ON BACALAR'S DEFENSE. COLLOQUIAL VERSION

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ON BACALAR'S DEFENSE VOLUME I. THE NEOLIBERAL ENVIRONMENTALISM TRIAD, HOW DO THEY GANG UP? Colloquial version María Luisa Villarreal Sonora

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VOLUME I. THE NEOLIBERAL ENVIRONMENTALISM TRIAD, HOW DO THEY GANG UP? Narrated version

1st Edition Independently published

All rights reserved © 2021 María Luisa Villarreal Sonora maria.luisa.villarreal.sonora@gmail.com Cover and image desig, translation: María Luisa Villarreal Sonora

This book can’t be reproduced partially or totally by printed or electronic means without the consent of the author.

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CONTENT WHY A COLLOQUIAL VERSION? ________________________________________ IX NEOLIBERAL ENVIRONMENTALISM or the bussines mafia of environment ___ 1 RAMSAR, mexican style ___________________________________________________ 19

2011 – 2014 RAMSAR. 97,591 hectares for the triad __________________ 37 APIQROO _______________________________________________________________ 47

ECOSUR and IEUNAM, in APIQROO ____________________________ Rule 23. PROTUR proposal in APIQROO _________________________ Rule 23. The CONCCLAB in APIQROO __________________________ The Secretary of the Navy and APIQROO _________________________

52 53 54 58

PROTECTED NATURAL AREAS __________________________________________ 61

The failed PNA, in Quintana Roo ________________________________ 65 Sian Ka'an Biosphere Reserve _____________________________________ 71 Chacmochuch Lagoon System _____________________________________ 77 Nichupté Mangrove Flora and Fauna Protection Area __________________ 79 Xcalak Reefs National Park ________________________________________ 81 Puerto Morelos Reefs National Park ________________________________ 87 Banco Chinchorro Biosphere Reserve _______________________________ 90 Tulum ________________________________________________________ 92 Holbox ________________________________________________________ 94 Manatee Sanctuary, Chetumal Bay _________________________________ 96 Chichankanab lagoon ____________________________________________ 99 Bacalar’s PNA propposal _____________________________________ 102 Who benefits from PNAs? ____________________________________ 107 The PNA Management Program does not solve the problems __________ 111 PROTUR________________________________________________________________ 114

The Master Plan for Sustainable Tourism of Quintana Roo 2030 ________ 115 Participatory construction simulation ____________________________ 121 SWOT without feet or head __________________________________ 125 The Unexplained Calculation of Load Capacity and Acceptable Change Limit 126 Unexplained zoning criteria ___________________________________ 132 Subzone 5.1 Microbialites of Buenavista __________________________ 135 50% of the Lagoon in Conservation or only for Research ______________ 136 "Innovative" strategies that put the lagoon and user safety at risk ________ 137 Strategies ____________________________________________________ 138

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EP1. Installation of buoys ________________________________________ 139 EP3. Microbialites Protection Structures ____________________________ 142

EP4. Services________________________________________ 144 Pollution control strategies ______________________________________ 146 IBANQROO and PROTUR ___________________________________ 146 SNAILS! NOW A CRITICAL HABITAT ___________________________________ 149 THE PMOTEDU, LIKE FRANKENSTEIN'S MONSTER _____________________ 159 MYTH BUILDING _______________________________________________________ 167

The myth of the lack of regulation of the Bacalar Lagoon and its basin _____ 168 Hundreds of instruments to regulate and over-regulate almost everything in Bacalar __________________________________________________ 170 The colonialist myth of the petty or ignorant local inhabitant ___________ 174 The myth of Carrying Capacity for Tourism ________________________ 183 The Acceptable Change Limit __________________________________ 196 The myth of tourism and tourism in PNA, pro-poor __________________ 199 Demystifying Stromatolites ____________________________________ 205 Myth 1: They are "living stones", "bioconstructions", "living beings" _____ 206 Myth 2: Bacalar's Stromatolites are 3500 million years old _____________ 209 Myth 3: Bacalar is a unique case. __________________________________ 213 Myth 4: The cyanobacteria of Bacalar's microbialites are the main oxygen producers that exist ____________________________________________ 215 Myth 5. They fix carbón dioxide ___________________________________ 217 Myth 6. Stromatolites take thousands of years to grow a few centimeters 218 Myth 7: Stromatolites are endangered by tourist activity and pollution ___ 218 Myth 8: The proposal for a protection instrument is a community demand220 Demystifying What happens in Bacalar with stromatolites? ____________ 222 How much cyanobacteria are worth? ______________________________ 223 WHAT HAPPENED TO THE VALLEY OF CUATROCIÉNEGAS, IN THE 1990s? ________________________________________________________________________ 224 A FEW FINAL WORDS _________________________________________________ 243 LITERATURE ___________________________________________________________ 245

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TO CARLOS, FOR HIS UNCONDITIONAL SUPPORT AND HIS FAITH IN ME

THANKS TO ALL THOSE WHO SUPPORTED THE RESEARCH IN DIFFERENT WAYS, FOR THEIR COMMITMENT, THEIR EXPERIENCE, THEIR PERSISTENCE AND ABOVE ALL, FOR THEIR HUMAN QUALITY

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WHY A COLLOQUIAL VERSION? Neoliberal environmentalism, anyone would think it was a crazy conspiracy theory, I thought it too, for 5 minutes. Do not think that it was many years ago, I just heard it in mid-2020, on June 5, 2020, to be more precise, said at a World Environment Day conference, precisely from the mouth of a very high-ranked official of the Ministry of Environment and Natural Resources (SEMARNAT), of Mexico. I had heard for decades the term neoliberal applied to economic and human rights issues, human rights violations, to be more precise. One relates the term Neoliberal to everything that has been wrong in social justice, poverty, everything irrational in the name of money, of profits at the expense of anything or anyone, but I never stopped to think that something as upright as the environmental struggle, could have a dark side as deep, as bad, as was the neoliberal adjective.

If I had heard it anywhere else I would have thought that it was a persecution delirium of some anarchist group against the government, but it was the government itself, and not any government entity, precisely that was most related to the environment. I found it incredible that someone from SEMARNAT was explaining how neoliberal environmentalism had been working, using the pretext of the environment to do what neoliberalism knows how to do better than anyone else: exploit, violate rights, control territories, activities, dispossess and manipulate, in the name of some good cause, but really with an eye fixed on profits and the market, and presenting themselves as if they were the best, the only alternative; under everyone's nose.

There were a lot of things that, over 30 years of working as a community technician, I knew were wrong, very wrong. But I didn't know what to call them or how to understand the puzzle with the thousands pieces that I kept

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in a mental box and as notes in notebooks and on my computer. I knew that much of what was done in the name of the environment and the fight for its "conservation" and "protection" was wrong; that there were groups that benefited monstrously, while other groups were crushed. It was like a mafia, "the green mafia" I gave to call it, for lack of a better term. And I kept accumulating pieces without understanding where to start putting the puzzle together.

Remember that movie where a guy wins a question and answer contest, because he had collected the answers throughout his life in experiences?

Well, after listening to the SEMARNAT lecture that June 5th, what happened to the protagonist, happened to me, all the pieces of the puzzle fit together, and the answers began to arrive as flashbacks of the past 30 years. It was neoliberal environmentalism.

When neoliberal environmentalism made things fall into place, I was engaged in helping local owners and historic users around the Bacalar Lagoon, in southeastern Mexico, fight the imposition of a seemingly innocent instrument of regulation that the state Secretary of the Environment and the state Secretary of Tourism had created, PROTUR. I had not really been involved in the process and I heard in the news about the resistance movements of the population to avoid what they considered to be an imposition with a dark background.

It was no wonder, what was happening in Bacalar had already happened in other regions of the state of Quintana Roo, in fact in other parts of Mexico, and probably worldwide, with results not favorable for the local populations, nor for the environment. Those of us who were working for environmental conservation with the communities had seen it happen again and again; the inhabitants of the Bacalar area, although they were not sure what was happening or what dark interests were hiding behind the seeming inocent imposition, that showed off a public image of being for the "common good", they sensed that something was very wrong.

The public opinion's assessment was that the community opposition was more responsive to the "ignorance" of the locals or to their “measly and obscure interests”. That is, public opinion pointed the locals as "the bad guys" and academics, environmental organizations and the government as the heroes who were trying to save the Lagoon. Basically because the locals

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ran out of arguments against the data and the supposedly scientific statements that the academics involved wielded in front of public opinion, who made urgent calls to give control of the Lagoon to a third party, as the only way to "save" it from disaster.

But there were inconsistencies and "strange" things in their information, they changed their speech, depending on the audience they were addressing, and they pointed out very quickly culprits, without their data being really substantiated, not even conclusive. And what was more worrying, this had already happened on countless occasions, just before the imposition of Natural Protected Areas or similar instruments, in other parts of the country. Instruments which, by reviewing information from many sources, had not really contributed to the objectives that justified the impositions.

The locals sensed it, they had seen it; elsewhere in Quintana Roo and Mexico, there were still many local groups fighting to regain control of their seized territories, which had been made available to the market for "sustainable" activities at very high prices, and which had initially been taken from them in the name of the environment. Or was it just a coincidence?

The pseudo-heroic stories and the almost miraculous results of the Natural Protected Areas and other instruments were everywhere, but digging a little into the basis for such assertions, I found that most were more marketing than science. All the success stories were told from the point of view of the actors who had helped to establish them, as a kind of modern adaptation of "the conquerors’ version", but weren't there other opinions? Every story must always have several versions, and I wanted to find out if anyone, from science, had another opinion on these environmental instruments.

I found a lot of information from unexpected sources, the social sciences; social scientists had been severely questioning not only the way in which communities and other local actors had been stripped of their territories, but how favored groups had made a juicy bussiness with the controlled territories, far from the altruistic discourse that had won them public opinion, and the points, to impose themselves. But these investigations and opinions were hidded, ignored and made invisible by the power groups that enjoyed the benefits of the environmental struggle, and remained unknown to the majority of public opinion, or were qualified as anarchism.

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In april 2020, some of the community technicians and local actors I knew who were actively involved in local resistance groups against PROTUR, provided me with the document and asked for my opinion on it. It had been presented as a "voluntary" instrument, built in a "participatory" way by the community, which was intended to be as a kind of regulation to control tourism, for aim for conservation and protection of the lagoon, which established scientific bases to impose a carrying capacity, such as a maximum number of boats or people and a maximum permissible limit for tourist activities in the water body.

It took me a couple of hours to realize that the whole document was not just a farce, but it lacked total scientific or moral foundation, because it had been built on a huge pile of lies. I prepared a report that I provided to the group to complement their arguments and went on my way, surprised and insulted by the level of cynicism and brazenness that the academic, governmental and environmental actors had reached, to cynically try to tease the local population and public opinion with their document.

On a couple of other occasions the local actors asked me to analyze the proposals of the "environmentalists" in other instruments such as the Operation Rules of the Integrated Port Administration of Quintana Roo (APIQROO. in spanish), for Bacalar, where they were trying to include their map of restricted areas, the natural protected area (PNA) type plan of PROTUR. That seemed very low, to me, and again I got involved analyzing their arguments and bases; again, the level of lack of foundation and the weak arguments for insertion was almost ridiculous but, as APIQROO’s management told the local groups: there was no other proposal. Which was an even poorer argument, to include a deficient instrument and a tendentious plan, rigged, because there was no more, because it was the least worse. It wasn't just ridiculous, it was insulting.

Almost at the same time the change of color of the Bacalar Lagoon happened, by mid 2020, a phenomenon that the locals know has been happening from time to time, after extraordinary events of rains and runoff.

And the scandalous and alarmist arguments of the groups in favor of imposing an instrument of control in the lagoon skyrocketed. With an avalanche of data, rarely substantiated or generalized from a partial vision or pseudoscientific research, presented as solid science, scientific research published with methodological errors, manipulation of information at

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convenience, and explosive more like tabloid notes, putting pressure on local opposition groups to favour their cause, with the help of public opinion. And then it came the SEMARNAT speech of June 5th, 2020, where I came across neoliberal environmentalism, and what was happening, the groups involved, their way of acting and and not altruistic, dark interests on which they based their actions, became clear, like daylight.

At every opportunity the local actors came sensing what I already had clear, and I only had to name it and organize the information to dispel their doubts.

While I was elucidating how this alliance between groups that benefited from the imposition of natural protected areas in favor of the environment, worked, it was easy for me to baptize them as the Triad. More specifically, the Neoliberal Environmental Triad, composed of academics (scientists), non-governmental organizations and government agencies, all related to the environment.

What I found often seemed like something out of a conspiracy novel, so a commitment I made to myself and made to the local actors was to explain in writing what was happening, which in fact had already happened elsewhere for decades, and to solidly base the findings, beng aware of the strategy of the members of the triad for trying to discredit any information that contradicted their saying or that tried to expose them.

When I started writing this book I thought it was going to be a report of about thirty pages long, where I could briefly explain how the neoliberal environmentalist promoters were acting in Bacalar. They had been trying to impose instruments of control in the name of the environment in the territory, they had started with the Lagoon and little by little they had climbed to a territory of more than 219 thousand hectares (around 541,161) that they intended to place under a system of environmental protection.

They were criminalizing and targeting groups of historic local inhabitants and producers, and clearly benefiting from all that campaign they had been putting together.

As the research progressed, so much information emerged that it became necessary to divide the results of the research into three volumes, in a collection that I decided to call: "On Bacalar’s Defense". The resulting book contained a lot of information, all substantiated. This book is volume I and I called it " The neoliberal environmentalism triad,

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How do they gang up? " Here I explain how members of three sectors of society ("the triad") have colluded to impose instruments of neoliberal environmentalism in such an amalgamated and subtle way that it is almost unnoticeable to the unwary citizen, a citizen who truly believes that the motivation of this group is altruistic and pro-environment or pro-poor, little do they suspect that it is just an incredibly orchestrated simulation.

Perhaps the word Triad sounds like something fictional, but the name came when it became clear that it was three sectors of society, united by a bond of particular interests, benefiting treacherously from the environmental discourse. That's the triad. But I have no evidence to assure that it is like a conspiracy where prominent members of each of these sectors meet to compromise intrigues against the rest of the population. Nor could I say that it is a sect, although they use many strategies of dominating manipulation like one, you know they acquire followers who will socially lynch anyone who opposes the ideas of the leaders of the triad. Much less is it an Illuminatitype group, at least not at the local or regional level. The triad functions as an unfortunate coincidence of interests and roles of three sectors of society, at the service of big capital, which has taken the environment as a flag to control resources and enrich itself more, with the international approval and approval through an altruistic screen.

The local triad, in Mexico, to which we are going to refer in this book, acts more like a gang with individual interests of its own, which coincide. Each of its members fulfilling a role to validate the actions of the other two, a complicity that yields great benefits at the expense of the rest of the population and territories. A very well articulated triad, in which some necessarily need the others. The government, in its role as rector and judge; academics functioning as validators; and non-governmental organizations appointing themselves representatives of the rest of society. Receiving benefits in many ways.

The most relevant discovery of this research that perhaps surprised and disappointed me the most, as incredible as it may seem, was the lack of capacity of most of society and the media to evaluate the information they receive from the triad, without a critical eye, receiving it passively, without questioning foundation, much less the intentions. This happens because in one part of society there is such a great need to find heroic actions among so much cynicism, to find individuals and groups that act selflessly for the

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good of all, and another part of society and the media have an urgency rather to find sensationalist news and tabloid like news in their outburst to receive and provide news consumption material. Either attitude plunges individuals and groups into a frenzy that puts them in an almost childish state of credulity, which contributes to disperse the myths created by the triad; a society that reacts gaslighted by academic titles, labels of "experts" or the tray of authority of a government position, or worse, to sentimental blackmail.

Among the things we find there is everything: extremely deficient planning processes, without arguments, simulated, which had been thriving in the face of inaction and resignation, but above all, before the general attitude of the dominated that the population has, an attitude that society adopts outside the triad, convinced that the government has power, scientists the ultimate truth and wisdom, and non-governmental organizations have a the mission... which reminded me many times of the history of the Spanish invasion, more than 400 years ago in the name of a god of religion, only in this case it has been more like a new colonizing invasion, this time in the name of another god, the environment.

Championing a supposed altruistic interest, the members of the triad manage to impose instruments of control that do not even meet the objectives for which they were created, that is: instruments that were supposedly designed to protect the environment, and that do not protect it; instruments that were supposedly created to prevent the deterioration of the environment and biodiversity, but whose application does the opposite. Whose only real objective is to benefit few, individually or institutionally, only to obtain territories reserved for big capital, to generate gains to the triad, those who with the discourse and the flag of being protecting the environment, fill their pockets with money, the mouth of "successes" and the chest of medals with a carefully constructed image of semi-heroicity, before a public opinion that does not realize that it is lied to and manipulated blatantly.

This group has an excessive ambition, encouraged by its successes in blatantly stripping and benefiting with impunity from resources and landscape, only to continue simulating, increasing the vicious circle of placing more restrictions and instruments on the locals, stripping them of control over their territories and even contributing to their criminalization, only to continue enriching themselves, through control of the sites, biodiversity

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resources and ultimately, genetic resources existing in once ancestral territories, while local communities end up cornered, impoverished and displaced.

How did I come up with the idea of creating this series of documents? It was an epiphany, because I didn't even know how to start writing. The idea was given to me by a public opinion open letter written by Víctor Toledo, former secretary of SEMARNAT, in July 2020 – a few weeks after I came across the term neoliberal environmentalism of June 5th. In his letter Toledo questioned the true intentions of the signatories of another letter, in which they accused the current government of "... undermining, dismantling, corroding, and collapsing of environmental institutions..." The document questioned by the, then, secretary of SEMARNAT was signed by 24 former environmental officials, a very suspicious conjunction of politicians from openly neoliberal political parties (PAN, PRI, PVEM and Nueva Alianza) and members of an environmental organization called Ceiba, integrated by former environmental officials, among others and whom Toledo openly accused of wanting to discredit the current government.

The secretary of SEMARNAT pointed out that, without exception, the signatories had at some point been main or secondary authors, accomplices or silent spectators of the ecocide that the country had suffered. The vast majority were cover-ups, partners, advisors or image launderers of companies and corporations such as Cemex, Grupo México, Coca-Cola, Bimbo, Monex, Volkswagen, Telmex, Walmart, Holcim, Ford, Banamex, etc., or they were running green laundry business organizations such as the Water Advisory Council. And he suggested: “…His collusion with the economic powers can be corroborated by examining their biographies. Finally, together and scrambled, he publicly accused them of having "come out of the closet of neoliberal environmentalism."

I thought it was a wonderful epiphany and followed the advice. Some of the names of signatories in that letter appeared throughout the investigation, so I decided to investigate, in the case of Bacalar, precisely that: the network of neoliberal environmentalism, conflicts of interest and the possible motivation of the group of promoters who for almost a decade had tried again and again to take control of the lagoon, pretexting its conservation.

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I published the oroginal book in September 2021, it was a very thorough investigation but had an unexpected problem. It was, according to local actors, very dense to read and understand. That is, it was very extensive, full of technical terms, with many data, many graphs, many tables and many literature references, which was perfect, technically speaking; but it had made it inaccessible to the actors I was interested in reading and understanding the whole phenomenon of neoliberal environmentalism and its simulated and failed instruments.

It was also very expensive, since it contained many color graphics, which made it inaccessible to the sector of the population that needed to read it.

So I took on the task of making this lighter version, colloquial from the experience of research and what I found. For reporters and researchers more interested in the foundation of the investigation, even for the members of the triad who feel the irrepressible urgency to discredit what I expose, the extensive and color technical vesion is available, also a technical version, in black and white.

This version of On Bacalar’s Defense, Volume I, I hope will be more readable, entertaining and illuminating.

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NEOLIBERAL ENVIRONMENTALISM or the bussines mafia of environment "The declaration of protected areas on indigenous territories without our consent and participation has resulted in our dispossession and resettlement, the violation of our rights, the displacement of our peoples, the loss of our sacred places and the slow but continuous loss of our cultures, as well as our impoverishment. It is therefore difficult to talk about the benefits for Indigenous Peoples when protected areas are declared in our territories unilaterally. First, we were stripped in the name of kings and emperors, then in the name of the development of the state, and now, in the name of conservation.

Final declaration by indigenous delegates at the 5th World Parks Congress, held in 2003 in Durban, South Africa

In the last 5001 years of documented history, Bacalar has been a booty coveted by opportunists and invaders who have come to these lands trying to take over their natural resources and territories, trying to subdue local populations in the process. I am also passionate about history, where I found many answers for this research and as a comparison, I can almost assure that there was no human settlement, during the Spanish colony, that had suffered as much harassment as Bacalar, who had been defended so many times, against so many different enemies who seemed to take turns attacking the locals and trying to take control of the territory and its riches. Many, in the name of a king of faraway lands; many moved only by their own greed or their need to transcend history; but as happened with the attacks of the invaders, pirates, corsairs, baymen, smugglers, enemies, traitors, who again and again attacked the local populations in colonial times, these constant attacks built an incredible resilience and a remarkable force in the local inhabitants, who

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In the previous original versión I wrote 300, instead. The Spanish invason took place in Mexico 1511, so its around 500 years.

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always refused to be subjugated and opposed to surrendering their heritage and their territories.

As then, in today's history, local populations rise again against modern pirates, invaders and swindlers, that now take the form of institutionalized and local non-governmental organizations, government actors and academics. As happened during the Spanish colony, where the encomienda for religious faith, was used for the invaders to take over land, control and power, natural resources, heritage and local populations, in the name of a god brought from Europe, violating all the precepts of humility, compassion, mercy and justice that they claimed to protect with their faith, using it only as a simulation to seize these lands and to enrich themselves; today, as if it were a modern colonial invasion, these modern environmental encomenderos try to carry out a spectacular dispossession in the sight of all, in the name of a new god, the environment, in a modern crusade of control and subjugation of the locals, in the name of biodiversity conservation, of environmental protection, of the climate crisis, using all the strategies of neoliberalism, and as in the past in breach of the precepts of their environmental faith: to protect, be sustainable, just, human, respectful of the locals and their ways of life, with ethics, transparency, legality, but above all with the protection of territories and their natural wealth. Acting to hidden interests and pacts, in the shadows.

The basis of this whole book is common sense, local ecological knowledge, local intuition as a basis and we will go down from there to Westernized scientific knowledge, mainly that of the exact and natural sciences. Why do it the opposite of how it is styled? That is, why go from the knowledge of the community to the scientists? Because scientists are recent, local knowledge was the way to understand nature and each other for thousands of years, until a couple of centuries ago that Western scientists called themselves emperors of knowledge and granted themselves the license to appear as the only ones capable of downloading knowledge and "wisdom" from wherever it was, to the rest of humanity, almost as priests with connection to the divine, whose knowledge and access was superior to the rest of mortals. Academic titles and government positions handled as noble titles of the colonial era, to the current context.

Scientists and the rest of the triad have underestimated or discriminated against other types of sciences such as social sciences and very, very low, considering it as something folkloric or anecdotical without real value, they 2

have left local knowledge, which is usually invisible. Academics and the government argue that local wisdom is invalid, since it does not originate from an academic degree, because it is not built in a laboratory, or because it did not follow the scientific method; they argue that it is "biased". However, when reviewing the cases where academics have supported the arguments of the triad, it is easily seen that the criteria used not only tend to simplify, reduce and suppress the particular features of resources and territories, but are biased because they obey their own specialization or over specialization and are influenced by their conflicts of interest, which gives them a myopic vision, at a very short distance that does not allow them, in turn, to understand geographically and temporally complex scenarios. Like someone who tries to understand an extensive landscape by looking through a keyhole, who sees only what they want to see, and also explains what they see as it suits them.

One might think that the research centers involved have sufficient human resources in which our country has invested scandalous amounts of funds for their preparation, a body of researchers with various approaches to reduce the limitations that a single researcher telling the story could possess; that would be ideal if it were not for the fact that these institutions are in a permanent carnage for prestige, points, positions, funds and positions at the National Researchers System (NRS), they are war fields of egos, professional jealousy, envy, distrust and malicious rumors, a permanent dirty game for maintaining positions and privileges, which prevents most of the time an ethical, selfless and productive collaboration, among them.

The tide is changing and local knowledge is beginning to be seen in a different light, especially because of its flexible, comprehensive and open nature, which allows local populations to understand all the dimensions, how phenomena vary, processes, how they move in all directions, throughout the territory.

For local people, local ecological knowledge (LEK) is key. What local people and historical users know, has received the growing recognition and momentum for its use internationally. Many forums recognize, inter alia, the breadth and scope of the information obtained, with merit. Something in which the academics of the triad have failed, from the unreliability of their assertions, the short scope of their research, and the little or no predictive power of their proposals, due to the poor quality and quantity of data generated. And despite all the government, the NGOs (Environmental Non-

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Governmental Organizations) and the triad's own academics, all of them insist that only THEIR science is valid.

Why is it so important to strengthen local knowledge and citizen science?

First, because the amount of data generated by them, the members of the triad, cannot be compared with the amount of information obtained from the observation made by individuals or groups from local communities, over years, over decades or through generations, in their day to day. This places local actors as true experts, people with relevant, broad and deep experience on a topic, because they have first-hand knowledge. Secondly, because local knowledge generates information from which legitimate instruments can be created, because they come from the social base of common knowledge. But the real urgency of positioning and valuing local knowledge is because who puts the science, and what science is taken as a basis, will determine who has the control, funding and power over the territory.

So, if western science is so deficient, why has only the voice of western scientists been heard so far? The answer is that all environmental instruments, mainly environmental policy, were created and organized by western scientists, bureaucrats, bureaucrats-academics and environmental organizations, who self-appointed themselves as "representatives of society" or by those who finance both, to perpetuate the interests and maintain the benefits of these sectors, in a kind of perverse toxic marriage. A perfect hodgepodge for the emergence and permanence of neoliberal environmentalism.

Another common factor that we find in the discourse and marketing of the triad is that its intervention was requested, that all its proposals were requested by the communities or were designed and validated in a participatory way by society, which approves and supports them unconditionally, which was never true. Time and again we come across a perverse simulation of participation that is easily unmaskable. In this model of neoliberal environmentalism, social participation, whether for a Ramsar site, for a Protected Natural Area or for a proposed Common Management Program (PROTUR), is reduced to a well-mounted spectacle of manipulation or a sad tokenist simulation.

What is tokenism? This concept was another concept that I think is relevant to define. Tokenism is a practice widely used by the triad as far as community 4

participation is concerned, it is a simulation where public opinion is shown that the groups in power (in this case the triad) have incorporated certain minorities, disadvantaged groups or in this case the local inhabitants or historical users, and that they "allow" them to share their work, participate at the same level where their opinion is taken into account and even that the community opinion bases the actions or decisions, but when analyzing the processes and results it results in a simulation, a false image, an unfounded justification or an ornament in a document.

We do not refer to the simulation of incorporating Environmental NonGovernmental Organizations (NGOs) that are part of the triad, as selfappointed representatives of society; rather I refer to the cases where they integrate real social actors for the photo, in order to validate their action.

When the way in which they are made to participate is analyzed, it is more like an infantilization, giving them the instruments already created, subjecting them to accept without opposing or canceling them, making them invisible or even humiliating them if they try to protest, make themselves heard and assert their opinion, when social opinion is contrary to the interests of the triad, as happened with PROTUR, as always happens to participants outside the power group.

For the academic sectors of the natural sciences and bureaucrats in Mexico, local knowledge is seen as a folkloric matter, sometimes as an obstacle to the "efforts" of conservation or development, as a resource to obtain and use in their favor, a reference data that must be improved, or at most as a discourse to base interests outside the community itself, in a supposed participatory process to "improve" its environmental management. In the worst case it is used as information that is plagiarized or patented, which is a crime that has been overlooked countless times. Which implies serious conflicts of interest in their performance.

Let us understand the expression "conflict of interest" (CI) as those situations in which the professional judgment about a primary interest and the validity of a research, may be influenced by a secondary interest, typically an economic benefit, or of an academic nature, such as the desire for professional recognition or the pressure to publish. In government it can be economic interest or to follow an order of some actor of greater hierarchy or power and in NGOs it can be to obey the particular interests of the partners, the financiers or the government, in the dark. Although the secondary interest 5

does not have to be illegitimate, what is questionable is the relative weight of these interests with respect to the primary interest. We base the analysis on benefit data and on personal and institutional history and relationships with other actors, as suggested by Víctor Toledo in his article "Neoliberal environmentalism comes out of the closet".

As an apparently unrelated conflict of interest we could exemplify an individual or group of individuals who, for example, need to preserve the perverse incentives, which they achieve by "producing" a lot of research – even if it does not solve problems or only contributes to adding papers to a curriculum – in order to maintain their level and privileges within the National Researchers System (NRS) and the consequent additional compensation to their salary that their academic institution can offer, in addition to their institutional salary. These academics must ensure their "productivity", the "relevance" of their work topics, their "leadership" in their research area, to produce quality "human resources", which in some cases forces them to perform unethical actions or allow bias in their research, as we will see in more detail, later.

What is more questionable and perverse are the criteria or indicators of productivity of the NRS – measured on the number of scientific articles published in foreign journals; which by the way make the Mexican scientific literature written in English, inaccessible to local populations that might require the information obtained, often with their participation and investment. Researchers often compete, with lack of ethics, to check the relevance of what they investigate, inflating or forcing their results, as we find in many of the articles published by some academic members of the neoliberalist environmental agents’ group.

To demonstrate "leadership" – which they also measure in number of publications, amount of funding, number of theses or size of their laboratories; another indicator is "production of human resources", which is measured by the number of postgraduate courses they form, which end up indoctrinated to the same unproductive, self-centered and petty vision of science that is NOT available to society, absorbed in their own curricula, oblivious to the responsibility of contributing to solving real problems or committing to the rest of non-academic society, whom they see as inferior human beings.

6

Another very serious conflict of interest may be a researcher or an institution that is seeking considerable economic benefit by patenting biotechnology from the genetic material of existing biodiversity. Even with the modification of the Science and Technology Law in 2015, under the government of Enrique Peña Nieto to allow the inclusion of private capital to public support to generate technology and to be able to patent discoveries in financial favor (up to 70%) for researchers, in the case of genetic material, it is still bioprospecting or biopiracy. It is shameful that the objective of the vast majority of the academy in Mexico is limited to being a member of the NRS to ensure the financial incentive and prestige for life, and to have as an ideal to achieve an emeritus NRS category to ensure a lifetime payment, above anything. This is certainly a perverse incentive.

In Bacalar an additional conflict of the members of the triad, is the promise that they will benefit from their closeness to the groups that will "control" the area or their privileged economic position (with capital in dollars or euros). As happened in Cuatrociénegas in the nineties, for 2019 we realized that Dr. Luisa Falcón and her collaborators had not stopped insisting on their proposal, and had dedicated themselves to promoting the urgency of creating a reserve of stromatolites and criminalizing before public opinion the inhabitants and local service providers who, according to them, they were irretrievably damaging the Lagoon with their activities and who, according to their statements, had to be arrested. It must be understood that in the discourse of the triad, the term conservation equals business.

While conservation is conventionally interpreted as "saving the world" from the human excesses of capitalism, it actually works to reserve nature for capitalism, while also creating broader economic possibilities for the expansion of whoever can afford it. “…Capitalism may well be the enemy of nature, but conserving nature, paradoxically, also seems to have become capitalism's best friend.…” (Kovel, 2002).

In order to understand the environmental neoliberalism practiced by the triad, we need to understand neoliberalism as an economic policy. Economic neoliberalism spread in Mexico from the 1970s - 1980s while permeating most countries, worldwide. In our country it was the regime of Carlos Salinas de Gortari (1988 to 1994) that promoted it to all sectors, which "curiously" coincided with the appearance and deployment of environmentalism, which 7

gradually rose as one of its most notable and least related pillars. In this regard, Víctor Toledo states that: “…In the end, environmentalism was absorbed, sweetened and neutralized by the deployment of neoliberalism. The consecration of environmental discourse that took about four decades gradually faded. Today, almost without exception, the positions of governments, companies, academies and international organizations revolve around the fact that the solution to the global ecological crisis is only possible through the market, technologies and institutional arrangements. To this end, apparently scientific concepts such as sustainable development, green growth and economy, and natural capital were introduced, but which basically seek to hide the commodification of nature.…”

Toledo, then secretary of SEMARNAT in 2020, had the honesty – or simplicity – to acknowledge that while SEMARNAT had been created with "... great vigor and scientific quality, powerful legislation and gave rise to administrative instruments for environmental regulation in 1994, as in the rest of the world, the effectiveness of SEMARNAP (T) was weakened by the neoliberal policies of the following six-year terms…”

This statement gave me a good idea to guide the investigation with the public recognition of Toledo as Secretary of SEMARNAT, of the ecocides that had been committed by the promoters of environmental neoliberalism, in Mexico:

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1.

The arrival of inexperienced and unscrupulous officials at key posts;

2.

The delivery of almost half of the country to mining companies for the extraction of gold, silver, iron, zinc, copper, including one thousand 900 concessions in 68 percent of the natural protected areas!

3.

The unstoppable industrial pollution of the main rivers of the center and north of the country that have given rise to environmental hells due to the high number of patients with cancer and other diseases;

4.

Total inaction on the use of more than 80 toxic pesticides spearheaded by glyphosate;

5.

Semarnat's legal position on the side of the large biotechnology and agro-industrial corporations (Monsanto, Syngenta, Bayer, Dow, Dupont) in the case of transgenic corn and soybeans;

6.

Overexploitation, illegal and fraudulent use of aquifers by large agricultural producers, mining, breweries and soft drinks;

7.

The obscene delivery of beaches and coasts to tourist megaprojects;

8.

The indolence of the conservation policy that protected flora and fauna in 30 million hectares, but forgot about the 3,697 communities that made it possible, 84 percent of which today suffer high degrees of marginalization!

9.

The suspicious delay of procedures and loss of documents in Profepa (The Federal Environmental Attorney Office);

10.

Disdain for solving environmental conflicts (560 revealed per thousand 30 journalistic records); 11.

The total absence of solidarity with the 157 Mexicans killed, until 2020, for defending the environment, who had been completely ignored Many of the crimes listed above are summarized in three elements shared by the members of the triad: Conflict of interest, Corruption and Simulation; something that the promoters of the protected natural area of Bacalar had in common. All this disguised with a well-oiled apparatus of simulation and urgency to "conserve and protect", validated by a public opinion that allowed itself to be wrapped with sentimentality and half-truths, without analyzing in depth the reasons of the promoters to promote and force, almost obsessively, their simulated protectionist crusade.

The formulas of the neoliberal environmental movement are based on affirming that the solution is to fight voracious capitalism with capitalist mechanisms, which have another type of voracity. In neoliberal environmentalism it is said that there is no other way to save nature than with actions where control is given to one of them, because the owners or local actors are inept, and they in turn must see that the sites generate profit potential or else there is no incentive for rational actors to conserve. And then they create the instances and finance each other to in an apparent disinterested action appropriate the discourse and control the conservation efforts for their benefit or their financiers (The big money). Because by beneficiaries they never mean the locals, but them and their related groups.

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Some of the neoliberal mechanisms include the purchase of land to cede it to conservation, private natural areas, the incorporation of private or social lands into protected natural areas or similar mechanisms, by unilateral decision (State – Environmental Non-Governmental Organizations – Academics) to put it under the control or ownership of the State (State at the order of big money) or third parties; the creation of private funds and trusts for conservation; the establishment of financial products -bonds, creditsexclusive for conservation, managed by third parties, the decrease in the presence of the State in the practice of conservation, as well as its alliance with NGOs, private companies, multilateral institutions or groups within the same communities, with particular interests that are championed by the "common good", and that are only the vision of a close and privileged group following their own interests.

Similarly, funding for "conservation" or "sustainable development" ends up being an endless list of projects for academics and NGOs, who call themselves representatives and defenders of the rest of society, as an organized civil society, and who are given the right to "manage" and "apply" the funds from their conservation vision, that it is limited to research and more research; of sustainable development, limited to workshops, organizing vulnerable groups to do "acceptable" economic activities such as handicrafts or guidance; or for a long procession of endless consultancies and trainings, all financed by national or international bodies that most of the time were created by the same members of the triad, on an international scale.

All this around the massive dissemination of the message of urgency and disinterest to justify taking control and stripping local populations of their governance. The message is summed up like this: Local community groups are unable to know what "is best for them and the environment," which justifies the need to take control from the outside and put them as passive spectators or actors. Perpetuating the colonialist vision of the encomendero, a new colonialism, with environmental encomenderos, who then make it available to those who can pay for conservation, under a model of "sustainable development", or a "green economy" as an incentive.

To achieve all this there is another key element: Public opinion. They require public opinion to exert pressure; therefore, the groups of academics, bureaucrats or technocrats involved invest a large number of resources in advertising their discourse and thus generate polarizing positions, based on the criminalization of a sector of 10

the population, usually producers, service providers or local inhabitants. With the media hungry for sensationalist or yellowish news, they promote catastrophic notes that permeate public discourse, create myths and generate complicities to make local actors or owners criminalized and seen as causing the deterioration of wild spaces, and thus “add fuel to the fire” to create panic in order to justify their proposals, urgently and taking what ever it takes.

These complicities do not stop after obtaining control of the territory, because once they have control, the same actors of the triad change the game to promote the opposite to new users of the territory, usually large capitals, and consumers (usually tourists or investors) in the form of availability or access to "wild" spaces "preserved" of a "closer contact and intimacy with nature", with an economic benefit, direct or indirect, for the promoter and / or controller of the resource or "conserved" site, which are usually the members of the triad themselves, who present themselves as environmental guardians or public servants fulfilling their obligations, but receiving juicy legal or illegal benefits, while perpetuating this public image of crusaders saving the world.

Using two simple quotes collected during the celebration of World Environment Day in 2009, where Mexico was the world headquarters for this celebration, it is exposed how some sectors of the population visualize environmentalism, from the neoliberal philosophy. The event was held at the ancient Mayan ceremonial site of Xcaret, converted into an amusement park.

Among the guests, in addition to the entire cabinet of then-President Felipe Calderón, academics and researchers, there were prominent businessmen.

With this image, the position of neoliberal environmentalism is clearly exemplified. “…We must make the conservation and sustainable use of these natural resources more profitable [...], the care of the environment will be, in the near future, a very important economic sector and a great generator of jobs. Carlos Slim, businessman…”

“…It is not surprising that several companies in developed economies have substantially increased their market value, to the extent that they have made fully compatible the growth of their own businesses and the harmonious development of the environment [...]; taking care 11

of our common home today with an eye on the well-being of future generations is the best investment we can make [Agustin Carstens, Secretary of Finance] (Presidency of the Republic, 2009) …”

Most of the neoliberal environmental instruments, such as the PNA, make unfulfillable promises since as we would say in Mexico, " making promises never impoverished anyone". Management programs are created, if they any are created, with ambitious objectives, without evaluating the conditions, challenges and capacities of the agencies themselves and other actors of the triad, objectives and commitments listed and promoted in a theoretical way, which hardly reflect or adjust to the current reality of the sites or populations on the site, in the local or regional context, and even in the national context.

Following the actions and commitments that are demanded of them from abroad, often from the international triads that monitor the permanence of all the protectionist instruments that were created in the academic / bureaucratic complicity of neoliberal conservationism on a global scale.

The relationship between the academics and the rest of the triad to benefit each other is clear from the statement expressed as a presentation of a book on research in protected natural areas, by the late Gonzalo Halffter, an academic, high-level bureaucrat, from the time of the dominion of the PRI, considered among the members of the triad as the creator of the Mexican model of biosphere reserves. Halffter makes it clear that: • One of the stated objectives of natural protected areas (PNAs), especially biosphere reserves, was to provide logistical support for the development of research, education and training programmes.

• That in developed countries the main link between scientific research and PNAs was that of a flourishing of scientific articles and publications once an PNA has been created.

• That in Mexico the relationship between scientific research and protected natural areas (PNA) was established at a much more primordial stage of the PNA. • That the first biosphere reserves in Mexico had arisen from the work and tenacity of Mexican scientific researchers working in higher education institutions or research centers.

• That the administration of the PNA in Mexico had been complicated, because it took a lot of money, people and laws to manage biological elements and diverse ecosystems.

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• That the strengthening, and despite the uncertain autonomy of CONANP, were bearing fruit in terms of the number and territorial extension for the conservation of the different ecosystems.

• That what was most needed was money, because still "some of the Mexican PNAs lacked sufficient and permanent surveillance” • The solution? A concession scheme to NGOs with renown and experience in the field of conservation and the inhabitants of these areas, who by law are directly involved in the monitoring, maintenance, conservation and distribution of income from environmental services in this area.

This list has all the elements of the triad strategy, which I already explained above. The text demonstrates the vision of the academics of the natural sciences precisely, from the pen of one of its most important academic promoters, on the role of CONANP and the local inhabitants, to measure the success of conservation by the number and territorial extension of the PNA, but above all to give control to NGOs. As far back as the seventeenth to the nineteenth century, some of the "naturalist" philosophers from privileged classes shared the class view. The vision of belonging to higher classes for whom Indians and communal property posed a threat to conservation. In the nineteenth century, Leopoldo Río de la Loza stated that the indigenous peoples of the forest-owning peoples had cut and cut the trees at will, without subjection to the ancient forest ordinance and without even observing the method that reason advised for their own benefit, a system that had tried to impose itself "unsuccessfully" by the Spanish invaders, then by the privileged political and social classes of the independent era.

Some social researchers express that since that time philosophers and scientists were concerned about the terrible consequences of deforestation, but more than arguments based on scientific data, their position reflected the annoyance at the situation, for them unacceptable, that the indigenous people could travel through remote or entirely unknown paths, and exploit at their free will the "public wealth" without having been able to be civilized to put an end to that practice for the Gentlemen and scientists of the time, so abusive... because it didn't give them benefits. Since then, the commitment they had to a model based on the promotion of private property was noticeable; not much has changed in 200 years.

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Later, just after the Second World War, conservation emerged, like most colonizing invasions, from Europe. With the intervention of some outstanding academics of the natural sciences in Mexico, who set the precedents of the "conservation models"; for them, human systems were a problem and/or omitted and/or set aside and/or overridden.

Not only was it a problem of classism, it was also a problem of professional training, conservation, designed from the natural sciences approved and continues to approve only that: Nature; in his equations the human factor is not understood. Biologists, ecologists, chemists, oceanologists, geneticists built the entire conservation model since the 70s in Mexico and those researchers, in addition to having the vision of the door lock, belonged to the hegemonic political class that ruled the country by then since 1917.

The institutions in our country dedicated to safeguarding and conserving the natural environment were created throughout the period of emergence and consolidation of neoliberal economic policy (from the 1970s to 1980s), during processes in which the country required financing because it acquired external debt and the international bodies that provided it began to condition support to push underdeveloped countries to become "sustainable". –translation: that they let themselves be recolonized again-, so that they would follow the prerogatives of the groups of scientists at the international level, which was how neoliberalism got into everything. Scientific groups that were at the command of capital, groups that were creating all the instruments for which, through environmental discourse, it was possible to obtain complete territories, limit local populations, carry out bioprospecting disguised as biodiversity knowledge management, to be able to monetize first the biodiverse resources, then the intangible values such as environmental services and lately genetic resources.

Since this union between ecology and neoliberal economics comes from a construction mainly developed by scientists of exact and natural sciences, it is very difficult, almost impossible, to find in these areas objective analyses, criticisms or denunciations of negative impacts or the disastrous consequences of these instruments for human communities, and consequently, for nature itself; because environmental instruments are evaluated from the vision instilled and directed only to the biotic aspects of the system and subsequently the benefit they can represent in the "green economy".

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This discourse has uniquely and exclusively privileged the fictional idea of wild, untouched or wild nature, setting aside the interaction and key role that human populations have had over the years with resources and their environment. The triad does not consider that the environment is a changing system, in constant process of development and change, influenced by factors that escape even the local scenario, as evidenced by historical geography and even archaeological and paleontological research in the basin of the Bacalar Lagoon.

In the case of Bacalar, the neoliberal environmentalists disguised as citizens concerned about the lagoon system and its future are, for the most part, upstaters newly arrived in the territory, government officials and people who from their privilege do not hesitate to point out and look for culprits in order to justify their interests, manipulate discourses at convenience to gain followers among the most vulnerable population, who believes that what is said is true and unquestionable only because the person who says it has a political office or an academic degree. They feel offended that the territory and economic activities of places like Bacalar are in the hands of "savages", of "Indians", as they look over their shoulder at ejidatarios and local service providers; and not because of them, civilized people, "good" people who could get more out of it and would better preserve the place, from their classist beliefs of first world-ism, region four.

They support themselves with that part of the population that does not question and that clings to a discourse, without understanding reasons, from sentimentality and blackmail, and that in the purest style of the subject blindly believes what they have been taught, instilled and disseminated by the modern feeders and priests of "Mother Earth", the "possessors of absolute environmental truth" who come from outside; is a very interesting case of group dependency disorder by restrictive manipulation, as if it were a cult.

