement with isolated people. No methodology is in evidence to address the potential for incomplete and flawed communication between culturally immensurable parties unequally positioned within resource hierarchies who use mutually incompatible and unintelligible socio-linguistic frameworks of reference and conceptual norms. The use of inexpert Machiguenga translators would also have contributed to flawed communication. The Machiguenga and Nanti languages are similar, but not identical. As a result, the possibility of misunderstanding is high particularly during discussion of concepts related to energy development that are alien to one or both cultures. The potential for miscommunication in such contact situations reinforces the need for a policy of 'no forced contact'.

The deficiencies in the baseline study for semi-contacted and uncontacted peoples partly explain the EIA's ensuing failure to adequately identify and mitigate project impacts on them.

Inadequate Framework for Stakeholder Consultation and Participation:
It is imperative for any energy company engaged in resource extraction to involve all affected persons and groups in all stages of the project, a principle enshrined throughout ILO Convention 169. Special attention should be given to stakeholders who are most vulnerable to project impacts. Article 7 of ILO 169 refers to indigenous peoples' rights to "participate in the formulation, implementation and evaluation of plans and programs for national and regional development which may affect them directly."

Participation should be proactive and meaningful allowing groups a genuine influence on the decision-making process. According to World Bank OD 4.20, meaningful participation demands a "mechanism" for indigenous involvement in project planning and implementation.

No evidence is given in the Social Impact Study of any participation of indigenous groups in initial contact in the Camisea gas project decision-making processes. Although visits were made to Nanti communities, no participative mechanism is identified. There is no report of the comments and opinions of the Nanti people on the project and their contribution appears not to have been integrated into any phase of project development. The lack of information about how the interviews with the Nanti were conducted implies a lack of transparency on the companies' behalf and casts further doubts over methodologies for engagement.

As forced contact is not recommended it is impossible for the semi-contacted and uncontacted peoples of the Nahua-Kugapakori Reserve to participate in any way in the formulation, implementation and evaluation of plans and programs for the Camisea Gas Project. As such, the government should protect these populations by not allowing industrial activities in the Reserve that was created to protect them from this very type of premature contact.

Deficient Assessment of Social Impacts:
The EIS for the upstream project focuses its impact assessment almost entirely on main river Machiguenga communities. Mostly impacts are assessed village by village and not generally for the culture or way of life of the lower Urubamba indigenous groups. It correctly identifies numerous damaging impacts on their lives as a result of the project including reduced game and fish supplies, contaminated water supplies, colonization, strain on inadequate local infrastructure, increased social conflict, delinquency and prostitution.

Assessment of project impacts on isolated peoples however, is incomplete. Estimated levels of influence establish in the EIA include direct, indirect and potential. The report underestimates the level of impact by stating that seismic testing will "potentially influence the Nanti Montetoni and Marankiato communities." This assessment also ignores direct and indirect impact on the nomadic populations not living in the two settlements who roam the Nahua / Kugapakori Reserve. The Reserve which includes the majority of block 88 and its nomadic populations are more likely to be directly influenced by production wells, flow lines, explosions and related seismic activities, and all air and river traffic along the Camisea river which is the principal river in the Reserve. The report states "those that can be potentially affected include...groups of native nomads within the Nahua-Kugapakori," but the nature of influence on these peoples is not stipulated (chap 4, pg 4).

Initial recognition of the "potential impacts" and "indirect impacts" on peoples in isolation is not developed as the analysis progresses. Only three project impacts on isolated indigenous peoples are contemplated:

· Brief mention is given to isolated communities in a discussion of the likely spread of timber dealers away from Sepahua into the Nahua-Kugapakori reserve. It is stated, "this could cause land conflicts in the event that timber dealers invade private lands and protected areas such as Nahua-Kugapakori Reserve" (chap 4, pg 116). The effect of the trauma of conflict on peoples is not considered.

· The likelihood of contamination of the river systems in the area resulting in reduced fish supply and increased malnutrition is considered, but no direct reference is made to the ensuing impact on semi-nomadic isolated peoples who may fish in the rivers (chap 4, pg 117).

