Position of the Mexican Center for Environmental Law regarding the Mayan Train Project

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At the Mexican Center for Environmental Law, AC we promote as a fundamental objective the promotion and defense of the Right to a Healthy Environment in Mexico, through the strengthening, consolidation, harmonization, application and effective compliance of the current legal-environmental system.

CONTEXT

In Mexico, there is a generalized situation of violence, impunity, and corruption that generates and perpetuates a series of violations of various human rights of people and communities in the country.

These violations are usually circumscribed within the framework of the development of megaprojects, largely due to the existence of an economic and social policy that lacks a perspective of sustainability and biocultural relevance, which translates into excessive consumption of natural resources, which causes the destruction of natural capital, deforestation, soil erosion, desertification, as well as water and air pollution. It is possible to say that megaprojects or “large development projects” represent investment processes of public and/or private capital, national or international, for the creation or improvement of physical infrastructure and that it implies the long-term transformation of activities production, changes in land use and property rights.

In Mexico, many of these megaprojects are planned, approved and located in rural areas where there is a significant part of the country’s biocultural heritage and where indigenous and peasant communities live. Due to the prevailing economic and social policy, various violations of collective human rights are being generated, since human rights such as autonomy, territory, traditional access to natural resources, a healthy environment are not respected or guaranteed. , as well as access to information, consultation and other related rights. It is important to highlight that, many times, the socio-environmental impacts of a megaproject are not evaluated in a comprehensive and effective manner; the information on which the State evaluates the impacts is deficient and partial,

In addition to the above, the lack of effective actions by the State to ensure the compatibility of development projects with the affected populations increases the level of conflict in relation to megaprojects, causing serious social problems such as violence and legal insecurity. , promoting attacks on environmental human rights defenders. 

PROBLEM: THE MAYAN TRAIN PROJECT

Since December 2018, the development plan called “Mayan Train” was announced, which proposes the construction of road and rail infrastructure as the engine of real estate, commercial and tourist development in the Yucatan Peninsula. The project includes, among others, 1,460 kilometers of the medium-speed railway (its maximum speed will be 160 km/h for passengers and 120 km/h for freight), several railway stations, road infrastructure, aqueducts and new population centers and development poles. The project covers more than 50 municipalities and 5 states in the southeast of the Mexican Republic (Chiapas, Tabasco, Yucatán, Campeche, and Quintana Roo) [1], where various indigenous and peasant populations currently live, in addition to being one of the most biodiverse areas in the world. The railway will cross the Mayan jungle -the second largest forest lung in Latin America after the Amazon-, fragmenting it and causing irreversible impacts on vegetation, soil, water, and biodiversity.

The Mayan Train project was not decided by the Mayan people, nor by any other Mexican indigenous people, but the name seeks to appropriate the indigenous cultural denomination of the Mayan people, with the purpose of making it friendlier. It is included in the National Development Plan (PND) [2] , where it is mentioned that it is a project aimed at increasing the economic benefit of tourism in the Yucatan Peninsula, creating jobs, promoting sustainable development, protecting the environment from area by discouraging activities such as illegal logging and species trafficking, and promoting land use planning in the region. However, there is little official information available so far (May 2020), and neither the Executive Project has been made public [3]nor the Declaration of Environmental Impact [4] . On the official website of the Mayan Train [5] it is stated that it will have a total length of 1,460 km with 18 stations and it is expected that the route will be divided into seven sections [6] , but the final line of the railway is unknown, as well as the exact number of stations or new development areas to be built. The project intends to take advantage of the existing railway infrastructure in some of the states, using the right of way of the railway. For the rest of the route -68% of the project-, the right of way has to be managed [7] . Likewise, the urbanization of many regions of the Yucatan peninsula is proposed, linked to the development that, it is hoped, the Mayan Train will create.