The following table presents a list of the initiatives of declarations or similar instruments that have been emerging from different groups in Bacalar of which we are going to talk. As can be noticed, the proposals have always been promoted, supported and managed among scientists, government bodies or individuals from government bodies, and ultimately non-governmental organizations: the triad.

15

Taking advantage of each of the various stages of attempted instruments of protectionist environmental policy on Bacalar, a situation that has been happening since 2011 in the area, promoted by these neoliberal environmental groups, we will be delineating and taking advantage to not only talk about what happens, the interests and the process of each of them, but we will also take the opportunity to analyze the background and the groups that were building each of these instruments: The Ramsar Wetlands Convention, the Natural Protected Areas, the Critical Habitat, the registry of species at risk or danger of extinction, among others.

Neoliberal environmentalism proposals to control of the Bacalar Lagoon.

2014

Institute of Ecology of the UNAM, ECOSUR

Dra. Luisa I. Falcón

RAMSAR Site Designation

2014

Institute of Ecology of the UNAM, ECOSUR

Dra. Luisa I. Falcón

RAMSAR Site Designation

2014

Institute of Ecology of the UNAM, ECOSUR and Secretary of Environment of Quintana Roo, CONANP

Dra. Luisa Falcón

2017

Amigos de Sian Ka'an, AC, Federal Deputies of the PVEM, SEMARNAT, CONANP and Secretary of Environment of the State of Quintana Roo Secretary of Environment of the State of Quintana Roo and Secretary of Tourism, municipality of Bacalar, GEO Alternativa SC, Agua Clara, AC

Dra. Luisa Falcón

RAMSAR: Bacalar Coastal Transverse Corridor and Chetumal Bay Natural Protected Area

16

Biol.

Alfredo Arellano.

MC Silvana Ibarra

Tourism managemen t program with PNA Management program structure

system and connection with Chile verde lagoon Creation of a transversal corridor in addition to the proposal Bacalar Flora and Fauna Protection Area (BFFP) PROTUR, Common Management Program for tourist use in the Bacalar Lagoon

Not approved

Regulation and concession payments

Decreed

SCT

Not approved

APIQROO

Creation of a stromatolite reserve in the Bacalar Lagoon It was granted the administrati on of the body of water Stromatolite system and connection with Chile verde lagoon

Result

Rejected

2014

Reason

Suspended

RAMSAR Site Designation

5,893

Dra. Luisa I. Falcón

Lagoon

Institute of Ecology of the UNAM

Area (ha)

22,255

2011

2019

of

22,255

Type proposal

97,591

Proposal leader

219,000

Leading institution

Aprox Lagoon

Year

Neoliberal environmentalism proposals to control of the Bacalar Lagoon.

• •

Secretary of Environment of the State of Quintana Roo and Secretary of Urban and Territorial Development of the State of Quintana Roo, Municipality of Othón P. Blanco.

DirectorateGeneral for Urban Development and the Environment. Municipality of Othón P. Blanco

Otoniel Segovia.

Municipal Program of Territorial, Ecological and Urban Developmen t. Othon P. Blanco

2019

Institute of Ecology of the UNAM, Agua Clara, ECOSUR, SEMARNAT, Secretary of Environment of the State of Quintana Roo and City of Bacalar.

Stromatolite Day for Critical Habitat Proposal

2021

Secretary of Environment of the State of Quintana Roo, IBANQROO, Bacalar City Council, Agua Clara, AC

Bacalar municipali ty Luisa Falcón Francisco Remolina Lic. Efraín Villanueva Rafael Robles de Benito

2021

Citizen and Scientific Council (IEUNAM, ECOSUR, SEMA, IBANQROO, Agua Clara, SELBA, Bacalar City Council, Geoalternativa, and other local groups

Dra. Luisa Falcón

RAMSAR site

Natural Protected Area

In process In process

2020

Integration of all existing instruments and attempt to fill existing regulatory gaps Integration of all existing instruments and attempt to fill existing regulatory gaps

In process

Municipal Program of Territorial, Ecological and Urban Developmen t Bacalar

Basis for declaration of Critical Habitat PNA

Área Natural protegida Laguna de Bacalar

Área natural protegida / sitio RAMSAR

Established the date by municipal council.

Secretary of Environment of the State of Quintana Roo and Secretary of Urban and Territorial Development of the State of Quintana Roo, Municipality of Bacalar.

Basis for declaration of Critical Habitat PNA

Taken up

by SEMA

2020

Result

Taken up by her and the Citizen Scientific and Council

Decree of Chivita snail (Pomacea flagellata) as an endangered species

Reason

Lagoon

Biol.

Alfredo Arellano

Bacalar municipality

Secretary of Environment of the State of Quintana Roo ECOSUR, local deputies of the PVEM, Francisco Remolina, SELBA, AC

Area (ha)

Blanco

2019

Dr. Alberto de Jesús Navarrete (ECOSUR ) Lic. Efraín Villanueva Arcos.

of

P. Othon municipality

Type proposal

Lagoon

Proposal leader

Lagoon

Leading institution

and Lagoon surrounding wetlands

Year

* Approximate calculation of own measurements (KMZ file available) Table Source: Self-Creation.

In summary, we will see how all the actors mentioned in the table and their instrument proposals exemplify the functioning of neoliberal environmentalism, and we will show how they do it so that it goes unnoticed, as Durand (2014) stated: Neoliberal environmentalism no longer tries to sell nature to save it, but to save it to negotiate with it.

17

18

RAMSAR, mexican style To understand where the Ramsar Convention comes from, we would have to ask a question that seems like the beginning of a joke: What did an Arab, son of a prince, a Frenchman, owner of one of the largest and most powerful pharmaceutical and biotechnology companies in the world, and an English, son of a lord, have in common? But it's not a joke, what they have in common is: 1.

2.

3.

4.

All three were influential figures in the politics of their regions, They were powerful businessmen for whom money was not a problem, They were ornithologists and...

They created the Ramsar Convention.

Ramsar's page states that its founders were: Eskandar Firouz (former Minister of Environment of Iran), Luc Hoffmann of the Tour du Valat research station in the Camargue in France, and Geoffrey Matthews of the Wildfowl & Wetlands Trust in Slimbridge, in the late 1960s.

Eskandar Firouz was an Iranian ornithologist, son of Prince Mohammad Hossein Mirza Firouz; Luc Hoffman was at that time owner and member of the board of directors of Hoffman-La Roche. Vice-President of IUCN from 1960 to 1969. In September 1961, he was one of the co-founders of the World-Wide Fund for Nature (WWF) and was Vice Chairman of the Board of Directors of that organization from 1961 to 1988. He also led in 1961 the MAR project, which eventually gave rise to the international convention for the protection of wetlands of international importance, known as the Ramsar Convention, signed in 1971 and founded the Luc Hoffmann Institute, which we talked about earlier.

Geoffrey Matthews was then Honorary Director of Wetlands International (then the International Wildfowl Inquiry), an organization founded by Peter Scott, a close friend of Luc Hoffman, with whom he also founded IUCN and WWF. Geoffrey Matthews devoted a good part of his career to the 19

development and promotion of the concept of an intergovernmental convention on the conservation and wise use of wetland habitats and resources. In that inter Luc Hoffman was on the board of directors as part of the family that owns Hoffmann La Roche.

The initial convening of an international convention came in 1962 during a conference that was part of the MAR Project (from "MARshes", "MARécages", "MARismas"), a program established in 1960 following the concern of developed countries about the speed with which large areas of marshes and other wetlands in Europe were being "used", with a resulting decrease in the number of waterfowl.

The MAR Conference was organized by Luc Hoffmann, with the participation of the IWRB (International Waterfowl & Wetlands Research Bureau), IUCN (the International Union for Conservation of Nature), the International Council for the Preservation of Birds, ICBP (now BirdLife International), and of course the Luc Hoffmann Institute, which we touched on earlier, all NGOs created or with the participation of Hoffman, which contributed, and the MAR Conference was held in Les Saintes Maries-de-la-Mer in the French Shire, from 12 to 16 November 1962.

Luc Hoffmann, the man behind all these initiatives, was then a member of the Board of Directors of his family's company: The Hoffman – La Roche Pharmacological Laboratories. The history of this company is very interesting, given that it is currently the most powerful company in biotechnology and pharmacology worldwide, and is valued at more than 62.1 billion dollars, with a market capital of 287.1 billion dollars. This family business began as a modest pharmaceutical laboratory in the late nineteenth century, selling vitamins and some medicines, until it found vitamin C, which it markets worldwide to date, this supplement allowed it to greatly increase its profits but it was not until after the Second World War, that Luc Hoffamnn, grandson of the founder, biologist by training and connoisseur of the importance and relevance of biodiversity (he was an ornithologist), entered the board of directors, that the company began to become what it is today: The largest pharmaceutical and biotechnology company in the world.

The Ramsar Convention was established in 1971 and was an agreement between 19 countries (currently includes 190 countries) and its stated and stated objective was to protect important waterfowl nesting areas globally.

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Although the agreement says that sustainable development proposals should be considered for these registered wetlands, the proposals for declarations of Ramsar sites are limited to placing value on those elements that allow highlighting the importance of the wetland in ecological, botanical, zoological, limnological or hydrological terms... not social, biocultural or socio-economic.

This has been questioned by multiple social researchers given that it fails to promote effective mechanisms to guarantee the "rational use" of the wetlands they claim to propose and only focus on the environmental component of the site.

As a corollary, the Ramsar Convention works very closely with six global nongovernmental organizations (NGOs) which, in resolution VII.3 (1999), were confirmed as official status as international organizations associated with the Convention. These NGOs are: Birdlife International, IUCN – International Union for Conservation of Nature, Wetlands International and WWF, all created and at some point, led by Luc Hoffman. Without going any further, as Sánchez (2004), stated: “…There are three main ways of obtaining drugs are currently nature, chemical synthesis and biotechnology, which allows the discovery of molecules through genetic engineering techniques.…”

We do not assume anything at this point, but two of them require the active ingredients or genetic material of biodiversity resources and the conservation of the sites where to locate the parental material.

Although the Ramsar Convention was established in 1971, it took our country about 15 years before deciding to declare the first site on national territory, in 1986. It really seemed that it was done by commitment rather than anything else because there was no other declaration until 1995, in the government of Ernesto Zedillo (6 declarations to be precise).

And then, out of apparent thin air, our country was inspired by wetlands and between 2000 and 2012, during the government of pan members Vicente Fox and Felipe Calderón, there was an explosion of declarations: 58 in fox's time and 73 in Calderón's time; someone could argue that there was enormous environmental awareness at that time, but both governments were harshly questioned precisely because of the violation of human rights of the

21

communities and the simulations of creating reserves to hand over to foreign companies the management of key resources.

So, if those two administrations were not characterized by being very ecological or committed to the communities, what was happening in those two six-year terms (from 2000 to 2012) in our country in terms of "conservation" and "protection" of the environment? When one asks oneself that question, it becomes obligatory to analyze the context of the time when the "boom" of Ramsar's Mexican declarations took place.

It is very interesting to note that of the 142 areas established from 1986 to date, 92% of the sites were established in the six-year terms of Vicente Fox and Felipe Calderón Hinojosa. That is, 9 out of 10. It is that apparently, they had no other choice. You see, in 1999, when Ernesto Zedillo –as president– and Julia Carabias –as secretary of Environment– were preparing their departure from the federal government to hand over the political administration of the country to another political party after the Institutional Revolutionary Party (PRI) managed it in a hegemonic way for 75 years, they ensured that the arrangements and management that the PRI had made at the international level could not be reversed, or worse, they were not to benefit members of the triad who were no longer them; and changed the law.

Before this change in law, international treaties were at the same level as federal laws, all below the Political Constitution of the United Mexican States.

But Zedillo and Carabias, among others, managed to place them above any national regulation, only below the Constitution. The justifications of the judges who promoted this reform are summarized as follows: the country and the President would be badly off if we do not comply with the international commitments we acquired, so the President and the Senate have the power to force us all to comply and not make a fool of ourselves; and the second argument went something like this: the President and the Senate can bind us on any issue, even if in any other situation not outside their competence. And as in the end to the International Treaties, because they are international and not Mexican, the constitutional 124 does not apply to them, which limits the legal action of certain Mexican regulations in Mexico, because they applied it to us all.

Thus, an international treaty or agreement, such as Ramsar, was placed above any federal or state law, and in this case environmental authorities were 22

granted (because it is their sector) to intervene when it was considered that the internationally recognized wetland was being harmed and which could leave our country in a bad position for breaching an international convention.

Let's not go and make the world bear.

With regard to the repercussions, although Ramsar officials at the international and regional levels insist that for both this instrument and other environmental policy instruments there is NO retaliation against a party (a signatory country) for breaching it, the reality is that, given the mechanisms created by this and other international environmental policy instruments if there is "punishment" to a party (a country) that fails to comply with its commitments, but it becomes concealed. For example, fulfilling Ramsar's commitments conditions countries like Mexico to obtain international funds, since Ramsar is a prerequisite, for example, of the Global Environment Facility (GEF), in the World Bank.

Non compliers would see their funding opportunities limited and would be badly placed in front of world opinion, so they are obliged to comply, even if it is a simulation, and in a country like Mexico simulation has become a culture.

And since that fund in particular is the one that pays for the affairs of most of the members of the triad, such as financing for ENGO, the CONANP Fund for PNA and the research funds, and everything they can think of for sustainable development, green economy and whatever incentive arises in "pro" of the environment, because we cannot look bad to the Bank, because we would run out of funds for the triad... who are the main beneficiaries.

In this sense, given the hierarchy and the "interest" of the country for the fulfillment of environmental commitments and the urgency of perpetuating the image of leadership and concern for environmental conservation that Mexico strives so hard to maintain, the violation of the rights of locals and indigenous peoples is not an obstacle, when it comes to placing this type of instrument on the territory of indigenous peoples or rural communities. And that, as we will see later, to make matters worse, they are really inoperative environmental instruments.

Going back to 1999, the international financing lines had been "shielded" to ensure that the new governments (of other political parties) did not have access to them, as an example the Mexican Fund for the Conservation of Nature that manages since 1998 the Fund of Protected Natural Areas (FPNA), 23

agreed by the Government of Mexico and the World Bank. With this fund this ENGO ministered (and ministers to date) directly to the protected natural areas, at that time they gave them the rectory attribution to research centers and local environmental organizations, under the pretext that there was no institution in the government dedicated to Protected Natural Areas, exclusively.

By 1997-1998 the GEF had placed several million dollars in the Natural Protected Area Fund and since the government had not grasped the wave of the importance of having an administrative body of the PNA, the money that began to arrive by carts was passed in front of the noses, directly to the promoters and private operators of the triad, and even if they were triads, the government could not allow that. It reminded me of a phrase from my grandmother "among thieves there is no honor." So, organizations such as the Quintana Roo Research Center (CIQROO) or the NGO Amigos de Sian Ka'an, in Quintana Roo, made it a Natural Protected Area administrator. The government denoted to develop its functions through SEMARPNA (T), but did not have access to funds as an administrative entity, so its slice was reduced in relation to that of the private and, to be honest, at the international level the neoliberal pressure of the big interests was already positioning itself in the environmentalist discourse.

So, at the beginning of Fox's six-year term, other ways of financing his bureaucracy were sought using the discourse of sustainability, the so-called Green Plan was established, with GEF funds (World Bank to the rescue). This Plan was to be a strategy of inclusion of sustainability aspects. It was trying to generate a more neoliberal image and articulated with the vision of sustainable development of the new government, clean industry and environmental conservation, which was in vogue. The Green Plan was intended to be a oneyear consultancy to establish the baseline where the environmental policies with a vision of development that Mexico needed would be built, according to the international current.

It was easier said than done. Although it was a new government, under a new political party, many of the previous structures and "tricks" of 75 years of PRI government remained in place, such as the propensity to "deviation", "simulation", "corruption" and the total disarticulation of actors, policies and true intentions; thus, the initiative, and the one-year consultancy to structure the country's environmental policy took 10 years. 10 years of pretexts, of 24

requests for more time, more funds, more consultancies, until the GEF ordered to close and evaluate the achievements around 2010.

From the observations of the audit ordered by the World Bank and supervised by the United Nations Development Program (UNDP), which at that time was the operational arm of GEF, it was found that only two, of the almost 20 millionaire consultancies paid by this fund, were worthwhile, according to the parameters committed. Only 10% of the work delivered, which took 10 times longer, and funds, had any use to consider that it could have contributed something to the development of such a policy, which by then was an obsolete initiative. That is, the money was spent, it took 10 times longer than committed and only 10% of what was done on average would have served for something, but the country was already in other matters, it was too late. Very Mexican Green Plan.

Then at the beginning of Fox's six-year term, the federal government had not been able to throw the gauntlet to the FPNA freely, since the fund was controlled by a private ENGO and the administration / operation of the PNA was in the hands of ENGO and Research Centers. Given that in the inter Mexico had made many commitments worldwide to be "sustainable" (by pure pressure from the World Bank, which as we said is the one who really directs environmental policies around the world – a Bank), the new form of government needed to demonstrate that it could be able to get on the boat of environmentalism, but from their technocratic perspective (which was perfect for neoliberalism). Thus, from the year 2000, ways were sought to comply with the commitments and position as a country, to get a hold in the growing tendency of neoliberal environmentalism, that poured tons of funds to establish mechanisms that "promoted" conservation through sustainable development, so that Mexico would retain the leadership role at the Latin American level before international bodies such as the GEF, while applying the instruments designed at the international level ex profeso (that is, for that very reason).

The government urgently needed to take the lead, and the Commission of Natural Protected Areas (CONANP) was created, with all the powers to administer, control and obtain financing for the PNA. This allowed to recover the administrative control of the PNA and to substantiate the need for more funds to continue creating more PNA, to have more personnel, more administrative expenses and to be able to publicize those funds were being 25

turned over to communities through financing NGOs and some groups, as long as they fit into the paradox of neoliberal conservation: sustainable use for conservation, from the neoliberal point of view. But there was a design problem with CONANP, as a study that they were sent to do, many years later, says: CONANP was born bankrupt, with the goal of obsessively placing hectares under the PNA scheme, without ever stopping to think about how they were going to maintain the structures, personnel, operation and requirements that each addition implied, which in turn led to problems such as the degradation of sites and corruption. Like a kind of compulsive accumulator.

Returning to the happy times of the newly created CONANP, among the attributions that were given to it was the creation of the National Wetlands Committee, as an advisory body, and formed them 3 years after its creation (in 2004). The objective of the Committee was to coordinate the implementation of the Convention on Wetlands of International Importance (Ramsar). How was the Committee integrated? Government sector 60%, civil society organizations 28% and academia 12%. The same neoliberal conservation trinomial as always.

It would seem logical for the newly created CONANP, to seek to consolidate its administration, strengthen itself as an institution and for this it needed to consolidate some kind of "certifying" tool that would position the areas beyond what the previous administrators had achieved. Ramsar was a perfect choice because it implied that they did not have to consult with other actors, such as communities or owners who in themselves might be "a little furious" with the protected natural areas that had been placed on them, mostly, practically in the backyard of their communities or PNA that had "ironed" their territories.

To answer some of the questions about what really happens and the way in which the registered wetlands work administratively and operationally, what would have happened to Bacalar if this group had achieved its objective, we will make a brief analysis of how Ramsar works in Mexico. The paragraphs below analyze the results expressed by Mexico, taken from the National Reports on the implementation of the Ramsar Convention for our country.

We take the National Reports that were presented for the 12th and 13th meeting of the Conference of the Contracting Parties (COP12) in Uruguay, 2015, around which time the proposal was promoted by Dr. Falcón and the 26

other actors, and a comparative reference of the national report for COP13, where we include data from the 2018 report.

Let's talk about numbers, for 2015 How much surface area was there in Ramsar declaration? Page 29 of the 2015 report stipulates: area under declaration: 5'413,568.79 hectares. From just over 5 million in 2015, it jumped to just over 8 million hectares in 2018. This is relevant if we stop to think that IN NONE OF THE CASES, they took the trouble to consult the owners or users of the territories whether or not they wanted to place their territory as a Ramsar site; and here the self-appointed NGOs representing society do not count, nor the close groups of similar environmental interests, which are usually neither owners nor historical users of the territory. 8 million hectares decreed by unilateral decision of one or all members of the triad.

How many Ramsar sites were there in 2015? 63 Sites that were formerly a Federal Protected Natural Area, 79 Sites that were a state or municipal PNA or some protection figure, or Sites without any regulation or prior protection figure. Here we return to this last data of 79 sites that were either state PNA or were municipal PNA, or had some type of protection or were none of the previous ones. It sounds like a joke, it made me laugh: we told the international community that 79 sites were red, or they were black, or they were green or they were none of the previous ones. Guess which is which... shame on you CONANP! Why not just separate the data by category? Simple, because they didn't have the data, or they didn't want to give the data.

When you declare a Ramsar site, what's next? Once the declaration has been established in a site, for all cases, CONANP develops a Management Program or adapts the existing one (if it is an PNA and already has one), which must integrate the ecological and monitoring tools, developed by Ramsar. Because Ramsar's approach is ecological and biological, so no matter the social groups and local economic activities, which are subordinated to the "common good" of the environment and species of flora and fauna or ecological processes.

How many Ramsar sites have a Management Program? An PNA is supposed to be based on the management program, but that does not seem relevant to the Mexican triad. I explain, since there were 63 PNAs as a Ramsar site, one assumes that at least there should have been by 2015, approximately 63 Management Programs of the 63 federal PNAs / declared Ramsar sites, plus some of the 79 state / municipal PNAs, leaving out who knows how many 27

were of another type and who knows how many were that were none of the previous ones, also mentioned. But no, the 2015 report admitted that only 12 Ramsar Sites, less than 10% of the total Ramsar Sites in Mexico, had such an instrument. What happened to all the PNAs that some had been decreed for more than 30 years? Why didn't they use your Management Program? Maybe because they didn't have them.

Then they make a series of assertions that we see as VERY FALSE, when we review the CASES of PNA/Ramsar. CONANP ensures that the Management Programs of the PNAs that are also Ramsar sites, incorporate social, economic, ecological issues and a legal framework that will allow the generation of strategies for the conservation, protection, management (use and exploitation) and restoration of them. Likewise, it ensures that they encourage the proper use of the system and promote the realization of productive activities, for the benefit of the quality of life and well-being of the population with emphasis on rural and indigenous communities that live near the wetlands.

It continues to inflate the role, arguing that Ramsar site management guidelines seek to ensure consensus with the actors involved, but if we take into account that even for 2018, the 8 million hectares that were declared as Ramsar sites were established in the first place WITHOUT consulting those involved, without their approval and what is more, most of the time the communities, local inhabitants and historical users did not even know that they were declared a Ramsar site on their territory, because it is difficult to verify their saying.

The case of the ejido Dziuché, in the municipality of José María Morelos, Quintana Roo, later exposed, serves as an example to deny the statement of CONANP where it ensures that the documents are consulted with the local communities through workshops, particularly, the zoning proposal and its management matrix, prior to its adoption as a final instrument. The owners of the land did not even know that they applied a Ramsar in more than 11 thousand hectares of their ejido, by Friends of Sian Ka'an... and then they wanted to put an PNA, what were they thinking?

So, the assertion of the promoters of Ramsar's declaration for Bacalar, where they argued that the federal or state environmental authority would not be involved in determining the way of life and destiny of the productive activities 28

of the premises because Ramsar "was NOT established by decree, and was not like an PNA", was FALSE. When you create a Ramsar Management Program, what things are written in them? What does the management program say, which is going to be done on the Ramsar site? With what actions does the triad say that the Management Program will save the wetland? Above all, taking into consideration that I needed to understand, what did a Program of these look like for a site that was not previously an PNA, like Bacalar? Since there were 79 Ramsar sites that were state, or municipal, OR were either something else or were not PNA, I assumed that in that pile of sites, I could find something. It was not easy to find these types of examples, which gives an idea of the scarce effective operation of the model in our country.

Fortunately, double fortunately, I found one of those programs made in 2014 for the Ramsar Presa La Vega site, in the State of Jalisco. A site that was not before some kind of PNA Who did the Program? Researchers and academics of the technical committee for the integral management of the La Vega Dam, which included the University Center of the Valleys, officials of the State Water Commission of Jalisco, the Ministry of the Environment for sustainable development, the Promoter of the conservation of Culture and Environment A.C. – triad of promoters of the neoliberal environmentalism model. Why was it a double fortune? Because we found that the consultant that made the Vega program, called Geoalternativa, was the company that would later be hired by the Secretary of environment of Quintana Roo – then in charge of Alfredo Arellano Guillermo – and the Secretary of Tourism in charge of Marisol Vanegas, to create the infamous PROTUR, which we will talk about in due course.

What activities did the Ramsar Presa La Vega site program include? What interested the program builders? What activities were going to help save the Ramsar Presa La Vega site? In summary (and mentioning what are the types of actions that include): • Protection subprogram, includes surveillance, training on rules and regulations, signaling, promoting PNA declarations when areas do not have them, agreements with universities, research centers, monitoring of water resources, discouraging productive activities "not compatible" with the vision of conservation (of the triad).

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• Management subprogram: Includes ecological and biological monitoring activities, reforestation, more monitoring, involvement of universities and research centers, training, more monitoring, promoting territorial Ecological Ordinances, managing before SAGARPA and other instances the "reconversion" of risk systems or activities that make use of excess water, training, creation of territorial tourism ordinances to attract investment, certification of tourism service providers.

• Restoration subprogram, actions for "appropriate" allocation of water for the wetland, reforestation, management before various instances for reforestation, surveillance, increase species in NOM 059, involve universities and research centers to carry out restoration, studies, consultancies, municipal infrastructure, more monitoring and disseminate information to the public.

• Subprogram of knowledge or communication, includes involving the inhabitants in the research activities that make education centers and researchers – they call it citizen science, I call it cheap labor and tokenist validation -, involve educational institutions to do research permanently, monitoring and more monitoring, agreements with universities and research institutions for research, geographic information system that will usually be in charge of a university or research center, create centers of education or dissemination or environmental education managed by non-governmental organizations, research centers or universities, environmental promoters, organize producers to comply with the Annual Operation Programs (POA), the management plan, manage restoration involving the community).

• Education subprogram, more training for producers, official education, inclusion of conservation policies in CONAGUA decision-making, workshops, diplomas, courses, involving universities and research centers to do so, promoting ecotourism, training and more training, creating an environmental training center or something similar for academic and government institutions to educate the public.

• Management subprogram, create funds, trusts, manage supports, funds and calls in collaboration with government institutions, NGOs, academic institutions to obtain funds, diagnoses, studies, consultancies and plans, training so that the population "learns to do their activities well in the wetland”.

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You do NOT have to think hard to realize that the program was designed between academics and authorities; the consultation was limited to workshops, without describing methodology, size or scope of the same, nor were data of participants and form of validation provided before community or ejido assemblies or any design mechanism that really showed that the rules of participatory planning were complied with at the international level or even national regulations, outside the environment.

We must not try to understand what happens between the triad by dividing the sites and placing their activities on paper to make it a decree. Agreements and agreements are made between government, academic bodies, research centers and non-governmental organizations; the population is only a passive recipient of education and projects related to the triad's vision of what their role should be: activities "suitable" for them and the wetland, as passive actors, as if they were only observers who see from afar this party between the promoters of the Ramsar sites and the creators of the Management and Conservation Programs to control and manage their house, without being invited.

Is management and conservation under the Ramsar Site Program effective in Mexico? One would assume that so much enthusiasm for the declaration of sites in Mexico, on the part of all these instances of government, academics and researchers and NGO, could be due to the fact that the effectiveness of this model for conservation is excellent. In addition, counting on CONANP, a government body created precisely to ensure that the conservation and protection of territories work, which has a fund insured to operate each year through the Fund of Protected Natural Areas (FPNA), financed by GEF and administered by the Mexican Fund for the Conservation of Nature, we would have a guarantee to ensure the effectiveness of the actions on these sites, but this is not the case.

From the Chavodelochesque (nonsense) responses of CONANP to Ramsar, to the question asked by the Secretary of Ramsar in the report format for Mexico COP12 Has any evaluation of the effectiveness of the management of Ramsar Sites been carried out? in the 2015 National Report, the answer of our country was: NO. What does that NO mean? It means that, 28 years after Mexico was adding hectares, violating the rights of the populations, syringe that it was for 31

the common good, for the wetlands and was the only way to effectively conserve a site; 28 years since Ramsar's first declaration in Mexico. 28 years later and the managers did NOT know whether or not the Ramsar sites were being effective for what they were decreed. We already had a lot of sites, an area under Ramsar wetland management at 5,413,568.79 hectares and we had never done an assessment to know if they were complying, we didn't know if they really worked.

Worse, not even the fact that most of these sites were previously declared natural protected areas, with budget, staff and a multiplicity of ENGO and academic actors and researchers working on them since 1986 provided them with information to be able to answer that question from the Ramsar secretariat.

What did Mexico do about it in order to improve the answer to the question for the next COP13? Was the necessary and obligatory evaluation carried out? what other countries did? That is, do we focus the batteries on existing sites to consolidate them and improve the indicators? No! We said: we don't know how the 5 million hectares are, so let's declare more hectares so that it is not noticed! So, for the next report of 2018, we present ourselves with 142 sites and more than 8 million hectares under Ramsar denomination in Mexico.

We still didn't know if they were working, but who cared! How good we looked with almost three million hectares more on our shelf. Not like the United States, with only 40 sites and 1.8 million hectares, or Canada, only 37 sites, although they covered more than 13 million hectares, but in the latter case had not declared any Ramsar site for more than 15 years, and that both had only dedicated themselves to consolidating their sites and meeting the indicators.

We continued with the same problems of lack of funds, making it a priority for Mexico to obtain funds but without fulfilling key aspects: There was no data to determine if the Ramsar sites had improved water use, or if effective management planning was being implemented, without counting official management plans, or without knowing if the private sector had been encouraged to make better use of these sites and their resources. By 2018, after 32 years obsessively declaring Ramsar Sites, only 28% of the sites had been fully ecologically characterized and only 36.6% had intersectoral 32

management committees, and that is because CONANP used the Advisory Committees of existing reserves declared Ramsar sites, and it was not even fulfilled.

Imagine this Ramsar situation as the family party of the North American family, where if the Ramsar sites were children, Canada and the United States would have closed the factory so as not to continue accumulating children, and would have dedicated themselves to giving them education, nutrition, giving them the tools to put them to work and see that they fulfilled their goal in life; and our country is the loudmouth brother who comes to every family reunion bragging that he already has more children... starving, uneducated, in rags and lice. And whining to The World Bank (daddy) to give him more money to support them because it is not enough with so much children, and so every family reunion; giving pathetic excuses as to why he doesn't have his children in better condition and referring to justifying that it's because he never gets enough money, because his goal is to have more children, not to support them or make sure they are okay.

We did not comply even because they made it easy for us. By 2018 only 18 sites, out of 142, had been subjected to evaluation of the effectiveness of the management, nor because they put us the R-METT method, which is like a survey that is filled out and in which points are added to see data of the site, name, size, location, identification and description of the ecological elements, and data that were put from the beginning; it is a survey that practically oneself answers and qualifies. And even so, in Mexico only 18 evaluations of this type were met, that is, 12% of the total of the Ramsar sites declared, in 32 years.

By 2018, no plans or projects had been made to maintain or reinforce the role of wetlands to help or maintain viable agricultural systems. This is a key point that should be a priority in Ramsar initiatives in our country, as it would allow us to stop criminalizing agricultural products and establish better strategies that would respect biocultural heritage and improve the relationship of wetlands with human populations. What did the triad do on this issue? What they do best: Criminalize producers; for example, in Presa La Vega, the solution was: eliminate concessions for agricultural use once they expired, if they had involved land use change. That is, a kind of punishment and retroactive sanction.

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The 2018 report also failed to work on documentation of and respect for traditional knowledge, innovations and practices of indigenous peoples and local communities that related to the wise use of wetlands; that is, Ramsar Target 10 for COP13 was not met.

Ramsar COP13 Target 11 required the wide demonstration, documentation and dissemination of the functions, services and benefits of wetlands. In Mexico only 2 (1.4%) of the 142 sites partially met the requirement, none included cultural values in management planning. So, it was not fulfilled either.

The response given to the fulfillment of COP13 Target 13 is striking: Have measures been taken to increase the sustainability of key sectors such as water, energy, mining, agriculture, tourism, urban development, infrastructure, industry, forestry, aquaculture and fisheries when they affect wetlands? The answer was: YES. It is not surprising at the outset that the answer was YES, the surprising thing was the explanation of this affirmative answer. In Mexico, the actions to increase sustainability, I repeat: to increase sustainability, of key productive sectors in wetlands were: "... the Rules of Operation of SAGARPA will NOT grant support to lands classified as Ramsar Sites, except for those activities that do not involve a change of land use..." I no longer knew whether to laugh or cry.

That is, the Mexican strategy to increase the sustainability of productive sectors that were key and that the Ministry of Agriculture and Livestock saw in wetlands was: deny support to the agricultural sector if it involved agriculture and livestock (change of land use) in a wetland. Answer: We increase the sustainability of agriculture and livestock in wetlands, denying them support to stop farming and ranching. And it's not a joke, it's an anecdote. Probably those producers ended up being guides of tourists or artisans, which is what the triad considers that the locals should dedicate themselves to.

To be fair, it would have to be said that it was not only a matter of not making a fool of ourselves in front of the international community by saying that Ramsar was just an excuse to ask for more money and strip the locals of their territories, it would also have to be said that it was about avoiding being punished for not complying with the neoliberal quotas of the international community. Although of course, it would be easier if we did not get into an 34

eleven-rod shirt to have to continue doing as if we comply, without really complying, and everyone pretends that they do not realize that our country uses ridiculous excuses and explanations that seem to be written under the effects of some narcotic, when presenting reports that border on the ridiculous and ludicrous.

Another thing, Ramsar is not free. It is not a goodwill agreement, belonging to Ramsar not only implies signing a document, you also have to pay a fee as a country, because it is a contract where you have to make annual payments.

Also, in the Ramsar report format Has Mexico already paid its dues to Ramsar? On average our country disbursed between 80 to 114 thousand Swiss francs a year - an average of two million pesos a year, at the current exchange rate - between 2012 and 2014 to pay contributions to Ramsar.

So, if Ramsar's strategy is being implemented in such a mediocre way in Mexico, if it is so disjointed and lacking a comprehensive approach that allows the country to meet the minimum requirements of sustainability, respect for culture and people within the framework of the Convention, why is Mexico still incorporating Ramsar sites?

As we mentioned before, the answer is simple, the promoters of these declarations that come from academia or research, are not interested in human populations, because their approach, topic and often their conflict of interest are species, ecosystems or their idea of the untouched wild site, funds, recognitions or points in the National System of Researchers.

Environmental non-governmental organizations, on the other hand, as selfappointed representatives of society, "survive" and some "live quite well" from these initiatives, getting significant economic benefits, prestige and recognition without really being able to prove a positive impact of their actions.

And so, government, obtains recognition, funds and other juicy benefits that are created from over-regulation and control imposed in a forced manner on local actors, which often results in the juicy business of corruption.

As in the rest of the country, most Ramsar sites in Quintana Roo were declared between 2003 and 2008. 13 areas were established that were approved, and an additional proposal, that of 2014 for Bacalar, promoted by Luisa Falcón and her team, which did not proceed. Of these, 9 were proposed directly by the Directorates of the same reserve, as part of CONANP, 35

without saying that water goes to the local communities. Two sites were proposed by Amigos de Sian Ka'an, one by a local group of environmental NGOs and one more by the Secretary of the Environment of the State of Quintana Roo. All declared between 2003 and 2009, during the six-year term of Vicente Fox and Felipe Calderón.

Chichankanab Lagoon is an unprecedented case that set a precedent of the owners of the territory gaining their right to eliminate an PNA decree imposed by the members of the triad, on their territory. But Ramsar's declaration could not be eliminated. Friends of Sian Ka'an registered the wetland of 11,609.73 hectares of the territory of the ejido Dziuché, an indigenous ejido nucleus, located in the municipality of José María Morelos, to the west of the State of Quintana Roo, where the lagoon and wetland system of Chichankanab is located... without notifying and without the authorization of the ejido. Subsequently, as the Mexican strategy provides, an attempt was made to convert this territory into a Protected Natural Area by the government of the state of Quintana Roo, but the ejido managed to reverse the decree in court, but not the declaration of Ramsar site.

After reviewing Ramsar's procedures, a procedure for "deleting" or "removing" a designated site from the list could not be found. There is only one site relocation mechanism, called the Montreaux mechanism, for Ramsar sites that are subject to negative change, but what if the owners of the areas where the wetland is didn't want their site included in the first place? If the designation was from a third party, without authorization.

In the case of Laguna Chichankanab, the site, without Ramsar and without PNA, worked well and was under a scheme of use and conservation through the Forest and Wildlife Management Program with authorization at the federal level, many years before, by decision and royal community approval. Because the community didn't need environmental encomenderos, maybe that's why.

If they were not like PNA, if they were only sites for the conservation of wild species of birds, as was the initial spirit of the convention (or its pretext) – it was reasoned locally – they would be supervised and under the management and supervision of the General Directorate of Wildlife (DGVS), of the same SEMARNAT, which is precisely the one who is granted the issue of management and protection of mangroves and species in the risk category of flora and fauna, such as waterfowl, since the time of the Presidency of Felipe 36

Calderón. That is, a Ramsar site would be more of a Management Unit for wildlife conservation (UMA), supervised by the General Directorate of Wildlife, and not a Protected Natural Area (PNA) managed by CONANP.

2011 – 2014 RAMSAR. 97,591 hectares for the triad What did Ramsar's proposal for Bacalar include?

Between 2008 and 2009 some academics and researchers from ECOSUR and the University of Milwakee, had been preparing the ground media-mind to create an PNA, promoting forums and working meetings around the urgency of establishing some protection system for the fragile ecosystem of the Bacalar lagoon. But it was not until 2011 that two researchers from the Institute of Ecology of the UNAM (IEUNAM), headed by Dr. Luisa Falcón, specialized in microbial ecology, microbial mats, microbialites and biofilms, in different aquatic environments, and M.C. Osiris Gaona, a specialist in bat microbiomes, unilaterally presented the proposal to incorporate the Bacalar Lagoon as a Ramsar site.

It seems that since they made their proposal for Bacalar, they proposed to get the support of other actors in the triad and this was not only to promote their idea, but to increase the number of hectares they were going to obtain and leave under protection / control, at the expense of whoever it was. The list below exposes not only the actors involved that were mounted in the proposal, but also the number of hectares that each incorporation added to the proposal of Falcón and Gaona: • 2011. Proposal by the Institute of Ecology of the UNAM. Lobbying researchers, academics, organizations and local governments (5,893 hectares) • 2014. Incorporation of ECOSUR researchers: Dr. Héctor Hernández Arana (with a specialty in Marine Benthic Ecology), then director of ECOSUR, Dr. Miguel Ruiz Zárate (specialty benthic organisms and, after 2015, remote sensing) and MC Alejandro Vega Zepeda (Marine Ecologist, GIS and Remote Sensing) to rethink the proposal for Ramsar, now proposing stromatolites and connection with Laguna Chile Verde to the east of the Bacalar system (22,255 hectares).

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• 2014. Second proposal. (26,422 hectares), including wetland ecosystems between Bacalar lagoon and Estero de Chac.

• 2014. Third proposal. Expansion of actors involved: Ministry of the Environment, represented at that time by Mr. Rafael Muñoz Berzunza, Undersecretary José Luis Funes Izaguirre, the director of the Manatee Reserve, Biol. Víctor Manuel Hernández and the state director of ordinance regulations. Salvador Poot Villanueva. (92,591 hectares).

This proposal was supported by the city council of Bacalar, chaired by José Alfredo Contreras Méndez, and the city council of Othon P. Blanco, headed by Eduardo Espinoza Abuxapqui. This initiative was much more ambitious, since it included terrestrial and aquatic ecosystems in the community-owned territories of 11 ejidos, with 4 population centers, directly affected, as well as another 4 populations, indirectly affected.

Neither ejidos nor settlers were consulted or taken into account. The Xcalak Reefs National Park, the Manatee Sanctuary, Chetumal Bay (71% of the proposal) were incorporated and the remaining 29% were in "unprotected" areas such as the Estero de Chac (Hernández-Arana, et al, 2015).

• 2014. Fourth proposal. The previous surface did not seem sufficient and finally the body of water, apparently proposed by CONANP, was incorporated. This final proposal had 97,591 hectares.

Actors involved: Ministry of the Environment, represented at that time by Rafael Muñoz Berzunza, José Luis Funes Izaguirre, the director of the Manatee Reserve, Víctor Manuel Hernández and the state director of ordinances Salvador Poot Villanueva.

Also included were the municipalities of Bacalar, headed by José Alfredo Contreras Méndez and Othon P. Blanco, headed by Eduardo Espinoza Abuxapqui. Alfredo Arellano Guillermo was quoted as a representative of CONANP, but the "letter of intent" document does not include the signature of any legal representative of the National Commission of Protected Natural Areas, although in the zoning of this proposal it is stated that the last 5,000 additional hectares included, which correspond to the lagoon body, were proposed or included at the initiative of CONANP.

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At the same time, the academics created a parallel proposal to "scientifically reinforce" the Ramsar site proposal. Either as a justification or as a future incorporation, researchers from ECOSUR and the UNAM Institute of Ecology created a more extensive proposal and called it the Bacalar – Chetumal Bay Transversal Corridor. As it usually works for the triad, this parallel proposal generated funds and prestige. This corridor was intended to connect the proposed area of 97,591 hectares and a much wider corridor that included the entire Bay of Chetumal and Mahahual, to the south – east, bordering Belize, to include the Xcalak Reefs National Park (also a federal PNA).

The pretext was that all these areas were interconnected and the Ramsar declaration guaranteed the permanence of the biological processes of the interconnected ecosystems, their maintenance, conservation and protection.

If they had asked local actors how the Bacalar geohydrological system worked, they would have learned that the most relevant interconnections and significant impacts come from the limits of the upper basin of the system, to the west, NOT to the east as was the proposed corridor. That is, his proposed corridor was at the opposite end, the receiving part of impacts to geohydrological and biological processes. The area of origin of impacts is 300 kilometers to the west between the limits of Campeche and Tabasco, and in the northwest, on the limits of Quintana Roo and Yucatan. There was NOT much to be done to protect the biological processes of the Bacalar area and towards Chetumal Bay, from the impacts that happened upstream. But working with agricultural and forestry communities does not seem to be so cache and, as several researchers of the triad have told me personally, they work with snails, with stromatolites, with water pollution and giving talks in schools or academic events, but they do NOT work organizing people, less of communities. They can give talks to teach people how to "take care" of their environment, but they're not going to organize them. They are not engaged in that (nor are they interested).

In addition, the fact that the proposals have a foundation or have a real positive impact is never the objective of the triad, with sounding scientific for public opinion is enough, as I had to verify on more than one occasion; their intentions are always to benefit them. In the case of the Transversal Corridor proposal, the triad groups were already receiving benefits for proposing the site, even without having declared it. And they had no qualms about exposing it openly in a presentation made to attract other interested like-minded 39

groups, where they made it clear that the beneficiaries of the opportunities that the Ramsar site would bring to Bacalar, would be researchers and academics, ENGO and authorities.

If we take as an example the proposal of the Coastal Transversal Corridor, which is an initiative of ECOSUR Chetumal, its inclusion in Ramsar's proposal gave it a reason for being and validation to justify that the ERIS antenna that had been under repair the two years before, was being used, at a cost of 4 million pesos; so, it was the opportunity to generate a series of projects to get funds and show that they were using this technology for the common good.

Between 2014 and 2015, that cost Mexico 15 million pesos, for a research project in which ECOSUR was involved, led by Héctor Hernández Arana, then director of that institution in Chetumal, the Mexican Space Agency, with funds from the National Council of Science and Technology (CONACYT), in an alliance with the United Kingdom space agency and the University of Surrey (England) that invested 1.5 million pounds sterling (approximately others). 38 million pesos at the exchange rate of 2015) to perform a remote sensing analysis, which among other things served to justify Ramsar's declaration. 53 million pesos for research that resulted in a series of scientific articles, some interviews, a workshop for scientists, ENGO and government, and merits in the National System of Researchers, but that outside of that, after 6 years, has not demonstrated its practical usefulness in the territory, although it is still used to substantiate its "urgent" requests to establish an instrument of control (after Ramsar, it was the PNA, PROTUR and Critical Habitat, and again Ramsar), more publications, collections and more research.