· The study acknowledges that workers engaged in seismic prospecting activities in remote areas could come into contact with isolated peoples. It is stated that in such cases "contingency measures" must be taken (chap 4, pg 116). Pluspetrol has defined a contingency plan but lack of independent monitoring and oversight weaken the potential effectiveness of the plan. It cannot be assumed that the plan will effectively prevent harmful impacts like the spread of introduced diseases that could prove fatal for the isolated populations.

It is not clear why the more comprehensive analysis of impacts on main river Machiguenga communities was not extended to include direct and indirect impacts on indigenous peoples living in voluntary isolation. Identification of impacts on main river communities should have been amplified to include consideration of the associated effects on isolated peoples. Mounting pressures on the resource base of main river communities will force the growing main river population to seek resources found in isolated peoples' lands. Taking into account these associated affects, the Camisea Gas Project will influence the lives of the region's isolated indigenous peoples. Different groups and individuals will to varying degrees experience some or all of the following impacts that are related to their health, cultural integrity, and physical survival:

· increased presence within their lands of company workers, colonists, loggers and members of other indigenous groups possibly resulting in conflict over land and forest resources and in some cases violent conflict and even incidence of deadly assault
· poorer nutritional intake due to shrinkage of their natural resource base on which they almost wholly depend for subsistence due to the rise in local population and noise from passing helicopters and explosions for seismic testing scaring away game
· the need to acquire sources of monetary income for food and medicine possibly from greater involvement in market "cash" economy
· reduction in fauna and flora limits access to food, ceremonial and medicinal resources and building materials and work tools
· more introduced illnesses resulting in death, poorer health and increased reliance on non-traditional medicines
· poorer health due to drinking and bathing in river water contaminated by industrial waste and soil erosion
· cultural and social disintegration, depression, retreat from traditional grounds, and fear based decision making

By setting in motion these health impacts, the Camisea Gas Project violates a number of international agreements and poses a number of threats to internationally recognized indigenous rights.
B. OTHER SOCIAL IMPACTS
1. Introduction:

The Camisea Gas Project may impact the lives of approximately 7,000 people living in 42 communities in the Lower Urubamba region in addition to an estimated 500 to 1,500 indigenous people living in isolation and approximately 20,500 people living in 60 communities in the Upper Urubamba region. The potential negative impacts to indigenous people living in isolation have been discussed in the previous section. There are additional potential negative impacts that may affect all people who live within the direct and indirect areas of influence of the Project - the Urubamba River Valley.

The ERM EIA documents that there are six different ethnic groups in the Lower Urubamba area - 5 of them indigenous to the area. Of the indigenous there are approximately 4,800 of the Machiguenga group, 700 of the Yine group, 700 of the Ashininka group and between 500 and 1,500 of the groups living in isolation - the Nanti (Kugakaporis) and Nahua. There are estimated to be approximately 800 people of mestizo (mixed) origin on the Lower Urubamba. Socio-economic welfare indicators show that most people in the area live below the poverty level. The indicators show that the local population is worse off than most Latin Americans. The infant mortality rate is 126 out of 1,000. The average life expectancy is approximately 50 years of age. Thirty percent of the population above 15 years of age are illiterate. Per capita income is estimated at US $60 per year.

The indigenous population has lived in the area for thousands of years and subsist off of their natural environment - forests and their related aquatic river system, in a sustainable manner. They realize that their survival depends on the health of the ecosystems within which they live. They subsist from maintaining small-scale agriculture plots on the edge of the forest, hunting, fishing and extraction of non-timber products such as fruits and nuts and medicinal products. Like many indigenous groups they realize the importance of living in harmony with their environment and have a reverent and spiritual relationship with their natural surroundings expressed in traditional ceremonies and sustainable practices .