On November 15, 2019 [8]began an indigenous consultation process that was carried out simultaneously in various municipalities of the Mexican southeast, with an informative session and another deliberative session, where authorities and people from indigenous communities participated. However, the “indigenous consultation” on the Mayan Train was not convened with the purpose of obtaining the consent of the indigenous peoples and communities, as established in Convention 169 of the International Labor Organization, it was not prior, culturally appropriate, informed, not in good faith. In this regard, the Office in Mexico of the United Nations High Commissioner for Human Rights has described the Mayan Train indigenous consultation process as negative, considering that it did not comply with all the international standards ratified by Mexico on the matter [9] .

Given this situation, several members of the peninsular Mayan and Ch’ol people filed an amparo claim with the Judiciary, achieving the suspension of the project in the territory of the municipality of Calakmul, Campeche. In response, the Mexican state has stigmatized and criticized defenders and has refused to abide by the judicial suspension.

In the spring of 2020, in the context of the SARS-CoV2 pandemic, the works related to the Mayan Train were included among the essential activities that may continue despite the measures adopted by the Ministry of Health [10] .

Tren Maya project suddenly stopped in its tracks by judge

Environmental risks and impacts

The Mayan Train project and related works involve numerous risks and environmental impacts throughout the Mexican southeast, an area of ​​high biological wealth and importance for the conservation and protection of the Mayan jungle, the aquifer and biodiversity. Although the lack of certainty about the final outline of the project prevents identifying the specific impacts that could be caused to the habitat and to the terrestrial and coastal ecosystems, it is possible to identify that the Mayan Train and related works will cause various environmental risks and impacts. The National Council for Science and Technology (Conacyt) has warned that the project will impact various municipalities in Chiapas and Tabasco, the high jungles, the swamps and savannahs; in the Yucatan Peninsula it will impact the largest forest massifs and in the best state of conservation in Mexico and Mesoamerica, areas with mangroves and other wetlands. These ecosystems will suffer alterations (degradation, fragmentation and deforestation) associated with the construction, circulation and development proposed by the Mayan Train project.[11] . In the opinion of CEMDA, these are the main risks and environmental impacts associated with the Mayan Train project and related works:

Fragmentation of the territory [12] : the terrestrial ecosystems of the Yucatan Peninsula will be broken and divided. The Mayan Train project will affect [13] 23 Protected Natural Areas (including the Sian Kaan and Calakmul Biosphere Reserves), 7 Priority Terrestrial Regions, 11 Priority Hydrological Regions and 10 Important Bird Conservation Areas [14]. The proposed works will increase the fragmentation and loss of ecological connectivity between the conservation areas, favoring the reduction of forest cover, the isolation of populations of flora and fauna, the interruption of biological corridors, the change of microclimates, the transformation habitat and species extinction. The fragmentation of ecosystems can occur to such a degree that it could turn them into biologically degraded and inhospitable areas [15] .

Depletion and contamination of the aquifer in the Yucatan Peninsula [16] : the only source of water supply for all uses in the Yucatan Peninsula is groundwater from the aquifer [17] . For example, the areas near the city of Campeche and the town of Champotón, also located in that entity, are already without water availability [18] . The project will affect various bodies of surface water, including perennial and intermittent lagoons, flood zones, aguadas, jaguey, temporary runoff and wetlands, especially in the municipalities of Benito Juárez, Tulum, Felipe Carrillo Puerto, Pedro Antonio Santos, Bacalar and Othón P. Blanco from the state of Quintana Roo; Calakmul from the state of Campeche[19] . Conacyt has determined that the Mayan Train will have a negative impact on the environmental services provided by the ecosystems that will be affected, particularly in the ring of cenotes named in 2013 as a Geohydrogeological Reserve and in the jungles of the Calakmul region, where the waters harvested are transported and accumulated to, at some point, flow towards the main coastal systems of the Yucatan Peninsula [20] . Likewise, tourist activities and new urban centers will bring with them an increase in population. This will cause an increase in the generation of waste, [21]as well as contamination that will filter into the aquifer, due to the type of karstic soil, its high permeability, the absence of a porous medium that serves as filter material, as well as the shallow depth of the groundwater level [22] . All the water that rains on the Yucatan Peninsula infiltrates into the subsoil [23] , facilitating the access of contaminants to the cenotes, with a rapid spread in the aquifer and serious risks to human health [24] .