Trying to sell their proposal, in that presentation, the promoters when presenting the supposed benefits of the declaration of the Ramsar site, exposed: •

A joyful account of complementing the objectives of the REDD+ initiative

The Program to Reduce Emissions from Deforestation and Degradation promoted by the UN Framework Convention on Climate Change, an international group that from time to time generate carbon to the beast to travel and I will meet for weeks to talk and plan what to do to stop climate change. As of 2021, they have already held 26 meetings. Going back to 2005, 40

the 11th meeting raised the idea of financing actions for developing countries to reduce emissions from deforestation and degradation of their ecosystems.

Many will wonder why it is not better to stop and reduce the greenhouse gas generating activities of developed countries, well, first because they do not feel like stopping doing what they do, because it gives them pretext to criminalize the poor countries that have the forests and accuse them that we do not know how to take care of what we have and it is necessary that they pressure us while they control our economies by international pressure and because they pretext have the money and we underdeveloped needed the money. Like a cycle of international violence where Daddy World Bank beats mom Mexico, and mom and her favorite children, dispossess, starve and humiliate their weakest indigenous children and local groups to keep the father happy so that he does not starve them and reward them for being obedient. Something like that.

REDD+ has really passed without real results and continues to benefit only consultants and intermediaries. And time serves governments to condition and get the funds for carbon capture or avoided deforestation. And that it is currently a model where the federal government, through its institutions in the environmental and forestry sector, directly benefit from obtaining carbon credit payments. Even when the areas are under private or communal property, they require institutional authorization, for which, through CONAFOR, it would imply consulting the rest of the environmental bodies of government to obtain their permission, mainly CONANP, if an area were to become a RAMSAR site.

• The economic benefits of biotechnological development, for example, of the cyanobacteria of stromatolites that can degrade pollutants.

Well, don't pollutants kill them? The discourse of the triad to criminalize the locals goes to waste with this proposal of the promoters. It turns out that cyanobacteria degrade pollution and it can be a good biotech business. Put your ideas in order, people.

This topic of personal interest for Luisa Falcón and other academics who are looking for benefits for themselves, as can be seen with the patent on cyanobacteria, requested in her name and name of her mentor Valeria Souza in 2012, approved in 2014 and granted by the World Intellectual Property Organization, just one year after they began to promote their urgency to 41

decree Bacalar as a Ramsar site. This benefit is related to the potential market/environmental services by nitrogen fixation as fertilizer and with carbon fixation. That is bioprospecting – potential biopiracy – even with the modifications to the Science and Technology Law made in 2015 that promoted it. I do not know about you but I would call it "Conflict of interest of stratospheric dimensions" if these actors who promote the delimitation of protection instruments where this type of resources is located, were carrying out bioprospecting / biopiracy.

• A potential payment for environmental services of stromatolites and mangroves for carbon sequestration.

To get an idea of what Luisa Falcón meant by this statement, just take a look at the report by Russi, D. and other authors, called: "The Economics of Ecosystems and Biodiversity for Water and Wetland", published jointly by Ramsar, the European Institute for Environmental Policy, Wetlands international, the Convention on Biological Diversity, IUCN and the Helmholtz Center for Environmental Research UFZ, a report where the monetary value of the services provided by wetlands was calculated in international dollars, per hectare, per year. Monetary value was placed on four types of services: 1) Provision services, 2) Regulatory services, 3) Habitat services and 4) Cultural services. In that document, the advisory group presents a table of minimum and maximum monetary values that wetlands can generate.

If the criteria defined by them are followed, the value of the services generated by wetlands such as the Bacalar lagoon, which falls into the classification of "lakes" would reach a minimum value of $1,779 international dollars per hectare to a maximum of approximately $13,487 international dollars per hectare per year, depending on the services provided, calculated for an area of 5,814 hectares.

But there is also an extensive area of wetlands that includes the sedimentary or floodplains that are located in the center and the estuaries, such as the Estero de Chac, which would reach a minimum value of $ 981 international dollars per hectare per year to a maximum of $ 44,590 international dollars per hectare per year, in the area of sedimentary plains, lake soils, wetlands, flood areas, savannas and petens, and comprises approximately 8,413.12 ha and is located in the vicinity of the body of water, but mainly in the central 42

area. You can imagine how many neoliberal environmental actors rubbed their hands and the "love" for protecting and placing under protection (control) as many wetlands as possible, was resuscitated They pretend they don’t know that communities are developing, since the 1980s, various instruments to preserve their territories. These include the certification of impact on environmental services of their good land management practices, such as the international certification of the Forest Stewardship Council, and voluntary markets for carbon capture, managed through the communities and their technical teams. Although these incentive mechanisms were generated at the level of neoliberal environmentalism, of the market to "save nature", communities while resisting, adapting and taking advantage of them. Does not require a Ramsar site to drive payment for Environmental Services.

• That Bacalar functioned as a kind of natural laboratory At the disposal of municipalities, the State, ENGO or public research center, universities and institutions of secondary education, since the delimited areas were neither in the water nor in the ejido polygons or of private properties or possessions, rather in areas of floodable sedimentary plains and the body of water that were subsequently placed as protection zones, but that most are possessions.

• Finally, the proposed area would have the potential benefit, they argued, of being presented as an "area with a sustainable use of natural resources in tourism.”

As we will see later neither the Ramsar sites, nor the PNA, nor tourism have been able to guarantee that. A very well-orchestrated simulation between government and academics, and an effective way to have reserved territories, full of biodiversity that can later be commoditized, that is, they can be priced as if they were a thing, for the benefit of large capitals.

In addition to these attractive benefits for the actors of the triad, there was the power to control a huge territory. The Ramsar initiative for Bacalar, which began with only 5,893 hectares included the lagoon, the Chac estuary and the wetlands between them and ended up proposing 97,591 hectares (an increase of 1653% in 3 years), where the Xcalak Reefs National Park, the Manatee 43

Sanctuary, Chetumal Bay, which together made up 71% of the proposal, were incorporated, and the remaining 29% in "unprotected" areas such as Laguna de Bacalar. The triad was having a fest, and at no time the legal owners of the adjoining territories, the inhabitants and users of the ecosystems, were included in the negotiations or even consulted. Fortunately, the declaration of a Ramsar site for the Bacalar Lagoon was put on hold in 2014. Perhaps the beneficiaries are reached an agreement, and realized, municipalities and state that everything was going to be under the supervision and monitoring of CONANP, or what unofficially happened, the proposal did not bear fruit.

However, at least Luisa Falcón has not relented in her intention; in fact, by April 2021, he made a public statement that points to the promoter group returning to the streets to declare a Ramsar site to the Bacalar Lagoon. Said: “…The university affirms that various scientific groups warned of the deterioration of the Bacalar Lagoon, at least seven years ago, and it has been requested that it be included among the RAMSAR sites of Mexico -referring to Wetlands of International Importance- or be declared a Protected Natural Area or Critical Habitat, in order to ensure its conservation…”

However, these proposals have not prospered and the pursuit of quick gain has been deteriorating in the ecosystem. "There is a misconception with conservation. People believe they won't be able to do anything; however, it is the other way around. If you take care of the resource, you can take advantage of it for the rest of your life," she said...” (Gaceta UNAM, 27th, April. 2021) All the elements of manipulation and myth-making, criminalization of the locals as ignorant and petty, justifying the actions of the triad as something almost heroic. The truth is that who has been benefiting, including obtaining juicy scoring benefits in the National System of Researchers, funds to establish a laboratory of evolutionary ecology, funding of thesis, equipment, not even mentioning a patent in his name for future developments of fertilizers from genetic material of cyanobacteria and media visibility has been the interviewee.

I don't know about you, but that's really a "quick win," for just tearing your clothes, changing your discourse depending on who you're talking to, and manipulating your followers with "scientific" data that you modify as locals unmask and refute your signals. 2 billion potential dollars worth the cyanobacterial biotechnology market for fertilizers, such as the patent it holds, could also be considered profit, perhaps not so fast because it has to be sold, 44

but it is more than any local group would dream of earning with its economic activities added up, not to mention that it is a serious Conflict of Interest, or biopiracy, as I prefer to call it.

In Bacalar, Luisa Falcón and her growing group of enthusiastic precursors of Ramsar’s declaration insisted again and again that Ramsar was NOT like establishing an PNA. The locals, in their intuition and understanding wondered why if declaring a Ramsar site does not mean establishing a Protected Natural Area, this system was under the administration and monitoring of the National Commission of Natural Protected Areas? Because, indeed, YES it was something very similar to a Natural Protected Area.

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APIQROO On January 2, 2014, while the triad promoting the declaration of the Bacalar Lagoon as a Ramsar site met and planned the incorporation of more actors and more hectares, the Integral Port Administration of Quintana Roo (APIQROO) S.A. de C.V., was made the concession for the administration of the Bacalar Lagoon. A kind of cheat base stealing maneuver.

The Secretariat of Communications and Transportation (SCT) granted APIQROO the concession for the Integral Port Administration of the ports of Isla Cozumel, Chetumal, Puerto Juárez, Puerto Morelos and Isla Mujeres, in the State of Quintana Roo, since 1994. This gave it authority for the use, exploitation and exploitation of the public domain assets of the Federation and of the works and facilities owned by the Federal Government, as well as for the construction of marinas, terminals and port facilities and the provision of port services in the aforementioned ports. In 2014 an addendum was made where the SCT also granted the administration of the Bacalar Lagoon. Thus, the State Government took control of the Lagoon with its company.

An API (Integral Port Administration) is a commercial company that is entrusted with the planning, programming, development and other acts that are related to the goods and services of a port through the concession for the use, exploitation and exploitation of the goods and the provision of the respective services. That is, Mexican ports are owned by the Nation (they belong to all Mexicans) but the law allows them to be concessioner for their administration, construction and operation. According to the above, the function of each API is to build and operate the terminals within the port area and to provide port services or to hire private operators.

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In Quintana Roo, the Integral Port Administration (API) is under State responsibility. This includes the Chetumal, Playa del Carmen, Cozumel, Puerto Morelos, Cancun and Puerto Juarez APIs. It also includes some ports and terminals not concessioned to an API, such as La Aguada, Xcalak, Mahahual, Punta Allen, Puerto Aventuras, Cancun, Holbox and partially the port of Punta Venado. Bacalar, granted in 2014, is part of the Chetumal API. The General Directorate of Ports has among its powers: "to process concessions, permits and authorizations in the ports of Mexico, to authorize or build port, maritime and dredging works; authorize master port development programs," including regulating the operation of APIs and approving their contracts. Since the Bacalar Lagoon was declared a national property, along with Huay Pix, Chac Laguna stream (estuary) and Milagros in 1990, they are goods that fall under the competence of both CONAGUA, SCT and SEMAR. While all APIs are located in coastal areas, port captaincies are included for coasts and for inland bodies of water, as is the case of the lakes of Chapala, Cuitzeo or Catemaco, among many others. When the concession on the administration of the body of inland water that was the Bacalar Lagoon was given, the rumor arose that this concession was not within the competence of the SCT, since the one who was empowered to manage the water in Mexico was the National Water Commission (CONAGUA).

However, reviewing the regulations, CONAGUA's competence refers to the quantity and quality of water from surface and underground water bodies, its concession for direct use of water resources, the infrastructure for its extraction or what refers to wastewater, defined in the National Waters Law, article 9, paragraphs I to the LIV. The Law on Maritime Navigation and Trade, on the other hand, defines bodies of water as general routes of communication through waters or waterways in its article 3, paragraph c), includes: vessels, lakes and navigable inland lagoons. This law establishes federal jurisdiction (Article 4) over them. In this sense, it is the Secretary of Communications and Transport, together with the Secretary of the Navy, within the scope of their own competences, which have the attribution in matters of merchant marine. For navigation and infrastructure related to navigation, it is the responsibility of SCT, now of SEMAR, and therefore of APIQROO. 48

APIQROO immediately proceeded to adjust charges for the use of docks, boats and other rights, such as the use of an exclusive area for owners and historical owners. Immediately the owners of the properties in the lagoon of Bacalar and Xul Ha were dissatisfied, through the Association Friends of Xul Ha, added to ejido representatives of Pedro Antonio Santos, Buenavista, Aaron Merino, Bacalar, Juan Sarabia, Santa Elena, La Peninsula, Laguna Guerrero and Raudales, they disagreed with the regulations that the APIQROO intended to establish, stating “…The Integral Port Administration intends to obtain from the SCT the administration of the sea route from 1 to 100 meters of the lagoon from the shore, "explained the interviewee at the time of exposing that they intend to charge 8 pesos per meter, and that in case an owner cannot cover it the parastatal could grant this concession to third parties. He explained that although the 8 pesos per meter seemed low, it would be necessary to calculate according to the extension of the properties, and when the calculation is made

by APIQROO representatives, amounts are unpayable.…”

There was a deep, additional feeling of injustice, which to this day continues to permeate, after years of defending the territory against the abusive proposals of researchers, government agencies and environmental nongovernmental organizations that continued to apply dirty war strategies, consisting of harassment and discrediting of entrepreneurs and local inhabitants, and their criminalization, product of the constant bombardment of partial and manipulated information of the Triad with its proposal of dispossession, now had to deal with a company that had taken over the administration of the body of water and wanted to get money, at point-blank range.

To finish complicating it, a few months before the arrival of APIQROO and the collection of rights to use docks, CONAGUA arrived at the properties adjacent to the Lagoon, to carry out measurements to delimit the Federal Lagoon Zone. The inhabitants and historical users of the lagoon include civil engineers and surveyors with extensive experience. They observed and limited the technical teams of CONAGUA about measurement errors that they were incurring, and that caused the federal zone to move more than the 10 meters regulated by law from the shore of the lagoon, in some cases entering up to 300 meters inland. They made the relevant observations in

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order to prevent potential conflict when the official measurements and plans were obtained. “…We, who live around the lagoon, have placed hopes in tourism development.

We agree that there must be rules, but they must be agreed harmoniously between citizens and authority..." Héctor Peña, president of the Friends of Xul Ha Association.

But it was the period of Roberto Borge Angulo's government. Human rights violations, spoils and other crimes committed, covered up by the state government were common, so it was better to reach a good agreement, than to get involved in a bad lawsuit. Somehow many of the users of the Lagoon saw APIQROO as "the lesser of evils". “…In the end we felt that it was preferable to have APIQROO, then an administrator of a Protected Natural Area ... that it was preferable APIQROO to have an PNA, and we no longer moved him at least with APIQROO we could reason and he did not limit or harass us as an PNA would. APIQROO only messes with navigation or docks. We knew that it was not legal what they did with their concession, but we had nothing left but to suck ... at least it wasn't a reservation..." Provider of tourist services. 62 years old. 30 years of working in the lagoon.

Finally, the installation of the APIQROO Operations Committee for the Bacalar Lagoon was carried out, in which the service providers and members of the community were given the opportunity to participate and an agreement was reached to let APIQROO operate the nautical aspects and the related in the Bacalar Lagoon.

When one carefully reads the chapters of the Regulations of Operations one realizes that a master program of port development is contemplated, aspects of maintenance and in the scope of application of the rules the schedules in which navigation can be carried out are clearly established, aspects such as the types of vessel are clearly established in a very specific and well-defined way, the draft, the type of pier according to its use, communication and rule 23, which corresponds to maximum and minimum speeds within the lagoon and some sites of restriction to navigation, aspects of port services, procedures, maritime maneuvers in the lagoon, safety and hygiene aspects are contemplated and in that aspect even safety is contemplated and in case of damage or accidents the specific procedures.

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Related to the triad discourse of the lack of environmental regulation in the lagoon, the APIQROO Regulation counts in chapter 10 and we stop to observe that this chapter includes aspects of environmental control and pollution prevention in which even rule 47 encompasses control of the pollution of the lagoon and access restrictions. The APIQROO Operations Regulation demolishes the triad's discourses that there are no environmental rules that reduce the impact of boats on the body of water. Even Chapter 12 establishes the penalties for non-compliance with the rules and the infractions to which the owners and operators of vessels and port areas in the lagoon are creditors in case of non-compliance.

In 2019, APIQROO was unexpectedly an advantage to protect the system against attempts at a decree of the Protected Natural Area. The existence of Chapter 10, became key to the defense against the triad that returned promoting a decree of PNA, arguing that "there were NO instruments of regulation of the activities developed in the Lagoon" as one of its justifications.

APIQROO was not only legally empowered to manage the body of water, it was managed with rules and had the power to articulate its regulations with other regulations and the ability to sanction non-compliance with them.

It was very naïve to think that even with all the analysis work and the foundation provided by the community technical groups, it would be possible to contain the ambition of the triad to take control of the Bacalar Lagoon.

During the process of reviewing and updating the APIQROO Operating Rules, in 2020, the triad tried to sneak an instrument promoted by the Ministry of the Environment and the Secretary of Tourism of the state of Quintana Roo through a Geoalternative consultancy: PROTUR. Since the only body recognized with a concession to manage the lagoon water body was APIQROO and the attempts to insert the proposal of Ramsar or an PNA by its promoter groups were not being so simple, especially because of the local opposition and its lack of solid arguments, the members of the triad tried to insert their proposals in the opening space that APIQROO gave for the review and update of the Rules of Operation of Laguna de Bacalar, despite the fact that the promoters continued to insist and manage before their followers and the media that there were no instruments that regulated the lagoon, hence the urgency of decreeing an PNA or declaring a Ramsar site and then the PROTUR.

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They tried to insert their proposal into the Regulation so that what would not otherwise be validated would not be validated, given its unilateral and biased origin, would be validated. Kind of like sneaking it under the door, but the community kicked them back.

By 2019 local groups and grassroots organizations were defending the territory from several fronts: against PROTUR (promoted by Geoalternativa, SEMA and State Tourism), against a new proposal with an intersecretarial declaration scheme for Critical Habitat in the Bacalar Lagoon (with a new NGO in the area: SELBA, AC and former CONANP members), Ramsar continued to be promoted (by the people of IEUNAM and ECOSUR), it continued to try to implement a protected natural area without having arguments (SEMA and local and regional ENGOs), manipulating public opinion and creating myths along the way to validate its invalidable proposals, insisting that such requests came from the community but it was the communities that were fighting against these proposals. And then came the triad proposal to modify Rule 23 of the APIQROO Regulations.

ECOSUR and IEUNAM, in APIQROO If there was the doubt of how the triad acts to validate each other, there is the document that was sent to the APIQROO Operations Committee where precisely the importance of leaving the conservation areas derived from the investigations of Luisa Falcón and AlfredoYañez is emphasized, without specifying what these investigations have been, simply and simply placing a map made freehand with Google Earth and providing arguments that have been repeating a and again as part of your strategies to achieve your goals.

They addressed a letter to the director of APIQROO in order to try to influence the design of the instrument. It mentioned Luisa Falcón (IEUNAM) and Alfredo Yañez of ECOSUR, whose opinions were considered to have sufficient authority to influence and change the guidelines of the APIQROO instrument without more evidence than their university degree, through categorical statements that were opinions taken by facts.

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In this case, the letter sent by IEUNAM and ECOSUR, the academic part of the triad, proposed and reinforced the proposal of one of the NGOs of the triad that promoted the establishment of a Critical Habitat and the proposals that they themselves inserted in PROTUR, another instrument promoted by the governmental part of the group. That is, it was part of a strategy, concerted or not, that sought to indirectly validate its control proposals, from various flanks.

Rule 23. PROTUR proposal in APIQROO In parallel, the governmental part of the triad tried to insert another instrument created by them, PROTUR, in the process of updating the APIQROO Operating Rules. The promoters of PROTUR, calling themselves owners of an instrument built and validated by the community without more evidence than the document and the coming from the Ministry of the Environment and the Ministry of Tourism, both from the government of the state of Quintana Roo, included a proposal to incorporate their criteria, and tried to validate a document that was being, at that time, severely questioned – I would say torn to pieces Olympically – by the local inhabitants and technicians.

The strategy, in this case, was to manipulate the text of rule 23 of the APIQROO Regulation, referring to minimum and maximum speeds of the Operations Regulations and forcibly placing the PROTUR plan in Annex III of the Regulation in question. This rule requires a map of areas where it could be transited at different speeds or restriction zones for navigation, an operational plan of traffic control and movement of boats, nothing more.

But the triad tried to sneak its PROTUR zoning plan in an integral way, a plan that included areas on land and that referred to a restrictive regulation and an PNA-type format (as we will see later). The proposal of the promoters of PROTUR sought to validate their zoning proposal and was inserted under the justification that it was a proposed instrument, built and validated by the community, in a participatory manner, they divided the Bacalar Lagoon into two zones: 1. Low speed zone, indicating zoning and establishing permitted activities referring to environmental laws. AND II. Restriction zone no navigation zones.

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According to the promoters of PROTUR, there were only two zones: low speed and restriction. That is, the triad said either you go at very low speed or you do not sail. This "regulation" indicated a total ignorance of the operation and dynamics of historical use of the Lagoon and nautical operation.

The plan was only a collection of PROTUR which in turn was a copy of the previous proposals of Ordinances and proposals and Ramsar. We analyze this later, in the PROTUR section.

PROTUR's proposal was NOT a proposal for speed zones, and the plan was just a crude copy of the proposals for protected areas that had been cooked up by the triad since 2011. If it was a plane of navigation speeds and restricted navigation areas, why did the PROTUR plan that was included as a proposal for Geoalternative, SEMA and State Tourism include wetland areas where there were no canals or navigable areas?

It did NOT make sense from the point of view of the object of Annex III and Rule 23, but it was logical if the intention was to validate your document to establish the bases of control and restriction type PNA, as it would result, using the existing valid APIQROO regulatory instrument for it, but APIQROO does NOT have authority over land areas and the object of Rule 23 was clear: Navigation Zones.

By the time the representatives of the communities noticed this attempt and were dissatisfied with the direction of the APIQROO, it was already June 2020 and the directors of APIQROO observed that it was the only proposal that had been presented, the community did not know that proposals could be submitted, so they asked for the opportunity to build a document, from local ecological knowledge and participation, and the capacity of its community technologists.

Rule 23. The CONCCLAB in APIQROO Since APIQROO argued that there was no other proposal for speed zones and navigation restriction areas, the representatives of the communities in the Community Council of the Bacalar Lagoon Basin (CONCCLAB), which was made up of local inhabitants, representatives and community technicians, who had been fighting the triad proposals almost from the beginning, and who 54

finally constituted a grassroots group, requested the opportunity to build a plan from the basis of local knowledge of the experts in the lagoon, the captains of boats and historical nautical users of the lagoon. They required the opportunity to demonstrate how a plan of the Lagoon was built from the basis of actual experience. They were given a period of two weeks to submit arguments and proposals.

The CONCCLAB was organized to convene the most recognized boat captains in the different communities in order to locate those who emerged as recognized experts, that is, those most mentioned and recognized by their peers, as those who had more knowledge of the system.

It required key informants who knew about navigation, the lagoon, zoning, restrictive aspects to navigate, knowledge of the various types of boat that existed, variations of the lagoon over time and geography. It was decided to ask boatmen, members of cooperatives and historical users (because many of the owners of houses next to the lagoon own private boats and had toured the lagoon for generations).

Due to social distancing restrictions, it was decided to limit gatherings to a maximum of 5 people. 5 names were obtained from local experts in navigation of the Bacalar lagoon. They were informed of the intention to build a spoken map of the Lagoon, including: a) b) c) d) e) f)

Navigation in the lagoon, Zoning of speeds, Restrictive aspects for navigation, Knowledge of the various types of existing boat, Zones and variations over time in the lagoon, Particular requirements in the geography of the body of water.

Given that most of the informants were over 55 years of age and with the current epidemiological risks (June 2020) due to COVID19, two alternatives were suggested for the construction of the plan, they would be provided with material and would work individually with each one to build it. Then there would be a unified instrument and an individual validation would be carried out or a virtual event would be held with all of them to work the map together.

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But all respondents admitted they were more comfortable with face-to-face interactive building exercises which allowed them richer and in-the-moment answers, validated among peers of experts at the time. The necessary measures were taken to protect the health of the attendees and over the course of a weekend the information was collected by combining the experience of 5 boat captains of which 3 were of public service for tours and two owned private boats. Information was also obtained from owners of properties adjacent to the body of water who have inhabited the area continuously for more than 30 years. A total of 8 key expert informants.

We worked by creating a speed plane, superimposing a plane of the lagoon and letting local experts indicate the location and scope of these areas. The guidelines of information need that had to be covered with the exercise so that they were present in the discussion and construction were placed in view.

Aspects that were considered to construct the plan and rule included: Lagoon Navigation, Speed Zoning, Restrictive Aspects for Navigation, Knowledge of the various types of existing vessel, Zones and variations over time in the lagoon and particular requirements in the geography of the body of water.

What was considered as navigation activities in the lagoon? Public navigation for nautical services and private navigation. In the first case they were considered Cooperatives, where there were private service providers that subleases docks or have agreements with local businesses and those who owned their docks and businesses.

Private navigation was considered owners who move for recreational purposes and those who move from one town or site to another, using the lagoon as a way of displacement.

What was the use of the Lagoon? A complete characterization of the uses was carried out. Docks were found, private such as those of house room, business, spas and boats or only boats. Also, community docks of spas and boats or only boats. There are spas only for swimming and those for swimming and boat transit. Another use is the maneuvering and approach areas, such as those adjacent to docks and spas and towns, those that are between areas of different speed and those that are at the entrance of cenotes, "lagoons" and springs. Finally, there are the restricted navigation areas, such as the wetlands in the eastern portion adjacent to the lagoon, blanquizales and microbialitos.

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The restrictive aspects for navigation that were considered to determine the zones included data from depths, areas with presence of people in smaller boats, presence of people in the water (swimming), infrastructure and areas with higher density of boats.

In the end, a proposal for speed zoning was obtained. There were 4 zones identified: Low speed, Zones for very low speed activities, High speed and non-navigable zones. Regardless of the type of boat there were four types of speed for the engine: high, medium, low and approach. Sailing or humanpowered vessels had their inherent limitation. It was sought to build speed parameters for the various types of boat and use (high speed), medium speed, which was divided into tour and transfer; low speed, which was divided into sail and human traction. And the speed of approach and maneuvers, which was the lowest.

The flow of the current, the direction of winds throughout the year and the geographical variations of substrate and water composition were identified.

The shallow areas were located and with stone, white and microbial structures. Differences between areas that limited the use of one or another type of vessel were identified. The areas were grouped by their similar characteristics and by the shared conditions in terms of navigation. Once the information was obtained, the areas were located on the map and the approximate hectares were calculated.

I lead this exercise, as part of the Community Council of the Bacalar Lagoon Basin (CONCCLAB) which belongs to an Alliance of grassroots organizations and community technical assistance at the basin level. The resulting plan was placed in a KMZ file in a Google Earth stroke and then referred to community technologists from CONCCLAB's partner organizations, who georeferenced it in Arc Info, made overlap corrections, delimited zoning types, and presented the plan in AutoCAD, kmz files, and shape, to present it. A glossary was also integrated. This exercise was done with community participation, without external funding and was ready in 10 days. The information was submitted to APIQROO for consideration.

Microbial structures were included in the section of non-navigable areas, by common sense of local experts, because they were areas of risk of stranding, and not because of the scandal and manipulated media information of the researchers and ENGO. 57

The high-speed zones were located in the central portion of the lagoon, where there is greater depth, and the presence of people swimming or with low-speed boats or human traction was limited (this is found in the areas near the shores or in the areas limiting with the high-speed areas). Later it was clarified what was considered high, medium or low speed, from the common sense of the capacity of use, zoning and activities carried out in the Lagoon.

The CONCCLAB proposal was submitted to the proposed Operating Rules, but to date (2021) the Secretary of Communications and Transportation has not validated the update of the document, and we do not know what was the final version of Rule 23 that was incorporated into the document sent for authorization. And the triad insists that local actors and technicians lack capacity.

The Secretary of the Navy and APIQROO As part of the fight against corruption, the federal government established the strategy of control of ports and coasts by the Secretariat of the Navy (SEMAR), on December 7, 2020, the Official Gazette of the Federation (DOF) published the Decree by which various provisions of the Organic Law of the Federal Public Administration were reformed, added and repealed, the Maritime Navigation and Trade Act and the Ports Act. This decree highlighted that the human, financial and material resources that the Secretariat of Communications and Transport (SCT) had for the General Coordination of Ports and Merchant Marine (CGPMM), including the Integral Port Administrations (API) – as in the case of Bacalar – and in general, all those resources necessary for the execution of their attributions were transferred to the Secretariat of the Navy (SEMAR). From the entry into force, 180 days from the date of the decree, SEMAR will be responsible for regulating communications and water transport, formulating and conducting policies and programs for their development, according to the needs of the country; Direct military naval education and merchant nautical education; Regulate, promote and organize the merchant navy; Establish the requirements to be met by the technical personnel of the merchant navy; Grant the respective licenses and authorizations; Build, rebuild and conserve the port works required by the Navy and the Secretariat of the Navy, as well 58

as the maritime, port and dredging works required by the country; Award and grant contracts, concessions and permits for the establishment and operation of services related to communications and water transport with vessels or naval devices; Coordinate maritime and port activities and services in sea and river ports; Coordinate the means of transport that operate in them and the main, auxiliary and related services of the general communication routes; Manage the centralized ports and coordinate those of the parastatal administration; Grant concessions and permits for the occupation of federal zones within port areas and set rates.

This meant that as of June 6, 2021, the Secretariat of the Navy-Navy of Mexico is responsible for acting as a national maritime authority in coasts, ports, port enclosures and facilities, terminals, marinas, among others.

Since “…The National Maritime Authority will work shoulder to shoulder with those who develop activities in Mexican marine areas to achieve a management of the sector, which benefits users in terms of safety, protection and preservation of the marine environment ..." and that this change is being generated at the time this document was written, we will have to wait for SEMAR to begin to manage the port area in a fair, equitable manner and listening to all voices to issue an opinion on its approach or performance..

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PROTECTED NATURAL AREAS In 2017, when a controversial former regional director of CONANP was at the head of the environmental sector in the state of Quintana Roo, the proposal arose to establish a Protected Natural Area on the Bacalar Lagoon.

The communities had not finished breathing because of the fatigue involved fighting against the triad and public opinion manipulated by the triad when they already had an PNA about to be mounted on the Lagoon. This proposal was promoted unilaterally by Luisa Falcón, again, of the Institute of Ecology of the UNAM, as she herself established in a journalistic interview, given that she had already failed in her attempt to lead the Ramsar site proposal between 2011 and 2014. This proposal was even more ambitious than that of the Ramsar site, which was ambitious in itself. The ambition of the proposals to place territory under the protected natural area scheme, proposals that began at 5,893 hectares as a Ramsar site, by 2017 had become 219,000 hectares in PNA, with community and private territories included.

Lodger Brenner, in his 2010 article, "Environmental Governance, Social Actors and Conflicts in Mexican Natural Protected Areas" exemplified the way in which communities and local actors are not considered as actors capable of deciding, analyzed from what happened with the establishment and administration of the Sian Ka'an Biosphere Reserve, but applicable to all other Mexican PNAs. In their research, the actors of the triad consider that the solution of a socio-environmental problem, such as the effective management of a Biosphere Reserve, is the exclusive and preponderant responsibility of one or more particular actors – members of one of its groups – who must achieve certain objectives, relying on a range of resources of political power, economic, social and moral at your fingertips. For them "the rest of society" is considered as a set of influenceable actors, without capacity or legitimacy to evaluate the nature or severity of environmental problems; and much less 61

to solve them, which not only diminishes the legitimacy of the Mexican PNA, but also affects their efficiency.

If we talk about tourism as the guiding axis to create PNA, it will be enough to read the documents coordinated or written by Gustavo Marín Guardado (2012 and 2015) to realize that tourism as the guiding axis of the establishment of an NPA has proven to be harmful to local communities because the revaluation of the land and natural resources that remain within the NPA has of course important economic repercussions, social and ecological in the life of the communities involved, since these spaces become the object of greed by big capital and governments. In his research, he explains how in recent decades, in developing countries, large areas of territory that previously belonged to indigenous communities, peasant societies or groups of fishermen, have become the property of investors, commercial companies, or have become spaces managed by international organizations or government agencies. This largely has to do with the implementation of development, tourism and environmental conservation policies and programs, through which world organizations, state institutions and individuals manage to have control of these territories. I'm not the only one who realized this, you see?

Zizumbo-Villarreal, in 2012, state that the creation of Natural Protected Areas in Mexico is the result of the process of refunctionalization of rural areas, from which it seeks to end the production of food, to give way to economic activities that apparently use sustainability as a principle, with which capitalism is painted green and the process of dispossession of resources and expulsion of original rural settlers is justified, arguing that they are restricted from traditional use in favor of the conservation of the territory and natural resources to then be able to pass it into the hands of investors with large amounts of funds.

Natural Protected Areas (NPA) have been for decades the most comfortable and convenient solution for those who champion forced and tendentious sustainability towards the ecological, without considering or respecting the other two pillars of sustainability, the social and the economic for the communities they restrict. Because the social and economic benefits are reserved for the proponents, promoters and the instances that stay with the administration of the areas, which is an excellent business for them. Worse, in proposing an NPA, institutions partner with environmental NGOs,

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research centers and educational institutions, and turn a deaf ear to the inhabitants and traditional users whose heritage is curtailed.

In Mexico, the NPA are located in territories where human populations have coexisted for generations, where there is historical, biocultural and economic heritage of the historical settlers, but they are proposed, proposed and decreed as if they were uninhabited spaces. In his research Robles-Zavala, he describes it clearly emphasizing that protected areas are not an isolated entity, established in a vacuum, but on the contrary, they are included in an environmental, socio-economic, political and institutional and community setting.

From the beginning of the explosion of environmental protectionism and reserves, some social science researchers began to observe that there was a combination of factors that explained the increase in "global concern for wild spaces" that arose from ethical concerns about the loss of natural ecosystems and biodiversity, but that were also encouraged by the increasing availability of international funds for conservation and the possibility of generate income from activities that took advantage of protected areas, such as tourism in protected areas. Other incentives for establishing NPAs were to transform them into political weapons for the ruling elites or as a channel for foreign financial aid.

With the creation of an international structure with many millions of dollars in stimulus, and studies such as the economic value of wetland environmental services – in international dollars – the risk of voluntarily or involuntarily introducing perverse incentives became real, under which projects, instruments or policies were created to help solve a problem in a comprehensive way, but instead generating an additional problem or worsening the existing environmental, social or economic problem(s). The generation of perverse incentives forged by the growing market for green business, ecological, conservation, sustainable development, compensatory funds to mitigate environmental impacts and the entire market of funds that arise around, includes not only direct payment to producers or owners of territories, but also the financing of researchers, NGOs and government agencies that force instruments, territories and environmental policies in exchange for direct or indirect economic benefit for their "contribution", "achievement", "work" or "research".

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In this scenario of perverse incentives, NPAs were born from neoliberal environmental strategies where the processes of privatization, such as commoditization (transforming something into a priced thing), deregulation and re-regulation, characteristic of neoliberalism, manifested themselves in the field of conservation through phenomena such as the growth of international non-governmental organizations (NGOs) and researchers who received many benefits in exchange for proposing them. and to support them; the creation of new goods in situ and economic activities that replaced the lack of access to resources (ecotourism, payment for environmental services, bioprospecting, certification, non-timber forest products); the contribution of capital to ENGO for the purchase of land to put it at the "service" of conservation in private natural areas; the incorporation of private land into protected areas owned by the State without the consent of the owners; the creation of private funds and trusts for conservation; the establishment of financial products and the horde of carbon market developers who take a part – sometimes huge – of bonds, shares, offset credits – and the decrease in the presence of the State in the practice of conservation benefiting particular groups of relatives who took advantage of the incentives promoted by the institutions, as well as its alliance with NGOs, private companies, communities and multilateral institutions for the execution of conservation projects (Igoe and Brockington, 2007).

In Mexico, the members of the communities had not only the anger of the abuse of power of the authorities who wanted to unilaterally dispose of their territories, without respect for the historical possession that the Nation, represented by the government, had granted them by decree in some cases since the 1930s; the lack of respect of the promoters for their biocultural legacies, coupled with concerns about the bureaucratic inefficiency and corruption of the agencies responsible for the NPAs, their network of "influential" actors and their true intentions. For the latter it was only enough to review some dates in the reserves decreed in the state, many NPAs of the entity were left in a regulatory limbo due to the lack of Management Programs, some of which took decades to build, such was the case of the Sian Ka'an Biosphere Reserve, decreed on January 20, 1986, whose Management Program was decreed on January 23, 2015. 29 years after his decree; Sian Ka'an Reefs, decreed in 1998, whose Management Program was decreed in 2011, 13 years later; Isla Contoy, decreed on February 2, 1998, and its Management Program on July 9, 2015, 17 years later; Yum Balam, decreed on 64

June 6, 1994, whose Management Program was decreed on October 5, 2018, 24 years later.

What was the urgency of decreeing an area to manage, conserve and protect it, if it took almost 30 years, in the case of Sian Ka'an, to create the instrument that precisely allows it to be done in a clear, transparent and substantiated way? The Management Program is so important in a protected natural area that the decrees themselves establish an average of 6 months to a year maximum for the creation and decree of said program, but as evidenced by the cases mentioned above, practically no agency responsible for the NPA saw it as a priority. The urgency seemed to be at all times to take control of the site, although it was not treated with rules, in some cases, almost for three decades.

The failed NPA, in Quintana Roo The state of Quintana Roo has 5,021,200 hectares of continental territory. Of that area, 21% of the state territory is included in an NPA. That is, 2 out of every 10 hectares of the state area are under the control of some environmental authority, mainly coastal / tourist areas. This is without counting the 6'383,701.59 hectares of territorial sea that CONANP, with the support of the NGOs as Friends of Sian Ka'an, A.C., was awarded under administration in Banco Chinchorro, Arrecifes de Xcalak, in Puerto Morelos, but especially with the Biosphere Reserve of the Mexican Caribbean, which in 2016 placed as NPA a total of 5'754, 055.36 hectares of territorial sea off the coast of Quintana Roo. Let me be more specific, CONANP placed as gigantic NPA ALL the coastline of Quintana Roo, everything that was not in marine/ coastal NPA previously, was included in this NPA. It would be worth mentioning that it is incredible that, to establish and decree a reserve of this scope and of this caliber, it has taken 5 months (from July to December 2016) from its justifying study to its decree and management program included, and that although it affected an area greater than that of the entire State, it was presented and promoted by CONANP and ejidatarios of the Yum Balam Reserve, that were not affected by his decree because they had the reserve of Shark Whale and Yum Balam, but they gave the social validation to impose an NPA to the rest of the coast to the border with Belize.

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CONANP will be able to say it complied with the consultation for public opinion, which was carried out only virtually, as cited in the MarFund report, a few days, and taking into consideration that it affected ALL inhabitants, users, service providers and anyone whose property bordered this reserve and now it will have to ask CONANP for its blessing for any project or business that it wants to develop in the adjacent area or on the coast that includes that reserve, practically no one found out. The Mexican Caribbean Biosphere Reserve, whose management and public consultation went unnoticed by most people, has a marine area greater than the entire land area of the state. Which means that now CONANP has control and dictates what can and cannot be done in ALL the coast of Quintana Roo, when it pleases and according to the case / client.

It is almost insulting what MARFund confirms in its report The justification? this PNA had a fast track because it urged the government of Mexico, then chaired by Enrique Peña Nieto, to make the show and have something to show at the opening of the 13th Conference of the Parties (COP) of the Convention on Biological Diversity. This decree would allow tourist activity in the area, but would shield it against the exploration and exploitation of hydrocarbons. In turn, the governor of Quintana Roo, Carlos Joaquín González, reported that the decree protected 37,000 hectares of jungle and mangroves. 5 months including the review and structuring of the Management Program and not only the decree. The approval in 5 months included a Management Program that leaves many doubts and raises many concerns. As an example, it states emphatically in its Rule 53. "The construction of docks, breakwaters, breakwaters, breakwaters, jetties, platforms or any infrastructure, with the exception of artificial reefs, is prohibited; that affects coral formations, seagrasses, dunes or modifies coastal dynamics", that is, along the coast. The implications of those lines are incredibly complex. The processes and consequences of this hyper fast decree deserve an investigation and a complete book.

By contrast, many of the state and municipal protected natural areas in Quintana Roo, at the time of this research, did not have a management program for the most part, that is, the state government and the municipal government had been decreeing protected natural areas since 1983 without taking equal importance to the obligation to generate and decree the management program, creating protected natural areas as a way to collect 66

hectares under their control, without written rules, without zoning. It is understandable, because as happens to CONANP, the state, now with the IBANQROO (Institute of Biodiversity and Protected Natural Areas of Q. Roo) never has sufficient funds to properly operate its PNAs. A fertile territory for chaos and corruption.

These protected natural areas were established using only representatives of community groups, on behalf of the entire community; overexploiting the media to build custom discourses, with procedures and zonings designed to suit the client, to increase prestige or guarantee obtaining funds, manipulating the information they provide, making up community participation as if it really existed, and insisting that PNAs work, without giving solid arguments, are just some of the strategies of the promoters of these protected natural areas, when Mexico's national reports to international entities and committees of experts are nothing more than lists of excuses for why commitments have not been met, the absence of real performance parameters or their objective measurement, while more PNA continues to be decreed.

There is also the Voluntary Area for Conservation (ADVC) model, which is an additional strategy for generating protected areas in privately or socially owned territories to continue accumulating surface, which justifies the fulfillment of the country's commitments to the international community, with the promise of benefiting the holders of the territories with the same benefits that the reserves receive. consolidating local governance and protecting biodiversity, but only contributed to CONANP's manic compulsion to accumulate hectares, without stopping to verify that these new private community PNAs are strengthened, and creating new schemes of pressure or incentives (which seem very much conditioning / threatening) so that social and private owners "dare" to include their territories as ADVC. And as the effort is to accumulate hectares, while CONANP points more stars at the expense of the locals, the ADVC are joining the paper PNAs, with honorable exceptions thanks to the owners, not to the triad. But that's the subject of another document.

When you review state and state decrees together, you can easily determine how the triad operates in them, reviewing the elements in common between them:

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• The surveillance and administration are in charge of one of its instances in environmental matters, SEMA or the assigned state instance, in this case it would be the IBANQROO for the state and SEMARNAT, in this case CONANP, for the federation.

• The management plans or programs are in charge of the authority and some ENGO, and other authorities, researchers or academics are summoned: NEVER to the communities.

• The authority is responsible for authorizing all types of use in the PNA (even if it has not previously been within its competence).

• The state or federal authority in charge may make "agreements" with third parties that carry out activities within the PNA including administration or exploitation (and generally this means granting concessions between actors of the triad).

• Any public or private work project that is intended to be carried out within the protected natural area, or in its area of influence, must have the authorization of the "administrator" instances of the areas and must be in congruence with the guidelines established by the Management Program that, as mentioned above, can take more than 20 to 30 years to be decreed, which subjects local populations and other actors, outside the triad, who wish to intervene in the territory, to a legal vacuum and mercy of this group, for decades.

When the surface of the State territory in protected natural areas is analyzed in detail, whether of federal or state administration, we can realize that just over 70% of the surface is more managed, managed and controlled by the National Commission of Protected Natural Areas, a total of 7,140,318.63 hectares or 71,403,1863 km2, equivalent to the sum of the surfaces of the states of Hidalgo, State of Mexico, Querétaro, Colima, Aguascalientes, Tlaxcala and Mexico City, which must be administered, monitored and managed (in theory articulated to the actions and policies of other sectors) by the CONANP of Quintana Roo, which has a limited number of personnel, between 50 and 200 people, with poor infrastructure and equipment, and always without money to operate. Why do we say it's always broken? Because in reports like Ramsar to the question, what do you need? They keep answering: Money.

The state has the same problem with even fewer staff being responsible for the comprehensive management of 312,860.61 hectares. This last point is key, 68

when you want to understand why so much insistence on decreeing an PNA in Bacalar? In a simplistic way, the followers of the triad tend to consider the reaction of opposition to the decree of the PNA in the lagoon body of Bacalar as "ignorance" on the part of the inhabitants and historical users, but they do not know that the key issue is not the decree of the PNA, nor the protection, nor the conservation. The key to imposing an PNA is to give the state or federation a "play" in the authorization of projects in the PNA and in the area of influence. The PNA is key because it empowers and controls the triad to achieve its materialistic goals, while pretending to conserve or protect. Really what is promoted is "saving nature to negotiate with it".

Proponents might argue that establishing the PNA is a positive thing because it would avoid negative environmental impacts, but they forget that there are already regulations to prevent that, that there are already planning and regulatory instruments and that, in the case of Bacalar, the municipality has not fulfilled its obligation to create the key instruments to regulate urban development: such as the Urban Development Program and building regulations or key regulations for economic activities in its field of action.

Since it is precisely the municipality that has direct responsibility for the urban area, adjacent to the Lagoon.