However, the indigenous peoples who live in settled communities also participate in the local, regional and national political system and have been influenced by people who have migrated to area - most notably missionaries, a few government service providers and mestizo agricultural settlers, oil companies, timber industry workers and traders. They interact in a market economy, which supplements the goods available from their natural environment. They are not isolated from the surrounding world yet they have managed to maintain their unique cultures and traditions. Their political influence is not as strong as most social actors in Peru and for this reason they are organized into representative organizations that advocate for their rights - COMARU and CECONAMA . Despite their efforts to organize themselves they are often at a disadvantage in representing their interests. They have lost out in the past to more powerful interests such as large companies interested in exploiting their natural resources, i.e., timber and oil extraction. Peruvian law favors hydrocarbon activities over conservation of communal lands and protected areas. It stands to reason that they are also at a disadvantage in successfully advocating for their interests with the sponsors of the Camisea Gas Project. Tactics to divide and weaken local indigenous organizations have also been used by powerful interests to weaken efforts to advocate for local rights.

The supporters of the Camisea Gas Project profess that the Project will improve the economy of Peru. It is hoped that the socio-economic well-being of the people of Peru will improve - an indirect positive impact of the income from the sale of gas products. It also stands to reason that the people who are hosting the Project on their lands should be among those who realize socio-economic benefits from the Project. They certainly should not have to bear the burden of any of the costs. Care must be taken to plan and implement the Project in a manner that does not make the local people worse off. Conserving and safeguarding the natural environment is critical for maintaining the well-being of the local people. It is also very important to respect and maintain cultural traditions as well as traditional leadership and organization that have been the key to the survival of these people over time. Social welfare indicators should improve not decline.
2. Best Practices and International Standards:

Indigenous peoples seeking to affirm their human rights have recourse to a number of widely ratified international legal instruments such as the Universal Declaration of Human Rights, the Convention on the Elimination of Racial Discrimination, the Convention on the Prevention and Punishment of the Crime of Genocide and the International Human Rights Covenants - the International Covenant of Civil and Political Rights and the International Covenant of Economic, Social and Cultural Rights - in which universal human rights are defined "without distinction as to race, sex, language or religion".

As regards their historical rights as indigenous peoples, the International Labour Organisation (ILO) has a binding instrument focusing exclusively on indigenous rights - Convention 169 of 1989. Rights laid out in the above international agreements and other rights defined through debate at the UN Working Group on Indigenous Populations have been incorporated into a draft UN Declaration on the Rights of Indigenous Peoples, which is presently under discussion by the UN Human Rights Commission. The draft Declaration has yet to be ratified, yet it is already referred to as the most comprehensive and progressive statement of indigenous rights to date. A similar declaration is also in discussion at the continental level at the Organization of American States.

International conventions and agreements on indigenous peoples in summary advocate for indigenous peoples to legally assert their rights to live according to their own cultures and maintain their ways of life; to full participation in decision-making; to free and informed consent; to apply and enforce customary law; to represent themselves through own traditional authorities and institutions; to own, control and manage ancestral communal lands. World Bank Operational Directive 4.20 (WB O.D. 4.20) basically enforces the implementation of these principles in World Bank funded projects. The international conventions sited and the World Bank's policy for indigenous peoples (O.P. 4.20) would apply to the majority of the people who live in the area.

These conventions and standards imply that developers should respect the rights of indigenous peoples to maintain their traditions, cultures, and traditional decision-making and organizational structures. The project developers are obliged to fully inform local indigenous people of any potential short or long-term, direct or indirect impacts that might affect them in any way. Once the local groups are fully informed they have the right to participate in decisions regarding the Project that might affect them. WB O.D. 4.20 goes a step further to require the preparation and implementation of indigenous peoples development plans (IPDP) to address any adverse impacts and help ensure that indigenous peoples benefit from the project. Such plans usually include legal establishment of land rights where traditional access to natural resources may be at risk and economic and social development activities to ensure that local peoples are benefited and not harmed by the project.

Although local consultations were held with the local communities as part of the EIA process the local indigenous groups do not feel as though they have been informed adequately regarding the Project. They also don't feel as though they have been involved in decision-making over issues that might affect them. These opinions were expressed to the Independent Assessment Coordinator when she visited Peru in February and met with a number of stakeholders - local communities and non-governmental organizations. The period for review and public comment on the thousands of pages of the EIAs was not sufficient. COMARU received the full Pluspetrol EIA documents on November 17th, 2001 an

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