Deforestation : The impact of the project on the existing forest cover in the Yucatan Peninsula is large. According to Series VI of land use and vegetation coverage, published by INEGI (2018), 71% (2,578 ha) of the area that will be devastated corresponds to humid and dry forests [25] . In particular, the project crosses areas of great importance for the conservation of the forest such as the Calakmul region [26]. Likewise, the construction of road infrastructure, railway stations and development poles will increase agricultural activities, human settlements and tourist activities, and therefore will accelerate the change in land use throughout the Yucatan Peninsula, affecting coverage forest. Conacyt has indicated that, with the Mayan Train development project, the capacity of these forest ecosystems to capture, through photosynthesis, atmospheric carbon dioxide will also be affected; that is, to act as carbon sinks [27] .

Extinction of flora and fauna : the project will impact the area where various species are housed, such as ramón tree, cedar, ciricote, mangrove species, palm species; jaguar, ocelot, tapir, howler monkey, spider monkey, turtle species, opossum, cacomixtle, raccoon, puma, crocodile, snake species, bat species, iguana species, macaw, flamingo, quetzal, toucan, wide variety of birds residents and migrants, among many others, that are listed as threatened, subject to special protection or in danger of extinction or that have special protection by various regulations [28] . In particular, the serious impacts to biodiversity in the Calakmul area that the project will cause have been pointed out [29].. Likewise, among the most common effects of the railway infrastructure are the running over of fauna and the barrier effect, for which the ecosystems lose connectivity [30] . In particular, the project could interrupt the connectivity of the aquifer, putting the mangroves of the Yucatan Peninsula at serious risk, a species that enjoys special protection in the Mexican legal system [31] .

Waste generation : the Yucatan Peninsula does not have a capillary waste collection system, but in many municipalities the inhabitants burn the waste in the open air. Likewise, it does not have an efficient and functioning sewage system in all the municipalities, with wastewater discharges being one of the main problems of groundwater contamination in the Yucatan Peninsula [32] . The Mayan Train and the related works will not only produce waste in its construction, but in its operation they intend to displace millions of tourists and thousands of other people as workers to the Yucatan Peninsula [33] , with which the production of waste will be increased. and the fragility of municipal systems will be exacerbated.

Noise generation : the Mayan Train and related works will generate an increase in noise in various municipalities of the Yucatan Peninsula. The Mexican State does not have information related to the noise that the project will cause and the measures taken to mitigate it, both in its construction and in its operation [34] . The noise from the project can affect human health and cause severe impacts to humans [35] . Likewise, it can seriously affect the El Volcán de los Murciélagos cave, (located within the Balam-kú State Reserve), one of the largest colonies of bats that exist in southeastern Mexico [36] .

Social risks and impacts

The Mayan Train will cause various social impacts, since it is a development proposal that is diverse from the culture of the indigenous, peasant, and fishing communities that are found there, in addition to exacerbating inequality and marginalization between the people who travel and the inhabitants who offer services. . Just over half (53%) of the Mayan Train route is located on communal land, affecting a total of 177 communal lands [37] .

Adequate and reliable information about the project has not been offered and real and effective participation in decision-making has not been allowed [38] and there is already a deterioration in the social fabric and community division between those who approve and those who reject it. the project. The free, prior and informed consent of indigenous communities has not been obtained [39] .

Likewise, in other projects with a massive tourism industry development scheme, the dispossession of lands and cultural traditions has been observed, as well as the commercialization of cultures, sacred sites, knowledge and ancestral memories and products. crafts, in addition to the grabbing of territories and indigenous and peasant lands. This urbanization implies, among other things, the increase in the price of land, the inflation of the costs of goods in general, the decrease in agricultural and traditional productive activities, as well as the denigration of peasant work [40] .