Have the PNAs in Quintana Roo served to stop pollution? It does not seem so, as an example Sánchez et al (2013) when conducting a study on the content of stable isotopes of Nitrogen product of anthropogenic activities in several bodies of water in Thalassia testudinum, a very common algae in all coastal areas of the state, not only found, as expected, this component in the samples that we already know are affected by pollution of wastewater discharges such as the Nichupté Lagoon, in Cancun; they also found that: “…The Yum Balam Reserve and the Sian Ka'an Biosphere Reserve showed higher d15N values although they are in areas of low development and with restricted tourist activity …”

Well, the researchers will have to excuse me, they perhaps wanted to mild the finding, but Yum Balam and Sian Ka'an, are not simple areas of low development and with restricted tourist activity, they are Protected Natural Areas for at least the last 30 years, as to show this type of Nitrogen values.

This finding is especially relevant, because Luisa Falcón has used the argument of increased nitrogen in the water of the Bacalar Lagoon as one of her 69

justifications for continuing to promote the establishment of the Ramsar site, as she stated for a newspaper, in May 2021. “…Falcón knows the lagoon well. She first came in 2004 to do a master's thesis. So, the level of nitrogen in the crystal-clear water was so low that it could not be detected on their meters. Since then, she has traveled three times a year to follow the monitoring and has checked the drastic and accelerated growth of substances in the water. "We've been saying for years that nitrogen and phosphorus levels are rising," she says indignantly. "I applied for the PNA in 2017, but I needed the social consensus of the Bacalar community. We worked on that proposal for years and it did not prosper, it never left the offices because they do not want a protected status for the lagoon," she adds.

All in all, he doesn't give up. A request is underway for the lagoon to be added to the 142 sites designated as Wetlands of International Importance (Ramsar Sites) in Mexico. But Falcon fears that the conservation commitment will come late to the pace of ecosystem deterioration.…”

Later, in volume III we present "The changing discourse of Luisa Falcón" where we analyze, with the methodology of discourse analysis and more closely, with the media statements themselves as their media strategy has been changing, in which media as prestigious as El País®, the BBC® and The New York Times®, have fallen into the trap of not verifying sources or not conducting a real critical investigation, in order to participate in a yellowish discourse and scandal with the same sources that have powerful conflicts of interest.

If, as we will see later, many – the majority – of the PNAs were decreed without the community participating or knowing, or through manipulation of information and simulated "participation" processes, that many of the PNAs do not have a management program, that pollution has not been stopped, nor uncontrolled urban development, nor the illegal extraction of natural resources, and if third parties have been privileged to make use of the sites, the dispossession has been validated and even encouraged, to limit the access of premises to pristine places, to have exclusive sites that can be put at the order of the highest bidder (big capital), or where they can carry out their research (their exclusive natural laboratories in situ), conditioning access to those who can afford it, so that tourists "enjoy" them, and then restructuring the instruments to adjust to the client, the objective of the promoters of the reservations is very clear to have control in a disguised way.

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Sian Ka'an Biosphere Reserve What are Biosphere Reserves? The MAB-UNESCO Programme describes them as "learning spaces for sustainable development". It states that they are places intended to test interdisciplinary approaches to understanding and managing the changes and interactions of social and ecological systems, such as giant laboratories, where researchers are supposed to be able to understand conflict prevention and biodiversity management. UNESCO assumes that these reserves function as laboratories where local solutions to global problems can be "offered". These reservations are requested by governments, and are validated and recognized by the international community.

The page of the United Nations Educational, Scientific and Cultural Programme (UNESCO) describes the Programme's Man and the Biosphere Programme (MAB-UNESCO) as an intergovernmental-mental scientific initiative aimed at establishing a scientific basis in order to improve the relationship between human beings and the environment. But the MAB focuses on the exact and natural sciences to supposedly improve people's livelihoods and preserve natural or orderly ecosystems, thus promoting supposedly innovative approaches to economic development that are socially and culturally appropriate and environmentally sustainable. However, it remains short-sighted in scope due to its one-sided scientific approach to the sciences (exact and biological) that maintain their hegemony in the PNA declaration system, so it is clearly only a self-validation initiative.

This is relevant because it has been social scientists who during the last decades have been raising their voices to denounce the disastrous consequences of the imposition of this type of neoliberal environmental mechanisms, not only on human populations, but on ecosystems themselves and biocultural heritage. But the triad has its private party, and as happens to the local inhabitants and historical users of the territories, social scientists are also not invited.

At this point it is not surprising that in the early 1980s, a team of researchers from the Quintana Roo Research Center (CIQROO) and personnel sent from Mexico City, members of the Secretariat of Urban Development and Ecology (SEDUE) carried out extensive preliminary research on the eastern region of Quintana Roo and that those investigations ended in an PNA decree.

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The researchers studied the biological and ecological aspects of the area, its habitats, geology, climatology and wildlife in order to argue the high level of diversity of its ecosystem. They also studied the productive activities of local populations, including ethnobotany and hunting.

The research was funded by the World-Wide Fund for Nature (WWF) and the Mexican National Council of Science and Technology (CONACYT); the findings were published in 1983 and underpinned the creation of the Sian Ka'an Biosphere Reserve was established by presidential decree in 1986. This happened exactly when G. Halffter, the creator and main promoter of the Mexican concept of Biosphere Reserves, was Deputy Director of Scientific Development of CONACYT (1982-1986) and was in the process of earning the merits to be appointed President of the International Council of the MABUNESCO Program (1984-1986).

The decree of Sian Ka'an, had the support of the Governor of Quintana Roo, at that time, Pedro Joaquín Coldwell, and the technical support of the Research Center of Quintana Roo (CIQROO) from where G. Halftter became a Member of the Technical Council (1986-1995). The Sian Ka'an Biosphere Reserve became the flag of the Mexican model of reserves and then resources began to arrive to meet the research objective of these models. Since the administration, the governing body of the reserve, was allocated to CIQROO (which would later become ECOSUR), about 70% of the research budget of this institution during that period was allocated to projects in Sian Ka'an, and many of these projects were carried out in cooperation with international institutions and funds. CIQROO (under the supervision and support of Halffter), together with officials from the Secretariat of Urban Development and Ecology (SEDUE) and the state government created a Council of Representatives, which was established in 1986, but ceased to function in 1988. This was due to a rupture between SEDUE and CIQROO over aspects of administration and approach of both instances. After the decree of Sian Ka'an in 1986 and his incorporation into the MAB-UNESCO network, SEDUE, appointed one of its deputy directors of Mexico City, the biologist Juan José Consejo, as Director of the reserve.

However, the resources were to operate through CIQROO and after a few months, differences arose with the Director of CIQROO on the approach and governance of the reserve; these ultimately irreconcilable differences

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polarized the bodies that were involved in the Sian Ka'an council and ultimately resulted in a rupture between the two institutions.

This conflict created uncertainty between foundations and international organizations which chose to support the newly created civil association Friends of Sian Ka'an (ASK), an organization created by prominent political figures and businessmen of Cancun, all influential people, very influential, involved in real estate businesses, hoteliers, restaurateurs, some politicians and socialites. The reservation was decreed on January 20, 1986, by June 5 of that year friends of Sian Ka'an was constituted. Which was very convenient.

ASK took the lead in implementing alternative projects in Sian Ka'an. The reserve council was reinstated with the participation of interest groups in 1994, which would later include representatives of communities in the area of influence of the reserve, but consider the type of citizen participation the model of participation of the members of the communities remained in a consultation or at most as a mechanism of appeasement, because from the composition of these councils, the basis of the information for decisionmaking and the ultimate decision was in the hands of the authorities and scientists of natural and exact sciences (and their stakeholders).

The Biosphere Reserve of Sian Ka'an is located in the municipalities of Tulum, Felipe Carrillo Puerto and Othon P. Blanco, in Quintana Roo, comprises a polygon of 652 thousand 192 hectares declared as a reserve in 1986, and a few years later declared by UNESCO as a Biosphere Reserve and Natural Site World Heritage Site. It is one of the beneficiary areas of the PNA Fund and the Small Grants Program of the Global Environment Facility among many other sources of funding, whose funds are "lowered" through NGOs and Research Centers. While the government, academics and environmental organizations consider this a triumph, because at the end of the day they are the beneficiaries: The Sian Ka'an Biosphere Reserve, founded in 1986, in Quintana Roo, is a good example of a well-managed natural area based on local participation.

Lane Simonian, Defending the Land of the Jaguar (1995)

It contrasts with the perception of the communities of native peoples who were displaced with the decree: 73

The President of the Republic established Sian Ka'an and they took part of our land from the ejido without asking us. They also didn't compensate us because they claimed it was federal territory.

Esteban Poot, resident of Chumpon (personal interview) (Martínez-Reyes, 2016)

In his research Martínez-Reyes explains that since the establishment of the biosphere reserve, but particularly between 1993 and 2006, all the new projects seemed to be titled "Exploitation", whether the resource was honey, wood or orchids. These initiatives and programs arose from a perspective that often conflicted with Mayan moral ecology, and in the documented case of the Ejido Tres Reyes, their implementation engendered a clash of views based on nature's colonial condition.

In 2009, after three decades of collaboration with several NGOs (Environmental Non-Governmental Organizations) and Mexican natural resources agencies on conservation projects, the community had had enough.

One leader told the author that "They had to kick all the NGOs out of there.

They didn't want to know more about conservation." What would drive the community's drastic decision to collectively declare the independence of NGOs and state intervention? From the community's point of view, the decision had nothing to do with being against the conservation or protection of ecosystems. Rather, it was perceived that the extensive time and effort that the people of Tres Reyes had devoted to working on initiatives with different NGOs had resulted in few benefits for the community, as government bureaucracy, environmental agencies and NGOs pushed for the implementation of ineffective projects that were participatory in name and not in effect." Locals fighting in Bacalar came to, among others, the same conclusion.

NGOs, self-described community representatives, benefit from and continue to benefit from this self-validated role by themselves and other members of the triad, while justifying the resources that funders channel to communities by being "representatives" of society. Martínez-Reyes' study shows how two NGOs acted in Tres Reyes: the "institutionalized" ENGO: Amigos de Sian Ka'an and a "localized" ENGO: Uyol Ché (which in fact was created by former employees of Amigos de Sian Ka'an – more of the same, but smaller). Their study exposes the weaknesses of the projects and how they ultimately failed.

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I think there comes a point where the community realizes that three spectacular signs and two environmental education workshops do not require a million pesos... that the ENGO receives. This situation is repeated again and again with the funds managed by ENGO, in most of the communities located in PNA areas or in their area of influence. Projects whose vision is a mixture of paternalism and condescension towards the local populations, who stripped and subjected to the control of their territories "for the good of nature and their own future", "in the name of the common good", are "compensated" with miserable punctual subsidies to placate them, give them the feeling of progress at their level, because the power groups consider that the locals cannot go beyond being artisans, collectors, guides or boatmen, so the projects are just a way to simulate that they are included in sustainable development, but who takes the business are the NGOs. In his research Martínez-Reyes mentions that when the Sian Ka'an Biosphere Reserve was created, the proponents (the triad) asked permission from the municipal president as well as the owners of the private lots along the coast of Sian Ka'an, but not from the local Mayan communities, this generated various reactions ranging from resignation, anger to disbelief among these populations of original inhabitants and users. This motivated the local populations to get involved in a struggle of more than three decades trying to recover not only the territories that belonged to them for generations, but access to the coastal zone, since the decree of Sian Ka'an stripped the municipality of Felipe Carrillo Puerto – where these populations in struggle are located – of access to all its coastal zone, along 280 km.

It is interesting that the reserve decree, published on 20 January 1986, stipulated "... That of the studies and investigations referred to in the eighth recital, it was determined that a total area of 528,147-66-80 Hectares is required. This area is made up of national land that the Secretariat of Agrarian Reform, considering it of public interest, has reserved for the establishment of the "Biosphere Reserve "Sian Ka'an" under the terms and conditions provided for in this Decree..." but in article sixteen of the same decree it contradicts itself by stating that. - "... The ejidos and communities established on the surface that comprises the "Sian Ka’an Biosphere Reserve" will be obliged to the conservation and care of the area in accordance with the provisions issued for this purpose by the Ministry of Urban Development and Ecology, and in accordance with the provisions of article 154 of the Federal Law on Agrarian Reform..." What the ejidos and mayan communities 75

have been saying since then: where they established the reserve had been territories of ejidos and communities in an ancestral way, and no one asked them for their opinion, much less permission.

If we take into consideration that the coast of Quintana Roo comprises 1,157 km of coastline (INEGI, 2010), Sian Ka'an "reserved" not only the territory of communities and ejidos, but 100% of the coast of a municipality, which at the same time was 24% of the Quintana Roo coast; 24% of the coastline adjoining the Caribbean Sea, to the privilege of some members of the triad and those who could pay the price of neoliberal environmentalism for these law-isolated, pristine and beautiful landscapes.

Returning to Sian Ka'an's decree, NGOs almost immediately began to bring in "sustainable development" projects. Martínez-Reyes explains that despite the enthusiasm of the initial projects, there was a shared feeling among the residents: That after stripping them, the government and the NGOs arrived offering projects, which almost never materialized, and again, they returned with more projects as quickly as they discarded those, they had previously proposed. They arrived and made their proposals to improve agriculture, beekeeping, wood harvesting, etc. but the local Mayans did not see the benefits of these projects. And when funds ran out, often before the results materialized, NGOs left communities. “…This is the experience the Tres Reyes community had with Amigos de Sian Ka'an, the ENGO that was largely responsible for advocating and pushing for the creation of the reserve, and why they didn't want to work with them in the end. They considered that NGOs only wanted the money they received from funding agencies and that they moved from one community to another, initiating projects in search of funds and without following up on their previous activities.

U Yool Ché was created as a consequence of this problem: its members, once members of Amigos, broke ties with them because they wanted to keep track of development projects even when there was no more funding in the hope that they could eventually get more in the future to continue their work. Other organizations such as UNAM and "gringo" organizations also arrived with projects that they ended up abandoning. The first for planting, but the project was abandoned. The "gringos" arrived to demonstrate the use of pesticides for their crops, but the Maya avoided using them because "insects and animals became stronger and more resistant to them.

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The overwhelming wisdom shared was that most development projects lacked positive outcomes and resulted in the community becoming increasingly skeptical about outsiders' intentions.…”

Of the cases described by Martínez-Reyes in Sian Ka'an and Galván, in Cuatrociénegas – see What happened to the Cuatrociénegas Valley in the 1990s? it is shown how institutionalized NGOs (and, in many cases, academics and researchers) specialize in making projects and managing international and national donations, to ensure prestige, funds or positions, but do not work with local people.

As Igoe, J. (2010) quotes "... This is a result of the growth of the "nature industry", which relies on "the spectacle" of promoting conservation, and being disconnected from the local…”

Other researchers who elucidated the phenomenon of the accumulation of capital for tourism through the dispossession carried out with the decree of this PNA, expose the role of tourism and PNAs as facilitators of dispossession, which is not reduced to taking possession of something specific but occurs through a process of accumulation of common goods to convert them into private property. They explain how PNAs truncate the right to access the areas of greatest value to the community and reserve it for whoever has the capital. As happened to the Mayan peoples of Sian Ka'an.

They take these areas and their resources and landscapes and monetize them.

While the communities that are dispossessed and displaced, and have nothing left but to work for big capital, they have nothing left but to migrate to the tourist poles. The Sian Ka'an Biosphere Reserve and the injustice committed against the Mayan indigenous peoples with the establishment of the PNA in 1986, deserves a complete book.

Chacmochuch Lagoon System The Chacmochuch Lagoon System, which is a state PNA decreed in 1999, located in the continental zone of Isla Mujeres, in the north of the state, has been suffering from negative impacts, due to the lack of a PDU in the area adjacent to the reserve. The fact that it has been an PNA for 22 years has not stopped the unbalanced development in its entire area of influence and in the system itself. It is even part of a POET (Territorial Ecological Planning Program), but this was modified several times increasing the hectares of use.

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Originally the document established that 2,293 hectares could be exploited due to the fragility of the ecosystem, but currently nine thousand hectares are contemplated and the number of hotel rooms increased from 19,000 to 22,000, as denounced by local groups.

In its decree, specifically in article Eight it states "... Any public or private work project that is intended to be carried out within the protected natural area, or in its area of influence, must have the authorization of the State Government and the Municipalities of Benito Juárez and Isla Mujeres, and must be in congruence with the guidelines established by the Management Program ..." But the conservation of its environmental and scenic quality continues to be lost, pollution and pressure on the ecosystem has not stopped, and the foundation that gave rise to its decree only remained on paper as shown in the note of 2015 the Excessive hotel boom, warns Conabio. Lagoon system agonizes in CancunIsla Mujeres, where according to CONABIO (National Commission for the Knowledge and Use of Biodiversity) the problems are documented, are considerable and have not been resolved for years due to the lack of surveillance of the environmental authority, in this case of the Federal Attorney for Environmental Protection (Profepa).

There is contamination by leachate and waste, even five years after the closure of the garbage dump in the continental area, the polluting fluids still drain from the mountains of garbage and will give to the water. In the area of influence, 27,000 hotel rooms were authorized in an area of 1,125 hectares, the Megaproject of Ciudad Mujeres, where names of businessmen such as Carlos Hank Rhon appear. This is the situation of the new Cancun, at the expense of the Chacmochuch lagoon reserve, punished by predation…”

Other notes indicate that, five years later things had not improved, the 2020 note entitled Serious pollution of Chacmochuch lagoon. The hotel "Villas del Palmar" of Punta Sam discharges wastewater into the bodies of water, old landfill is generating serious pollution in the Chacmochuch lagoon, denounce environmentalists, in the absence of the authorities, the environmental monitoring groups promoted from among the communities around the site themselves made complaints, which the authorities ignored. They pointed out to the administration of Paul Carrillo, the lack of maintenance of the landfill without the complaints they have made having been addressed by PROFEPA or the Attorney General's Office for Environmental Protection (PPA). They denounced the felling of mangroves to build stalls selling seafood and fish, and 78

the only thing the authorities did was "wash their hands" and collect "mochadas" (bribes) of control and sanitation.

There are also scientific studies that corroborate this situation, a study of contaminants in aquatic pastures found evidence of environmental deterioration of the study area, probably due to the amount of nutrients that was changing the conditions of the lagoon. This system was already between 16 and 21 years old being an PNA when these notes and studies were conducted. The PNA has not contributed to curbing its deterioration, nor does it even have a management program, 22 years after its decree.

Chacmochuch did NOT need an PNA, it needed an operating PDU, reenforce and keep updated the regulations on development and environment, fight corruption, needed an integrated, real management of its BASIN, not only of the wetland that is the reserve. It was not about leaving an area island without construction, it was about articulating the development around, to reduce the risks inherent in interconnected ecosystems and the only thing that has been achieved has been to leave an island of aquatic grass in the body of water rich in leachate nutrients, developments and surface runoff from the areas of influence, where the authority has not put order and only took care of creating a decree to have opinion and control over the development around the body of water, not to regulate it, but to negotiate with the promoters, with other authorities. Corruption.

"Saving nature to negotiate with it" does not mean in any of these cases to really save it. It just means that the triad must pretend that it saves it with an PNA, manages to make a profit, and then lets it die slowly because the underlying problem was not really solved, it was just simulated. While this same agony they continue to use it to capitalize on more support, without anyone questioning why their proposal and promises, which gave rise to the PNA, did not turn out... and the evidence is obvious.

Nichupté Mangrove Flora and Fauna Protection Area This PNA was established by federal decree published on February 26, 2008, supposedly to combat its very serious pollution problem, stated in a scientific document of 2007, which was used among others as a public justification for decreeing the reserve. The document was entitled: Environmental pollution 79

of the lagoon system of Nichupté (Cancun ‐ Mexico) and was it resolved? No, the problem is still very serious as evidenced by the headlines of many notes: Laguna Nichupté is at risk from toxic metals, Due to its contamination, Laguna Nichupté could cease to be a protected natural area, Pollution kills Laguna Nichupté, Hydrodynamics and transport of pollutants and sediments in the Nichupte lagoon system - Bojórquez, Quintana Roo, Mexico (CQ063).

In their study, Romero-Sierra, et al (2018), recognize that the PNA has not served to avoid such impacts establish that the changes in the geomorphological structure were due to hotel and residential development, and a long-term environmental quality assessment was necessary. The results highlighted the need to establish urgent measures for their recovery and protection, as the pressure with new developments was increasing. Even if the mangrove swamp of the Nichupte Lagoon System was within a Natural Protected Area, the management plan had to improve and protect the water bodies with stronger measures.

The fact that it has 13 years of having been decreed as a reserve has not prevented in the lagoon system the discharges of wastewater, which have been increasing over the years, resulting in a chemical imbalance and the presence of pathogenic microorganisms, which potentially represents an ecological and human health problem?

In their research, Maya & Ferrusca (2014) show a worrying scenario that has been repeated as tourism development centers are detonated on the Caribbean coast of Quintana Roo. His research analyzes the phenomenon of "short-falling" planning for tourist destinations such as Cancun. Planning that is conceived in the short term, visualizing the tourist areas and their needs, without considering the provision of services that guarantee the quality of life of individuals and families who move to the site, attracted by the promise of work and opportunities for a better quality of life to work in these tourist services. A neoliberal vision of tourism.

Development plans do not consider that at some point plans and sites will be exceeded in their ability to sustain human populations, which coupled with poor long-term planning brings with it exacerbated shortcomings. They explain that it was not enough to design and implement the investment of new tourism development projects, it was also necessary to rethink the coexistence of high-impact tourism and the social and environmental carrying 80

capacity so as not to exceed the critical limits of sustainability of Cancun and its metropolitan area. It is no longer just ensuring that sustainability parameters are met, it is also ensuring that sustainability contributes to the construction of a more just and equitable society in the present and for the future, in tourist destinations like these.

Nichupté did not require a PNA, it required long-term planning of the area of influence, and combating corruption that allowed excessive growth and the simulation of sustainability around it. It needed to reinforce the rules of operation of APIQROO, which manages navigation in the bodies of water in Quintana Roo, reinforce the regulation of construction, of urban development of the area of influence, not only of the water mirror, of the wetland, but of its entire basin, and to implement sanctions to discourage pollution, it needed to eliminate corruption.

Xcalak Reefs National Park The case of this PNA, from the point of view of the impact on the community and the consequences of the establishment of the PNA, is exposed in the newspaper article The people who changed fishing for tourism and repented, where fishermen came to realize that the PNA not only failed to fulfill the commitment to bring bonanza and sustainable development, to protect the development opportunities for the locals that had been promised to them by those who went to promote them, in this case the NGO Friends of Sian Ka'an, and to generate the conditions for the decree in 2000.

The proposal to establish the Xcalak PNA came from the friends of Sian Ka'an association, who has already mentioned by some authors are an institutionalized NGO dedicated to promoting this type of initiative by advertising that they did it "on behalf of the communities" or "at the request of the communities", for which they receive many funds and international awards. But these statements are questionable.

By 2000, the regional tourism development project called "Costa Maya" began, promoted by FONATUR. This project proposed the detonation of 4 new towns, Nuevo Xcalak, Xahuaxol, Nuevo Mahahual and Pulticub, in the south of the state, in the region known as Costa Maya. The vision was to create low-intensity tourism supposedly promoting sustainable development.

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He proposed to relocate the town of Xcalak, to the southern end of this area, as New Xcalak. Two kilometers to the west, towards the area called La Aguada. The Secretariat of Agrarian Reform authorized the government of the state of Quintana Roo to cede national land where the new population would be built, far from the coast. These lands would be operated by Fidecaribe (Fideicomiso Caleta Xel-ha y del Caribe) a state trust who assumed the responsibility of integrating – in theory – as partners of tourism development the owners of land, investors and the state government through the allocation of land and the control of investments in Costa Maya.

Chapter 4 of the thesis of David Tello (2009) entitled "The process of management of the marine protected area as a montage for the mediation of interests" relates in a clear and timely manner, how the process of establishing the PNA and the media statements of Friends of Sian Ka'an, the State government and the foreign financiers of a reserve made "at the request of the community”, it didn't happen quite like that. It is incredibly necessary to expose this myth because it has continued to be repeated to justify the creation of other PNAAs supposedly at the "request of the communities", that organizations such as Friends of Sian Ka'an placed themselves in key positions to channel resources and make decisions, appointing themselves representative of society and brandishing the case of Xcalak as one of their greatest achievements. It is mandatory to go step by step to make sure that it does not happen in other communities, in other areas.

The version of the government promoters, academics and ENGO (Friends of Sian Ka'an) of how the decree of the Xcalak reserve was obtained is more or less like this: 1. An express request was made from the community to establish a conservation zone 2. A Community Committee was created with the support of Friends of Sian Ka'an 3. The PNAA was decreed 4. Everyone Happy ever after The truth is that ASK arrived, as its then Director, Juan Bezaury-Creel, said, when the opportunity was "served in silver tray".

What was happening in Xcalak before the booking? Some 8 years before the decree, in 1992, the Andrés Quintana Roo cooperative that grouped the 82

fishermen of the community and some fishermen from the neighboring country of Belize, faced not only a need to have more catch quotas, but also a "New Fisheries Law" and its regulations, which canceled the "social sector" of the exclusive fishing rights of certain species that had been reserved for groups like them. This was a risk because the private sector had greater investment capacity than they did.

By 1993 in addition to the pressure on fishing, the state government began to generate an investment project to develop the southern coastal area of the Mexican Caribbean with a comprehensive tourism project (PTI) for the Xcalak-Punta Herrero corridor. And then, as if that were not enough, the following year the Secretary of Fisheries disappeared and was integrated into the environment, creating the Secretariat of Environment, Natural Resources and Fisheries (SEMARPNA). It meant that from that moment on any issue to be dealt with Beaudry fishing included the environmental, which was already beginning to look conservationist and protectionist (neoliberal environmentalism).

That same year, in 1994, the Costa Maya Master Plan was published. This was a mega tourism development that was supposedly "harmonious with nature", but whose proposal was very similar to the structure that Cancun and Riviera Maya had: a coastline available to developers and "service cities" where to put the workers of those resorts, who migrated by carts from other parts of the state and the country to live in poor conditions most of the time. For the area, "New Xcalak", a sustainable and low-density city, was proposed, but FONATUR, which promoted the project, had no idea what the concept of "low density" meant. A population of approximately 160 thousand inhabitants distributed in the 4 populations was proposed. Control of the project was granted to FIDECARIBE, a trust created by the state government to manage itself as a real estate and developer, which monitored the legality of everything, but ended up promoting the fractionation of lots, speculation, dispossession, caciquism and land tenure conflicts, which were aggravated by the inflated prices reached by the coastal lots.

While this was happening, in Banco Chinchorro, which was the fishing area of the Xcalak fishing cooperative, its designation as a biosphere reserve was being prepared, with the participation of Friends of Sian Ka'an, and therefore, all the dynamics of fishing, permits and authorizations were under the control

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of "the biologists", as they called the OFFICIALS of SEMARPNA and the technicians of Friends of Sian Ka'an who promoted this proposal.

The exploitation areas were reorganized, the constitutive act of the cooperative was modified, Belizean members were excluded, fishermen from outside the community were accepted. And young people, seeing the proximity of tourism, began to bet on this activity. At that time, hanging off Chinchorro, Friends of Sian Ka'an took advantage of Chinchorro's planning actions with the cooperative to reach Xcalak.

Taking advantage of the fact that the cooperative sought to secure and protect their rights and fishing sites, which they saw endangered with the tourist development that was going to compete for the same sites, with the growing idea that the town was going to be relocated away from the coast to give the big tourist capitals the coastal zone, it was easy to convince them that a PNA would protect them from any abuse.

The only thing that Amigos de Sian Ka'an did was to accommodate the discourse of sustainable development linked to the establishment of the PNA, according to which the PNA was going to protect its historical economic activities, its way of life, its rights, from the negative impact that loomed over the community and the reef, product of the neoliberal tourism development that hovered over their heads and threatened their community, the beauty and richness of fishing and biodiversity of its reef.

With all that, most of the community didn't trust environmentalists at all. As Tello puts it, "... the doubt of the inhabitants of Xcalak was to know which side the conservationists were on, because they were not sure of " who is that the biologists work for…”.

The way of proceeding of Friends of Sian Ka'an, as an institutionalized ENGO, in that case and in the following decrees in which it was involved tends to generate distrust since its apparently "bottom up" approach was nothing more than a very well-orchestrated simulation and media strategy. The distrust arose since the villagers were met with the news that "they had supposedly been the ones who had asked the government for a reservation," as ASK advertised, which was not true.

Contrary to what the publications of friends of Sian Ka'an and CONANP affirm, the starting point of the initiative was not the proposal of the 84

community materialized in the two writings addressed to the office of the governor of the State and the National Institute of Ecology. According to some villagers, as Tello describes in his research, before these requests ASK "worked" the community in a manipulative way, from which the ideas that resulted in the letters of the cooperative and the delegate of the town sent.

According to the local inhabitants, it was the Delegate of the community who was the first to be approached by "some people from Mexico". As the delegate was a fisherman, he called the cooperative. These people who came from outside told them about the development that was coming, about the changes that were going to happen to the community and that staying as fishermen was going to stagnate them, that those who were going to arrive were going to steal their wealth. This caused panic in the cooperative and many families in the community... and then Friends of Sian Ka'an appeared.

Tello's interviewees mention that in the group that came to talk to them at first was Juan Bezaury, that he was the one who spoke to them and recommended Friends of Sian Ka'an. The group of people who came from Mexico to create panic and urgency to create a reserve in Xcalak, was Friends of Sian Ka'an, or at least was the Director of that association and other people, and from there they convinced the community to let their staff in to "help" them. Friends of Sian Ka'an came to Xcalak taking advantage of funding from USAID, the U.S. government's funding agency, to promote coastal management, with the University of Rhode Island. They mixed the discourse of the coastal management model that brought the funds, to promote the PNA. Thus, the mix of information from a community strengthening initiative was handled in a way that justified the establishment of a PNA. The villagers were represented as a community using the cooperative, but the cooperative, as a figure, did not represent the inhabitants of Xcalak. For some, the petition incorporated only the interests of a fraction of the fishermen's cooperative: the managers of the new generation. A small group was convinced that ASK appointed as representatives of the community, without true legitimacy and worked with them to promote their participatory design discourse.

The community committee was a similar story. Friends of Sian Ka'an took some members of the Cooperative (not the community) to visit the Hol Chan reserve and San Pedro Island in Belize where they were planted with the idea 85

of what they could achieve, which ended up convincing them to organize. So, as Tello puts it: "... But when the Community Committee was integrated, the community stopped mattering..." The agreements and new rules for the management and decisions, management, dialogue with other actors, validations and constructions, with respect to the protected natural area were built with the committee. This committee was composed of representatives from local productive and service sectors. There were four representatives plus the support staff, who served as members and bearers of the information that, through them, was reproduced in the rest of the local population. It was an "initiative of the people", but the title it carried, of protection and management, "came to those of Sian Ka'an's friends.”.

Later in 1997 the University of Quintana Roo intervened to "adjust" the PNA's proposal to the Costa Maya Territorial Ecological Planning Program, which they were building as government consultants. The community was skeptical and reluctant to accept the modification of the polygonal that the committee had built, more if it came from the outside, so the rector of the then University of Quintana Roo went to the community to convince them that the Ordinance and the PNA could be integrated without causing them any unforeseen conflict. The rector of the University of Quintana Roo in that period was Efrain Villanueva Arcos, founding partner and recognized operator for the south of the state of the ENGO Amigos de Sian Ka'an itself. This promise, as has been demonstrated over the years, turned out to be false.

In Xcalak, by 2006, the local actors with the greatest strength in the town were the members of the Andrés Quintana Roo fishing cooperative and the tourist cooperative; however, by this date there was a rivalry between these groups and the free fishermen, since they accuse each other of not respecting the closures and the areas assigned for fishing within the protected natural areas (Xcalak reefs and Banco Chinchorro).

However, the main conflict detected was between local inhabitants and foreign investors, as well as between these two actors and the State, represented in this case by Fidecaribe, the Ministry of Tourism (Sectur) and the Ministry of Environment and Natural Resources (Semarnat), which was manifested by the complaints by investors who accused Fidecaribe of extortion and several businessmen who complain that they are illegally collect fines from SEMARNAT.

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The businessmen denounced that these actions were a form of pressure or reprisals for not being liked or openly complaining about the members of the environmental institution (SEMARNAT and / or CONANP), represented locally by the Directorate of the Chinchorro Reserves and Xcalak Reefs. The supposed order that PNA bring with them.

The same PNA that the community had helped build and was supposed to contribute to strengthening its sustainable development, according to Friends of Sian Ka'an, the ENGO that promoted it, sank them.

The PNA decree did not stop the pollution, nor the deterioration of the reef, nor the deforestation of the mangrove (Mangrove deforestation agents in Mahahual-Xcalak, Quintana Roo, southeastern Mexico*). Xcalak didn't need a PNA, it needed a PDU, strengthen APIQROO's operating rules, and strengthen real community governance.

In a recent telephone conversation with a senior SEMARNAT official (2021) he told me: - We are dealing with the degradation quarrels that Xcalak suffers, it is a disaster. – he told me - Doesn't it have a PNA that prevents all that? - I asked There was a silence on the other end of the phone line. There was no answer to my question.

Puerto Morelos Reefs National Park The movement for the protection of the Puerto Morelos reef was more like a community social action in response to the loss of economic development opportunities – not the environment – by local inhabitants. Puerto Morelos is a clear example of the failure in the design of environmental policies in Mexico that are created without considering economic activities and the populations that depend on and live on sites and resources.

In 1995, a group of the community felt threatened their way of life (which was mainly fishing) with the forced migration of tourism service providers who had to move from Isla Mujeres and Cancun, specifically from the West Coast National Park of Isla Mujeres, Punta Cancun and Punta Nizúc, when the 87

creation of Natural Protected Areas, that is, the Addresses of the CONANP NAPs kicked them and excluded them, as it would be officially said, when in these sites they limited the number of providers (the famous load capacity that is restricted or expanded depending on the amount of money you have as a service provider), causing the 'expelled' to move to Puerto Morelos. The lack of sensitivity and the exclusivist vision of the policies of creation of PNA that sought to conserve one site, caused a serious problem in another, 36 kilometers to the south.

Local people called for the creation of the NAP and immediately repented and demanded the cancellation of the rules prohibiting access to certain areas, due to the restrictions imposed by zoning to protect the most ecologically rich areas. But there was no turning back.

The interests that lead to the creation of a PNA, although it is said that it arises from the community, may have darker origins, as exemplified by Erika Cruz Coria and other authors in the research called: "The social confrontation for the coastal space: the configuration of tourist landscapes in Puerto Morelos, Quintana Roo". She explains that during the 1990s, a generalized trend emerged in the country with greater force due to the supposed conservation of natural resources, which in Puerto Morelos materialized through the creation of a protected natural area (PNA), whose seeming objective was to prevent external agents from continuing to deteriorate the resource, not to mention that they were taking economic advantage of it.

But reality reveals that the creation of this NAP was due, above all, to the pressure exerted by actors who sought the generation of economic resources, as well as the political and administrative control of permits and concessions for the tourist use of the reef. They were told that as long as there was no government institution administering the resource, there would be no control. There was an urgency to decree the NAP, where have we read that before? Ah, yes! In the last three reservations we have described. Well, here they also created them and the hotel and restaurant entrepreneurs saw threatened the main attraction generated by the tourist influx of foreigners to their establishments, as well as their expansion to offer nautical services.

For the municipal delegation, the illegal exploitation of the reef represented a leak of money for the town, which could well be used to improve the tourist infrastructure. On the other hand, the interest of local nautical service 88

providers was focused on the defense of their main source of employment, whose demand was being monopolized by external companies. The fishermen believed that with the creation of the NAP their fishing areas would be respected and even thought that they would have exclusive use over them.

With the creation of the park, the coastal landscape of the coast began to transform, from being a space shared and managed by those who had historically been dedicated to fishing, it was divided into several areas of use that have caused clashes between the social actors that exploit them as a tourist attraction.

The movement was led by the municipal delegation in the town, the academics of the UNAM, specifically the Institute of Marine Sciences and Limnology of the UNAM who were the main promoters of the movement due to their knowledge regarding the reef and procedures for the constitution of the National Park. For three years they worked to establish the PNA, in an organized manner and directed by UNAM researchers and the Port delegate.

But, as happened in other populations and in other PNA, community participation was limited to inviting direct users with economic interest in the resources in question to participate, that is, only the nautical and fishermen were integrated as if they were the community. The rest of the population was only informed through representatives.

In order to avoid conflicts, information was manipulated towards the other sectors of the population, something widely used by the members of the triad for their PNA, telling them that the NAP would bring benefit to all equally. A clear strategy of neoliberal environmentalism described by Zizumbo-Villarreal et al (2012) in a clear way: "... in this way people who had no way to integrate into a cooperative, due to lack of resources, were prevented from claiming something, they were made to believe that the movement was open and everyone could participate, when in reality it was seen that only a specific group could be part of it. Once the PNA was formally decreed, the problems began, which coincided with the realization of works to improve the community and encourage investment. The opinions of the population were divided and expressed their feelings that they were not informed and that their opinions were not represented...”.

Another example described in the research specifies that various social clashes occurred, because a part of the population was excluded.

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“…An example of this is that when the nautical cooperative was created, a call was opened to integrate, however, it was only possible for people with the economic resources to acquire a boat or condition those that were already available to the new requirements. This situation generated in a certain part of the population the feeling of having been excluded…”

Not to change, the content of the Management Program was developed by personnel of the triad: Academics, ENGO and Government: staff of the Institute of Marine Sciences and Limnology of the UNAM, of the Dr. Alfredo Barrera Marín Botanical Garden, of El Colegio de la Frontera Sur, of the nongovernmental environmental organizations of the locality (Lu'umK'aanab A.C., Yumbalam A.C., Sin Fronteras A.C), as well as state and federal authorities.

With funding from the Mexican Fund for nature conservation.

The demand on the part of the community became a legitimizing movement of the triad, which ended up controlling it, as agents external to the community (UNAM and the NGOs), and representatives of institutional organizations (FMCN, SEMARNAT, CONANP, SEMAR, SHCP, PROFEPA and SAGARPA), and the initial objectives were diverted, passing the control of the action to the institutions, mainly the government through CONANP. These changes occurred in a discreet and gradual way, to the extent that currently, only a part of the population has noticed the loss of control over the resource. Puerto Morelos did not need a NAP, it needed, again, an adequate, operationally sustainable management of the landscape surrounding the body of water, of its BASIN, to update the PDU, its regulations of ecology, urban development, construction, a comprehensive territorial planning that avoided the displacement of people and families who lost their job opportunities due to the imposition of a NAP in another place, but above all to combat and punish corruption effectively.

Banco Chinchorro Biosphere Reserve At Banco Chinchorro, the PNA decree has brought them a series of conflicts that David M. Hoffman described perfectly in his article Conch, Cooperatives, and Conflict: Conservation and Resistance in the Banco Chinchorro Biosphere Reserve (Hoffman, 2014). This author documented very fully the conflicts that the PNA created (and continues to create) for historical users.

Hoffman describes the conflicts of the Banco Chinchorro fishing cooperative 90

with conservation authorities. First, cooperatives were being flattened by the biological and regulatory reality of the snail fishery. They had complied by reducing catch quotas, but the authorities failed to comply with increased surveillance. Second, the conservation regime at the Bank did not meet two mandates of the biosphere reserve model: (1) support for local livelihoods; and (2) the inclusion of resource users in the management of the reserve.

Fishermen felt that undue pressure was being exerted on their use of the snail, while pachucheros or illegal fishermen continued to go largely "unnoticed", "unregulated" and were almost never sanctioned. The participation of fishermen in the decision-making of the reserve was also minimal at that time.

They were largely excluded from decision-making regarding the reserve policies that were made at SEMARNAT's headquarters in the city of Cancun (and later Chetumal).

After citing a case of arrest and imprisonment of a fisherman for snail extraction for self-consumption, a part of his cultural identity, but out of season imposed by the triad (ENGO, academics and government), the members of the fishing cooperative and the community in general were outraged by this event for several reasons. One, the fisherman was not commercially exploiting snail. The amount I had on board was obviously not destined for the black market, as there would be no real interest from buyers for such a small amount of snail. Two, many people cited that the authorities spent too much time behind small infractions like this, made by cooperative fishermen, just to give lessons from them.

Meanwhile, the Pachucheros freely took what they wanted right under their noses or in collusion with the authorities, they specifically pointed to the Reserve Directorate. There were widespread accusations that both fisheries and conservation authorities were receiving payments (the pachocha) to ignore the continued extraction of snail destined for the black market. Finally, traditions are hard to break, and the thought that a cooperative fisherman couldn't return home from Chinchorro with a snail for the family blew up in their identity's face.

Tello (2009), in his study on Xcalak (the population where members of fishing cooperatives who fish in Chinchorro live) describes the decree process of the Chinchorro NAP, where he says that the process was more academic. The promoters, who were Friends of Sian Kaán, came to introduce the fishermen 91

to what was already going to be done. It was not a participatory construction, it was a tokenist simulation.

The same thing happened as in Xcalak, they created panic and risk to their way of life and presented them with the PNA as the only solution. But Banco Chinchorro did not need a NAP, it needed real support to the fishing cooperatives that historically took over the area and were the most interested in the resource and ecosystem being conserved. It required sanctioning the pachucheros (pachocheros), fighting corruption.

Tulum In their research Marín-Marín, et al (2020) describe an atrocious scenario of dispossession and abuse of the state in favor of capital, against the ejidatarios of the Ejido Pino Suárez, located between the Biosphere Reserve of Sian Ka'an and the Arrecifes de Tulum National Park.

Describes the strategies that the triads implement against the locals “…As part of the need for expansion and reconfiguration of capital in the face of its crises, the intense search for areas to develop them productively has made it possible for territories, previously considered unproductive, to enter into a dynamic of commodification, causing problems around the management and access to resources. Thus, the various forms of valorization, management, access and control of nature and territory have created strong tensions between the State, capital and populations, since the different interests in relation to nature cause disputes above all between two main groups: the first, formed by the State and capital, which function as a complex network of power that dominates, among other ways, through policy-making; while the second includes the local inhabitants, who are the ones who, for the most part, manage the resources, aimed at their own subsistence…” (Marín – Marín, et al, 2020) The ejido Pino Suárez exemplifies the processes and collusion between the State and economic capital that protects the interests of those who can pay for neoliberal conservation, from which disputes and violent spoils by the State and capital are turned a deaf ear to the appropriation of the territories and resources of the communities. "... The network of actors that control the economy and politics is not enough, it is also necessary to control natural resources following the logic of capital 92

accumulation, which has led to an ecological imperialism…” (Bellamy & Clark, 2004, in Marín-Marín, 2020).

Already before, Arroyo, et al. (2013) analyzed the disarticulation of the vision and discourse of sustainable tourism with what had been happening in the coastal area of Tulum. Even with the existence of the NAP and different environmental laws, these were subject to the objectives of tourism, without solving the environmental problems such as the loss of mangroves, the pollution of the water table and its overexploitation of it by the resorts and the mega developments that were allowed to be built in the coastal zone, as well as the social problems that have generated a marked imbalance to favor and guarantee the provision of urban services for the residential complexes that house tourists with high purchasing power, without doing the same for the areas where local populations live, which lack these services. Tulum is an unsustainable destination.

Gustavo Marín Guardado speaking in this sense, says: "...it highlights the murky issues of tourism development and the relationships between politicians, businessmen and real estate speculators... However, not always those directly affected are private owners or agrarian community members, but in many cases, they are forms of appropriation of nature reserves or beaches, which are usually public goods or governed by federal laws, where attempts are made to impose projects even when environmental laws prohibit their construction, or when local societies are against certain forms of development ..." (Tourism, globalization and local societies in the Yucatan Peninsula, Mexico).

The most recent public scandal on this subject derives from the report "Tulum: Land of ambitions" by journalist Lydia Cacho (2015) In this report she documents "... Enforced disappearances, homicide, persecutions, threats, extortion... this is how it is possible to dispossess ejidatarios of the Riviera Maya of land. The dynamics of dispossession respond to an open war between corrupting businessmen and corrupt politicians, who have taken the agrarian courts hostage, corrupting judges at times. Tulum is a sample button of what the country is facing: a battle to disappear the ejidos in a context of institutional 93

pulverization in which business ambition is imposed on the law and sustainable development plans..." (Tulum, tierra de ambiciones).

Tulum did NOT need a PNA, it needed to strengthen the capacities and governance of the locals, of the ejido, it required to really provide opportunities to the local population, strengthen local institutions, fight corruption.

Holbox The PNA did not prevent, in fact it was used in favor of, that economic interests outside the ejidatarios stripped them of their patrimony (Isla Holbox: Crónica de un despojo); Caballero (2014), reported: “…The Quintana Roo island of Holbox is the center of a conflict between ejidatarios and a consortium that aims to establish a high-flying tourism development there. Peninsula Maya Developments has resorted to dirty plays: with deception it seized the ejido assembly and stripped the original holders of the land of agrarian rights and plots; with violence he prevented the community members from defending themselves from looting and to top it off he accused some of them of environmental crimes, when the hotel complex will be located in a protected natural area. And the authorities did not come to the aid of the Holboxeños, but on the contrary…”

In his research López-Santillán (2014), shows how Holbox continues in a spiral of environmental crisis, despite having a PNA, some journalistic notes reinforce what has been investigated: Holbox, the Mexican paradise threatened by pollution and lack of water, Profepa intervenes in Holbox for pollution of the island, Holbox, Caribbean paradise, at risk.

