HidroAysén's Severely Flawed Environmental Study

In late August 2008, the Chilean-European company--HidroAysén--planning to dam Chile’s Baker and Pascua rivers submitted an environmental study (EIA) for review by Chilean public services.  Thirty-two public services participated in this review, which identified more than 3,000 problems with the EIA.  Here is a summary of the most glaring deficiencies found in the EIA by Chile’s public services:

MAPPING DEFICIENT.   The EIA contains insufficient mapping to show precisely where the project works, including reservoirs to be created by each dam, would be located.

REQUIRED FLOODING LEVELS NOT PROVIDED.  The EIA failed to specify the minimum and maximum flooding levels expected from each proposed dam's reservoir.  This basic information is required for testing the accuracy of the company's own estimates for the area that would be flooded by its project.

IMPACTS ON PRODUCTIVE SOILS IGNORED.  The company’s EIA included no studies on productive soils and no mapping to identify productive soils in areas that would be impacted by the project. These omissions left Chilean public services with two significant problems.  First, without a soils study or sufficiently detailed mapping, no evaluation of the project's potential impacts on productive soils was possible.  Second, productivity of soils in the impacted areas could not be compared with productivity of soils in areas to which displaced persons would be relocated.  This difference in soil productivity would be one very important part of the project's impact on Aysen residents who are in the way of the project.  Most of them earn their living off the land.

SEISMIC RISKS IGNORED.  Chile is one of the most seismically active countries in the world.  The region in which the project would be located, Aysen, has recently experienced damaging seismic events.  Despite the existence of numerous fault lines and other unstable geology in the region, the EIA did not even attempt to describe potential seismic risks that could lead to catastrophic loss of life in the areas where the dams and related structures would be located.

HYDROLOGICAL RISKS IGNORED, e.g. GLOFs (Glacial Lake Outburst Floods) and LANDSLIDES.  A GLOF results in a sudden and potentially catastrophic release of accumulated melt water from one or more glaciers.  GLOFs and landslides are hydrological risk events that could create dam breaching or overtopping events that would endanger downstream communities and ecosystems and threaten the viability of the project. The HidroAysen EIA included no analysis or information on possible GLOF or landslide risks. Ignoring these risks could lead to catastrophic loss of human life.  For example, in 1963, a landslide event led to a catastrophic failure of the Vaiont dam and killed thousands of people in an alpine valley of northern Italy. The geo-hydrological conditions that led to the Vaiont dam failure are very similar to those that exist in the areas where HidroAysen has proposed to dam the Baker and Pascua rivers.

SOCIAL IMPACTS IGNORED OR UNDERESTIMATED.  

• The EIA contains no information on relocation of people, even though the project would undoubtedly require these relocations.  
• The project would require construction over a period of at least twelve years and a temporary worker population that would exceed 5,000 at its peak.  Nevertheless, the EIA description of worker camps is superficial. The study neither identifies the potential impacts of these worker camps, nor does it describe a commitment or plan to mitigate whatever these impacts would be.
• The potential for dramatic increases in vehicular traffic, including extremely large and heavy vehicles and machinery, is completely ignored in the EIA.
• Impacts from transportation of material, fuel and hazardous waste required by the project are not addressed.
• The EIA consistently underestimates its area of influence.  For example, it fails to include all the territory that would be impacted in the Provinces of Capitán Prat and General Carrera.  The EIA does not describe impacts that would be specific to communities such as Villa O'Higgins and Caleta Tortel.  The potential for a dramatic increase in demand for education and other public services is ignored.
• The project would require new coastal port facilities, plus new roads and the expansion of existing roads, and the project would lead to a dramatic increase in demands on existing airport facilities.  These public works impacts of the project are ignored in the EIA.

PROTECTED AREAS LAWS VIOLATED.  This was either obvious from the EIA (admitted potential flooding in San Rafael National Park) or the potential for violation was not addressed as required (in the case of Bernardo O'Higgins and Lago Cochrane protected areas).  It is improper under Chilean law for an EIA to propose plans that would violate the law or to ignore the clear potential that these plans would violate Chilean law.

IMPACTS ON ON FAUNA and FLORA IGNORED.   The EIA was either grossly negligent or intentionally uninformative in these areas.  For example, estimates for terrestrial wildlife numbers were based upon only 23 days of fieldwork performed exclusively in the area's best weather for humans.  This is a woefully inadequate number of observation days in unrepresentative conditions in only two consecutive years.  Further, techniques for detecting hard-to-observe wildlife (e.g., the critically endangered huemul deer), such as aerial reconnaissance, were not used.  Because of insufficient fieldwork, many wildlife estimates in the EIA are not even close to being scientifically valid.  And the EIA was even worse on potential impacts for flora.  The EIA presented no overall analysis of all the factors determining the presence of vegetation in a given zone, and the study did not even attempt to identify potential linkages between flora of the zone and project activities.   The EIA did not even present one simple chart of vegetation in the zone that could have been used by the public services on their own to assess possible impacts on flora.

IMPACTS ON TOURISM and TOURISM IMAGE OF THE REGION IGNORED. Even though it is clear to SERNATUR, Chile's tourism agency, that the project's damage to the region's image for tourism would be considerable, the company’s EIA states explicitly that it will not address potential impacts on the region's image for tourism. Further, the EIA presents no landscape details on the basis of which a public service might on its own estimate possibly specific examples of impacts on tourism and the region's image for tourism.  Though the region is known to be attractive for 'adventure tourism' (e.g., kayaking, rafting, trekking), the EIA does not even mention it.  Sport fishing is also a known tourist attraction of the region, but the EIA does not address how much potential for this kind of fishing would still exist after the wild, scenic and free-flowing river that attracts this kind of fishing is transformed by the proposed dams into a series of lakes.  Finally, the EIA presents no data or analysis on how much tourism income each of the region's communities receives, or on how much each community has invested in attracting and serving tourism.