In the case of the Mayan Train, it has been proposed that the people who have properties on the project area can participate in the Mayan Train trust, contributing their land as an endowment, as material and financial support. This implies that the land becomes property of the trust and the farmers participate among the partners, being able to access benefits if the project is successful [41] .

The project also puts at risk the traditional management of water that indigenous peoples have done in the Yucatan Peninsula. The main indigenous settlements are in the states of Yucatán and Campeche, in areas that generally lack piped drinking water and drainage services. The main source of water supply in the region is groundwater. However, given the government’s failure to provide wells and pumps to extract it, the option to obtain supplies has been the collection of rainwater and its storage in pots, tanks, cisterns, jahueyes, among others [42] .

In addition to the aforementioned, the Mayan Train will cause population displacement in towns and cities. Many self-described indigenous people live in the vicinity of train tracks that were built decades ago, but were not consulted or consented to relocation.

El medio ambiente no es prioridad para AMLO; organismos tienen recortes de  37% (Forbes México) – Agua.org.mx

POSITION  OF CEMDA REGARDING THE MAYAN TRAIN

  1. The Mayan Train project violates human rights and does not contribute to promoting the conservation of biocultural heritage.

Despite the fact that the right to a healthy environment and to water are established in article 4 of the Constitution, the “Maya Train” development plan does not comply with its provisions, since it poses many risks and environmental and social impacts, without until now having the information to qualify it as a project that contributes to the sustainable development of the country. Likewise, the right of indigenous peoples and communities to autonomy and self-determination as a human right recognized in the Constitution and in several international instruments ratified by Mexico has not been respected, since the project was not decided by them. By not having sufficient information to guarantee the respect, protection and prevention of environmental risks and impacts and on human rights,

  1. The Mayan Train project must guarantee the publicity of all information on environmental and social risks and impacts, early and effective participation must be guaranteed, access to justice and the protection of environmental defenders must be facilitated and guaranteed.

Despite the fact that Mexico has signed the Rio Declaration of 1992 and has just signed the Escazú Agreement on access rights in environmental matters, not all the information related to the project has been published, an effective participation process has not been carried out, nor has access to justice been facilitated, nor has effective protection been guaranteed for defenders. It is necessary that the pertinent studies and evaluations be generated to determine if the economic, social, environmental and development feasibility of the project exists, and that said information be made available to society in general; particularly to potentially affected communities, as well as academics, civil society and stakeholders. All this with the aim of establishing a dialogue on the relevance, best practices and guaranteeing effective access to information and participation in decision-making. Likewise, it is essential to ensure access to justice for those people, communities and/or organizations that want to claim the violation of their human rights, especially in times of health emergency. Finally, the authorities of the Mexican State must refrain from carrying out any attack and aggression against environmental defenders. environmental legality The authorities of the Mexican State must refrain from carrying out any attack and aggression against environmental defenders. environmental legality The authorities of the Mexican State must refrain from carrying out any attack and aggression against environmental defenders. environmental legality

  1. No development project can be exempt from complying with environmental sustainability.

The Mayan Train project and related works imply numerous and serious risks and environmental impacts to the entire Mexican Southeast, an area of ​​high biological wealth and importance for the conservation and protection of the Selva Maya, the aquifer and biodiversity. There is a strong risk of causing the fragmentation of ecosystems, contamination of the aquifer, the extinction of species, the constant deforestation of the Selva Maya, the generation of noise and waste. The Mayan Train project must have an Environmental Impact Statement and the respective Environmental Impact Authorization (AIA), in the terms established by the General Law of Ecological Balance and Environmental Protection (LGEEPA) and its Regulations. in terms of Environmental Impact, since it is a communication route, railway infrastructure, of real estate and tourism developments that affect coastal areas and are works and activities that take place within Natural Protected Areas. As it is a development project, it must be evaluated in its entirety, so that, in this way, the identification, description and evaluation of environmental, cumulative and residual impacts are ensured. In addition to the above, the project must comply with all applicable environmental legislation, since this represents the minimum sphere of established protection of the environment. The Mexican State, for no reason can reduce the scope of protection of environmental legislation (Art. 1114 of the Free Trade Agreement between Mexico, Canada and the United States). In addition,