In his 2017 news story, Darinka Rodríguez does an extensive investigation into how corruption works around the permits for boats that CONANP grants to service providers in Holbox. Quotes: “…The tourist activities derived from swimming with the whale shark left a spill of 1.4 million dollars in 2014 alone, reason enough for foreign companies to compete against service providers in the area, who are in a constant fight for the permits granted by the National Commission of Protected Natural Areas (CONANP). as well as the number of tourists who move to the protected area...

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In another part of the island, "Ramón", who also offers walks with whale sharks or sells key chains and souvenirs to walkers, recognizes that this year tourism was much more abundant, but it is increasingly difficult for him to obtain permits from CONANP, because he accused that the director of the reserve gives preference to the largest companies ... Each permit is 30 thousand pesos, in addition to having the boat as requested by the authorities is very expensive. I and several of us here every year have to fight the permits…” “…It has been very evident the monopoly of companies there that have about 30 permits, which is serious; the same company has many permits, it is a pity because it is a resource. If you go in a fishermen's boat, they are also in very good condition, where the locals take care of the whale shark," says Ramírez...” “…For the 2016 whale shark swimming season, 160 permits were issued for 294 vessels in the area, according to data from the National Commission of Protected Natural Areas (CONANP). The permits granted are constantly increasing, because, according to an investigation carried out by the environmental consultant Carlos Álvarez, in 2009 90 to 120 permits were granted... Ignacio Millán, Deputy Attorney General for Natural Resources of this agency (PROFEPA), indicated that 206 permits have been registered, in contradiction with what was indicated by CONANP, which ensures that there are 160…”

In 2008, an investigation carried out by TNC (The Nature Conservancy) and CATIE (Centro Agronómico Tropical de Investigación y Enseñanza -Costa Rica-) (Cepeda et al, 2008), just before the declaration of a protected natural area in Holbox, identified a series of threats, in a SWOT analysis; 12 years after the whale shark biosphere reserve decree, the threats not only continue but have worsened. Most of the weaknesses and threats detected in that study have been studied and denounced in recent years by reporters and social researchers; as a phenomenon not only present, but growing.

Holbox did not need a PNA, it needed a PDU, municipal regulations, strengthening of municipal institutions in charge of public services, making an integral management of the entire island and the basin of influence on land, strengthening the governance of locals and eliminating corruption.

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Manatee Sanctuary, Chetumal Bay On October 24, 1996, the Sanctuary of manatee state reserve was decreed, with an area of 277,733,669 hectares. Total or partial territories of 5 ejidos, 4 human settlements: Laguna Guerrero, Raudales, La Fe, Calderas de Barlovento, and a large number of private properties and rural possessions remained within the polygon. In the case of the ejidos Tollocan and Calderas Barlovento, the entire territory was immersed in the polygon of the PNA. The management program was decreed on June 24, 2008, 12 years after the imposition of the PNA As in the other cases, this NAP was established without consulting the owner communities, endorsed by the representation of ENGO and groups close to the triad, as the only self-described representatives of the communities. The proof is that the communities, especially those whose plots remained in the core areas, have been struggling to recover their productive areas, since the decree.

In the technical sheet of the PNA, published by the IBANQROO (Institute of Biodiversity and Natural Protected Areas of Quintana Roo), it is stated that 25 years after its decree, this binational ecosystem (shared with Belize) does not have a binational management agreement, but there is "the intention".

That is, we have a PNA without management or protection, without environmental restrictions in 15 to 20% of the ecosystem, and the area of influence, to the south, because it is part of another country and has been like this for 25 years.

There is no analysis of the residual impact and synergy of the contributions of environmental impacts from the territory of Belize, which are added to the problems of the system, while continuing to insist on criminalizing the communities to the north, on the Mexican side, to whom PNA are imposed, restrictions, are deprived of their areas of plots, they are conditioned and harassed, over-regulation and corruption are encouraged, while the intention is still to make an agreement of understanding after 25 years of calamities and that the NAP has served only to control the authorities for their benefit, and to obtain funds for NGOs and academics. Additionally, in this tab it is assumed that the site will become a Ramsar site.

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“…Ramsar Site: Proposal to declare the Coastal Transversal Corridor Chetumal Bay – Bacalar, which is working in coordination with the UNAM, ECOSUR and the municipalities of Bacalar and Othón P. Blanco …”

This is in addition to the strategy of media insertion and manipulation of public opinion also used by other members of the triad, such as the case of the academic promoter of this initiative, Luisa Falcón, who, as we already mentioned for the Ramsar case study, publicly declared in May 2021 (7 years after the proposal for the Coastal Transversal Corridor Bahía de Chetumal – Bacalar, does not progress) that continues to manage a Ramsar site for the Bacalar complex – Chetumal Bay, as if it had the divine right to impose itself on the fate of thousands of families and hundreds of thousands of community territories, with the approval of the other members of the triad, the sectarian admiration of its defenders and followers and the disbelief of the locals.

This is a clear strategy of how the mechanisms of interaction between the members of the triad work, through the technical sheet of the NAP the proposal that they built unilaterally with the academics for public opinion and NGOs is "validated", despite the opposition of the community groups (which are not the same as the "organized civil society" of ENGO, that are part of the triad) and to demonstrate the support and approval in case of consultation of the national authority and the Ramsar Secretariat itself, pretending that there is a broad approval of the population, when it is not true.

Other aspects highlighted in the PNA data sheet include: The existence of Studies and Projects that apparently seem participatory, but when the research is thoroughly reviewed are difficult statements to verify.

For example, it is stated in the technical sheet that there is a project of Satellite Monitoring of the Daniel Manatee, with community participation. This last part of the declaration "with community participation", made it seem that communities are participating in satellite monitoring, assuming that the project is giving them tools and capabilities, empowering them technologically.

When one reads the research project it is not clear whether community participation really involved this type of empowerment or was only limited to supporting the capture of the specimens or indicating whether they have been observed somewhere in the body of water. Mentions of studies and projects are widespread, without providing the specific data to corroborate what has been said. Thus, investigating to elucidate about the manatee satellite 97

monitoring project, we find studies from 2006 and 2007, which continued to be republished until 2014, without knowing for sure if the mention of IBANQROO, made around 2020 was related to these investigations or some more recent, but not enough data was provided to corroborate what was declared.

Other statements from studies and projects included: Water Quality Monitoring. Implementation of the Community Development Strategy.

Community environmental monitoring through community guardians.

Implementation of the Environmental Education Program. Without specifying periods, actors, financing or direct and indirect beneficiaries. Which presupposes not a tool of transparency, but more a self-justifying and media scheme so that it seems that something is happening permanently and with community impact, but it is not possible to verify it.

It also mentions the Regional Projects being worked on in the PNA: “…We are currently a priority and eligible area within the Marine Resources Conservation Project in Central America phase II, which is financed by the German Bank KfW and administered by the SAM Fund (MARFund). Priority area for the project Integrated Management of the Basin to the Reef of the Mesoamerican Reef System" (MAR2R), which was approved by the Global Environment Facility (GEF), executed by the Central American Commission on Environment and Development (CCAD) and implemented by WWF…” The project had a board of directors chaired, in 2017, by Lorenzo de Rosenzweig who was the Executive Director of the Mexican Fund for the Conservation of Nature, A.C. (FMCN) from 1994 to 2019 – which as we mentioned before, also manages the FPNA (Fund of Protected Natural Areas).

The FMCN statement on this project establishes two lines of work: 1) Consolidation of marine protected areas and 2) Promoting economic wellbeing and improving the quality of life of local populations.

Only that the IBANQROO file does not clarify that the project ended in 2019, and in 2021 it is advertised as if it continued to be executed, without detailing that the period it covered was from 2014 to 2019; does not clarify that the projects were executed by ENGO, in the case of Mexico a different ENGO was chosen each year, as in the case of PRONATURA, Yucatan Peninsula for 2016, by government agencies or by research centers, and that the funds to "Promote economic well-being and improve the quality of life of local 98

populations", by either sub-fund administered by the FMCN, were used for training in monitoring, coral restoration, good practices in tourism, solid and liquid waste management, climate change, participatory management of MPAs, among others, but when the reports are read, these actions and results do not clarify how the strengthening of community groups occurred with them, nor how this type of strengthening contributed to "promoting economic wellbeing and improving the quality of life" of the locals.

The funds of the proportional part for Mexico, from the sub-fund for the Conservation of Marine Resources in Central America, were basically used to equip laboratories, construction of surveillance booths, meetings, studies and consultancies, PROFEPA actions against fishermen, seizures, surveillance and training. Direct beneficiaries: ENGO, Government and Academics; the triad.

Chichankanab lagoon Laguna Chichankanab is a body of water located in the ejido Dziuche, on the border of the State of Quintana Roo and Yucatan, has an area of 25,674.88 hectares (Phina, 2021) In March 2018 the ejido commissioner promoted an amparo against the government of the state of Quintana Roo because this instance decreed a protected natural area without notification, much less consent, of the ejido, owner of the lands legally, since its decree in 1936 and its extension in 1944.

The PNA decree was published on April 1, 2011, 4 days before thenGovernor Félix González Canto finished his term. The ejido had rejected the request of the state government and Friends of Sian Ka'an, to "donate" 14,026 hectares to create the state PNA, 54.6% of its ejido area. So, Friends of Sian Ka'an and the state government proceeded unilaterally and decided to take them on their own. After all, Friends of Sian Ka'an had unilaterally processed a Ramsar Site for that surface a few years earlier.

In its note, the Mexican Civil Council for Sustainable Forestry, states: “…It also manages the entrance to the Chichankanab Lagoon, open to the public for the enjoyment of local families, being the only natural spa to which they have access; it is also visited by inhabitants of Yucatan towns, such as Peto, Tekax and Oxkutzcab. For the above, the Ejido offers tourist services to visitors such as the use of palapas, and rental of kayaks and bicycles.

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This body of water has a high ancestral value for the community of Dziuche, because it still celebrates rituals linked to the Mayan culture, such as "Las Primicias", to give thanks to the deities for the rain and the sun, and renew the vows with nature, with Mother Earth, in which all the people participate, which guarantees the conservation of their traditions, and uses and customs.

"It's a privilege to have the lagoon. To take care of it, we have rules such as Ejido, which prohibit motorboats, so as not to affect the fauna and stromatolites; not a single tree is cut down 100 meters away, because we seek to take care, thinking about the next generations, "says the ejido authority.

The representatives of the Ejidal Commissariat stressed that behind the declaration of natural area, there is interest in taking away the lands and the management of the lagoon system, because there are documents in which "through puns", they restrict the use of resources within the polygon…”

Although this declaration was clearly illegal, and demonstrates again the strategies of dispossession carried out by the promoters of PNA, it is also exemplified how they collude among themselves to exert pressure. For those who wonder why communities and locals are affected by the decrees of Protected Natural Areas, how these affect them and how a community with a protected natural area is controlled, even if its activities are not within the decreed polygon, it is exemplified below following the case of Dziuché.

After the PNA decree, it took 2 years for the ejido to realize what had happened, as they themselves narrate, because SEMA authorities, members of Amigos de Sian Ka'an and other people arrived with a boat to tour the lagoon, supposedly because they were going to begin to see how to develop it, a disguised dispossession, as the community saw it. From there began the community's resistance against the state Secretary of the Environment and against Friends of Sian Ka'an.

In that interim, and after the ejido had been carrying out forest use under management for decades, which had an UMA and had been receiving payment for environmental services for good management practices, in 2016 the SEMA prohibited the ejido from forest use (although it is the responsibility of SEMARNAT) while the Management Program of the Protected Natural Area was not in place. When the decree is reviewed, it is observed that this document establishes:

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• Rule three: The administration, conservation, development and preservation of ecosystems and their elements are the responsibility of the SEMA. • Rule Four. SEMA and Amigos de Sian Ka'an will elaborate the Management Program inviting other agencies and entities of the federal, state and municipal public administration, civil associations, research centers and institutions of higher education. Again, a private party where the owners of the territory were NOT considered: the ejido.

•

Rule Nine: SEMA may enter into agreements to "concession the administration of the protected area". A dispossession simulated in the name of Conservation

The representatives of the Ejidal Commissariat claim, quotes the article of the CCMSS. “…In that process, where are we? What we see is malice and viciousness to dispossess us of our lands and the lands of our children, for the benefit of others…”

As we touched before, here the state government wanted to apply the "for the common good". According to the CCMSS article "... The Legal Department of the state government admitted the act of authority and subsequently denied it. Instead of thoroughly reviewing the case and admitting well-founded and motivated grievances and violations, the state government argued that the decree addresses the rights of "a larger population."…”

As we have argued above, for the case of Ramsar, Friends of Sian Ka'an had already incorporated Chichankanab Lagoon as a Ramsar Site in 2004. This ENGO and the state government proceeded to try to negotiate with the ejido "the donation" of just over half of its territory “in 2005, and when the ejido refused, they only proceeded to decree a PNA on their own, without consulting the owners.

Although the suspension of the PNA decree was issued in 2018, and set a precedent, the file and the polygon of the Protected Natural Area Reserve STATE RESERVE LAGUNAR CHICHANKANAB SYSTEM continues to appear on the PAGE OF THE IBANQROO and the Environmental Log of SEMA.

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Bacalar’s PNA proposal Although, in 2014 Ramsar's proposal for Bacalar was momentarily stopped, and the lagoon already had an administrative instance (APIQROO), the actors of the triad did not take their finger off the line and returned in 2017 with another proposal.

If we remember the 2014 Ramsar site proposal, called the Bacalar Coastal Transversal Corridor - Chetumal Bay, a polygon of 97,591 hectares, proposed unilaterally by Luisa Falcón and ECOSUR, was made up of three polygons: 1.

2.

3.

An area of wetlands, in the center of the lagoon, of 5,499 hectares An area of 87,092 hectares that was the state PNA Sanctuary of the Manatee, Chetumal Bay, and An area of 5,000 hectares proposed by CONANP that was located on the body of water of the Bacalar lagoon

Again the Institute of Ecology of the UNAM and ECOSUR, now with the support of the Secretariat of Environment of the State of Quintana Roo and the environmental organization Friends of Sian Ka'an, AC, who allied in turn with federal legislators of the Green Ecologist Party of Mexico and officials of SEMARNAT and CONANP, and again they attacked trying to justify a decree of a Protected Natural Area (PNA) competence of the Federation, which they called the Bacalar Flora and Fauna Protection Area (APFFB), which had an area of 219 thousand hectares that covered the municipalities of Bacalar and Othón P. Blanco in the territory of 12 ejidos and 18 localities.

In the 2017 proposal, the same actors returned, some in different institutions, but with a more extensive and aggressive proposal. The 2017 PNA proposal affected territories of the ejidos of Bacalar, Aaron Merino Fernández, Laguna Guerrero, Calderites, La Peninsula, Úrsulo Galván, Santa Elena, Buenavista, Pedro A. Santos, who had areas of important forest reserves that reach approximately 11,800 hectares, most with records before SEMARNAT and SEMA, with an average of 13 Management Units for the Conservation of Wildlife (UMA) for the reproduction and use of regulated species of flora and fauna, ecotourism, most of the ejidos had a Community Territorial Planning, reforestation and forest health programs, environmental services, community brigades against forest fires, protection and conservation of mangroves, all of them supported with the assistance of CONAFOR, 102

SEMARNAT, SAGARPA, INAES (National Institute of Social Entrepenuring) and Quintana Roo’s state government.

Similarly, at that time there were 27 low-impact ecotourism and alternative tourism projects, some active and others suspended due to lack of support for their operation, more than 12 aquaculture projects, which from the update of the Local Ecological Management Program (POEL) of the municipality of Othón P. Blanco in 2015, had allowed this activity to have sustained growth in the region.

The ejidos of Calderitas, Úrsulo Galván, Laguna Guerrero, La Península, Tollocan, Calderas Barlovento, were already immersed in the state protected natural area, known as Chetumal Bay, with the category of area subject to ecological conservation Sanctuary of manatee with a total of 281,320 hectares located entirely in the Municipality of Othón P. Blanco, in which since its creation in 1999 it had plunged producers into the almost obligatory need for assistance given that more than 10,000 ha of their productive territories had been separated by the decree of the PNA as an untouchable core area. And that's without considering the private, national and in possession lands that remained within the polygon.

They were pretty much the same actors. At this time this group worked on the media strategy for public opinion to say that this initiative was part of requests from environmental groups and organized civil society. However, as she admitted in an interview in 2021, this initiative arose from the direct request of Luisa Falcón of the UNAM, as she regularly mentions in some press releases, with the support of Alfredo Arellano, then Secretary of Environment of Quintana Roo, former Regional Director of CONANP. In the feasibility study for the establishment of the NAP, carried out by Friends of Sian Ka'an, it is mentioned that its elaboration was financed with resources from the Program for the Management of Protected Natural Areas (FMAN) of the National Commission of Protected Natural Areas (CONANP), which manages the Mexican Fund for the Conservation of Nature (FMCN), as mentioned above, those who on the CONANP page are informed were authorized $400,00.00 to carry out a previous study justifying the declaration of PNA (identified as RPC Bacalar), Land Tenure Study and with own funds of Friends of Sian Ka'an A.C., in collaboration with the Secretariat of Ecology

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and Environment of the State of Quintana Roo (SEMA) that was in charge of Alfredo Arellano.

As alfredo Arellano Guillermo mentioned, the Secretary of Environment of Quintana Roo who promoted the PNA initiative had previously been Regional Director of CONANP in the North of Quintana Roo, so he was very familiar with the mechanisms for establishing protected natural areas, the financing and the benefits that could be obtained from them. He is a controversial character on whom many complaints of corruption hang.

When the communities gathered to protest against this initiative it became clear that they had NOT been consulted or their opinions taken into account to include, in some cases, their entire territories within a Protected Natural Area.

Repetitively in all the proposals of the triad to impose the instruments of environmental policy, to justify actions such as the establishment of a Ramsar site or a NAPA, there are always four elements: 1.

2.

3.

4.

A count of natural resources or species that is "urgent" to save, with very general statements without justifying these statements with data.

One or more groups of actors that are criminalized and pointed out as a cause.

An imminent danger, and The mention that the instrument is THE BEST SOLUTION.

They made their count of things that were urgent to save arguing that the 219,000 hectares were necessary because it allowed the presence of emblematic and protected species that were at risk of survival such as stromatolites, chivita snail, Snail Kite, butterflies, reptiles and birds, as well as mammals and fish.

I emphasize the stromatolites because they are stones, what is alive and can be considered "species" are the microorganisms that inhabit the millimeter or two of microbial mat on its surface, and that not even the Chicxulub meteorite endangered, but build them a myth for their protection and urgency to save these stones built by accumulation of tartar (scales), became a key piece in his media discourse.

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They also argued that due to the tourist potential of the area and the development that was seen coming, in such a fragile environment they made a protected area urgent. But if we return to the presentation of the benefits of the Ramsar site for the triad presented by Luisa Falcón, there is the ability of cyanobacteria as a biotechnology base to process contaminants. It is very easy to evaluate and demonstrate how the triad discourse changes, depending on who nature is being sold to. They also argued that by joining the local ecological management program, the urban development plan, a strict and adequate program of collection and treatment of wastewater would make possible the sustainable development of the municipalities of Othón. P. Blanco, Bacalar and, in general, southern Quintana Roo. If we remove from the text the phrase: the protected natural area, everything else has been a request of the local population for many years. The triad put the NAP as the central axis of its call and linked it with the rest, arguing that the decree was going to be a mechanism to facilitate the institutional management of other processes for the preservation of the environmental values of the ecosystems, represented within the area, as an ideal legal instrument and ends with emotional blackmail its exposition: "... to protect a series of ecosystems that surround the Bacalar lagoon, a unique body of water in Mexico and in the world, for its extension, scenic beauty, biodiversity and connectivity with the Mayan jungle and the Mesoamerican reef, two ecosystems of continental and global relevance…”

When discourses of this type are analyzed, it can be verified that they are repeated in decrees, applications and throughout the environmental marketing of NGOs, government environmental agencies and scientists, to convince public opinion that action is being taken to save nature, in a disinterested, altruistic and almost heroic way.

That servility to academic degrees and government positions makes the population not ask questions and does not dare to question things like: • How is the PNA going to do that? If we remove the NAP from the equation, the rest of the instruments, implemented correctly and for which they were created, on their own, would solve any type of negative impact that was being generated on the body of water.

• How does the NAP come into the equation that makes it key so that now what has not worked, works? From the answers emerge others such as, that the promoters do not take the trouble to explain.

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• How are the authorities going to agree at different levels of government and different sectors, if they have not been able to agree before?

• How is another instrument of environmental policy, there are already three and two more coming (see below) going to be articulated to make a difference?

• •

•

How will it positively and negatively impact the population?

With indicators and projections, not with dreams and hopes.

How do they think the costs for protection/conservation (not only economic, but social, productive, technical, heritage, environmental) are going to be abided?

Who is going to bear the costs? How are we going to avoid corruption, as has happened in other PNA?

Public opinion continues to assume that the promoters of the triad have the answer, but this is rarely the case. Beyond a marketing statement of heroic dyes, the statements of researchers and ENGO affirm something that has not been demonstrated in a practical and concrete way with the PNA and other environmental policy instruments in the country in the last 44 years.

To understand the model of PNA in Mexico, it would be necessary to talk about the origin of the model of protected natural areas in the nineteenth century, particularly in the United States; whose purpose was "to protect wilderness threatened by a growing expansion of urban-industrial civilization conceived as destructive of nature and how this concept of protected natural areas collided with the reality of the "third world" countries of Latin America, where the inhabitants not only live closely with nature, but also coexist with it, but we will deal with that later when we talk about the myth of the tourist load capacity, because they are linked.

Ironically, many of the speeches of the promoters of these areas are based on a romantic idea of paradise in danger, as was the case with the naturalists of the nineteenth century, where the PNAs come from. Practically the same discourse of the naturalists and reservists of that time – two centuries ago – is handled: the only way to protect nature was to separate it from man, through islands from where "those who loved nature" could admire it. When one listens carefully to the justifications of the triad that involve spiritualoid concepts, new age, they are centennial discourses, from the colonialist vision 106

of paradises beyond the reach of the savages, for the enjoyment and use of civilized (wealthy) people who require those paradisiacal places to replenish their spent energies of the stressful life of the cities and monotonous work ... and that they pay very good money for it, we see that we are still practically in the same place as 200 years ago.

I love the reflection that Diegues (2000) leaves us in his research where he says that this situation is due to an updated reproduction of the myth of paradise lost and sought by man after his expulsion from Eden. This neomyth, or modern myth, is, however, impregnated with rational thought represented by concepts such as ecosystem, biological diversity, etc. Technical-rational thinking parasitized by mythical and symbolic thought.

For the proposal of PNA of Bacalar the communities defended themselves by making a technical, social and political analysis of the proposal and promoting a series of actions aimed at raising public awareness. On October 22, 2018, the authorities of the ejidos Pedro Antonio de los Santos, Buena Vista, Aaron Merino Fernández, Bacalar, Juan Sarabia, Santa Elena, Calderitas, Laguna Guerrero, La Península, Úrsula Galván, Tollocan, Calderas Barlovento, and the Civil Association Friends of the Lagoon of Xul Ha and Bacalar, on behalf of their ejido assemblies, sent an extensive letter, they established their position against and their technical reasons. This letter summarized all the arguments that we have been raising since the beginning of this document.

With the media pressure exerted by the communities and the efforts made by their representatives before legislators and senior government officials, the attempt of the triad of decree of the PNA was stopped... momentarily.

Who benefits from PNAs? “…For the Maya, the landscape in which they live, the k'aax (forest), has a moral ecology. It is the place where they feel "at home in the world", where they are situated in a daily commitment to their environment. It is also where their history, identity, spiritual beliefs, communion with other species, and ultimately their survival are rooted. The ethnic boundary they made with me, although it may seem funny or even trivial, is a marker of their identity as a group linked to a territory. While they continue to make a livelihood in the forest, a nature industry, led by gringos, debates what they should and should not do with their 107

land. Some of these outsiders include government bureaucrats, environmental NGOs, private entrepreneurs, conservation biologists, biosphere reserve managers, and even anthropologists.…” (Martínez-Reyes, 2016).

Perhaps the answer to this question lies in the origin of the most prominent Reserve model in Mexico: The Biosphere Reserve. This model was developed in 1974 by a working group of the Man and Biosphere (MAB) program. Since its foundation and to date, the MAB program promotes the establishment of Biosphere Reserves; at its core it is an intergovernmental scientific programme which, from the outset, aims to establish a proven basis for improving the relationship between humans and the environment. We emphasize that it has a scientific basis and involves numerous actors, but its approach is academic, from the exact and natural sciences, it combines research, education and training, includes demonstration sites and produces information for several constituencies but the social sciences that are dedicated to working with the concepts of heritage, human interaction and everything related to human populations, not included in the MAB program, ironically.

To date there are 16 Biosphere Reserves in our country, at least the first registered: Mapimí (1977), La Michilía (1977), Montes Azules (1979), Sian Ka'an (1986) and El Cielo (1986) are attributed to the precursor of the biosphere reserves in Mexico: The Mexican entomologist Gonzalo Halffter, founder of the National Institute of Ecology in 1975. Halffter established the first two biosphere reserves in Mexico, with the support of the Governor of Durango, Dr. Héctor Mayagoitia, a bacteriologist chemist who was then appointed director of the National Polytechnic Institute in 1979, and in 1983 was appointed director of CONACYT, where Halftter was Deputy Director of Scientific Development at the same institution (1982-1986). Between these two scientists turned high-caliber bureaucrats, the first two biosphere reserves were established: Mapimí and La Michilía. One from the academy and another academic from his privileged position as governor of Durango. Both received recognitions and awards for their contribution from CONANP, several decades later.

The Mexican model of Biosphere Reserve developed by Halffter proposed to achieve compatibility between conservation and development, researching 108

and promoting ecologically sustainable and economically productive alternatives for local inhabitants, in addition to turning them into centers of scientific cooperation. Again, something like generating natural laboratories reserved for environmental science in situ. Human populations were not part of the equation, although concepts such as sustainable development or rational use were mentioned or they were seen as mere passive recipients of the wisdom generated by the academy so that they learned to produce and work in harmony with the environment, because the neoliberal academic encomenderos considered they needed to be saved from themselves.

When Halffter's curriculum is reviewed, it does not highlight the 97 pages of it, but the clear profile of scientist and academic of this Researcher emeritus of the National System of Researchers since 1995, and it is understood why the focus of the Biosphere Reserves in Mexico has been research. By the time he proposed and promoted the creation of the Sian Ka'an Biosphere Reserve in 1986, he was Deputy Director of Scientific Development of CONACYT (1982-1986) and as President of the International Council of the MABUNESCO Programme (1984-1986), even becoming An Advisory Partner of Friends of Sian Ka'an and a member of the Advisory Board of CIQROO, it was quite simple for him, since by this point he enjoyed an ideal position, as a high-ranking bureaucrat, very well related, to promote on a national scale his "Mexican" model of biosphere reserves, forging alliances with governors, and supporting the strengthening of scientific institutions related to biosphere reserves. Very much in the hegemonic style of the school of the Institutional Revolutionary Party (PRI) in the government; let's not lose sight of the fact that the decade of the 70s and even the 90s in Mexico not only gave rise to the neoliberal boom but in context, the country was subject to the totalitarian hegemony of the dictatorship, disguised as hard democracy, of the PRI. The reserves were created by and for researchers, if there is any doubt about it, it is enough to cite a fragment of the presentation of the book "Protected natural areas and scientific research in Mexico" that makes clear the vision and position of academics, mainly from the natural sciences. It states that “…Just as the 1960s were truly prodigious because of the revolution it sparked in arts and culture, the 1970s were for Mexico a singular moment of explosive growth in science and technology, as well as the formation of some of the most outstanding cadres of modern Mexican ecology. At present, ecology and conservation science in Mexico are really cutting-edge areas worldwide...

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Without fear of exaggeration, we can say that the work of Mexican scientists is at the basis of our environmental legislation, and were the central factor in the decision to create the National Commission of Protected Natural Areas CONANP. But not all, fortunately, reason to congratulate ourselves. After years of efforts to achieve the professionalization of CONANP personnel, decades after having managed to introduce the criteria of science into the legislation on protected natural areas, the priorities of political decisions, and not technical, threatens again the management of protected natural areas in Mexico. While, on the one hand, our rulers promise us new protected areas, on the other hand the budget for the conservation of Mexico's natural capital is being rapidly reduced. We run the immense risk of returning once again, to the time of the "paper reserves", without personnel and budget, which only exist in official decrees but have no concrete manifestation in the countryside. … there is no - there should be no going back. Conservation based on rigorous science is Mexico's only alternative for a prosperous future and a viable economy …”

A clear vision of the inbred neoliberal stance of the academic sector, which sees protected natural areas not only as its creation, but as its right.

Later we will analyze the strategy of academia, environmental organizations and the government to pressure the establishment of a NAP in the body of water of the Bacalar Lagoon, by manipulating not only data and research presented as scientific, without complying with the rigor of the method or with serious errors of perception or data collection, through media disinformation campaigns in which many prestigious media, such as the New York Times®, the BBC® and El País®, participated voluntarily or involuntarily and we will analyze the actors who take part in this well-organized simulation of neoliberal environmentalism, of "saving nature to negotiate with it", with serious conflicts of interest.

While increasing the urgency and yellowing of their speeches, NGOs, academics and environmental government institutions began to receive financial resources in large quantities, to "contribute" to their crusade.

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The PNA Management Program does not solve the problems As ironic as it may seem, the argument that it is necessary to establish a Protected Natural Area so that, through its Management Program, the problems of pollution, uncontrolled and disorganized development in its vicinity are solved and economic activities are regulated, has no bases.

Local inhabitants and communities have insisted that the Protected Natural Area and its Management Program do not solve the challenges we face, that it is necessary for the municipality, for example, to take its responsibility for the consolidation of well-founded Urban Development Program, territorial ecological ordinances and municipal regulations to solve specific aspects, in addition to investment to improve the public service systems of the populations in the vicinity of the basin and in the basin.

The document called "Protected Natural Areas and Decentralization in the Yucatan Peninsula" clearly states this: “…The Management Program is the instrument that PNAs have for the planning of land uses and activities for the use of natural resources. However, this instrument has serious limitations, even though it is considered as the most appropriate to reflect a true integration of public policies. It has little legal weight, since for its elaboration it has to be subject to the provisions of the different laws and regulations of territorial administration, land uses and use of natural resources. That is, it cannot establish new rules and regulations if they are already defined in some other regulatory instrument, so it can hardly be an ad hoc instrument to meet all the specific needs of the particular management of each PNA...

Likewise, the Management Programs entail limitations for the regulation of the densities and construction rules of development works within the PNA, so that the use of the Territorial Ecological Planning Programs (POET-POEL) and the Urban Development Plans (PDU) become alternative instruments of planning and regulation. Based on this premise, to meet the need to regulate construction densities in the coastal area of the Sian Ka'an Biosphere Reserve, a POET was developed, while the Xcalak and Tulum National Parks have been considered within the planning of regional or local POET. In marine PNA, management

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programs for the regulation of fishing and other activities contained in other legal instruments are also limited.

Within this complexity are the processes of public consultation to submit the Management Programs of the PNA, in which the problem of the representativeness of the economic sectors, of the "community" and of the federal, state and municipal dependencies is presented. Another problem is that of the continuity of consensus and "appropriation": making own or sharing responsibilities on the part of the sectors involved. Generally, the social sectors orient responsibilities in a unidirectional way, leaving the total solution to the government. And on the government side, it is the municipality that often does not adopt the responsibilities and capabilities that correspond to it. The problem of communication and negotiation has to be considered not only in terms of the governing bodies and their different levels, but also of NGOs taking into account their strong dependence on the moments and actions of the agencies that finance conservation and development activities… (Arellano et al, 2008)” Two of its authors, Alfredo Arellano Guillermo and Rafael Robles de Benito have extensive direct experience on governance and this type of instruments in PNA, the first was an official of the Commission of Protected Natural Areas for more than 12 years, later he was Secretary of Environment of the State of Quintana Roo (from 2016 to 2020); the second is currently (2021) Director of the Institute of Biodiversity and Natural Areas of the State of Quintana Roo. However, occupying these positions, their arguments are the opposite. In the case of Bacalar, they argued that the establishment of the PNA and, consequently, its management program, would "save" the lagoon from the impacts of tourism, knowing that there is no PDU (Urban Development Program) in Bacalar, that the process of updating the Ecological Management Program has not been concluded and that many municipal instruments are missing, where local actors insist on investing first.

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PROTUR For 2019 the proposal of PNA, returned "transformed" into an instrument called PROTUR, a short way of calling the "Common management program for tourism use in the Bacalar Lagoon", a supposed voluntary program, product of a simulated consultation and a poor design, due to the haste of creating an instrument that was something close to a Management Program of a PNA (of which it has all the structure and zoning) although it is call it another way and promote tourism.

That year it was already very clear the inclusion of the region in the Megaproject Tren Maya (Maya Train), promoted by the federal government.

One could think and have the "very suspicious" (concept that means having an enormous amount of suspicion or a very powerful suspicion, and that was used in his 2017 article, by Rafael Robles de Benito, now director of the Institute of Biodiversity and Natural Protected Areas of the State of Quintana Roo) that with the proximity of development projects and the improvement of opportunities for the southern zone of the state of Quintana Roo, it was urgent for the State to consolidate its NAP in order to "save nature". We would not have space here to argue that the insistent interest of the State to take control of the body of water seemed to be purely economic or political thumping, given that the Federal Government, promoter of the Mayan Train project belonged to an opposing political party, and the policy of republican austerity at the country level, established since 2018, had restricted many of the discretionary funds with which the state government was accustomed to operating.

Given the strong resistance of the communities towards the idea of the Protected Natural Area or the Ramsar site, a new proposal appeared where the argument was that a regulatory and zoning instrument was urgently 114

required to solve the "lack of regulation that existed in the Lagoon". In the section below called "The myth of the lack of regulation in the Bacalar lagoon", we show that this alleged lack of regulation is a completely false argument.

So, we explored the scenarios around that proposal, its proponents had, at this point, clear conflicts of interest; very well concealed by the pseudoenvironmentalist paraphernalia of "saving the lagoon". In reality, what was becoming increasingly clear, as we have seen up to this point, is how far from the legitimate struggles for the environment and the sensible and intuitive management that the locals had been carrying out for generations, for a true common good, for the environment; these promoters with their unfounded sentimental discourses, of partial vision, disjointed and almost irrational, were closer to a need for resources and consolidation of power over a site with a high value of negotiation at the political and economic level.

We looked for the reasons why the protectionist proposal was insisted on in the body of water of the Bacalar Lagoon, supposedly to protect it from the pollution that tourism, and therefore, the development that the Mayan Train was going to cause; in part all the actors outside the triad agreed that a wellplanned and better executed development was required, so along with the fight against the promoters the community, made up of producer and grassroots organizations, have been involved in a struggle of local actors and communities where they insist on many occasions that the government should then hurry up and finish creating the instruments of urban planning, at the municipal level, to press for investment in infrastructure and services in the communities surrounding the body of water and the upper basin, from where the runoff and the main discharges that affected the Lagoon arrived, instead of focusing on protecting the body of water, receiver of impacts, which did not really solve the problem, as happened in other bodies of water that were now PNA in the state and whose pollution rates were scandalous, because the problem was around the upstream, not in the body of water. But the members of the triad turned a deaf ear.

Where did this new attempt come from?

The Master Plan for Sustainable Tourism of Quintana Roo 2030 115

To be able to understand where the PROTUR proposal came from. This proposal and the proposals that have followed, it is worth reviewing what was happening at that time around in the state and national context. In 2016 the change of government in the state of Quintana Roo had happened and the institutional revolutionary party, which had governed the state in the last 40 years was no longer in power. The new government, a strange alliance between the National Action Party and the Party of the Democratic Revolution was in government (right and left), and presented its State Development Plan 2016 – 2022 where, in Axis I, program 4, Action 1.4.2 established the "Design and implement the Master Plan for Sustainable Tourism".

When one reads the document, one notices that the basis of the Master Plan is made from a diagnosis, created by the Tourism sector, in this diagnosis five causes are delimited by which the tourism development model in Quintana Roo was not considered sufficiently competitive, and with which the need to create a Strategic Plan for Sustainable Tourism was justified. The causes of the non-sustainability of tourism included: 1. The tourism public sector governance model had not fully incorporated internationally validated sustainability criteria.

2. The tourism development model had generated environmental impacts on key ecosystems.

3. The tourism model favored an unbalanced investment.

4. The tourism model did little to promote sustainability and innovation 5. The tourism model in the state had generated gaps in social inequality.

These "discoveries" that had already been denounced for decades by social researchers and local groups, were contradictory to what on multiple occasions the official actors of the State Environment Secretariat and CONANP had wielded. They insisted that their policy, instruments, governance and in general the entire PNA model that had been developing in Quintana Roo since the eighties under the pretext of tourism, had created sustainability, prevented or avoided environmental impacts, benefiting investment for all and contributing to social equality. But the official tourism sector denied those claims.

The key focal activity – tourism – around which the environmental sector created its instruments, or at least served as a pretext for it, did not comply, 116

more than thirty years after it began to be used as an excuse for control, with the basic guidelines of sustainability, had not even considered them.

The most recent statement issued by the environmental sector in the state of Quintana Roo, announces that they have served to protect the ecosystems between the reserves (the case of the Calakmul and Sian Ka' a biological corridor), the truth is that in the last 30 years, the fragmentation of ecosystems in Felipe Carrillo Puerto, José María Morelos, Bacalar, Othón P. Blanco, Calakmul and Hopelchén, in that corridor, totals more than half a million hectares. An increase of more than 1000% since 1986.

To the communities the establishment of environmental management instruments was presented as a unique opportunity, to be able to get involved as beneficiaries of sustainable tourism development, that said the environment sector, the NGOs and the CONANP; people were told that establishing a PNA would benefit them with ecotourism, handicrafts and selling their products or generating jobs; but the tourism sector said, at the same time, that the tourism model (in Quintana Roo) privileged an unbalanced investment (See ahead, The myth of Tourism and tourism in PNA, pro poor).

If we do the exercise of comparing both postures: Environment says

Tourism says

Our environmental public sector governance model with protection instruments created around tourism, fully promotes internationally validated sustainability criteria.

Our tourism public sector governance model has not incorporated the internationally validated sustainability criteria that environment tells.

That's what PNA and Ramsar sites are for, which promote sustainability and protect our natural resources and biodiversity around tourism activities (in response to which they were established, first of all).

Although our tourism activities are developed in these areas (PNA, Ramsar sites) we have not integrated a sustainable environmental model.

Our instruments made it possible to protect ecosystems.

Tourism development has generated environmental impacts (because it does not follow a sustainable model) in key ecosystems, for the same area of the PNA and Ramsar sites.

Our tools created in areas of tourist interest have benefited local communities.

Tourism, even where there are PNA and Ramsar sites in Quintana Roo

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Environment says

Tourism says has widened social gaps and privileged an unbalanced investment.

The Master Plan for Sustainable Tourism of Quintana Roo 2030 (SEDETUR, 2021) stated in the diagnosis of its justification that tourism had generated various problems: a) Depletion of natural resources b) Short-term economy without a locally distributed economic spillover c) Decomposition of the social fabric in the state In the aspects of public policies and governance, they also exposed the weaknesses of the sector, which had definitely kept it unsustainable. These weaknesses included that existing laws and other regulatory guidelines for tourism in the state were outdated; that these guidelines were not articulated with sustainability commitments at the international level in which they were included in our country; that there was no investment from the public sector in tourism, this being the main activity in the state; that there was no followup or monitoring at the sectoral level in this sector so important for the entity, and that there was a lack of coordination between government institutions, civil society and the private sector and academia.

Part of the approaches to evaluate and determine the optimal level of growth for tourism activity in the program are related to the measurement of tourist load capacity (CST) of destinations or acceptable change limit (LCA).

However, for more than 30 years it has been evaluated and it has been determined by numerous researchers that the CCT is not suitable to evaluate the capacity of a site to withstand a certain use, because the sites do NOT have a natural CCT. Later we will talk about the failure of foundation of the load capacity model for planning (See The myth of tourist carrying capacity).

Another unverifiable assertion of the specific document that tourism, as an economic activity, has contributed to reducing poverty in our country, this point is also discussed later (See The myth of tourism and tourism in PNA, pro poor).

Within the framework of the Sustainable Tourism Master Plan, it was established that this was a strategic instrument to implement a new model of tourism development, with criteria that could contribute to meeting the 118

Sustainable Development Goals (SDGs) of the United Nations. Which implied that the previous model, which was used and pretexted by the NAPs and Ramsar sites, was NOT working. In this frame of reference, PROTUR emerged.

PROTUR was now protected by the Secretary of Tourism in charge of Marisol Vanegas Pérez and the then Secretary of the Environment of the state of Quintana Roo, Alfredo Arellano Guillermo. The Consultant was Geoalternative, led by Silvana Ibarra Madrigal, who had been involved as a public official for the government of Jalisco in charge of Ramsar sites and at the same time as part of a consulting company for the government itself, and had the approval and open support of the municipality of Bacalar, through the Director of Municipal Ecology, Romel Cano Alvarez, who became actively involved.

As an additional comment, the same actors that promoted PROTUR built another parallel instrument in 2019: Water Sensitive Territory in Quintana Roo (also built with Geoalternative) according to the then Secretary of environment of Quintana Roo, it was a planning scheme based on the underground aquifer, which flowed into the lagoon of the seven colors, which is the basis of the tourist development of the municipality and they intended to include it in the regulations.

The document specified that some guidelines of water-sensitive territories were being incorporated into the Territorial Planning of Bacalar, which made it an innovative planning method, which would be setting an example at the state level and mainly for the Yucatan Peninsula.

But the Territorial Ecological Planning of Bacalar was still under review (since 2011), the Urban Development Program (PDU) was being built since the foundation of the municipality, almost 10 years before, and was not being built in a real participatory way, but through a cabinet consultancy, and despite all the demands of the community to update this instrument, nor had it produced a revision and a decree. There were many contradictions in the way it was handled and many procedural shortcomings of PROTUR. The justification for PROTUR is quoted from page 36 of the document itself: “…Justification of PROTUR

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According to the analysis of the natural elements of the Bacalar Lagoon, we can indicate that it is unique, and its biocultural landscape has fascinated tourism, but in an accelerated way, with lack of order. The current socio-environmental problems also limit the possibilities of achieving a sustainable territory. That is why this PROTUR derives from the urgency of territorial planning and coordination between the social sectors. The socio-environmental problem puts at risk the biocultural heritage, being indispensable a program of public use according to the method of Acceptable Change Limit and Tourist Load Capacity…”

It sounded very ambitious, pertinent and fair, on paper. In reality, it did not meet any of the expectations with which it was sold to public opinion. The problem arises when the document is analyzed in detail. The serious thing is that it was used validated by the state government to try to make it work as a regulatory / governing document of the activities in the Bacalar Lagoon.

It had two elements: a base document and a zoning map (in the document and an interactive one). Reviewing carefully, we came across many unfounded approaches and assertions, which raised many doubts about their true intention and scope.

The paper argues that 4 criteria were used to determine the key elements for zoning: 1) Ecological conditions, 2) Access prevalence, 3) Duration of impacts, and 4) Visibility of impacts.

They mention having developed the methodology, of acceptable change limit and tourist carrying capacity and range of recreational opportunities, and having carried them out in a participatory manner. But it didn't happen that way.

We will review four points of PROTUR that demonstrate what "is wrong" with PROTUR and in general with most of the instruments created from the vision of the triad, which end up being easily demolished because they lack the foundation that is consolidated with a real and solid technical-community work. The four points that are a disaster with PROTUR include: 1.

Participatory construction simulation, 2. The inexplicable calculation of carrying capacity and acceptable change limit, 3. The unexplained zoning criteria and 4. The "innovative" proposals that really put at risk the lagoon and the safety of the users.

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Participatory construction simulation The diagnosis, at first, is only a count of statistics provided by the Port Captaincy for June 2019 and concludes with data from three elements: activities, infrastructure and vessels. Taking into consideration that the diagnosis should be based on and refer to the Bacalar Lagoon, the body of water, it is strange how the list of activities carried out in the lagoon begins with the visit to archaeological and cultural zones, includes rental of bicycles and scooters, rest in spa and yoga, rental of cabins, among other tourist activities. Which already indicates from the outset an unfocused view of the object of the study.

