State specialist services massively criticise Dominga project (1)

Santiago, Landau 3rd January 2023. Environment, Health, Undersecretariat of Fisheries, CONAF, Directorate General of Water and the Agriculture and Livestock Service have now outlined their concerns about the mining and port project.The comments are necessary for the Committee of Ministers to vote on whether to approve or reject Andes Iron's plans.

"This Secretariat of State suggests an unfavourable environmental assessment of the Dominga project", "it is clear that it does not comply with current environmental regulations", "there was no proper definition of the scope of impact throughout the process, thus scientific reasoning was prevented", are some of the conclusions of various state services that submitted their comments to the Committee of Ministers. This body has to decide on the future of the port and mining project of the Andes Iron company.

The opinions now published on the internet form the basis for the decision of the Ministers of Environment, Agriculture, Economy, Energy, Mining and Health (Committee of Ministers). The date for the decision has not yet been set.

The Subsecretaría del Medio Ambiente (Regional Ministry of the Environment) points out that the Andes Iron company has not included in its designated impact area areas where emblematic species of the (Humboldt) Archipelago such as the Humboldt Penguin, the Garnot Petrel and the Sea Otter live. Therefore, "it cannot be ruled out that the project will have a significant impact on the ecosystem.". Furthermore, the Subsecretaría of the Medio Ambiente warns of insufficient baseline data, especially in relation to cetaceans, and concludes that the mitigation, compensation and reparation measures for the protected marine fauna affected by the project are insufficient.

CONAF again criticised the company for not adequately defining the project's scope, for not taking into account scientific evidence and for not conducting a baseline survey of protected species in the Humboldt Penguin National Conservation Area. "Science has clearly demonstrated that the entire bay of the (Humboldt) Archipelago, where the port is planned, is an important feeding, resting and breeding ground for bird species that nest in the Humboldt Penguin National Sanctuary and on the islands of the archipelago," argued the authority, which is also responsible for the protection and management of the national sanctuary. It also warns of impacts from underwater noise and light pollution that could lead to the extinction of the Yunco (Garnot Petrel - Pelecanoides garnotii) in the short term. The Yunco uses the area for breeding.

The Undersecretariat for Fisheries and Aquaculture (Subpesca) noted that the information provided by the company was „neither sufficient nor adequate“ to capture the impact of the project on low-mobility species of tidal and subtidal communities (2). This is especially true for sensitive species on which coastal communities are particularly dependent. The Undersecretariat further notes that after the environmental impact assessment, Andes Iron proposed some mitigation measures for desalination plants that Subpesca could not evaluate. This is especially true for the benthic (3) resources of the (management) area, which are of great importance to artisanal fishers.

For its part, Servicio Agrícola y Ganadero-SAG (Agriculture and Livestock Service) questioned several aspects of the project: first and foremost, the insufficiently defined impact area and the failure to assess the synergistic and cumulative effect with the Cruz Grande project and its impact on marine fauna. Secondly, the insufficient database from "only two-day observations" in winter, without providing technical justification that "the intensity and timing of the observation are appropriate". Furthermore, the SAG calls the measure to mitigate the effects of oil spills on fauna "insufficient".

The Directorate General of Water (DGA) criticised the intervention in Los Choros groundwater flows and expressed concern about serious deficiencies in the Andes Iron submitted information. The deficiencies prevent the Directorate-General from ensuring that all significant adverse impacts have been correctly identified in terms of the protection of groundwater flows affected by the project. In comments, citizens expressed great concern about the stability, availability and quality of water from the Los Choros groundwater stream, which provides various ecosystem services. This includes the irrigation of the valley and the use of the groundwater flow for local agriculture.

The Ministry of Health expressed concerns about the assessment of the impact of particulate matter and gases that would be generated by works and activities under the initiative. The Ministry of Health expressed concerns about the assessment of the impact of particulate matter and gases that would be generated by works and activities under the initiative. However, the Secretary of State for Health points out that the standard used in the environmental impact assessment of the project in 2013 is no longer in force and has been replaced by a more demanding standard from 2021. 

The published reports are available to the ministers, the only thing missing is a statement from the Ministry of Energy.

It is worth recalling that the Dominga mining and harbour project was rejected in 2017 both at the regional level and by the Committee of Ministers during the government of President Michelle Bachelet. However, Andes Iron decided to appeal against this decision. After two instances, before the Environmental Court and the Supreme Court, the Corte Suprema has referred the decision to the Committee of Ministers, which will soon have to vote on whether to confirm or reject the Dominga project.

Translation G. & W.K.


(1) The article "Servicios técnicos emiten duros informes contrarios al proyecto Dominga" from the internet newspaper El Mostrador of 30 December 2022 quotes numerous points of criticism from the specialised services. The article does not, however, discuss the contradictory nature of various opinions. For example, the Subsecretaría del Medio Ambiente (regional environment ministry) uncritically adopts the narrative of the creation of numerous jobs. In reality, it has been repeatedly proven that the balance is negative. In the long term, more jobs will be lost through the Dominga project in fisheries and tourism, among others, than new ones will be created.

(2) Depth zone of the oceans from the lower limit of the intertidal zone (intertidal) to the shelf edge in about 200 m water depth.

(3) all life forms that settle in and on the sediment or bedrock of water bodies.

Translated by Claudia Wirth




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