  1. No development project can be exempt from complying with social sustainability.

The Mayan Train project is not socially sustainable since it generates and will generate multiple social impacts, modifying the existing culture and putting at risk the cultural survival of the indigenous communities that live there. Likewise, in order to displace indigenous people, it is necessary to obtain their prior and informed consent. In addition to the above, the project must comply with all applicable legislation, in particular with international standards regarding indigenous rights, displaced persons and cultural rights.

  1. The Mayan Train project must not put the legally protected environment in Mexico at risk.

Any work or activity that intends to be carried out in Protected Natural Areas (ANP) must be in accordance with the Decree creating them, as well as with the corresponding Management Program. The Mayan Train plans to pass through the Calakmul and Balam-Ku Biosphere Reserves, as well as the Cenotes Ring geohydrological region in Yucatan and very close to the limits of the Sian Ka’an, Mexican Caribbean and Los Angeles Biosphere Reserves. Petenes, in addition to important areas such as: the priority area of ​​the National Commission for the Knowledge and Use of Biodiversity (Conabio) of Balankan; the Lagunar Catazajá system and the La Libertad Wetlands; therefore, it is essential that the project fully comply with the provisions of the protection instruments. What’s more,

  1. In the design and construction of the Mayan Train development project, the rule of law, peace and freedom must be guaranteed at all times.

When the development, implementation and construction of a project is done in strict compliance with the constitutional framework of human rights, national legislation, international standards and good practices, it is unnecessary to include the use of public forces and armed forces in construction of an infrastructure project. Likewise, at all times there must be access to justice, understood as the generation of spaces for dialogue, free exchange of ideas and the possibility of accessing administrative and jurisdictional institutions without reprisals or aggression. In the event that a community, group of people or any individual expresses their will against a project,

[1] Information on the official website of the Mayan Train. Available at: http://www.trenmaya.gob.mx/

[2] Presidency of the Republic, National Development Plan, July 2019

[3] Response from the National Fund for the Promotion of Tourism to a request for information 2137200017419.

[4] Response from the Ministry of the Environment and Natural Resources to a request for information 0001600426419.

[5] Information on the official website of the Mayan Train. Available at: http://www.trenmaya.gob.mx/

[6] Section Selva 1. (237 km approx.); Jungle Section 2 (257 km approx.); Caribe Section 1 (237 km approx.); Caribbean Section 2 (120 km approx.); Gulf 1 section (253 km approx.); Gulf Section 2 (170 km approx.) and Gulf Section 3 (186 km approx.)

[7] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[8] “Call for the Indigenous Consultation process and Participatory Citizen Exercise Day on the Mayan Train Development Project,” published in the Official Gazette of the Federation on November 15, 2019.

[9] Press Release from the Office in Mexico of the United Nations High Commissioner for Human Rights “The indigenous consultation process on the Mayan Train has not complied with all international human rights standards on the matter: UN-DH ”, December 19, 2019.

[10] General Health Council, Agreement declaring a health emergency due to force majeure, the epidemic of disease caused by the SARS-CoV2 virus, March 30, 2020. General Health Council, Related Technical Guidelines with the activities described in subparagraphs c) and e) of section II of the first article, of the Agreement establishing extraordinary actions to attend to the health emergency generated by the SARS-CoV2 virus, April 6, 2020.

[11] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[12] Fragmentation is the loss of continuity of an ecosystem, and produces important changes in the structure of populations and communities of plants and animals, both in the physical and ecological environment, which affects their functioning.

[13] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[14] These environmental conservation instruments, in addition to being provided for in the Mexican legal system, show areas that have been detected as being of great importance for the conservation of biodiversity due to their physical and biotic characteristics.