The social actors who were invited to know it (and indirectly to validate it) were presented with the discourse that this was a voluntary, harmless instrument, of common agreement that was going to be set in motion with the will of all, in response to a very serious crisis that required a solidary, immediate community action; a harmless regulation to "save the lagoon", very much in the style of the triad with Ramsar. But the same promoters of the triad in other FORUMS of ENGO and academics, specifically the coordinator of the consultancy, Silvana Ibarra, stipulated something else as the objective of PROTUR, told them that they were going to build a public policy instrument that was possible to convert into a normative provision. From the wishes, projects of society, the advice and facilitation of people who study the natural system and nature tourism. A double discourse and a blatant discursive manipulation.

How were they going to do it? Ibarra stipulated that between February and March 2019, he said in his invitation, there would be 4 events, with various topics to share, in addition to office work, management and some fieldwork for verification of key points. It referred to 3 workshops and a seminar. The first was to be for mapping of tourist elements and SWOT analysis to be carried out in the communities of Buenavista and Bacalar; the second was to outline nature tourism activities and strategies to reduce socio-environmental impacts, to be carried out in the same communities; the third was on visitor management strategies, and finally a Seminar Reducing the impacts of tourism in the lagoon. In the end what was obtained was a brief bibliographic review, a mapping of zoning of the Lagoon, based on the map by specific consultations, without a true justification of the selection criterion of key informants, a 121

procedure that is repeated by the promoters of PNA: their informants and participants are their group of "cuates" (pals) or groups related to the interests or discourse of the triad, mostly.

One of the elements that were most repeated as justification for wanting to impose this instrument is that it had been built in a participatory and consensual manner, and that it had been validated by local actors, validated by the communities of the Bacalar lagoon area. But once again it was the communities that opposed its establishment. This made it seem that the communities were falling into intransigence. However, the opposition, as can already be elucidated in this document, came from solid arguments for not accepting the impositions of the triad, impositions built in a simulated way with objectives far removed from environmental conservation, now in PROTUR. Taking up the example of what happened in the PNA of Xcalak (Tello, 2009), the concept of community of PROTUR was personified in the simplistic representation of a group of people who, the majority, were there because they shared common interests of environmental groups, academics or government; the group was part of the community but was NOT representative of the community. Worse, they were part of a minuscule portion of the communities in the Laguna area, selected for affinity of ideas.

If we talk about participatory processes, where planning instruments like this are designed, there are two things that do not appear in PROTUR: how the participants were selected (based on very specific information needs) and how the information from the basic diagnosis/analysis was linked to build the rest of the instrument. Since it was trying to build an environmental policy instrument for the body of water, based on local knowledge, an essential issue in this type of research necessarily has to do with the means by which local experts are identified and summoned. And by experts, I mean experienced people, not triad scholars.

From the outset, the assumption of participatory construction of PROTUR loses all validity because it was not built with the consideration of all possible actors who had to participate and instead a quick exercise was made trying to pretend and justify the participatory aspect with nearby groups, without clear selection criteria.

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It was not a social gathering, nor was it an exercise in wishes and dreams, it was an exercise in planning tourism activities, mainly nautical tourism, given the objective of the instrument, established from the basis of the understanding of the environmental system, but also of the dynamics of use of the lagoon, to establish the bases of a regulatory instrument (a regulation).

Experiential experience was required and not only academic-scientific knowledge of the cabinet; but in addition, it was required a broad knowledge of the system with experience in situ, to characterize it from that perspective, to know parameters such as depth-des, seasonal variability, critical areas, navigation strategies, type of access to the areas, potential risks, human interaction in the various activities, hot spots, navigation strategies according to the types of boat, to understand how the system that was intended to regulate was conceived.

In Bacalar, if you know how to work with the methodologies of identification of key informants it is easy to elucidate that this information is held by the captains of boats and the historical users of the lagoon, as was done with the proposal of Rule 23 of the APIQROO operations regulations proposed by the Community Council of the Bacalar Lagoon Basin (CONCCLAB), described in the APIQROO chapter.

At PROTUR, many of the procedures they used to validate the product were, with no other way of defining it, "simulated". We obtained this perspective of the simulation from the beginning of the analysis of the instrument, with the answers, product of direct interviews with some of the actors who were summoned to participate in these workshops and of the opinion on the behavior and procedure especially of Silvana Ibarra, coordinator of the consultancy, during the alleged consultations, with which we gave ourselves an idea of how the supposed "participatory construction" took place. “…we were invited to hear a proposal and when we gave opinions Silvana did not like it if we did not agree and forcibly wanted us to accept what she said, I better end up just listening, because in the end she did what she wanted…”

Joaquin Calderon. Member of the cooperative of Nautical Service Providers

It is important at this point to make the observation that some of those involved appear in the PROTUR document as part of the core team of logistics convening, management and facilitation of workshops, but when they were interviewed to obtain information on the form of integration and 123

governance of said team, its agenda and its participatory work strategy, these social actors who were pointed out by Silvana Ibarra as part of her core work team... they didn't know what we were talking about. They clarified that, like the rest of the actors, they attended as guests but had not been informed that they were part of a work team, logistics or promotion of any instrument, and never acted as such.

Obviously, the document lacks the basis of participatory design, and had been presented at this point in a blatantly deceitful manner. It was logical that when he came to the opportunity to present it to the members of the communities there would have been annoyances and attempts to discuss what was proposed, but they were not given an opportunity. “…Well, if they invited us to a presentation, of an idea they had... but they didn't tell us they were going to do one thing like a reservation... they were like their ideas and I went and said ah, well it's okay to come and listen to that idea they have... but that's it.”

Luis Chimal Balam. President of the Ejido Commissariat of the Bacalar ejido 2018 – 2021.

In terms of percentage of participation, the social sector convened only included 4 actors, 7% of the total sample, while tourism service providers were 33%. 300 participants are mentioned, but from the talk with the representatives of the ejidos Bacalar and Aaron Merino (50% of the social actors who attended) it was found that the participation was not informed, and only one or two representatives attended one or two calls. When one reviews the PROTUR document the first thing that emerges clearly is that it tried to solve the deficiency of call and participation Including volunteers and students, and trying to give more formality to the structure, placing some of the attendees as if they had been part of the core team, when they were only assistants.

At all times the process was manipulated and directed, and sometimes led by the municipality of Bacalar, which geographically only has interference in approximately 30% of the entire system. The participation of the municipality of Othón P. Blanco was ignored, which has interference in the remaining 70%.

In conclusion, like-minded people and people "necessary" to demonstrate that other sectors of the population had been taken into account in a "fair" manner were invited to the meetings and workshops. A tokenist strategy to simulate participation. But the exercises were directed, manipulated, and the attendees 124

had no capacity or experience or experiential knowledge of the system to contribute adequately to a first moment of planning that was going to base the entire instrument.

SWOT without feet or head In step 3 of the PROTUR methodology, swot was used for the basic diagnosis, which they present as if it were an analysis, for the structuring of the project.

According to the team that was building PROTUR, SWOT was supposed to be "... would contribute to determine advantages and disadvantages to operate the tourist activity of nature in the present and future taking into account economic, political, social and cultural factors as well as aspect of service provided by financial and market, control organizations that represent the influences of the external and internal sphere to the community were also identified strategies for opportunities and threats and to potentiate the strengths and give solutions to the weaknesses identified..." (Geoalternativa, et al, 2020) But the SWOT presented as a result was far from the objective image and commitment that in the methodology, I know this exercise would constitute.

The SWOT analysis methodology used for PROTOUR was to determine advantages and disadvantages for operating nature tourism activity in the present and future, taking into account economic, political, social and cultural factors.

To identify strengths, opportunities, weaknesses and threats (SWOT) as objectively as possible, it must be ensured that participants have a full knowledge of the subject, to locate and substantiate the selected elements and the categories delineated in a coherent and useful way. Swot has limitations, because it is only a diagnostic tool: it can become a list of things or situations selected without a good definition or objective, due to prejudices, training or vision, even mood of the participant. What is listed may fall into one or more categories – it may be a threat to some and an opportunity to others – or it may not fall into any category, it may have no foundation. And of course, the most important criticism about the construction of swot is how easily it can become biased.

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That is, it is risky to use this diagnostic methodology if the objective and correct selection of the informants is not guaranteed, because a partial and subjective vision created from the interests themselves, profiles of the group, ignorance or knowledge of the subject, or the manipulation (intentional or not) of the facilitators will be obtained, as happened in the SWOT of PROTUR. The SWOT of PROTUR is a hodgepodge where it is difficult to understand the criteria that was followed to present it. Figure 31 of the PROTUR document shows the result of the SWOT by mixing the categories: Internal and external strengths - which should be Opportunities - placing them against (internal) weaknesses, but the threats do not appear. This shows how the facilitation of consulting either ignored the use and limitations of the tool or took the diagnosis and presented it as he wanted. Needless to say, the opportunity factor and threat counterpart were presented in a separate table.

It is striking that the categories themselves were modified, only strengths were delimited (they were supposed to be internal) but the list included internal and external factors, to which weaknesses were then applied. A confusing SWOT, which gave a Picasso-style image.

It seems like a lack of experience in this type of construction or a blatant simulation of tokenist participation. But the result is brief, unfounded, and completely disjointed from the objective, bordering on the confusing.

When local actors confronted consultants with the shortcomings of their "participatory methodology", consultants worsened the situation by trying to compensate for those shortcomings. They held group calls in the midst of the health contingency due to COVID19, the entity being at a red light, without caring to put the summoned participants at risk, which unleashed even more severe criticism against it. This demonstrated not only the lack of social awareness and empathy of the consultant towards local communities, but its total ignorance or total lack of qualifications to perform the committed work.

The Unexplained Calculation of Load Capacity and Acceptable Change Limit

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The World Tourism Organization defines carrying capacity as "the level of visitors using an area can be accommodated" (Buckley, 1999). However, there is still much confusion about this concept. We will talk at length about the reasons why the scientific community at the international level and the local inhabitants, the social actors, question the use of the numbers arising from the Tourist Load Capacity (CCT) and acceptable Exchange Limit (LCA) (See the Myth of the Tourist Load Capacity, below); for the moment we will limit ourselves to analyzing the concepts and data contained in PROTUR. When reviewed in Annex 1 of the PROTUR document, which supposedly explains the way in which the data and calculations of the Load Capacity were obtained, the data that were used to determine it are inexplicable; more than inexplicable, they lack explanation. As an example, the calculation of Physical Load Capacity, was exemplified with a single site as a reference base that was The Pirate Channel (Type of opportunity II, according to PROTUR): Result: Physical Load Capacity: 21,345.04 people per day. It was estimated between 5 to 14 people per boat up to 27 feet, which gave 1,778.75 people.

Used the physical load capacity formula: CCF = S*NV Sp Where: S= Available surface sp= Surface used by people NV= Number of times the site can be visited by the same person in a day (parameters Tv/Hv) But when reviewing the data, we found that: Hv/Tv = 13/Varies according to site. This does not allow to corroborate the reference data so that one can perform the calculation that the consultant made. However, below the calculation is made as follows (page 118 of PROTUR): Physical carrying capacity= 46571*3.666666667 = 21,345.04 people a day.

One assumes that 46571 (m2?) is the area of the Pirate Channel (S) that is mentioned as an example (Opportunity Type II), but the calculation presented does not follow the formula and is in fact wrong. If we take the data directly as it is in the document: 127

46571*3.666666667= 21,345.04 people per day, if the calculation is done in this way, 46571*3.666666667= 170,760.33 people per day. Unless the area used per person had been 8 (m2), which is what gives 170,760.33 between 21,345.04 = 8. But the document leaves us guessing where all those numbers came from? And it goes further, presenting a box of Data and results of the CCF, with another inexplicable number: Oportunity Class

II

Physical carrying capacity (persons day) 21,345.04

Persons per group/ eUp to 27 feet vessels

Carrying capacity vessels per day

5-14

1,778.75

per

Source: tkn from page 118 http://www.geoalternativa.com/acervo/PROTUR_2020.pdf

PROTUR

document.

En:

It does not explain how they averaged 5 to 14 people per boat, so that they turned out to be 21,345.04 (which we already saw is an inexplicable number), determined 1,778.75 boats per day, before the correction factors. The number of people to give us that result is 12. How was the criterion set for 12 to be the magic number in the range of 5 to 14? If we used practical reasoning, we would take 9.5, which is the average between 5 and 14. But that would have given a greater number of vessels: 21,354.04 / 9.5 = 2,246.8 vessels. 460 boats more than the result obtained by the consultant.

We do not say that this number is correct or not, from the outset it is difficult to understand the initial reasoning for this calculation of physical load capacity, let alone the criteria to determine its values and the way in which the results were communicated, and so with the rest of Annex 1. Correction factors are also not explained, and since they do not refer to bibliographic citations or calculation memories, all the numbers obtained seem to have magically appeared.

As a comment, there is currently a marked conflict between the boatmen and serious questions from public opinion about the number of boats in the lagoon, with only 500 or 600 boats operating. The Load Capacity of PROTUR established practically triple that number: 1,779 vessels; if we corrected the calculation as I did, dividing between the average of 9.5 and not 12, as they 128

inexplicably determined, the number of vessels would rise to 2,247. PROTUR would have determined almost 4 times the number of boats. However, Load Capacity is not a recommended method, as can be seen in the corresponding section of myths in this regard.

With respect to the Acceptable Exchange Limit, in the presentation of the methods (page 41 of the document) PROTUR determined: "... The acceptable change limit method is based on determining the desired conditions in a place to plan the actions necessary to achieve these conditions (García Rivas, et al 2005) The acceptable change limit includes elements on the visitor's experience, compatible with nature tourism and considers above all social empowerment so that society is the one who exercises compliance with its planning decisions, then precursors of sustainability in their territory through monitoring. A seven-step process... tends to the strategic planning of activities in the lagoon..." But it falls short. In the text, the way in which they constructed all the elements becomes confusing and fails to adequately communicate the basis of their procedures. For more details on Acceptable Change Limit, see later in the myths section.

About the ACL methodology used in the PROTUR, very strong assertions are made (for marketing), but they are hardly fulfilled in the development of the document. The consultant pledges: "...The acceptable change limit includes elements on the visitor's experience, compatible with nature tourism and considers above all the social empowerment so that it is society that exercises the fulfillment of its decisions in planning, being then precursors of sustainability in its territory through monitoring. Through a seven-step process (Figure 25) the strategic planning of activities in the lagoon is tended..."

If we stop to reason this statement, it follows that for PROTUR the LCA sought to satisfy the experience of tourists, not the knowledge of the system, nor its focus was environmental protection. Which is understandable since it is an evaluation of tourist activity for the benefit only of the tourist experience, not the protection of the ecosystem. But the community was sold in an environmental protection speech.

It also said that the acceptable change limit criterion was for tourists whose experience preferences were compatible with nature tourism. But that is a marketing and simplistic assertion without basis, if one takes into 129

consideration that the way in which a tourist could interpret an experience and determine a preference depends on very complex individual valuations, if we only took into consideration how human beings individually prioritize what is important to us. It is not possible to make a simplistic statement of the emotions of tourism customers, nor to have a simplistic idea of what they are looking for, given that other aspects such as their human condition, their baggage, advertising, attraction from the tourist offer, and various factors that stimulate the decisions of the tourist would have to be incorporated.

Another part of the LCA's goal was that society itself, based on tourist preferences, was going to have to build a stage with rules and abide by them.

But it was built from a flimsy and uninformed place, without knowledge of the target, with a disjointed process and with a level of tokenist participation, simulated.

Finally, he asserted that social empowerment was going to be limited to following the rules to meet the expectations of the tourist and learning to monitor the system to guarantee the tourist that he will have those experiences. What is understood is that the social empowerment promoted

by PROTUR, would consist of letting the group of close actors to whom they were invited, convened and granted the power to decide on behalf of the whole society (to simulate that it was done "in a participatory way"), was going to establish and decide on the criteria that the rest of the population was going to have to follow and monitor obligatorily; while they (with access to administer funds or direct benefits) and the rest of the community (bound by the triad's decision) guaranteed that the Lagoon would be a place where visitors would have a satisfactory experience of a cared for natural resource, regardless of what it was.

That, for the promoters of the instrument, was social empowerment and the key to the conservation of the Lagoon: Engage society, with what was decided by a group selected by themselves, with unilateral criteria, with a simulated "participatory" planning, to ensure that tourists could have a "reserved" and "protected" site that would guarantee them an experience of enjoyment of the Lagoon.

Where had been the initial justification of PROTUR? to be a solution to socioenvironmental problems and for the protection of biocultural heritage. The promoters of PROTUR, as part of the triad, believed that the passive 130

participation of the community was the ultimate goal of empowerment, to be there, validating what was provided to them, and not as part of a real construction. Also believing that the paradigm of sustainable tourism was going to work as if by magic, without the local inhabitants being really empowered.

The strengthening and empowerment of residents, i.e., local inhabitants, may not mean the same for local actors as for the government, for environmental non-governmental organizations or for academics, what is recognized is that "if the government does not empower residents, the success of tourism development and sustainability cannot be guaranteed" (Choi & Murray, 2010).

By focusing on the tastes, preferences and needs of tourists as the basis for planning a regulatory instrument from which to "empower" locals, that is, if the objective of the instrument is to regulate the site to keep the lagoon "pretty" for visitors, and then pretend that this decision and vision was "built" through a participatory methodology, Built with locals, such as PROTUR and its promoters, it openly violates the Berlin Declaration on Biodiversity and Sustainable Tourism that was issued in 1997. “…Tourism must be developed in a way that benefits local communities, strengthens the local economy, employs the local workforce and, where ecologically sustainable, uses local materials, local agricultural products and traditional skills. Mechanisms, including policies and legislation, should be introduced to ensure the flow of benefits to local communities. Tourism activities must respect the ecological characteristics and capacity of the local environment in which they are carried out. Every effort must be made to respect traditional lifestyles and cultures..." (Biodiversity and Tourism, 1997) …”

The reference literature for building PROTUR came from CONANP. Although it is insisted that PROTUR did not try to be a management program for a NAP, it was enough to be aware that the Tourist Load Capacity and Acceptable Change Limit are concepts that were developed for Protected Natural Areas... Bacalar is not a protected natural area.

The methodology used by PROTUR was adapted from the manuals for the Development of Public Use Programs based on the Acceptable Change Limit methodology in the protected natural areas of Mexico (CONANP 2016) and the Manual of method of elaboration of programs for public use in the region

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of the Mesoamerican Reef System (SAM) although it could not be found in the reference literature provided in PROTUR to verify.

With all the above and again questioning the ability of the office and its person in charge to work with this type of instrument and with the local population, the incapacity, neglect or total cynicism of the researchers and "experts" of the triad who did not even have the criteria or principles to ensure that the calculations were not only founded, but coherence, it was logical that local people and actors outside the triad severely questioned PROTUR and its promoters, some of whom had already been participating in the previous attempts since 2011.

Unexplained zoning criteria Parallel to the "participatory stage" what was obtained was a mapping of zoning of the Lagoon, proposing a division of uses not at all understandable, if what was sought was the conservation of the various ecosystems of the lagoon, the stromatolites and microbialites of the Lagoon and even ensure the scenic beauty so that tourists continued to enjoy the site. The base plan of PROTUR consisted of a representation of the main body of water of Laguna Bacalar, Laguna Mariscal, a portion of Estero de Chac and the connection zone between the northern part of the Lagoon of Bacalar and Laguna Chile Verde.

The area was divided into five types of use (Geolternativa et al, 2020), which according to the PROTUR document were category 0 areas or Conservation areas, or areas without access to tourists; I. Exclusive areas, in which the tourist can have a quality experience in a place of high ecological integrity; Type II zones. Areas that are natural, however signs of tourist impacts can be detected by a greater frequency of tourists; Type III zones. Areas that have the greatest Impact and Type IV Zones. Urban areas.

The first thing that catches the eye on PROTUR's zoning plan is how much its zoning resembles a PNA. The plan, if it had been built in a participatory, really participatory way, would have been difficult to repeat the same criteria of the previous instruments that were openly planned and designed from outside the community, created by institutional agents "from outside", who were only consulted, not built, with the population. It is a plan that keeps many similarities and criteria based on, for example, the base proposal plan of 132

Ramsar site of 2011, proposed by Luisa Falcón, of the Institute of Ecology of the UNAM, and both coincided with the plans and base zonings of the Ecological Ordinances of Bacalar (2005) and Othón P. Blanco (2015).

Here we must clarify two things, from the PLAN of PROTUR: The plan in the document said one thing and the interactive plan detailed by zones told a very different story. As a technical advisor to several members of the Bacalar lagoon operations committee before APIQROO, I was provided with the link to review the interactive plan proposed by the consultant. This link is not currently working but we reviewed it, downloaded the kmz file and had the opportunity to make observations at the time. One thing is what was presented in the document that was so much defended in all the support groups and another thing is what appeared on the interactive map that was presented to the authorities, who were the main cause of the real potential conflict that the community detected. I leave some examples, of the many that were found as inexplicable zoning criteria.

Magical Bacalar ejido swimming facility in the non-existent zone 9.9 When one reads the PROTUR document and finds the magical Ejidal Spa Bacalar, at the scale that can be seen in the plane, it is located within zone 9.

Biocultural landscape. The PROTUR document states that it is a kind of opportunity III. And quote: "...This is the unit of greatest tourist activity and is located in front of the urban center of Bacalar. It consists of various natural and induced elements that show social and historical events related to pirates and struggles of the Mayan peoples for their territory. West Coast is covered by hotels, restaurants and rental homes. Seven subunits within the lagoon and three outside them in which it is desirable to install a visitor reception and monitoring center (section of impact reduction strategies), where the tourist is received with high quality focused on a message of contextualization of the special of the site that is visited and the ways to take care of the previous to the entrance to the lagoon...”

It must be taken into consideration that this interactive plan that we review and that is currently no longer available, was the plan that was submitted to the consideration of the Integral Port Administration of Quintana Roo, it cannot be argued that it was any plan, it was a plan that was submitted to the 133

consideration of the legal administrative entity of the body of water, with the possible hope that it would be reviewed, included and validated during the annual review process of the operating rules.

From the outset it seemed that the criteria and restrictions applied equally for the entire polygon, but when placing the cursor over the area it was a sub zoning that appeared as 9.9 Microbialitos Bacalar. However, when the PROTUR document of the same date is reviewed, in the sub zoning table it only reached 9.7 established as Cenote Cocalitos, the version of June 2020, and that of August 18 and one of November that reaches up to subzone 9.8 (Geoalternativa, et al, 2020). The subzone where the Ejido Spa was Cocaleros was 9.9 in the interactive plan, it only bordered with land in the polygon of the Ejidal swimming facility. The established uses were: Stromatolite corralitos (little fenced stromatolites), snorkeling and swimming.

Why didn't it appear in the document? Fortunately, I took a screenshot of everything, in case they later argued that it never existed, and more importantly, what was the criteria to determine that only the ejido spa "Mágico Bacalar" owned by the Ejido Bacalar, was left with a lagoon front restricted only for Corralitos for stromatolites, snorkeling and swimming?

Coincidentally the most successful spa in the area, the oldest, which has been operating since the late 1940s, and which involves the families of the 155 ejidatarios and their families, approximately 3000 people, an area of almost 5 hectares, central, with services, basically privileged, and a spa that has one of the largest fleets of boats for tours, restaurant and activities, and that with the PROTUR it was placed in a restricted area that of course was going to place it at a competitive disadvantage against those who were as functional tourist units and did not have any PROTUR restrictions.

What was the criteria for placing the 9.9 Microbialitos Bacalar zone, which did not propose navigation, in the area just outside the docks of the spa and all the coastal businesses in the city, before the navigation area? There are islets and stromatolites on the shore, but it only affected the aquatic area adjacent to the ejido balneary.

We made clear our assumption that it was not related to the ejido's outspoken opposition to the instrument. If the instrument was built with representation of the ejido Bacalar, as advertised by the consultant and the state, why did they approve this restrictive use for their own area adjacent to 134

the body of water, more if their spa has the authorization of exclusive use of APIQROO and one of the fleets of boats for tours in the Lagoon, with more seniority and recognition?

If the criterion was to protect the coastline, where the stromatolites and microbialites are located and all these delicate structures that at the insistence of groups of the triad (non-governmental organizations, scientists and government) wanted to protect since the corridor is called Bacalar microbialites, why did the zoning leave out all the businesses and houses in the coastal area in front of Bacalar, except the ejido balneary? More worrying was the fact that the document does not mention any of this, in fact subzone 9.9 does not appear in the 2019 version or the 2020 version, but it does appear in the interactive plane that Geoalternativa wanted to submit for approval by the APIQROOO committee.

Subzone 5.1 Microbialites of Buenavista To the north of the Lagoon, on the southern coastal area of the Buenavista ejido, in comparison, a series of more lax opportunities are placed, just as restrictive but laxer. This part of the coast was on the plane with uses such as sailing, rowing, snorkeling, culture, nursery, diving, possibly stilts.

Navigation only in transit (to where?) Although he fared better than the ejido Bacalar, perhaps because they did not oppose it so openly. Again, the restriction on navigation is placed in front of the town but the possibility outside the zoning 5.1 of Buenavista is left open for all the properties that are located on the coastal zone.

There were some permitted uses that caught our attention, given that it was zoning in the body of water Nursery? Culture? And above all, "possibly palafittes" caught our attention. I want to elaborate a bit on this last allowed use. In a regulation or guideline of uses you cannot use adverbs, it probably means "maybe" or "maybe". Maybe stilt houses will be allowed? What kind of regulation is that? And without technical criteria to justify the construction of infrastructure in the body of water that is an attribution of other authorities.

Perhaps it was only a coincidence that at that time there were some controversial proposals for the establishment of stilt-type developments by 135

large capitals supported by some government officials in some areas of the lagoon.

50% of the Lagoon in Conservation or only for Research Who decided that 50% of the Bacalar Lagoon would remain only for Conservation and Research? Well, the part of ENGO and academics of the triad. Zones 0.0 classified as Wetland and marked in Green by PROTUR. In these areas, right in the middle of the Bacalar Lagoon and comprising almost 50% of its surface, its category was Conservation, navigation was not allowed and the permitted uses were Conservation and research. No tourist stays, no use, no possibility of visiting or being among groups of visitors. And if anything, the minimum group size indispensable for research and conservation. These were the "conservation areas".

After analyzing the proposals of Ramsar and the PNA it was clear that there existed and there are one or more interest groups that have been insisting behind these areas for supposed conservation issues and to ensure a "reserve" only accessible to researchers, specifically the promoters of Ramsar instruments to date that is Dr. Luisa Falcón, Dr. Hernández and other government actors who have been joining this strategy of taking control of the Lagoon.

The document establishes that these were the conservation areas and that they were established during the participatory construction process by the community, we already talked about the false declaration of community participation in the construction of this document, therefore we assume that they were interested groups that this area will remain with criteria of zero use. Arguing that this area had no opportunities for tourist activities.

Conservation zones They are the ones that during the participatory construction process the community indicated as a zero-opportunity class or without tourist activities.

They are areas that protect ecosystems whose psychological characteristics are still functional and their conservation is desirable so they can only be used for education and research purposes.

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Starting from the deficient construction of PROTUR or tendentious design lacking community validation, what part of the community made this point?

Taking into consideration that these are areas with private property and possessions of national land with documents. As we already reviewed in depth, there was no such participatory construction, they only took the liberty of making this type of statements, a self-validating speech. There is no indication in the PROTUR document that a diagnosis based on zones has been worked on, reviewing the SWOT and taking into consideration that the Acceptable Change Limit that was built based on the experiences or preferences of tourists, the "participatory" way of defining this site as a zeroopportunity class becomes inexplicable.

Other conservation areas were the wetlands, the microbials of the northeast coast, the microbialites of the southeast coast, which were 11 km of microbialites, finally the island of the birds and the heart island that were a pair of lots located in front of the urban center.

"Innovative" strategies that put the lagoon and user safety at risk The strategies that were established to supposedly protect the landscape experience of enjoyment of tourists in Bacalar, were of two types, the Particular, to apply in some areas and the General, applicable in all areas, similar to the general criteria and particular criteria of the Territorial Planning.

Two of the three objectives of these strategies were for the benefit of the tourist, not even the body of water. The first objective was to guarantee the physical integrity of the visitor and the common elements of the natural and cultural heritage; the second was to guarantee the satisfaction of visitors in the development of recreational activities and the third was to disseminate and raise awareness of the importance of nature and natural spaces.

Before arriving at the strategies, indicators were generated that do not seem to be articulated with other points of the document, or rather seemed to be generated upon request. In tables 10 to 14 of PROTUR, proposals for 137

indicators for the determination of problems were established, but, like the rest of the document, they are disjointed proposals, more related to the specialty of the proponent than to an articulated scheme for obtaining and monitoring indicators for acceptable change limit. PROTUR establishes the development of indicators of nautical operation and organic waste through the analysis of DNA from phytoplankton and zooplankton from oligotrophic systems (of waters without nutrients) to ensure that they do not change over time by microorganisms from eutrophic systems (with abundant nutrients).

However, in all the elements analyzed, fuels had NOT been handled as a source of eutrophication of water, but agrochemicals and fecal matter from the drains of the houses and shops of Bacalar, but the guide of the indicator refers to faecalism in the open air. It is also proposed for organic waste, but the proposal is research and more research, identify DNA from phytoplankton microorganisms and zooplankton from the lagoon and justify it from outdoor faecalism? Where in the SWOT design and the remaining analyses did this issue arise? Why perform DNA analysis? Perhaps because it is the specialty of the proponent, Dr. Manuel Elías of ECOSUR and his research interest is precisely that. The same happens for the evaluation of the chivita (Pomacea flagellata) specialty of the proponent Dr. Alberto de Jesús Navarrete of ECOSUR. It is also proposed to evaluate the water level (Table 11 of PROTUR) in the lagoon, the behavior of compliance with conservation standards of fragile habitats (Table 13 of PROTUR) and the eutrophication indicator (Table 14 of PROTUR). They apparently responded to the particular interest of each researcher consulted, without being related to the object of PROTUR or SWOT. And then we come to the proposals of Strategies.

Strategies If it was tried to justify that the strategies and proposals had arisen from a participatory process, with a complete diagnosis that allowed the generation of results to establish through the methodology of Acceptable Change Limit, and Load Capacity, the strategies and their indicators, also fail ostensibly. Here are some examples of the unjustifiable, and in some cases dangerous, "innovative" proposals.

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EP1. Installation of buoys The designers of PROTUR propose buoyancy as a strategy. Specifically, they say: The installation and maintenance of buoys in conservation areas will be carried out to achieve the control of activities, through the limits of navigation, mooring or predestined areas, which will reduce the physical impact of anchoring boats in mangroves, and other natural elements. They will also be able to install large mooring buoys to establish visiting shifts to each place, as a form of organization to apply the load capacity.

Nautical activity in general can cause a series of environmental impacts that derive from the actions of anchors and pollution caused by the discharge of waste into the water, garbage, anti-fouling paint, increased turbidity and erosion, noise, the spread of invasive species, and boats that hit animals (Forrester, 2020). The successful management of the increasing levels of activity of ships in the lagoon, therefore, required understanding where and when these types of impacts occurred, such an analysis does not appear in the diagnosis or in the proposals for suggested indicators.

Additionally, while anchor buoys have proven effective in reducing boat mooring incidents in fragile structures such as reefs, buoy fields at various nautical and tourism sites have been the subject of discussion over the past two decades. The issue revolves around their implementation, the environmental impacts they generate and the sustainability of their management and maintenance as artificial elements in "fragile" natural areas.

For the installation of buoys good intentions are not enough, it is necessary to determine the shelter areas suitable for such installation, the analysis of existing elements on the site, properly determine the elements involved in the proper functioning of the activity related to buoying. That is, what is the purpose of the buoy?

Buoying experts list a series of actions prior to the installation of buoys, such as the evaluation of anchoring trains, the parameters and dimensions suitable to ensure not only that they withstand the necessary tension, but that they generate the least amount of environmental impacts possible, a real mapping of depths, type of bottom substrate, direction of wind and currents, weight and dimensions of the vessels to be anchored, if that is to be the function of the buoy, to determine anchor trains, anchors and their reliability in order to 139

avoid future incidents and impacts. In Bacalar, aspects such as the effect of seasonal weathering, such as hurricanes, the elevation of the level of the lagoon during the rainy season, the currents and the change of direction of the same and the dragging of sediments in some places during these seasons must be evaluated.

It may seem simple to install buoys everywhere, but, as established by the PADI (2005) guide at an international level, the installation of mooring buoys requires professional experience in all phases of project planning and implementation. Several facts must be considered and, in many situations, the scope of the project will require a cooperative effort between relevant government agencies and stakeholders. The intended use of the area determines the number, location and type of moorings deployed. Financing of installation and ongoing maintenance, a crucial element of any mooring buoy system, must be arranged. Educational programs should be carried out to ensure that private users understand what buoys are for and that appropriate arrangements are made for the implementation of project or site regulations.

In the proposed indicators, a quantitative study of the benthic habitat where anchors, substrates, bathymetry and the degree to which anchorage rates in sensitive habitats change when mooring buoys are installed would have been useful (Lloret et al., 2008; Sagerman, et al., 2020) and how often anchors are deployed, this is mandatory, and was not considered.

According to the PADI manual, it is necessary to consider the impacts of buoy fields (PADI, 2005). These impacts include visual impact. The area will face the visual impact of floating plastic buoys bordering the horizon. Many tourists will not like to see buoy fields in its pristine landscape, in addition to the visual impact of the buoys, the visual impact and the increase in the effect of "crowding" by boats moored very close to each other (the same buoy) Was not the objective of PROTUR "to guarantee a satisfactory experience close to the pristine landscape for the tourist"? Therefore, the concentration of buoys in coastal areas can become an aesthetic problem that will have to be considered. In addition, a permanent maintenance programme should be ensured in order to avoid deterioration of buoys and detriment to the aesthetic quality of the visitor experience.

There are also the environmental impacts. In the case of anchor buoys, strategies must be evaluated and established to prevent the environmental 140

effects of the concentration of vessels in shallow areas that may not have good water circulation. The concentration of chemicals and contaminants in mooring areas can affect local water quality and, in turn, harm organisms in the environment. Mooring buoys can also increase the use of an area, with associated impacts. Optimal ACLs and acceptable change limits will need to be established, and if these limits are exceeded, use should be decreased.

Demand for mooring buoys is likely to increase with supply, so the number of mooring buoys installed in areas with limited capacity to accommodate vessels will need to be limited.

It is also important to consider conflicts of use as once the mooring buoys are made available to the public, the potential for conflict develops. In small isolated areas with one or two commercial tour operators and only one occasional boater or fisherman, conflicts will be minimal. However, in areas of high use and high traffic conflicts may arise that must be anticipated.

Another aspect to consider is the lagoon's own system, especially the chemical composition of the water. As PADI's own manual states: Buoy downlines often develop the growth of aquatic life and build a small ecosystem. This is especially true for the case of Bacalar, where any object in the water tends to petrify over time, part of a natural process involving microorganisms and the high concentrations of solute in the water of the Bacalar Lagoon (Villarreal-Sonora, 2021), such as calcium, magnesium and sulfur.

The creation of long processions of materials that can be populated by bacterial colonies that generate deposit of solids around the delimitation buoys, which in turn can contribute to the turbidity of the water and the consequent affectation of the fragile areas, which it was trying to protect. The oligotrophic ecosystem of the "blue" portion of the lagoon, requires to keep clear the whitish substrate, calcium carbonate that allows the reflection of the shades of blue; this substrate is susceptible to the establishment of patches of other types of materials where a successional process can be generated. Once plankton are established, hence the patches of aquatic grasses or any other type of vegetation, the area loses its "blue" quality.

Also, why is the proposal of this type of strategy worrying? Because they give rise to INITIATIVES BY INSPIRATION such as the initiative of buoyancy of 4 kilometers of the body of water in the Bacalar Lagoon without considering 141

the aforementioned aspects, mobilized by well-meaning citizens, but without having the basic information that experts in buoyage require and without knowing the geohydrological processes of the lagoon itself.

There are sufficient regulations to guarantee the sustainability of activities in the Bacalar Lagoon (See The myth of the lack of regulation in the Bacalar Lagoon and its Basin, below), it is necessary to consolidate an education and surveillance effort among users and service providers, with the strengthening and articulation of existing regulation; a comprehensive and comprehensive analysis with the recommended factors to determine the system and strategy of installation and maintenance of the buoy, as well as the indicators.

EP3. Microbialites Protection Structures The strategy is justified like this: it is one of the physical Visitor Control Strategies. EP3. Microbial protection structures. And refers: Microbialites must be protected from physical impacts by water and land with infrastructure: temporary constructions (without cement, glass, or metals) with piles, must allow the flow of water and the passage of sunlight to Microbialites, but the passage of light should not be increased by any material, such as glass (for example) because they are photosynthetic.

The design encourages tourism to learn from them without physical contact such as standing or sitting, it also prevents people from approaching them with enough distance to avoid their contact.

The installation of this infrastructure must be susceptible to an environmental impact exception in federally owned areas or to make an environmental 142

impact statement for the installation of infrastructure. For the shores of private properties, the owner may include them in the environmental impact statements corresponding to the works and activities of his property (PROTUR, 2020). In the first versions of PROTUR they were called microbialith corralitos. The proposal was to build a fence around the existing Microbialite structures in the lagoon.

The proposal involved the placement of wooden barriers along stretches of up to 11 kilometers, continuously or with spaces, in nearby structures or within existing spas in the lagoon, houses and all coastal infrastructure.

This strategy demonstrates a broad and atrocious ignorance of the geohydrological and edaphic processes of which microbialites in Bacalar are protagonists. Additionally, it is proposed as a strategy to leave its construction and installation outside the Environmental Impact Assessment mechanism in federally owned areas, referring to the central part that the instrument determines as conservation zones and that for more than a decade have been one of the areas that the promoter group wishes to claim for itself.

There are no microbial protection structures anywhere else in the world, and it is not for a gratuitous reason. When we know the process of soil formation of which the microbialites are the basis and that is easily observable on the margins of the lagoon, along the successional scale, from the center of the body of water to the terrestrial ecosystems to the east and west you can notice a process that we simplify as follows: The microbial mats (mats of microorganisms that accumulate the predominant calcium and magnesium salts of the Bacalar Lagoon) are formed into mats that accumulate sediment, cementing it and forming the flat columns on the margins, practically columns of tartar. Once the column of petrified material (the stromatolite) protrudes from the body of water, or is left with a thin film of water, or the water mirror is reduced or diverted, as a side effect of the accumulation of these platforms and columns of tartar, it begins to colonize with other types of components.

This film tends to accumulate around any structure that is a certain time in the water, it happens with docks, boats and buoys (already explained in the buoy proposal) and the succession begins to develop on these columns and platforms, soil, mud, wetlands and vegetation.

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Placing artificial barriers, even if they allow water to pass, but that reduce the flow and increase the surface of accumulation of cementable particles around the columns that are already accumulating tartar, will generate impacts.

But it is also proposed NOT to evaluate the environmental impact for the federal areas that are interested in the triad, this type of infrastructure establishment decisions require a detailed and knowledgeable evaluation to prevent cumulative impacts that sometimes a negative affectation product of the accelerated synergy of introducing artificial elements extensively. Adding also the potential impact of anchoring these structures around.

Additionally, there is the security aspect. The strategy proposes to build wooden fences within the body of water, the depth in some areas around the microbialites is more than 3 m, so placing a network of wooden strips of 4 to 5 meters, where at least 30% would have to be buried in the substrate, in areas where there is current of 1 to 3 knots (some seasons) means subjecting areas to a permanent impact from the base of the structure and below; creating unnecessary barriers without an in-depth evaluation and basis of how the system works, more for an inspiration, is not only dangerous but offensive.

Your solution to preventing the impact of people approaching the calcium carbonate (tartar) column is to place permanent fences around. A colonialist and childish vision, simplistic and dangerous.

In addition, the photo that appears cut in the document is part of the whole of Hamelin Pool in Australia, an ecosystem of marine stromatolites very different from what is Bacalar and even in that site, the structure is not a fence, it is an observatory bridge of 220 meters, in very different conditions. A clear example of the way in which information is manipulated at the convenience of the promoter group.

EP4. Services They propose basic bathroom, shower and evapotranspiration treatment plant services in public places and boarding sites. One should only cite the U.S. Environmental Protection Agency which states that an ET (evapotranspiration) system is a feasible option in semi-arid climates where the annual evaporation rate exceeds the annual rate of precipitation. The 144

amount that evaporation exceeds precipitation is the ability to apply wastewater.

As a reference data, the semi-arid climates in Mexico are mainly located in the center and north of the country, have an average rainfall of between 400 mm to 1,000 mm, an average annual relative humidity of 59%, in contrast to areas such as Quintana Roo, which are classified as warm subhumids where the average annual rainfall ranges from 1,000 mm to 4,000 mm, with an annual average of 1,500 mm and with an average annual relative humidity of 66% to 88% almost all year round, with a rainfall of around 1,500 mm that can fall in a day, when a hurricane happens.

Requirements for the use of evapotranspiration (ET) type treatment systems include latent heat of approximately 590 cal/g of evaporated water at 15 °C, the existence of a vapor pressure gradient between the evaporative surface and the atmosphere to remove steam by diffusion, convection or a combination of the two, and a continuous supply of water to the evaporative surface.

The disadvantages of these systems are that they are governed by climatic conditions such as precipitation, wind speed, humidity, solar radiation and temperature. They are not suitable in areas where land is limited or where the surface is irregular or where up to 1,300mm of rain can be received annually, as is the case of Quintana Roo, not counting the precipitation that may fall during a hurricane or tropical storm. ET systems have limited storage capacity and therefore cannot store much volume of wastewater when there is an amount of moisture in the environment, for evaporation.

There is the possibility of overload due to infiltration of rainfall, something that has already been demonstrated on countless occasions during the events of intense rains that occur in the area. They are generally limited to sites where evaporation exceeds annual precipitation by at least 24 inches (i.e., for arid and semi-arid areas, not tropical ones). Transpiration and evaporation can be reduced when vegetation is dormant (i.e., the winter months). The accumulation of salt and other elements can eventually remove vegetation and therefore transpiration. In an area where water is high in salts (calcium and magnesium) such as Bacalar, it is another unmeasured risk.

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Pollution control strategies It is interesting to observe how PROTUR places administrative strategies for visitor control, referring to the regulation of the municipality for the provision of services in tourist sites of boats forgetting that there is a specific regulation by the relevant authority that in this case is the APIQROO and that establishes very clearly the way in which the boats can or cannot be operated, schedules and port infrastructure enclosures throughout the lagoon. Although the municipality can sanction boatmen, it is not the corresponding authority.

For its spill prevention strategies here it is also evident the deficient knowledge of the regulation that already exists at the national level for the prevention of pollution in water bodies and refers to establishing rule 51 of the municipal tourism regulations where it is prohibited to spill the lagoon lubricating fuels, wastewater and garbage, ignoring that there are specific rules in Mexican legislation.

The document commits the sin of presenting supposed innovative proposals, product of inspiration, lacking technical foundation, which will represent a risk. We are not going to go any further because I think we have already made this point clear. It is also inconsistent with the discourse of environmentalists, of the triad itself, who advertise that pollution and impacts to La Laguna are generated mainly by runoff derived from agricultural areas or urban areas surrounding the Bacalar lagoon, and structure PROTUR as an instrument that seems solely and exclusively to be used to control the body of water, recipient of impacts, not sources of pollution.

And beyond, it makes an enormous effort to delimit and control the number of people who enter the body of water and the tourism activities that will be developed to guarantee the enjoyment of the visitor, without an analysis or foundation of the complete environmental system.

IBANQROO and PROTUR If there was any doubt about the intention of creating PROTUR as a disguised instrument of environmental policy for control, similar to a NAP, for the Bacalar Lagoon, in a COMPARATIVE ANALYSIS BETWEEN INSTRUMENTS 146

carried out by the Institute of Biodiversity and Protected Natural Areas of Quintana Roo and the Secretary of Environment of Quintana Roo and delivered to members of the Community Council of the Basin of La Laguna de Bacalar, in a meeting convened by them on October 20, 2020, a comparative table was presented between Indicators for the elaboration of PNA Management Programs of federal competence and PROTUR. The intention of IBANQROO was somehow to validate the instrument as an alternative to the PNA. It analyzed the similarity of both instruments, for the 12 indicators used for the development of PNA Management Programs of Federal competence. So, it could be said that this was another strategy of members of the triad (government) to validate an instrument of control, arguing that it had most of the components of a PNA, without being so. But they avoided clarifying how poorly built PROTUR was. In detail, they pointed out where specifically in PROTUR the PNA guideline was complied with. The strange thing is that the table was made to show that PROTUR was not like a PNA, when it showed everything else. It was like a PNA, without being a PNA, contemplating becoming a PNA, as happens with Ramsar's declarations.