[15] Navarro Rodríguez and others, Fragmentation and its implications Analysis and documentary reflection, University of Guadalajara, 2015

[16] The Yucatan Aquifer covers an area of ​​124,409 square kilometers, fully comprising the State of Yucatan and almost all of the states of Campeche and Quintana Roo; It has an extremely important ecological function, since it is an interconnecting system for inland recharge areas (forest, wetlands and marine areas -Mesoamerican reef-) and it is extremely vulnerable to contamination, due to its great connectivity (AGREEMENT by which to know the technical studies of national groundwater of the Yucatan Peninsula aquifer, code 3105, states of Yucatan, Campeche and Quintana Roo, Official Gazette of the Federation, September 4, 2013).

[17] Ministry of Environment and Natural Resources, AGREEMENT by which the technical studies of national groundwater of the Yucatan Peninsula aquifer, code 3105, states of Yucatan, Campeche and Quintana Roo are disclosed (DOF September 04, 2013 )

[18] National Water Commission, Water Statistics in Mexico 2018.

[19] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[20] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[twenty-one]Both SEMARNAT and CONAGUA agree that the main source of groundwater contamination is the lack of sanitary sewage systems, as well as the low efficiencies of current treatment plants, reporting information obtained from the Ministry of Health, where the state Yucatan has the highest incidence of gastrointestinal diseases nationwide, while the states of Campeche and Quintana Roo report incidence rates higher than the national average; parasitic diseases being the main public health problem of water origin, due to high levels of bacterial contamination, which coincides with the reported water quality results where points are shown that exceed the parameters BOD5, COD, TSS, CF, among others.

[22] Ministry of the Environment and Natural Resources, Challenges for territorial planning in karstic sites, November 2009

[23] Ministry of Environment and Natural Resources, AGREEMENT by which the technical studies of national groundwater of the Yucatan Peninsula aquifer, code 3105, states of Yucatan, Campeche and Quintana Roo are disclosed (DOF September 04, 2013 )

[24] In the municipality of Calakmul, the construction of a Mayan Train station is proposed, which will imply an increase in the population and subsequently in waste and surface contamination. However, the Xpujil area functions as an aquifer recharge zone (Determination of the availability of water in the Calakmul Aquifer, State of Campeche), and does not have a drainage system (Mexican Center for Environmental Law AC, Participatory Diagnosis of community needs in environmental matters in the context of megaprojects in the municipality of Calakmul, Campeche), for which it is more likely that contamination infiltrates the aquifer in this area.

[25] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[26] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[27] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[28] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[29] Benítez et al., Impact of the Railroad and Tourism Growth Associated with the Mayan Train; mitigation measures and design changes for the Calakmul and Balam-kú reserves, 2019

[30] Benítez et al., Impact of the Railroad and Tourism Growth Associated with the Mayan Train; mitigation measures and design changes for the Calakmul and Balam-kú reserves, 2019

[31] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[32] Mexican Institute of Water Technology, Master Plan on water for the protection, conservation and environmental recovery of the Yucatan Peninsula, 2011

[33] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[34] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[35] Government of the State of Mexico, Health effects due to noise

[36] Benítez et al., Impact of the Railroad and Tourism Growth Associated with the Mayan Train; mitigation measures and design changes for the Calakmul and Balam-kú reserves, 2019

[37] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[38] Press Release from the Office in Mexico of the United Nations High Commissioner for Human Rights “The indigenous consultation process on the Mayan Train has not complied with all international human rights standards on the matter: UN-DH ”, December 19, 2019.

[39] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[40] Information contained in the documentation process of the Mayan Train Megaproject in the Yucatan Peninsula carried out between January and November 2019 by the Mexican Center for Environmental Law AC

[41] National Council for Science and Technology, Mayan Territories in the Passage of the Train: Current Situation and Foreseeable Risks, December 2019.

[42] Mexican Center for Environmental Law AC, Participatory diagnosis of community needs in environmental matters in the context of megaprojects in the municipality of Calakmul, Campeche.

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