It's amazing how much time and resources the triad, in its desperation. Instead of doing things right, but that would mean empowering the locals and that is something they are not willing to concede. Fortunately, the arguments of the technical groups of the community also avoided their imposition.

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SNAILS! NOW A CRITICAL HABITAT The proposal to ban the Chivita snail (Pomacea flagellata) to impose a critical habitat.

When the 2017 Natural Protected Area proposal did not bear fruit due to the resistance of local inhabitants, the triad sought ANOTHER channel to try to establish its Protected Natural Area, and transformed it into a Critical Habitat proposal. On May 1, 2019, at the working meeting of the united commissions of the Congress of the State of Quintana Roo, an agreement was taken with which it was intended to declare the Bacalar Lagoon System as a Protected Natural Area, and to consider the Chivita snail (Pomacea flagellata) within the NOM-059-SEMARNAT-010. This initiative was promoted by the parliamentary fraction of the New Alliance party, headed by Delegate Ramón Javier Padilla Balam.

In its exhortation, SAGARPA, SEMARNAT, and SEMA were requested to begin work to include the chivita snail (Pomacea flagellata) in NOM-059SEMARNAT 2010, under the category of threatened species, while a 10-year ban was decreed for its use and actions were requested to protect the stromatolites of Bacalar, that is, put a type of reservation.

In this document, regardless of the sentimental arguments and the paraphernalia of statistics of consumption and fishing of snail, there was no scientific technical basis, in addition to citing three studies: one of population dynamics with a focus on aquaculture, one of perception of consumption and a journalistic note, it did not establish a solid argumentation for this proposal.

The request to place Pomacea flagellata in protected status as a threatened species was NOT justified, given that in itself, the genus Pomaceae is quite common and very well distributed.

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This snail has a wide natural distribution that goes from the southern United States to Colombia, and nowhere in that region has been reported threatened or endangered, because it is also a species that is being used as a cash crop, demonstrated with the extensive list of existing publications in this regard. Its inclusion as a threatened species was not only not justified by the lack of foundation, but would have ruined the production economy of a species that is abundant and in fact significant in its distribution in freshwater and brackish water bodies.

Other relevant aspects of the genus and the species are that they are considered of medical importance as they are transmitters of parasites that affect man and that generate bioaccumulation of toxins, which makes them a risky food; in this genus there are also species considered pests, there are governments that have control and eradication programs for some of their relatives. While P. flagellata in Bacalar is local, some of its relatives such as P. caniculata have proven to be very aggressive and cosmopolitan invasive species, decimating crops such as rice, in many regions of Latin America, Asia and Europe.

With this proposal of closure and inclusion of the chivita as a species at risk, it was intended to give basis to another proposal for a control instrument in the Bacalar lagoon, the establishment of a Critical Habitat. This proposal arose as part of a project promoted by SELBA, AC, an ENGO, with funds from the Small Grants Program of the United Nations Development Program (UNDP PPD).

Critical Habitat is an instrument of neoliberal environmental conservation – read control – that derives from the definition established in 1973 in the Endangered Species Act enacted in the United States of America. Yes, another import from the northern neighbor, as happened with the case of the Protected Natural Areas, the concept of Critical Habitat was taken as an adapted import of the legislation of the neighboring country. In Mexico, the concept of critical habitat was inserted in the General Wildlife Law, specifically in Title VI, which refers to the conservation of wildlife, and there, in its chapter II, which contains what is related to critical habitat, in two articles (63 and 64).

The Law establishes as justification to decree a Critical Habitat: 1) That the conservation of the natural habitat of wildlife is in the "public interest".

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Which means, as we saw above, that it can be imposed, and in this case, it can be determined unilaterally for the benefit of the "common good" (provided that the common interest is the interest of the triad).

2) That critical habitat should be established by secretarial agreement.

Unlike the NAP, which requires the consensus of local actors, critical habitat is more like a Ramsar declaratory type, it only requires environmentallyrelated governance bodies (the government part of the triad) to agree. This was something that was tried to be done in the virtual forum of the Stromatolite Day, on July 15, 2020, where the three secretaries of environment of the states of Puebla, Coahuila and Quintana Roo, where there were stromatolites, positioned themselves and placed the same title to each of their presentations: "Alliance to conserve the Stromatolites of Mexico", with which they were giving the guideline for the inter-secretarial agreement, in the presence of the Federal Secretary of the Environment, who at that time was Víctor Toledo. The inter-secretarial declaration does not specify the need for consultation with the owners, only an agreement between secretaries.

The Critical Habitat can be established, in this practically unilateral way, "when it comes to" Specific areas within the surface in which a species or population at risk is distributed at the time of being listed, in which biological processes essential for its conservation are developed. Or of specific areas that due to deterioration processes have drastically decreased their surface, but that still harbor a significant concentration of biodiversity. Also, for specific areas in which there is an ecosystem at risk of disappearing, in case of continuing to act the factors that have led it to reduce its historical surface or in specific areas in which essential biological processes are developed, and there are species sensitive to specific risks, such as certain types of pollution, either physical, chemical or acoustic, or risk of collisions with land or water vehicles, which may lead to populations being affected.

Obviously with data provided by the academic part and the NGOs of the triad, regardless, as happened in Coahuila and Bacalar, what the local population, scientists from other branches of science, inhabitants and historical users of resources and ecosystems thought about it.

What the proposals to ban the chivita and the alarmist presentations of the day of the Stromatolites wanted to demonstrate with the media bombardment was that the authorities were making a unilateral decision for 151

the sake of something, because it was not a species of wildlife that was being reduced, and so in a foggy scenario they tried to impose a declaration of Critical Habitat to protect the stromatolites, but Critical Habitat does not apply to Stromatolites.

This instrument is for wildlife species, that is, the law says that it serves to protect species and habitats of wildlife, and stromatolites are stones with bacteria and other microorganisms, they are not as such cataloged as wildlife species and it has not been shown that the species of microorganisms are in NOM 059, that would give its quality of wildlife, to something that is not flora, nor fauna.

Therefore, it could not be covered with the declaration of Critical Habitat... except that at the same time the chivita was declared threatened, and then everything could fit perfectly. Without objective assessments that it was endangered they again tried to manipulate public opinion by presenting the image that it was an emergency, that the species was being decimated and it was the fault of the local inhabitants who were polluting and preying.

That they had had to make that unilateral decision for "the common good" and the species. And even if the population had not been consulted, it acquired the obligation to submit to the conditions established as special measures on management and conservation in the management plans in question, as well as the corresponding preventive report. Such as a PNA or a Ramsar site declaration, with another name: Critical Habitat.

And he finished with the declaration that the "power" could be imposed for the Federal Executive to impose limitations on the rights of domain in the lands that cover said habitat. This is the most serious aspect of this instrument, as Ramsar, grants the power to impose restrictions over the rights of local communities and the owners of the territories, totally treacherous, bordering on the illegal, because excusing the urgency of "saving" the chivita, opened the possibility of imposing limitations on the rights of domain in the lands that cover said habitat and referred us to the Expropriation Law. If Bacalar had been designated Critical Habitat, it would imply the obligation of the federal government NOT to authorize projects or provide funds in all areas, if the areas or properties involved had remained within the territory declared critical habitat. Something very similar to what happens with the populations and properties that remain in a core area of a regular PNA or 152

what happens with the wetlands of Ramsar sites where producers are excluded from support programs.

According to Olivo-Escudero, J (2016) in Mexico the Critical Habitat model has never been used, suggesting as a cause "... that the LGVS and its Regulations do not provide clarity as to the procedural part to establish it, and that their scope regarding the negative meaning of the issuance of authorizations and the generation of causes to impose modalities on private property seem to be very restrictive…”

Fortunately, Bacalar's proposal had a number of inconsistencies and did not prosper. In the case of the Chivita (Pomacea flagellata) the proposal of closure and inclusion in NOM 059 SEMARNAT 2010 did not succeed, because the risk or threat to the species was not adequately founded.

Why did the proposal for the inclusion of Pomacea flagellata in NOM 059 NOT proceed? Because it did not meet the requirements for inclusion in NOM059, it was not justified in the procedure established in paragraph 5.7 of NOM 059 to determine the degree of threat and according to the Risk verification process, there was no baseline of population studies to determine its status as "threatened" (if they did not have how to compare the size of the population previously) and they could not be sure what affected their status. population density not only in the Laguna de Bacalar, if they were going to propose its inclusion at the national level, the data should have been collected at the national level or at least within its national distribution range.

Inclusion in a national NOM could not be argued for an application for a local body of water. Chivita is not on CITES, it was not on the IUCN Red List, it was not on NOM059. Because at the international level this genus is considered cosmopolitan, even a pest, transmitter of harmful parasites in free life and is a species of extensive management for commercial reproduction.

The request for a ban and the creation of ADP or critical habitat, based on the inclusion of chivita as a threatened species, was based on several scientific investigations, which we analyzed and pointed out had serious sustainability deficiencies. They are listed below and explain what these deficiencies consisted of. At this point I want to emphasize something, the scientific academics who champion Western science as the only one capable of providing solid bases for proposals for protection, management or conservation, are human and in many cases subject to conflicts of interest and, 153

as I show you below, have serious deficiencies in their research. Perhaps accustomed to the academic degree being sufficient validation for their saying.

In the article Abundance, distribution and secondary production of the apple snail Pomacea flagellata (Say, 1829) in Lake Bacalar, a tropical karst system in southern Mexico, De Jesús-Navarrete, A., Ocaña-Borrego, FA, Oliva-Rivera, JJ, De Jesús-Carrillo, RM, & Vargas-Espositos, A, published in 2018 it is established as a result that the density (the number of chivitas per m2) ranged from 1.27 to .11 snails and it is discussed that there is relatively low snail density in comparison with other species of Pomacea. In Venezuela, P. dolioides densities were 100 ind.m-2; while Brazil's P. haustrum went 20-215 ind.m-2; P. canaliculata also had higher densities (130 ind.m-2) in Hawaii; and hong Kong (25.6–42.7 ind.m-2); Pomacea paludosa in Florida wetlands showed very low density (0.05–1.0 ind.m-2; 0.33–1.58 ind.m-2).

It would seem logical to think that the basis of comparison was made for the same species or a species of similar ecology in similar habitat conditions, which would validate the comparison, and justify the concern that arose from the apparent low density of the chivita snail in Bacalar, but given that in this and the other two research papers carried out with chivita snail in Bacalar and Laguna Guerrero it is argued that the population density depended on the conditions of the medium, it was worth reviewing in detail the comparison references.

In Bacalar, the chivita is located in ecosystems adjacent to the body of water, of an oligotrophic lagoon (an unproductive ecosystem, characterized by nutrient deficiencies) you have a first idea of why the low density, however there is a certain impulse of urgency to see that compared to the other cases mentioned the density is very low. However, from the sources from which "the comparison" was obtained to justify the very low density of the chivita population in Bacalar: • In the Venezuela study, P. dolioides densities were 100 ind.m-2 (Donnay & Beissinger 1993). But the study was conducted in a flooded rice crop where Pomacea dolioides is an invasive species in a site with high primary productivity, shelter site, low depth, a lot of food. An anthropogenic ecosystem, where it is a pest and we know that the characteristic of invasive pests is precisely the ability to multiply and become a problem.

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• P. haustrum in the Brazil study reached 20-215 ind.m-2 (Freitas et al. 1987).

It is a reservoir recently created by the establishment of a dam, a new ecosystem that was quickly colonized by invasive snail species, not at all comparable to Bacalar.

• Invasive species such as P. canaliculata also had higher densities (130 ind.m2) in Hawaii (Cowie 2002) and Hong Kong (25.6–42.7 ind.m-2) (Kwong et al. 2010). Rice crops, where they are a problematic pest.

• Pomacea paludosa in the study of Florida wetlands showed very low density (0.05–1.0 ind.m-2, Karunaratne et al. 2006; 0.33–1.58 ind.m-2, Bennetts et al. 2006). These were ecosystems with significant variations in dryness and humidity at shallow depths, not a lagoon, much less an oligotrophic lagoon.

Where was the scientific basis for comparison? Since it was argued in many cases in the studies of Pomacea flagellata that there was NOT much reference information, which is not entirely true, how were alarmist statements of low population density made with these references?

Not satisfied with that, they continued to argue that in another lagoon in the area, Laguna Guerrero, a density of 1.43 snails was found, but it was immediately justified by arguing that it was due to the ecology and biology of the species, even so it was compared with data for P. canaliculata, an invasive species with pest strategies. It was obvious that large differences in the biomass of both snails were found in different studies. But it is not justified to make alarmist statements, much less conclude: “…Given the slow growth rate of the species and the slow recovery of the population, we propose a total ban on the collection of P. flagellata snails for at least 10 years in Lake Bacalar. It will be important to implement aquaculture programmes to protect and conserve this resource…”

Another article used based on P. Flagellata's proposal for a ban was: Ocaña FA, De Jesús-Navarrete A, Oliva-Rivera JJ, De Jesús Carrillo RM, VargasEspósitos AA. 2015. Population dynamics of the native apple snail Pomacea flagellate (Ampullariidae) in a coastal lagoon of the Mexican Caribbean.

Limnetic. 34(1):69–78. But their research admits a terrible flaw in methodology. In his discussion of results, he admits that the reported values were underestimated by an ERROR in the sampling method, because the offspring were transparent, small and confused with the substrate, but they 155

save the day by arguing the following: the locals said that there were fewer snails there; so, in this case they did took into account the locals. ah ha! And although there was no previous data to confirm that suggestion, and the spatial distribution of P. flagellata could not be explained by any of the environmental variables studied because it was enough to say that the snail was threatened.

So how to ensure that the chivita was in any danger? It was not even considered a risk species in the lightest categories of the red list of the International Union for Conservation of Nature, it is not located in CITES because none of the other countries where its distribution is located has requested that inclusion. It is absurd that there were those who proposed to include it within NOM 059 as a "threatened species", because there was no data on the danger in its natural distribution, from the southern United States to Colombia. There are many studies for a cousin of this snail, which is the Tegogolo de Catemaco, and many others for similar snails, because they are considered pests in America, Europe and Asia, or because they belong to a type of snails that are important transmitters of parasites, even transmissible to man; but it is also true that it is a resource for food use as a controlled crop and there are already many technological packages.

In this last point there is an enormous legal and political incongruity: several local producers had been repeatedly requesting for years authorization to cultivate chivita intensively, but had not allowed them since in Bacalar the Territorial Ecological Ordinances of Bacalar and Othón P. Blanco, do not allow the development of aquaculture projects, ironic. But the same academic part of the triad that was proposing the ban, established as an urgent need more research to develop technological packages that would allow intensive and controlled reproduction for reintroduction, which was applauded by the rest of its cronies, although for more than 10 years the proven technological packages already existed, but productive aquaculture had not been allowed as an activity for local entrepreneurs in all that time.

Proposing a ban and a protection zone with studies of this type did not help much to the Pink Snail, which was placed in NOM 059 and was decreed in a PNA (Banco Chinchorro). It did what researchers, environmental NGOs and the government said was required to preserve the species; the result?

Researchers continue to investigate, environmental NGOs continue to receive money to make more reserves and their restrictive and exclusionary proposals, the government continues to receive applause for protected areas 156

and their conservation "efforts", but local people lost an economic source that sustained them for generations, they lost a source of food for their families, which was in their traditions, many lost their freedom at the behest of the reservation directorates, and they lost their heritage while trying to regain their freedom, the illegal fishermen reached a better price and more incentive because now they had a "forbidden" product and now they have protected reserves to obtain it. To paraphrase Cristopher González Baca, regional director of CONANP, in 2019 – "the illegal fishing of this marine specimen is carried out, mainly, in the State Protected Natural Areas". And the pink snail continues to reduce its populations.

What happened to this proposal of the chivita? The arguments mentioned in this section were provided, and the proposal was frozen, although it has not been completely abandoned, because it appears to be used to reinforce the proposed Ramsar site declaration in 2021.

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THE PMOTEDU, LIKE FRANKENSTEIN'S MONSTER Or as a POET or a POEL is not equal to a PMOTDU and a PMOTDU is not the same PMOTEDU, the trap is in a letter.

The local population and historical users learned to live with the Territorial Ecological Planning Programs - POET - (based on the General Law of Ecological Balance and Environmental Protection). These regulatory instruments have been operating some for more than 20 years. What local populations and groups have been calling for is the updating of these instruments. In the interim, a few years ago the Territorial Planning and Urban Development Programs (based on the General Law on Human Settlements and Urban Development) or PMOTDU emerged.

As background, it happens that since the creation of the municipality of Bacalar, in 2011, a legal vacuum had been generated in terms of territorial planning, mainly due to the fact that the instrument that regulated its territory had been that of the municipality of Othón P. Banco, a municipality from which they became independent. But once Bacalar achieved its autonomy as a municipal entity, the portion that included them was left as an ordinance that did not include the municipality, but an area of influence around the lagoon.

The community began to insist to the authorities the urgency of having a Territorial Ecological Planning Program for the entire municipality, such as the one already had in the municipalities of Othón P. Blanco, Solidaridad, Tulum, Cozumel and Benito Juárez.

At some point, someone in the government of the State of Quintana Roo thought it would be a fantastic idea to add an additional component to this instrument: the ecological, and we ended up with a Municipal Program of 159

Territorial, Ecological and Urban Development Planning, which was not only confusing, but also threatened to further complicate the regulatory framework that was already overlapping and disjointed.

If I could summarize it would be: • POEL and POET are to order the entire territory outside of Human Settlements (whose UGA are referred to the corresponding Urban Development Program -PDU• PMOTDU, created at the federal level by the Secretariat of Agrarian, Territorial and Urban Development (SEDATU), orders all the instruments of the Human Settlement and its planned growth zones: PDU and all instruments.

• PMOTEDU, created by the government of the state of Quintana Roo, is a mix of POEL, POET, PDU and PMOTDU. That not only overlaps them, but duplicates them and in some points contrasts them.

The PMOTDU was originally thought to order human settlements, that is, to fill that vacuum of territorial planning that were the localities and their growth reserves, where the Urban Development Programs were the instrument to which the Territorial Ecological Ordinances referred us when one or more UGA fell into a human settlement. In the federal law they are well defined, but in the state of Quintana Roo they wanted to do something innovative and a Frankenstein-type monster was created that brought together in a crude and disjointed way the instruments of urban and territorial planning and development of the human settlements law, and the ecological ordering of the General Law of Ecological Balance and Environmental Protection, and their respective state counterparts. And it has not gone well.

What's wrong with this instrument? Taking as an example the instrument that in 2020 was being developed for the municipality of Othón P. Blanco, it used the same design and implementation strategy as with the instruments that we have already been discussing (Ramsar, PNA and PROTUR) in which a consultant was assigned and he structured it through a review of literature and pre-existing instruments as a diagnosis, for the selection of the criteria and the structure, the approach, the strategy, and then tried to validate with some consultations and workshops or meetings with different actors that basically belonged to the government and subsequently tried to convene the solidarity of the community by making a series of consultations at the end.

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As expected, the members of the communities who had the opportunity to attend these presentation meetings and supposed pre-validation of the instrument, found a deficient document where the complete model was not included or provided for prior review, there was a lack of management units within the planning units that were key within the model that they wanted to promote for in this case Othón P. Blanco, especially close to the Bacalar lagoon and no plans or basic files – the diagnosis – were provided that could be reviewed in advance in order to evaluate the basis of the proposals and the scope of the zoning.

During the presentation of the model by the consultants, there were a series of questions and requests for information channeled through writings by groups of local actors and their technical bodies, but which were not answered by the corresponding authority that was the municipality, which was the entity in charge of the instrument.

Something similar happened in the process of preparing the PMOTEDU Bacalar. For this case it is necessary to point out that the demand of the community for an updated POET, and they were shown as saying, there is what they asked for... and they were given the PMOTEDU, which obviously caused widespread anger for what was presented to them.

On August 10, 2020, the Congress of the State of Quintana Roo received a document from the Secretary of the Environment Efrain Villanueva Arcos where he promised to stop pushing institutionally to create a Protected Natural Area but to promote the consolidation of the ordinance. Far from updating the existing ordinance, which was the request of the communities, the state government presented them with a PMOTEDU (Municipal Program of Territorial, ECOLOGICAL and Urban Development Planning), the Frankenstein of Quintana Roo that they tried to pass off as the POET to the population that the community was requiring, and as PMOTDU -without the E-.

Again, the communities responded technically and politically with a generalized refusal. The level of disarticulation, cynicism and pettiness of the government bodies for taking over mechanisms to have their slices of the planning and control of territories is exemplified in this conversation we had with the state director of ordinances, in October 2020, regarding the scope of the PMOTEDU Bacalar, which they were promoting: 161

¿ This instrument (the PMOTEDU Bacalar) integrates all planning instruments?

Yes If then, the integrated instruments are going to be repealed?

No So, they're just going to double?

Yes Why aren't you just coordinating and articulating what already exists?

It’ not easy So, is it easier for everyone to make their own instrument?

Yes October 2020. At a meeting convened by the Secretariat of the Environment of the State of Quintana Roo.

There is a closure, disguised as the total inability of the government agencies to really generate articulating efforts, because nobody really wants to let go of their instruments, which give them that control and power, and obviously access to financing, and even to the benefits of non-legal acts. We are getting complicated with overregulation because there is no willingness, nor the sensitivity to really agree and articulate all these instruments. Or there is all the intention of, above any common sense, placing another brick on top of the wall of controls and power that the members of the triad really seek to translate it into benefits, by splicing another instrument, managed by an instance that previously had no such juicy slice in the neoliberal environmental business, in this case the state SEDATU and the municipalities.

For the ordinances to work they require other operational instruments, and in the case of Bacalar the missing ones are under the responsibility of the municipality: Urban Development Program not only of the population of Bacalar, but of Buenavista and Pedro A. Santos, which are located on the shore of the Lagoon; nor have they been in a hurry to create municipal building regulations, strengthen environmental regulations, regulate garbage dumps or make effective management to solve the pollution problem. To regulate the boats and everything related to the nautical in the body of water, the Integral Port Administration of Quintana Roo (APIQROO) was granted in 2014 the concession of the administration of the Bacalar Lagoon.

Already by 2014, before having the regulation approved, it was publicly announced: that Bacalar already had an instrument that regulated the 162

operations of vessels, infrastructure for these activities and port areas, guaranteeing the protection of the body of water. When it was validated that same year, the rules and zoning included the designation of areas for berths, spaces for transit of small boats, jet skis and the delimitation of buffer zones, where navigation is not allowed to any type of boat.

Municipality and APIQROO implement since 2014 the regulation to verify that the boats that provide tourist services, have the corresponding permits.

Although this regulation has been in force since 2015, when in 2017 the proposal for a Protected Natural Area was issued by CONANP, the lack of communication and inter-institutional coordination was evident when the director of APIQROO declared that the federal institution (CONANP) did not know that the Lagoon was already concessioned to APIQROO for its administration.

The operating rules of APIQROO are supervised and updated by an Operation Committee, regulate aspects such as the areas and facilities of the port, port schedules, port navigation, port services, maritime maneuvers in the lagoon, the availability of statistical information, everything related to safety and hygiene in port facilities, docks, boats and in general in people, environmental control and pollution prevention and aspects of surveillance and protection, as well as the sanctions to which users and concessionaires become creditors for non-compliance with the instrument and applicable regulations.

In an attempt to demonstrate that it was not a lack of regulation that the Bacalar Lagoon suffered, we carried out an extensive review of all the regulations of mandatory application in environmental matters, we found 87 instruments of regulation or environmental planning. When evaluating existing regulatory instruments, we find that for the issues of waste, water, flora, fauna, construction, operation of projects or activities, fishing, tourism and environmental health, at least 6 out of 10 instruments regulate one or more of these issues. In the same way we review all the mandatory regulations on safety and health applicable to companies, organizations and the development of any economic activity that is developed, a total of 133 applicable instruments that touch on aspects of construction, operation, if they refer to people, buildings, boats or other facilities.

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As we already had the opportunity to review when we talked about Ramsar, since 1999 the international agreements, conventions or treaties that Mexico has signed are only below the Constitution and above any other regulatory instrument. In this regard, there are at least 47 policy instruments that cover issues of atmosphere, ozone, climate change, biodiversity (flora and fauna), urban development and housing, forestry, environment and sustainable development, cultural and natural heritage, fisheries, population, health, social, desertification, agriculture, plant health, food.

It is not a question of lack of regulation in the lagoon, it is about the urgency of the articulation of the existing instruments and the creation of the missing instruments that help solve the problem of urban planning, in this case the Urban Development Program.

The analysis carried out if it provides the need to create or update several key instruments to order the territory and several activities that have legal gaps. The town of Bacalar that adjoins the lagoon, is a municipal seat and does not have an instrument that plans and regulates its urban growth, requires a coherent Urban Development Program, which considers the challenges of balanced and fair development that arise in the current framework of regional impulse, with a long-term vision, with care and foresight for environmental issues, but without neglecting the social, so as not to become another instrument that privileges sustainable development from the neoliberal vision, as often happens, and as has been happening in the tourism development poles in other locations in the state, where quality in urban design and services for large capitals were privileged while the needs of the rest of the population were made invisible, which ended up located in the famous regions with enormous shortages or in poverty belts, under extremely poor living conditions.

Taking into consideration that there are two municipalities that share the Bacalar Lagoon, it is necessary to carry out coordinated actions to establish coherent mechanisms and instruments, because the body of water works as an integral system. Currently 70% of the lagoon, on the side of Othón P. Blanco, to the east, has a protection policy, while 30% of the body of water, to the west, on the side of Bacalar has a policy that allows its use. Both polygons divided by an imaginary line that departs practically through the middle of the body of water.

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It is urgent to articulate the existing instruments, build the missing instruments, update those that require it and establish a coordinated implementation strategy, from real participation and not, as continues to happen, from the simulation of participation.

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MYTH BUILDING What is a myth? It is an imaginary story that alters the true qualities of a person or a thing and gives them more value, or less, than they actually have.

The members of the triad require the creation of myths through media manipulation of public opinion to validate their proposals and become adherents who support them.

In a study of this type, where it was sought to find objective bases of a socioenvironmental phenomenon to propose solutions, it was necessary to investigate, even briefly, the origin of these half-truths or blatant lies elevated to the level of myths. Because the modern myth, more with the influence of social networks and the capacity for dispersion / current communication, is more than mere story, for human groups it becomes a fact, and from there the myth / hypothesis, builds realities. Each of the myths created, which we found lacked bases, was and continues to be used as a tool to achieve followers, credibility, increase the sense of urgency, the need to acceptance, as it gives rise to the proposals of the triad, because they provide the groups that support them, their explanation of the world and life, and from there the myth builds social and psychological identities, strategies and actions, movements, policies, decisions and creates a current of public opinion that although uninformed, without foundations and manipulated to point out culprits, to benefit a few, in the name of "the common good" and exert pressure for the benefit of triad objectives.

If you ask yourself, why have promoters created these myths? The answer is simple: With the creation of myths, they create their version of the world and position themselves in it as the solvers, as heroes, to impose their protectionist instruments of the territory and perpetuate the colonialist vision, where the groups of power take control of the sites or the benefits of 167

the objects in which they transformed nature, through environmental discourse: Conservation.

Far from being immovable, myths change with changing discourses, since once the triad gains control of these "endangered" places, it suddenly becomes a priority to promote, ironically, a contrary, pristine image to consumers (usually non-local) in the form of tourist businesses with access to "wild" spaces "preserved" of a "closer contact and intimacy with nature”, with an economic benefit, direct or indirect, for the promoter and / or controller of the resource or site "preserved”. Or it serves them to get resources to be served with the big spoon to be able to remedy, clean and eliminate the danger denounced, even if they spend decades asking for more money to investigate, to educate the population or to organize trainings or finance trips, amenities under the pretext of having to attend an endless process of meetings and spaces for the exchange of information, or to generate discourses, design policies and instruments, without really reaching or even having the intention of real action. Since your goal is not effective action, it is to perpetuate the myth in order to continue to gain control and benefits.

In this way, the groups of academics, bureaucrats or technocrats involved invest a large number of resources in advertising their discourse, to generate polarizing positions based on the criminalization of a sector of the population.

As an example, we take up the myths arising from the change of color of the Bacalar Lagoon, handled to public opinion by members of the triad and especially by Luisa Falcón, ECOSUR, the members of ENGO such as Agua Clara, and other promoters and followers of the promoter group, published in the media and social networks.

The myth of the lack of regulation of the Bacalar Lagoon and its basin 168

The arguments used to propose the urgency of creating a regulatory instrument as a protected area in the Bacalar Lagoon included: The alleged lack of regulatory instruments to be able to stop "the serious environmental deterioration of the lagoon" that scientists from the Institute of Ecology of the UNAM and ECOSUR (promoters of Ramsar's failed proposal, of the PNA and indirectly of PROTUR) were denouncing and that local and institutional environmental non-governmental organizations repeated and dispersed in the media, creating a whole myth around the fragility of the ecosystem and the imminent danger, and the criminal attitude of local inhabitants and service providers whose economic activities were "killing the lagoon, the stromatolites and the chivitas”, due to the excessive growth of tourism and pollution by agrochemicals as well as a deficient waste treatment system for the population of Bacalar. Their solution was the creation of an urgent Protected Natural Area.

The extraordinary thing about this situation is that the problems shown by all these actors promoting the protected area or Ramsar or the following instruments that were proposed over the years were not articulated with their "solutions" to really combat the source of the problems that were being denounced; that is, placing a protected natural area restricting uses within the lagoon did not really contribute to solving the problem of the deficient wastewater treatment system in the adjoining populations, or the use of agrochemicals, upstream.

So, what was a PNA going to be for? Creating a protected area as we have already seen had only served government institutions, NGOs and scientists in the past to ask for more funds and obtain positions, but above all to obtain absolute control over the territories. The PNA proposal had the same cut as most of the declarations, a sense of urgency to create it, the criminalization of certain groups, the quasi-heroic attitude of the promoters and a condescending and colonialist attitude of the government actors.

“It is urgent " – repeated the neoliberal environmentalists’ defenders of the Ramsar site, the PNA and the infamous PROTUR for the Bacalar Lagoon – "that a regulatory instrument be created that guarantees the scenic beauty and nature of the Bacalar Lagoon, because there is no regulation in the Lagoon" (and they were going to save the Lagoon from the predation of the locals). They repeated this discourse in every opportunity and means of communication they have had at hand, even in recognized media that lent 169

themselves to their manipulation without verifying sources, in search of a news story shocking enough to sell, which they published and republished in intentional complicity or not, with notes that were half-truths to convince public opinion of a fateful scenario in which the Bacalar Lagoon seemed to be a lawless body of water, and the entire basin a "No Man's Land". With an unprecedented urgency to control the body of water by inventing figures from which sources were rarely or never cited, using again and again half-truth arguments and outright lies.

The lack of critical thinking of those who publish and those who continue to believe in the arguments of the voracious neoliberal environmentalism that these groups represent is worrying, but even more worrying is the excess of brazenness with which supposed researchers, neoliberal environmentalists and authorities are acting in complicity to impose an overregulation for Bacalar.

Their assertion and the way in which they manipulate public opinion is very questionable, if there is something in the Bacalar Lagoon it is overregulation.

It was necessary to question the statement of their "experts " (and we would have to question how expert they are, or in what) because they left aside that there are at least 4 validated instruments, decreed and operating in the body of water, not counting all the normative battery that regulates almost every aspect of human activity, biotic and abiotic aspects that exist and can be applied to the lagoon and the basin in general. What there is a lack of governance and leadership, a lack of political will and combating the gigantic amount of corruption that exists among the authorities (See Volume III of this collection).

Hundreds of instruments to regulate and over-regulate almost everything in Bacalar

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These are the instruments that are already territorially regulating the body of water and where the Bacalar Lagoon is an Environmental Management Unit (UGA).

5 Ordinances: 1.

POET Bacalar, where the Lagoon is the UGA Ff20

2.

POEL Othón P. Blanco, the other part of the Lagoon is the UGA 31

3.

POE Marine and Regional Gulf of Mexico and the Caribbean where the Bacalar Lagoon and its area of influence are the UGA 152 And in 2020,

4.

Municipal Territorial Planning Program, Ecological and Urban Development for the municipality of Bacalar (in process)

5.

Municipal Program of Territorial, Ecological and Urban Development Planning for the municipality of Othón P. Blanco (in process)

The ecological order legally in Mexico is defined as: An instrument of environmental policy whose purpose is to regulate or induce the use of land and productive activities, in order to achieve the protection of the environment and the preservation and sustainable use of natural resources, based on the analysis of trends in deterioration and the potential for their use.

These instruments are ALREADY built and in force and apply not only to the body of water, but to the entire basin.

The justification for creating the NAP or PROTUR was the lack of "Environmental policy instruments to regulate land use and productive activities in order to protect the environment and the preservation and sustainable use of natural resources ... which is the basis for the creation of the Ordinances that are already decreed and in force.

The lagoon, the body of water is split in two by the Ecological Ordinances of each municipality, in force, in this way there is a complex regulation, but in force on it. On the side of Othón P. Blanco, on the east bank of the system, we have a protection policy, on the west bank of the lagoon, the POET Bacalar has a policy and Conservation. This implies that as preponderant activities can be carried out on the eastern bank activities of management and conservation of flora and fauna and which refers to the competence of the constitutional mandate article 27 and the law of national waters (in the part of OPB), other 171

activities established and regulated by the instruments include natural corridor and alternative tourism, hunting and fishing, with a list of incompatible uses clearly specified.

In turn, these instruments incorporate general and specific criteria that involve criteria for cenotes and sinkholes, native aquatic vegetation, waste, wastewater, aquifer use and prevention of aquifer contamination, rainwater harvesting, roads, material banks, species in special category, nurseries, firewood, urban centers, organic fertilizers, recreational activities, archaeological sites, agrochemicals, wetlands and bodies of water, building materials, fisheries, infrastructure, alternative tourism, marine, mangroves, fauna, liquid waste management and flora.

For its part, the same body of water is placed as environmental management unit 152 in the Marine and Regional Ecological Management of the Gulf of Mexico and the Caribbean, which also refers to general and specific ecological criteria, and a well-delineated list of guidelines associated with ecological strategies, general and specific actions, with their respective strategies, that must be complied with by any project in the body of water and its area of influence.

This instrument published in the Official Gazette of the Federation (DOF) on November 24, 2012 sought to be a planning and policy tool at the regional level to guide in a coordinated manner the use of natural resources and the development of productive activities under principles of sustainability, which consider the conservation of goods and services of coastal and marine ecosystems but also the socioeconomic development of the Gulf region of Mexico and the Caribbean, including territories of coastal and marine influence of 11 states of the country. It was designed to address aspects related to climate change, clean technologies, invasive species, basic services to communities, environmental and territorial planning, productive activities (tourism, urban, industrial, agricultural, fishing), integral waste management, integral water management, vulnerability and risks to both the environment and the population and infrastructure, ecosystem conservation and others.

Unfortunately, the government of Quintana Roo, which participated in the planning and implementation of the instrument and made a commitment to publish it in its official state newspaper, in order to have recognition in local planning instruments, never did. Even so, for federal environmental impact 172

assessment processes and other procedures that involve the evaluation of the compatibility of environmental policy instruments at the federal level, it is necessary to consider their inclusion in the analyses, but not in state instruments.

The latter is a magnificent example of the basis of the problem with the application of instruments of this type: the complete disarticulation between the instances of government not only between the three levels (Federal, State and Municipal) but within the same levels (between the federal instances, between the state instances and between the same municipal instances) to whom it seems easier to create new instruments than to articulate the existing ones.

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The colonialist myth of the petty or ignorant local inhabitant Due to a careful media manipulation of the triad, public opinion considers that the accusations of the inhabitants and historical users, the ejidatarios who oppose the attempts at imposition proposed by the triad, are motivated by pettiness or ignorance of the locals. Rafael Robles de Benito, member of the ENGO CEIBA, who Víctor Toledo said was one of the NGOs that "came out of the closet of neoliberal environmentalism" and "be dedicated to attacking the present government", and who has been a close collaborator of CONANP and the former Regional Director and former Secretary of the Environment of Quintana Roo, Alfredo Arellano (Guillermo & De Benito, 2008), in his defense of Protected Natural Areas, clearly exemplifies the perception of public officials, researchers, academics and non-governmental organizations that externalize, without any qualms to the public, their opinion that local people act out of ignorance, manipulated by dark interests (again another type of ignorance) or by excessive cravings for profit..

When we affirm this, we do not do it because we have a problem of paranoia, it is that openly these actors of the triad, promoters of the PNA, Ramsar Site or something similar, stressed it at every opportunity they had: the local inhabitants and those who are against our proposals, are ignorant or petty.

The published article, entitled Why Opposition to a NAP? of November 15, 2017 on the portal of the CEIBA organization authored by Rafael Robles de Benito (RdB), who a couple of years later would become the director of the Institute of Biodiversity and Protected Natural Areas essentially for the Government of the State of Quintana Roo, appointed, by Alfredo Arellano Guillermo, began as follows: RdB: There is an express, articulated and sonorous opposition to the establishment of a protected natural area in Bacalar. However, there do not seem to be a robust argument to support such opposition. In reality, what seems to exist is a worrying confusion and not because it generates deep questions or substantive questions.

It is worthy of concern because it denotes one of two things: either it is not understood what they are, how they work and what protected natural areas are for, or there are voices of bad faith, who pretend to defend private interests, of 174

increased income and wealth, which are far above (in their conceptions) the public and sustainable interest.

According to Robles de Benito it was ignorance of the locals or it was a paranoid vision of external plot. In fact, there is an external plot, but it does not come from the communities, but from characters with foreign interests, like him, who are part of the triad (See in this document What is the triad?).

It would be necessary to return here to its conception of "public and sustainable interest", very conveniently defined as justifiable or not, depending on which side the interest is.

If members of communities, chambers, professional associations, academics and individuals are in favor of the PNA, they are in favor of the public interest and sustainability... but if those same groups are against it, then NO The public interest of whom? Arguably, children, families and individuals who have constitutional rights... as if precisely the members of communities, chambers, professional associations, indigenous people and other individuals, and even the owners of the territories, did NOT have that kind of rights... unless they are in favor of the triad initiative.

What is the public interest, in the environment? It seems incredible but very few stop to think what that argument means that has served to allow so many atrocities against local communities and individuals in the name of the environment. It has also been called the general interest or national interest, mainly in politics and speeches of that kind.

If we also talk about regulation in favor of the "public interest" from the economic sciences, the concept is used in two aspects: to explain in general terms that regulation seeks to protect and benefit the general public and, on the contrary, following the Chicago Theory (also known as the Economic Theory of regulation), suggests that regulation does not protect the general public, but only interest groups.

Stigler, in his paper, concludes that "... The review of the legal discipline shows that the perception of the public interest has to do with the fulfillment of political and moral values. Considering that the concept of public interest provides the judiciary with a basis from which to decide disputes in the field of community interest…”

Overlapping economic and political theories, the neoliberal basis of reasoning for protected natural areas is established, that is, the reasoning is followed that the allocation of scarce resources, such as clean water, clean air, environmental services, carbon sinks, the beauty of the wild landscape, 175

untouched, is governed mainly by the market (the growing demand for them) so they must be protected to avoid ending with they so that we can all continue to enjoy their benefits, at least the part of society that can continue to pay them. These concepts can be applicable to multiple areas where the government intervenes to generate regulations, in favor of "the public interest", supposedly implying that it is the benefit of the majority of a community.

When talking about the "public interest" and "the common good" used as a banner for the creation of environmental policy instruments, it should not be forgotten that in the end these instruments were created responding to the vision and interests of select groups of researchers, environmental nongovernmental organizations, government agencies of the sector, or other sectors or parliamentarians who did not necessarily represent society as an integral entity, but that most of the times they championed the interest of the State or group by naming themselves the emissaries of the public interest.

Paz Salinas, in her research discusses and exemplifies perfectly the issue of participation in the management and conservation of protected natural areas (PNA) focusing it as a conflictive issue in which the public interest, private interests and collective interests converge and diverge, simultaneously (PazSalinas, 2008).

RdB: “At first glance, it seems to me that there are no relevant voices that are really opposed to the conservation of bacalar's ecosystems and environmental services.

Ejidatarios often say that they agree with the conservation of the forest and the halting of deforestation. Some, like the ejido commissioner of Buenavista, say that "they would like to preserve the mountain, but nothing else knows how to grow the pineapple" (although pineapple is not a traditional crop and much less Mayan). Why, then, has the proposal to establish a protected natural area that includes the lagoon body and an area of dry land around it caused so much animosity?”

This simplistic way of seeing the problems and socio-environmental conflicts tries to reduce the reasoning of the locals, according to the "small world of Western science" of the triad, based on simplistic answers to obvious and even annoying questions that a "outsider" or "wech", like him, perform in a condescending way without understanding the depth of an answer such as "it 176

is that nothing else is done", and that they understand as if it were a lack of vision, skills, reasoning and even a lack of interest in conservation. This is a very common attitude in researchers and academics, especially from the natural sciences, lacking experience or tools to elucidate the discourses from the intuitive richness of the local ecological knowledge of the historical inhabitants of the communities around the Bacalar Lagoon.

This simplified answer for a foreigner who clearly asks the obvious, required a discourse analysis well framed in the context of the Ejido Buenavista of the last 30 years, and more the last 10. If that conversation really happened (because it does not cite sources) it should have considered the following: The Buenavista ejido must be seen from different angles: ethnic composition of its population, its history with the management of natural resources, the migratory processes towards the community in the last 10 years, the interest groups, the coercive manipulation of some groups of newcomers and the complexity of the interactions of its current actors.

No one opposes the conservation of ecosystems, in fact there are many examples of the efforts that for decades all the communities around the Lagoon have been making in favor of Conservation. The community informant, in his answer affirms what is happening: they may be interested in conservation and stop deforestation, but that implies, as we have already seen, ceding their territory, control and justifying funds to the triad, and given that the only support that the communities receive directly comes from the agricultural sector, because "that is the only thing they know how to do"... a sarcastic answer, which Mr. Robles de Benito could not read.

RdB: If the intention of those who claim to oppose the project is to ensure that they are scrupulously consulted throughout the entire process involving the creation of a protected area (the formulation of a justifying technical study, the design of the polygon of the area, the issuance of the decree that establishes it, the formulation of the management program and the presentation of the corresponding regulatory impact manifest), good and pass; although I believe that too many consultations can be excessive and constitute an unnecessary obstacle to the realization of a project that may well be entirely legitimate.

Too many queries? Here it would be very good to understand the concept of participation. Usually, this concept tends to be obscure and fuzzy, depending 177

on who is handling it. Participation, Paz-Salinas says in her research, can mean obedience, or subversion; directed action or independent movement. It can be understood as a critical argument against government inefficiency; or, on the contrary, as a project of the neoliberal State in its thinning and delegation of functions to the citizenry.

The processes of "participatory construction" that only include the social base in consultation meetings and not of real participatory construction, that participatory construction that is inclusive, that agrees and allows agreements, considering all possible angles in a socio-environmental, historical, economic and biocultural field; when these consultations are simulated scenarios, which reach only mere presentations, where the vision of the other is forced, where listening is simulated and the opinion of the social base is not heard, nor is it considered, they are doomed to failure (see the PROTUR case, in this document). In this sense, Agrawal & Gibson (1999), contribute to the discussion the argument of assuming the community as an influential and capable heterogeneous entity that must not only be recognized, but assumed.

The initiatives fail not because of the "number of consultations" that are carried out, but because the promoters end up with a proposal without a social, local base that supports it, since it is key that the sector that is going to receive said initiative and is going to put it into action, receiving its benefits or negative impacts makes it their own, appropriates it; and appropriation can only be generated with a real, fair and truly consensual construction among the actors. Simulations never work like this, it needs to be really built among the social actors, from their local knowledge, with respect, that is reflected in order to have the drive to participate, follow up, real legitimacy and that is not achieved with presentations and signatures of attendance list.

Invariably, when a proposal is received violently and with resistance by the social base, as in the case of the PNA Bacalar, attention must be paid, observed objectively and understood that the lack of legitimacy of an instrument before the eyes and community intuition comes from the inability of the promoters to consider social actors as entities capable of making decisions based on their knowledge and experience. and, therefore, to act accordingly.

The actors of the triad rise as possessors of the solutions in favor of the "common good", which justifies them to create instruments of "social participation" that they must induce from above (either by local governments, 178

environmental organizations, academics or funding agencies), because the population, from the governmental or paternalistic vision, of the contempt of the scientists who consider them "ignorant" or of the NGOs that are always more interested in to please the financiers and score merits, or in the political coup, all of them who are interested in "saving nature to negotiate with it", while positioning themselves before public opinion as those who have the moral, almost spiritual obligation to protect the communities from themselves, as if the locals were immature infants in permanent desire for the destruction of the natural environment.

RdB: However, it seems that the thing goes beyond the need to be consulted: thirteen ejidos, convened by their commissioners, have generated minutes of assembly where they record their refusal to establish a protected area that interests their land endowments. Apart from the fact that it is not often to see that so many ejidos unite around a single cause (which in principle is encouraging), the fact that they do so to oppose a project that does not harm them at all and that should even contribute to them being able to diversify their productive activities and improve their income, gives a lot to think about.

Again, RdB confuses the term participation. The communities DO know what a participatory process of consultation is, convening their Ejido assemblies, informing, discussing and making decisions. It is he and people like him who do not understand that communities are very clear about how real participation works, because they must constantly practice it within their working groups, general assemblies and community committees.

RdB: Most likely, the root of the refusal of the ejidatarios (who by the way have shown their consent to the promulgation of an ecological management program, which, by the way, is aligned with the Bacalar lagoon conservation project) lies in the already widespread distrust of any action taken by a government agency.

He himself exemplifies why the attempt to impose a NAP on communities from the outside failed: because his concept of consultation had nothing participatory and was a lack of respect for the social actors who ended up learning that the "presentation" of a project to which they were invited, was really a participatory consultation, in which they were not asked or allowed 179

an opinion, and that the attendance list they signed, turned out to be part of an act of agreements to impose a NAPA on them. From there the process lost all legitimacy and to the extent that it continued to insist on imposing it under those terms, it continued to increase the discontent of the social base.

RdB: Pero la desconfianza, encerrado en el odioso neologismo de “sospechosísimo”, es un arma de múltiples filos: lo mismo desconfiamos de las acciones de gobierno, como de las acciones de grupos organizados que no parecen responder a motivos claros, y que se sustentan en informaciones imprecisas y sesgadas, que generan confusión. En el caso del área protegida propuesta para la laguna de Bacalar, solamente se ha formulado un estudio técnico justificativo, por parte de una organización no gubernamental (Amigos de Sian Ka’an, A. C.), a petición de la Comisión Nacional de áreas Naturales Protegidas (CONANP).

The hateful thing is that he tries to discredit the just demand of the social base, as if it were a kind of paranoia. Since, according to him, "... only a justifying technical study has been formulated by a non-governmental organization (Friends of Sian Ka'an, A.C.), at the request of the National Commission of Natural Protected Areas (CONANP)..." Again, the myopic or perhaps cynical position is almost hateful because a couple of years later it ended up being in charge of the instance that is precisely following up on this study.

Arguing that it was only community paranoia that in 2017, by pure coincidence, a document was created that proposes to create a PNA in the Bacalar system, driven by two instances with a long history of creating and imposing restrictive instruments on communities, for their own benefit, as if they had done so because they had nothing better in occupying the $ 400,000.00 pesos that CONANP gave to Friends of Sian Ka'an, so it occurred to them to make a proposal to justify and put 219,000 ha under federal reserve status. Nothing else. This simplistic statement is offensive, and again, it makes very clear the position of these promoters who think that local inhabitants and communities are ignorant and manipulable, to the extent that they can mock with ridiculous observations like that, publicly.

Did he imply that people should have kept quiet, until they already had the PNA decree on them? Generally, that they hope, that the communities do not realize until they have practically the instrument on top, and at that time, 180

according to their reasoning, "now if it would be worth all the scandal they make" (although maybe it is too late). It should be reminded that even with the community uprising against the study that had only been done just because, the instance that he directs now, in 2019 he resumed the study to promote the PNA from the state government, through IBANQROO, and depends on the Ministry of the Environment, whose Secretary was, before he was dismissed for accusations of corruption, Alfredo Arellano Guillermo, former Regional Director of CONANP, where he also has pending allegations of corruption and now led by Efrain Villanueva Arcos, founding partner of Amigos de Sian Ka'an and recognized as its operational arm in the south of the state of Quintana Roo. RdB: Throughout the preparation of this study, the consultants held multiple interviews and workshops with representatives of the same ejidos that today oppose the establishment of the area. It may not have been a sufficient consultation for this very preliminary stage of the project. But, and here distrust and suspicion rear their ugly head, it is strange that suddenly these same ejido groups are so reluctant to conservation, that in no way harms them, nor does it strip them of their lands, nor does it prevent them from appropriating the natural resources and environmental services that are in them.

We are not going to wear ourselves out trying to explain the difference between participatory planning and simulated consultation, already explained above.

RdB: Those who can be affected are the owners and possessors of land on the margins of the lagoon, some of whom have speculatively opted for the detonation of a conventional tourist development, which allows them to sell their land at juicy prices, for the establishment of infrastructure for tourism. Perhaps they perceive the establishment of a conservation project as an element that subtracts surplus value from their real estate. Could it be then that there are "hands that rock the cradle" out there, from darkness and clandestineness? I wouldn't be surprised.

According to RdB, they are the individuals who want a Cancun in the Lagoon and who manipulate the other social actors, because as they continue to insist, 181

the local inhabitants do not reach the intelligence to be dissatisfied, someone had to impose the idea on them.

In his article Robles de Benito makes a disguised mockery of the just claim of the communities, as if said claim were by default of ignorance or candidness; perfectly exemplifies the type of colonialist thinking, part superiority complex, part condescension; which is precisely part of the schemes of neoliberal environmentalism driven for decades by the triad, which have managed before public opinion that the local inhabitants are like the "Indians" of the colonial era, who need to be educated, oriented, protected from themselves, cured of their "ignorance", in need of being saved by them, modern environmental feeders, sole owners of absolute truth.

According to this perception, "the rest of society" (communities, nonwestern scientists) are considered as a set of influenceable actors, without the capacity or legitimacy to assess the nature or severity of environmental problems or to do anything about them, in an effective and organized way; let alone solve them. A position that serves as a reference for communities and local actors to identify members of the triad who approach with discourses of urgency, threatened species, pointing out criminals and promising salvation with their instruments.

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The myth of Carrying Capacity for Tourism Recreational carrying capacity, ecological carrying capacity, tourist carrying capacity, or just carrying capacity. According to Sayre (2008) in his Genesis, History, and Limits of Carrying Capacity, this concept can be understood in four distinct definitions: 1) As a mechanical or engineering attribute of manufactured objects or systems, dating from around 1840, in the context of international shipping which, to some extent, can be measured in fixed values and numbers relatively objectively; that is, how much cargo does a ship bear? For example.

2) As an attribute of living organisms and natural systems, dating from the 1870s and more fully developed in livestock management and hunting in the early twentieth century, which gave or governs the concept used for recreational activities in the national parks of the United States and which permeated other countries; as an example, how many cows can feed a hectare of pasture?

3) Like K, the natural limit of population increases in organisms, used by population biologists since the mid-twentieth century, used to exemplify a system where the number of individuals is large enough to pressure existing natural resources and as the population grows, in a direct linear relationship, these resources are beginning to run out, slowing the growth rate. As an example, how much will a population of bacteria grow until they run out of space or food and begin to no longer grow or "decrease"? The maximum limit where that happens is known as K. 4) As the number of human beings that the earth can support, employed by neo-Malthusians, also since the middle of the last century. A theory that is rather a myth where it is said that the planet only has the capacity to sustain a limit number of human beings.

To understand how the concept of Load Capacity (CC) ended up being used to have a practically magical number of tourists who can visit a national park or protected natural area or boats in a body of water, with the aim of recreational use, we must review a little history. Leaving aside the first concept, for obvious reasons, an opportunistic hodgepodge was given to

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combine the remaining three definitions to complete the discourse of carrying capacity so cheerfully handled by the triad.

In addition to the concept in engineering, which was the most widely used since ancient times, the concept of population or environmental carrying capacity was initially developed by livestock and wildlife managers in the United States around the 1880s. This methodology was created to try to determine the limits of the plant ecosystem where an animal population of herbivores could develop and survive, given the ranching conditions. This mode of carrying capacity comes from the idea that an organism can only exist within a limited range of physical conditions. In the case of herbivores, plants and animals require a minimal amount of energy and nutrients, and could only withstand certain concentrations of chemicals. The availability of adequate living conditions determined, according to several authors, the number of organisms that could exist in an environment.

At the beginning of this stage of the evolution of carrying capacity for livestock and wild ranching, it was thought to be a simple matter to calculate, but the model began to get complicated as it became understood that there were many other factors that intervened in the ability to sustain a population of animals in a given area. Factors that were directly related to the species or species managed, biophysical conditions, nutritional requirements according to age or gender of the specimens, type of fencing, availability of other resources such as water, or nutrients other than grass or plant species found at the site, climatic conditions, intra or interspecific competition, among others. Reaching a point where, as they described, it was practically impossible to determine a single carrying capacity for a site (even talking about paddocks and livestock), given that the development of a population was subject to diverse environmental conditions, which could be caused by the specimens themselves, by external factors or by environmental factors or phenomena that did not depend directly on the resource-population interaction.

Some researchers concluded that the carrying capacity could only be calculated for deterministic and slightly variable systems, and only for cases where the behavior and ecological relationships of the species changed slowly on the human time scale, and it was not at all advisable to use it for stochastic systems, those where there are many variations of the environmental system (most environmental systems are of this type), and due to the nonlinear nature of many cause-and-effect relationships

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and lack of knowledge (data, information, understanding, experience), all of which introduced a great deal of uncertainty into the calculations.

This severe limitation in the predictive character has earned the capacity of very severe critical load in the last three decades; Price (1999) exposes not only the failures of trying to bring a laboratory population growth model to the field, and the pernicious way in which scientists have ignored or taken assumptions for granted, forcing their results to test this model in a tendentious way, to expose "... We conclude that the concept of carrying capacity is seriously flawed. In fact, it may be nothing more than a self-validating belief…”.

Other authors raised additional arguments questioning the practical usefulness of carrying capacity and its scientific foundations, raising questions about the validity to manage not only the management of herbivores from this perspective, but beyond, the uses that were subsequently given to it for economic activities where human activities and populations interact in natural sites.

Like many concepts and models of management and conservation that we use today, the carrying capacity came imported, in this case from the national parks of the United States. The fact that the origin of the use of the concept of carrying capacity to sustain animal populations in well-defined areas began to be used in protected areas and parks in the United States almost 100 years ago should be enough to give us an idea of how inapplicable the model is, in our context.

When one speaks of the establishment of the first American "modern" protected natural area in 1872, Yellowstone National Park, and in 1890 of Yosemite National Park, one tends to ignore the fact that the U.S. government violently expelled the Native Americans who lived and depended on natural resources in those areas (Burnham, 2000) Poirier & Ostrgren (2002), cite: “…These actions were influenced both by the views of the parks and pristine "wilderness areas", devoid of occupation and human use. And for the interests of powerful lobbies such as the railway industry, which wanted to develop parks for tourism; indigenous peoples were seen as incompatible with both interests…”

The American model of parks was created with the expropriation, bordering on dispossession, of the lands and territories of indigenous peoples and local communities where lands, especially common lands, were claimed for the 185

state, without even considering the pre-existing historical, legal rights of ownership and use under traditional historical tenure, and with the purchase of private property through the Land and Water Conservation Fund.

To date 84 million acres (approximately 34 million hectares) are owned by the state and only a little less than two million acres (809,371 hectares) remain under private (non-communal) ownership. That is, the system of protected natural areas of the United States is integrated into 97.6% of federal properties and 2.3% by private properties in the form of "inholdings" (private properties within national parks) waiting to be acquired by the Land and Conservation Fund. No communal properties.

It is a very complex system that includes: 63 National Parks, 129 National Monuments (managed by the SPN and other agencies), 19 National Reserves (more similar to our reserves), 61 National Historic Parks, 87 National Historic Sites (76 managed by the SPN and 11 are affiliated areas), 2 Authorized National Historic Sites (still pending purchase of the property), 1 International Historic Site, 4 Battlefield National Parks, 11 National Military Parks, 21 National Battlefields, 34 National Memorials, 25 National Recreation Areas, 10 National Coasts, 4 National Lake Coasts, 15 National Rivers and Wild and Scenic Rivers, 3 Mixed National Reserves, 10 National Roads, 23 National Trails, 15 National Cemeteries, 55 National Heritage Areas and 16 National Park Service Units.

Management is under the supervision of the National Park Service, and other government agencies, but the local management of most services is in the form of concessions. There are currently more than 500 concessions (franchise type) to manage visitor services in national parks and charge access fees, coordinated by the Commercial Collection Services division of the National Park Service. The gross income is one trillion dollars. Dealerships employ more than 25,000 employees in peak seasons. Although the record is more than 575 contracts, only 60 contracts generate more than 85% of revenue ($850 million). The franchise is 5% of the contracts. The system receives more than 292 million recreational visitors who spend $15.7 billion in Gateway communities located an average of 60 miles (96.5 km) from parks (Josephson, 2021). There are no communities within the parks or within 96.5 kilometers away.

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The Organic Act that gave rise to the National Park Service establishes the objective of its creation, which states: "the Service thus established will promote and regulate the use of federal areas known as national parks, monuments and reserves ... by means and measures consistent with the fundamental purpose of such parks, monuments and reserves, the purpose of which is to preserve the landscape and the natural and historical objects and wildlife in them and to provide for the enjoyment thereof in such a way and by the means that leave them intact for the enjoyment of future generations."

(NPS, 2018).

It was logical that they would look for a model to determine the maximum number of people making use of the areas, if it was one of their objectives to serve as "enjoyment" areas. In this sense, between 2008 and 2019 the U.S. Park system received 3,584.7 million visitors, at an average of 298.725 million annual visitors (Statista, 2021). Another statistic estimates that from 1904 to 2020, the U.S. Park system has received 14,891,410,480 visitors (nearly fifteen billion visitors in 116 years) (NPS, 2021) mostly local or domestic tourism.

By the time the American model of parks permeated the rest of the world, around the 50s – with the boom of local visits to parks within the same North American territory, the overlap of those models of protection of sites that had among their objectives the recreational use, in federal territories, came into conflict with the reality of other countries, such as tropical developing countries, whose forests, jungles, wetlands and other ecosystems were part of the social communal property and in them coexisted indigenous populations and other traditional groups, which developed forms of communal appropriation of natural spaces and resources for their subsistence.

These indigenous and rural communities had a close relationship with species and spaces, integrating them as part of their cultural heritage, their history and the traditional use of them, for which they had also developed models of protection and conservation and even improvement of biodiversity in their territories, for generations.

The local cultural had been carrying out a respectful and integral management that allowed the persistence of spaces, ecosystems and bodies of water that, in the eyes of third parties who recently arrived at the sites, seemed to have remained untouched or virgin since always. This mistaken and simplistic idea that indigenous or rural territories managed by generations were "untouched" 187

spaces, motivated, without prior knowledge, promoting groups outside the communities, mainly academics and NGOs, to propose restrictive schemes to maintain these "wild areas" "pristine" to turn them into protected natural areas as if they were public goods, with their partial vision of the neo myth of "untouched wild nature" (Diegues, 2000) without taking into account that these historically community spaces had remained so because of their close relationship and the identity created with local populations. That is, because the locals had kept them.

If we now make a comparison, an instance equivalent to the United States Park Service in Mexico would be a combination of the Commission of Protected Natural Areas (CONANP), the Institute of Anthropology and History (INAH), the Secretary of Tourism (SECTUR), the Secretary of Commerce, the Federal Attorney for Environmental Protection (PROFEPA) and the Institute of Administration and Appraisals of National Assets (INDABIN) with a recreational approach, of conservation and surveillance, in depopulated areas of federal property and a few private areas. In contrast to how the adapted model of the United States has worked, in Mexico, for 2013 the PNA system had 25,394,779 hectares (CONANP, 2014), and continued to accumulate hectares, because in 7 years it made a huge leap, and by 2021, it had 90,830,963 hectares reported by CONANP under its administration (CONANP, 2021); less than one fifth was owned by the Nation, the rest being private or communal property; according to the 2010 Population and Housing Census, at that time there were 176 Natural Protected Areas of federal competence where 1,713,628 people lived (CONANP, 2014), most of them in indigenous and rural populations.

CONANP has found itself practically since its decree and throughout its history in deplorable financial and operational conditions (Garcigalán, 2015), and the funds generated by the collection of fees for entry to the PNA, which they collect throughout the country are less than 70 million pesos per year (approximately 3.5 million dollars) (Quadri, 2014). Our NAPs have no recreational park targets and lack the franchise-like structure, infrastructure and resources or a system to actually allow them to function as recreational tourist receivers.

In contrast to the National Park Service, CONANP aims to

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“…maintain the representativeness of Mexico's ecosystems and biodiversity, ensuring the provision of their environmental services through their conservation and sustainable management, promoting the development of productive activities, with criteria of inclusion and equity, that contribute to the generation of employment and the reduction of poverty in the communities that live within the PNA and their areas of influence. This Objective will be pursued through a series of Strategic Objectives related to the following areas: Integrated landscape management, Conservation and management of biodiversity, Attention to the effects of climate change and reduction of GHG emissions, Conservation economics, Strengthening of intra-sectoral strategic coordination (Integrality), Strengthening of intersectoral coordination (Transversality), Legal framework for the conservation of natural heritage, Institutional strengthening and Communication, education, culture and social participation for conservation. (CONANP, 2021) …”

It might be thought that the phrase "promoting the development of productive activities, with criteria of inclusion and equity, that contribute to the generation of employment and the reduction of poverty in the communities living within the PNA and their areas of influence ...", which is mentioned in the objective, could represent the basis for the promotion, administration and operation of tourism and recreation, as in the United States, but because the management unit of the PNA belongs to the environmental sector its scope is limited to that sector and the "productive" vision is paternalistic.

"Productive" funds are related to conservation activities or small grants for community groups.

Due to the very characteristics and nature of the PNA system mentioned, the franchise model cannot be promoted to third parties for integral tourism management as the U.S. model, because in addition, in Mexico the territory in parks and reserves, for the most part, is communal or private property, or they are sites where economic activities of importance to the communities of the adjacent area or of influence are historically carried out, not related to tourism and that can compete for funds, spaces and recognition. So CONANP does not specify objectives for the development of recreational activities in the areas, although they try to establish strategies to promote and control tourism activities, among which it does promote the calculation of tourist load capacity.

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Returning to how the concept of carrying capacity for tourism in the United States evolved, by the 1920s the concept had begun to be used to describe the relationship between livestock and their environment, then applied to wild herbivores (Leopold 1933). But it wasn't until the 1950s that it began to be used to try to find a magic number of tourists that a reserve or national park could endure before the negative impacts, on ecosystem and wildlife, were irreversible.

To understand, how did the concept of livestock load capacity end up as the number of individuals (tourists) that an area (protected area or protected wild site) could support? one should be aware of the picture around the time when the carrying capacity of tourism in the United States began to permeate (which was later disseminated to other countries, including Mexico).

This was because many of the early recreation managers in U.S. National Parks had been trained in the sciences of forestry, wildlife, and livestock management, not in recreational or tourist park management, concerns about people and their impacts were quickly described as a carrying capacity problem (referred to the use of grasslands by livestock or deer), seeking urgent solutions when facilities and resources simply could not accommodate increasing increases in demand due to design and management constraints.

This decade (1950) also uncovered foundational struggles in the National Park Service. As the administration struggled to meet the growing demand for tourists, it had to deal with a philosophical question about the very nature of its lands. That question is still relevant today: do national parks exist to preserve nature, or to make that nature accessible to all? And if the service can only meet one of these two goals, which one does it choose? So, researchers and managers of these areas, which came from decades of wildlife management and not directly from recreation, implicitly assumed that levels of use and impacts were interrelated as was the case with livestock or wildlife in a grassland, thus presupposing that the site possessed an inherent or specific carrying capacity.

In tourist use this would suggest that as the impacts slowly increased, due to tourist-recreational use they would reach a point where the conditions of the site would deteriorate rapidly. The point just before reaching the point of no return, they theorized, must be the carrying capacity for tourism and recreation.

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In the 1960s and early 1970s, it was the scientists and especially the natural resource managers of the U.S. Forest Service, some of whom had become managers of recreational areas, who promoted research to identify the carrying capacities for recreation in the parks and sites under their responsibility. At that point it was recognized that most of the standards for space occupancy had been developed from intuitive judgments and trial-anderror experiences, rather than quantitative evidence of controlled research.

That is, the load capacity standards were built without scientific evidence.

In order to understand the reasoning of Carrying Capacity, McCool & Lime (2001) exemplify three variants of the potential relationships between the level of use and the amount of biophysical and social impact resulting.

• Curve A represents a situation where impacts increase rapidly with small amounts of usage, and then as site usage increases, the level of impact decreases or stabilizes.

• Curve B represents a situation in which impacts are a linear function of the level of use. In this situation, as the use of the site increases, the impacts increase. This was the relationship that researchers of the time assumed existed in the territories of the parks that were used for recreational activities.

• The C Curve represents a situation where the level of impact increases gradually, as the level of use increases and then, after a certain point, begins to grow rapidly. This curve exemplified the intrinsic carrying capacity of the ecosystem.

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Potential relationships between the level of use and the amount of biophysical and social impact resulting. Author Translation, Source: McCool, S. F. & David W. Lime (2001) Tourism Carrying Capacity: Tempting Fantasy or Useful Reality? Journal of Sustainable Tourism, 9:5, 372-388.

Lime and Stankey (1971) and even Odum himself (father of the concept of logistic population growth K – from which the third definition of carrying capacity emerged) made it clear that carrying capacity was not a space standard to define the number of units of use (people, vehicles) that could use recreational space at some point, to ensure a "satisfactory" experience by the visitor. The carrying capacity that was evaluated in national parks was the character or type of use that an area developed at a certain level can withstand over a specified time without causing excessive damage to either the physical environment or the visitor experience.

It was not the ecological concept of carrying capacity. It was a multidimensional and dynamic concept, capable of being manipulated by the administration of the protected natural area, in accordance with the budgetary and resource administrative restrictions of the agency in charge. The carrying capacity defined at the time by park managers in the United States had three components that are applicable to date: 1) Management objectives, 2) Visitor attitude, and 3) Recreational impact on physical resources.

These were not independent considerations, of course, but they were interwoven and dependent on organization, planning, and operation; that is, the carrying capacity not only depended on the type of visitor and the ecosystem, but also on the objective of managing the area, the administrative 192

limitations, tasks and available economic resources. Now let's try to adjust this vision to the Mexican model.

Why was it important, first of all, to have a management objective for the area? Because it is necessary to know the purpose, fragility and complexity of the system in order to have an idea of the scope of the activities that may or may not be performed.

It is not the same to determine the carrying capacity for a lagoon with a sport or recreational fishing objective, then for a lagoon where nautical activities of many other types are developed, and even swimming or biodiversity observation.

Determining whether the site is going to be of low or high density does not only depend on the "preferences" of the tourist. "... Without defined objectives to establish trying to establish a management scheme based on the load capacity of a site is futile..." (Lime and Stanky, 1971), and more importantly, the carrying capacity is not generalizable "... you cannot assign a single capacity to an entire area…"

It is tempting to use the carrying capacity politically to generate the public image that you have things under control, and obtain magic numbers as you tried to do with Bacalar and all the policies of Protected Natural Areas, tourism strategies and boat permits. In Mexico, the PNA do not have defined tourism objectives, and if the case uses terms such as sustainable use, which are too generalist to serve as a basis for planning a certain activity, because it leaves open the range for all sustainable use activities.

As field experience grew, in the United States, the term came to be defined as the amount of recreational use allowed by the management objectives of an area. When you read this definition carefully, two things are noticed: (1) It is NOT an intrinsic or innate carrying capacity, that is: an ecosystem does not bring a labeled maximum load measure, as if it were a bucket with a maximum capacity to fill; and (2) Since it is based on use, an area can have multiple capabilities, depending on which objective or objectives are articulated in it.

The objectives of the tourist load capacity are based on the use of the site, not on any environmental concept, nor on the tastes or preferences of tourists. That is, a protected area can have a very low recreational or tourist carrying capacity if its objective (recreational or tourist) focuses on providing opportunities for solitude, for exclusivist enjoyment, of very low density, in a natural environment of pristine beauty; but it can also have a greater carrying capacity, if the objective is recreational or tourist activities that involve more 193

people, and where there are fewer limitations in the impacts caused by visitors. For the same area there may be multiple load capacities. But this concept does not involve the environmental unless it affects the quality of the landscape, which is the product that the tourist buys.

And even more, it should not be lost sight of the fact that the development and choice of management objectives in a protected natural area is a human, social process, it is not physical, nor ecological, nor biological. That is, determining how much burden a site will bear, or how much change is acceptable, if it is subjected to a series of determined human activities (direct and indirect), is ALWAYS a human, social, informed or uninformed judgment, and supposedly based on science, but it is created, determined and sustained in the environment of political discourse and in many cases by particular interests, institutional or group. Even if there are scientists involved, who can give us information so that locally, in theory, we can assess How Much Is Too Much? and local experts can answer that question, in the end carrying capacity is always going to be a political decision.

Several authors insist that tourism carrying capacity should be seen as a comprehensive planning process, as a strategic policy instrument for the development of local models of sustainable tourism and not as a scientific measure, a unique number or a magic number. O'Reilly (1986) states that carrying capacity should be used as an indicator, as a baseline to identify critical thresholds that require attention, not as a fixed numerical limit, but as an indicator when making decisions and applying controls or regulations, at the time that is required.

In the case of Bacalar, a central aspect for a definition of recreational carrying capacity would depend on the needs, values and concerns of visitors and those in charge of managing the Lagoon, reconciling the load capacity determined

by APIQROO, as a concessionaire for nautical use, or that established by SEMAR as responsible for the integral management of the body of water, of CONAGUA as in charge of the sustainability and water quality of inland water bodies, but also of the Mexican Geological Survey, which knows about the geohydrological processes of the system, of the users and historical inhabitants of the lagoon who know very well what meta image they have of the body of water that generationally has been part of their life, of service providers who know how many boats can interact and why, and thus each estimates a load capacity according to their approach and vision. In this way, 194

carrying capacity could only be established in terms of specific management objectives, which vary widely on a case-by-case basis. Taking these options into account shifts the focus of recreational carrying capacity from asking how many vessels are too many to defining a joint vision, enriched with everyone's vision.

Now, the other issue is to implement carrying capacity policies, which is said more simply than it is in reality. It implies that an administrator or person in charge of an area must make restrictive decisions when the load capacity is about to be exceeded and this, as has been seen for the cases of the PNA of Holbox and Tulum, has not happened, with which the PNA far exceeded their tourist cargo capacity (the number of boats or authorized tourist service providers). Since when it is necessary to restrict the use or access, it will create problems of equity, because it implies that the administration or the person in charge must decide who can make use of or enter the area. This has led to the exclusion of actors, preferential treatment and corruption.

Another key aspect is that, since the criteria were based on the "preferences" of tourists, it was learned over time, that visitors have multiple expectations for tourist experiences, only some of which are related to the density of use.

Because the expectations of a visitor are as broad as can be the individual preferences of each one and their motivations (Maslow's pyramid). Emotions and valuation according to preferences and affections are an inseparable part of visitors' decision-making and that varies infinitely. Based on this point of view, there would be no such thing as the "average" visitor, therefore the conditions of an ideal standard experience do not exist either. This applies not only to tourists; it also applies to residents of Bacalar.

A resident's perception of what the optimal ecosystem conditions should be varies depending on, for example, whether their economic activities are linked to tourism or not. It can also vary according to how much the body of water knows or not, what scale of values the body of water has in its life (which feels so affected). So how do you choose which perceptions are valid and which are not, when setting limits? If as we have already seen, the ecosystem does not have a specific tourist limit, for example.

It should also be added that the impacts depend on existing policies of all kinds, existing instruments of ordering and regulation, the level of compliance of the authorities, which requires a real and efficient articulation. In 195

conclusion, different authors conclude that the numerical load capacities for stochastic systems (variables with many interacting elements) such as the Bacalar Lagoon, have not allowed to control, reduce or mitigate the impacts.

Hence the importance and insistence of the proposals of the local communities in the vision of basin and integrated management of the territory, and not of the vision of generating protected islands, such as Natural Protected Areas.

McCool and Lime (2001) conclude “…The concept of tourist and recreational carrying capacity maintains an illusion of control when it comes to a seductive fiction, a social trap or a political myth. Instead, we should focus on deploying frameworks and strategies that determine which of the many plausible futures are desirable, what social, economic and environmental conditions are involved in tourism development, the acceptability of the trade-offs that would occur, and how affected people can be given a voice to articulate the concerns and values involved. While we could look for a term to name this process, the important thing is that we understand what the objectives of tourism development are, what the science says and how we can do better management, given those considerations.… While the search for carrying capacity has led to a great deal of research that has been useful for management, its continued use as a method to solve the problems of tourism development is inappropriate and reductionist.…”

The Acceptable Change Limit The Acceptable Change Limit (LCA) method was created by social and forest scientists, who worked in recreation for the U.S. Forest Service and Department of Agriculture. Unlike the concept of Load Capacity, instead of focusing directly on looking for magic numbers, it focuses on determining how much change in the ideal initial conditions at a site, you are willing to accept.

The LCA requires the definition of social and environmental conditions, desirable and acceptable, in a given area, while generating aligned measures and indicators that allow monitoring, decision-making, generating actions and

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protecting these conditions. The goal of the LCA is to manage visitor impacts, rather than the number of visitors.

In order to determine the LCA, a participatory, comprehensive, collaborative and committed, non-simulated process is necessary to define management objectives; Identify what will be measured socially and environmentally and establish measurable standards to maintain those conditions.

That is, it is necessary to have a very complete and clear picture of the entire system and its operation, from social to environmental aspects, to determine the future social and environmental conditions that will be desirable. Not as subjective desires and good intentions, but as elements documented in depth and analyzed from the panoramic view of territory or landscape, not from the scale of species or specific site. Appropriate indicators must be established in order to assess the desirable social and environmental conditions, established in the previous step.

For the design of indicators, it is key to be able to select the appropriate counselors that fit the particular conditions of a site, activity or function, if you want to have an effective evaluation tool. It is not enough to establish what is to be measured, it is necessary to establish the minimum acceptable values in order to be able to make management decisions in time to reduce the potential for unacceptable change.

These measures are used to inform the establishment of monitoring programs and management activities to ensure the maintenance of site conditions. The process must necessarily be collaborative because in the end consensus and commitments must be achieved by all actors. The key is that the actors involved represent the majority of the groups in the system that make direct or indirect use of it, that will benefit directly or indirectly, or that will be affected by the decisions taken. In the end there must be a consensus on the amount of change that is acceptable to all parties and not just one sector of society.

When reviewing the Acceptable Change Limit methodology, proposed by Stankey, et al (1985) it consists of 9 steps with their purposes, processes and products. Together they are a continuous process of obtaining information for planning, generation of indicators and strategies for follow-up, monitoring and permanent feedback.

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The design of indicators of the Acceptable Limit of Change requires an integrated approach of systems, especially in complex systems with human and natural elements interacting and self-organizing, as would be the case of the Bacalar Lagoon, where there are groups of users, decision makers and other types pursuing their own "interests" and contributing at the same time to the development and operation of the system, interacting with a large number of environmental factors within the system and in the area of influence.

The indicators that allow us to see how the system is behaving are a complicated selection, which requires a deep knowledge of everything. To know in the system what are the essential components, their mutual relations, top-down relationships and one with respect to another; understand how these essential components contribute to the performance of other components and how these essential components contribute to the performance of the total system.

When determining acceptable exchange rates, it is necessary to establish what kind of compensation you are in a position to accept. At this point the issue to be assessed is totally a human question: what kind of compensation are those affected willing to accept? How can the decision of elements that are negatively affected be compensated? If we were to use the example of Bacalar, taking into consideration the selected indicators. How will the increase in revenue of local businesses compensate for the pollution that will be generated in the body of water? How do we prevent this impact from the source? And this must be solidly grounded, not with the marketing discourse of the triad, even if it is presented with a doctoral degree.

The LCA does not provide simple answers to the complicated questions, posed by the development of tourism activities or of any kind in a system and the significant impact they can exert, but it is also not achieved by looking for a magic number of carrying capacity. It requires information, capacity building, real leadership and governance. Therefore, the tangled way in which PROTUR was built, for example, arguing that it sought to establish the Limit of Acceptable Change with such a deficient and disjointed planning, was clearly only a media discourse to pressure the imposition of an instrument, without real bases and simulating participatory construction, which did not exist.

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The myth of tourism and tourism in PNA, pro-poor In Quintana Roo, the pretext for the imposition of all neoliberal environmental regulatory instruments has been ONE economic activity: tourism. The basis for establishing Protected Natural Areas, Territorial Ordinances and PROTUR itself, all are based on the hypothesis that it is necessary and justifiable, even urgent, to impose this or the other type of instruments, for the good of the environment and the natural beauties of the State, in favor of the tourism industry that is the main economic activity of the entity and that is key to contribute to the well-being of the population.

Tourism is presented as the solution to reduce poverty, creator of sources of employment and detonator of those areas provided with natural and historical resources, and presenting on the other hand as "poor and underdeveloped" the ejidatarios, communities and other local actors who have not "known how to properly manage their territories" so an adequate instrument must be imposed on them; But does tourism really contribute to reducing poverty?

In his research, Calderón Maya (2014) delineates how the urban model of Cancun, which emerged from the tourism development model of INFRATUR in 1973, has become a sample of how tourism development, far from promoting orderly and beneficial growth for local populations, has made it an increasingly socially polarized city in terms of access to housing and services, of the quality of life of its inhabitants. It establishes that although on the one hand, there are the large hotel, real estate, commercial and corporate developments; on the other, there are the "Regions" characterized mostly by areas without basic services, infrastructure, precarious housing and without health services… More than 60 thousand people live in more than 30 irregular settlements in which, due to their condition as areas not regularized by the federal, state and local governments, they suffer from the lack of streets, drinking water, electricity, drainage, health and educational services among others.... It is a reality that many of these families who on average have three or four children, suffer from hunger, lack of employment and lack access to health services and housing due to lack of opportunities.

Many researchers agree with this "finding." In their research Alam, & Paramati (2016) when conducting an assessment of the impact of tourism on income 199

inequality in a panel of 49 developing economies around the world between 1991 and 2012, they found a positive relationship between the tourism industry and income inequality due to the oligopolistic nature of the tourism market. Something very much to the Quintana Roo model, where the offer of tourist services such as accommodation, travel and other services are managed only by a few multinational companies, leaving small and mediumsized enterprises (SMEs) at the local level, unable to compete with these large conglomerates, and without being able to pay the environmental price imposed by the triad in the neoliberal environmentalism model, they end up giving in to the pressures of pseudo-environmentalists and governmentmental agencies, unable to strengthen their ability to compete, eventually abandoning their businesses. Which eventually leads to an unequal distribution of income; where the benefits of tourism development are limited only to a select class of people in society, such as the owners of large tourism service providers, entrepreneurs, investors and managers of tourism enterprises, big capital, which serves and is served by the triad.

It is also argued that tourism is a source of employment for the population, but the truth is that as in the tourism model in the State of Quintana Roo, tourism-related companies create low-wage jobs in local communities and exploit services and resources, which in the long run increases income inequality in any society.

At the international level, some researchers, when evaluating studies of 13 economies of intensive tourism between 1995 and 2012, with different methodologies, found only one where tourism contributed in some cases to reduce income inequalities and reduce poverty. Most of the studies examined found that tourism is "not pro-poor" In some cases it even increased income inequality at the local or regional level significantly, tourism was rarely found to significantly benefit the poor.

But the tourism sector insists that they are the panacea to guarantee the quality of life of the population. In its 2018 publication called Our Tourism, the Federal Secretary of Tourism exposed a situation that generated expectations and an ideal panorama: “…In this period (2012 to 2018), the tourism GDP registered a higher growth in relation to the national GDP, so the participation of this activity went from 8.2% in 2012 to around 8.8% in 2017. To put in context the share of tourism 200

in GDP, it is important to mention that the construction industry participates with 7.5% and mining including oil with 3.7%.

Similarly, employment growth in the tourism sector was higher than in the economy as a whole during this period. From December 2012 to December 2017, tourism employment grew 3% on average each year, more than double the job growth in the rest of the economy. Currently, around 10 million workers depend directly and indirectly on Tourism in Mexico.

Likewise, new historical highs were registered in the arrival of international visitors and foreign exchange capture, which placed us as the sixth most visited country in the world in 2017 for the first time in our history and the fifteenth with the highest reception of foreign currency…”

CONANP also asserts something similar to tourism. The document called the Strategic Framework for Sustainable Tourism in Natural Protected Areas of Mexico (CONANP, 2018) states: “…The arrival of visitors, both national and international, has an effect on the conservation objects and the communities that inhabit the PNA. ... provide socioeconomic benefits, including: the economic spillover that favors local inhabitants and communities, the generation of jobs, decrease in local migration and the opportunity for tourism ventures in the seasons of high visitation…”

And in this sense, were the Natural Protected Areas (PNA) established to guarantee the sustainability of tourism development in the state of Quintana Roo contributing to reducing poverty in the municipalities and communities where they were established / imposed? Because as we saw before, they are not contributing to minimize or avoid environmental impacts, at least they are complying in terms of social and economic indicators?

To answer this question, we analyze a little the data provided by the Council for the Evaluation of Social Development Policy (CONEVAL), which investigates and analyzes what refers to poverty in Mexico; This body establishes that the poverty rate increased between 2008 and 2018, around the same period when CONANP and SECTUR affirmed that tourism and tourism in PNA were generators of economic benefits and opportunities for local communities.

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Number and percentage of the population living in poverty in Mexico.

Population Population Population in poverty Year (millons) percentage (millions) Percentage 2008

111.6

100

49.5504

44.4

2018

125.1

100

52.4169

41.9

2.8665 Author’s construction. Data source: National Council for the Evaluation of Social Development Policy.

Multidimensional Poverty Report 2008-2018. A decade of multidimensional poverty measurement in Mexico. Mexico City: CONEVAL, 2020.

At first glance it would seem that the percentage of poor fell from 44.4 to 41.9%, but if we take into account, as CONEVAL itself suggests, that the population grew in that period, we find 49.55 million poor in 2008 and 52.41 million poor in 2018. 2.9 million more poor or half poor, additional. "Half poor", because CONEVAL clarifies, in this period 3 million people went from being extremely poor to moderately poor. If we make a cross-reference of the discourse of CONANP and SECTUR, on the benefit that tourism and THE PNA bring to the local populations we find the contrast of the analysis of poverty indicators of CONEVAL by municipality, in Quintana Roo. It is alarming to realize that, specifically for Quintana Roo, and speaking of tourism, between 2008 and 2018, there was a food poverty of between 55.0 and 65.8% of the populations of the municipalities of Felipe Carrillo Puerto (where the Sian Ka'an Biosphere Reserve is located), José María Morelos (where the Yum Ka'ax Reserve is located in part) and the municipality of Lázaro Cárdenas (where the Yum Balam Reserve is located). and Holbox – Whale Shark). What does this mean? Food poverty is the indicator that establishes the low capacity of the population to access adequate nutrition. In short, how often a person stops eating due to lack of money, or what nutritional quality the individual gets in what he eats (due to lack of purchasing power). According to CONEVAL, more than half of the population of the municipalities where the PNA are prominent and publicized generators of tourism and wealth, do not reach the income to eat.

CONEVAL also shows a poverty rate of capacities of 61.0 to 72.3% in those same municipalities (Felipe Carrillo Puerto, José María Morelos and Lázaro Cárdenas) and up to 27.2 to 38.5% in Solidaridad (where Playa del Carmen is located) and Othón P. Blanco (in the process of dividing with Bacalar). That is, in these municipalities two thirds of the population are in a situation of insufficient disposable income to acquire the value of the food basket and 202

make the necessary expenses in health and education, even dedicating the total income of households only for these purposes, as condescended in its study.

More alarming is that there was, in the period of success reports of Tourism and CONANP, 74.2 to 84.7% of wealth poverty in Felipe Carrillo Puerto, Morelos and Lázaro Cárdenas, again; and 53.2 to 63.7% for Othón P. Blanco (later included Bacalar) and Solidaridad (later included Tulum). What do these figures mean?). It means that practically 8 out of 10 inhabitants of these municipalities suffered from insufficient disposable income to acquire the food basket, as well as to make the necessary expenses in health, clothing, housing, transport and education, although the entire household income was used exclusively for the acquisition of these goods and services, CONEVAL said.

Where is all the wealth that tourism is supposedly bringing to the local populations that ceded – or lost treacherously – their territories in the name of the Protected Natural Areas and that are now treasures for tourism?

When the indicators of tourism, tourist load capacity and Limit of Change acceptable to PNA focused on tourism revolve around visitor satisfaction, and the initiatives of productive projects at hand of the NGOs, financed by international agencies, are limited to training guides, artisans or to be folkloric attractions of the local populations (for the enjoyment of the tourist), when an environmental conservation show is made and neither environmental protection is met, nor with the economic and social justice benefits that supposedly motivate the imposition of a reserve in a natural area of tourist potential, it turns out that the whole discourse of tourism and tourism in PNA driven by the triad, it's just that, a speech.

Explained by Palafox-Muñoz & Vilchis-Onofre (2019) “…The role of the State is to establish the conditions for the commodification of nature, for which it is based on two strategies: tourism for the economic valuation of the landscape; and Natural Protected Areas to guarantee ownership of the territory; both elements always under the discourse of sustainability...”

In the end, the discourse of sustainability and opportunities for local populations, owners of the territories, who lose their biocultural heritage to the triad, for the benefit of big capital, in this model of neoliberal environmentalism, turns out to be only an advertising, marketing ruse, a 203

promise unfulfilled by a simulated dispossession without benefits for local communities. The PNA truncate the right to access the areas of greatest value, monetize them and reserve them protected for the capitals, which are most of them, on the beaches.

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Demystifying Stromatolites The stromatolites of the Bacalar Lagoon have been, like the chivita, tourism and pollution, another flag very helped by the triad to generate spaces, credibility and followers among public opinion to try to impose their instruments on the territory of Bacalar. What is said about them by this group is questionable, half-lies are never half-truths, and that is precisely the case with stromatolites and the Bacalar Lagoon. This stratagem and discourse continue to spread and increase with the limited analytical capacity of the recipients. Dirty war media strategies to create their myths require only that a reputable media outlet publish so that others follow and no one questions.

There is one thing we have to understand: everything that the "environmental defenders of the stromatolites" members of the triad say, are half-truths, product of what I would call a romanticized vision of a rather vulgar geological process, understood in its definition as something that: it is the most abundant, which has no original or special feature or characteristic, abusing the catastrophic discourse with respect to something they do not understand, with a narrow, tendentious vision, with the attitude and posture of having discovered the black thread, which geologists and local inhabitants have known for decades and historical inhabitants have known for generations. But there are also fewer innocent interests behind the insistence on almost sanctifying these stony structures and their microbialistic mat.

It is a matter of specification and contexts, because a real fact, when it is generalized, is said halfway and out of context, can become a myth that bombards wrong information and manipulated at convenience to cause panic and urgency to decree an instrument of legal control (call it a Protected Natural Area, Decree of Critical Habitat or PROTUR) in order to "protect" these structures that according to the myth, are unique in the world.

From the assertions and catastrophic statements, I asked myself many questions, we investigated in very different sources since the myth had many edges created by its promoters, little by little the answers of the scientific literature itself were emerging and turned out to be half-truths (we could write a complete book about how this group of organizations and researchers lacking ethics manipulate public opinion). So, I will go point by point on the arguments of the "defenders" of stromatolites: 205

It was obligatory to investigate the basis of everything that was said by these groups, since something that immediately jumped from the interactions with the triad and its followers, was the attitude of closing oneself and blindly believing what the promoters said, based on an academic degree – many of them have doctorates – but overspecialization is also a disadvantage (as one who can only look at stromatolites from cyanobacteria and not in all the regional context of influence).

Also, because these promoters have called themselves "experts" in everything related to stromatolites; without a curriculum to protect him – his curriculum only covers one over specialization for example in cyanobacteria genetics, or because he had dedicated himself to writing and publishing many articles or books, to argue that Bacalar's microbialites were unique, the oldest and the largest. The followers of this myth believe them with the same blind passion with which the knowledge of the locals is discredited, that practical knowledge, common sense or popular wisdom, which comes from daily observation, from everyday experimentation, the intuition that is created with the interaction with the resource for decades, and sometimes from the knowledge by the knowledge inherited through generations.

As for other research carried out from within the community, we were interested in retaking all the points handled by the promoters of the Bacalar Stromatolites, which became almost myths among the population, and that the media contributed to increase, creating a snowball of opinions and factions. In a document of this type, which sought to find objective bases of a socio-environmental phenomenon to propose solutions, it was necessary to investigate, even briefly, the origin of these hypotheses elevated to the level of myths, which the different sectors of society had built on the stromatolites.

To begin with, it is important to clarify, the stony formations promoted by sediment accumulation promoted incidentally by microorganisms are called Microbialites. It means: Stones formed by microorganisms. In Bacalar there are at least two types of microbialites: Stromatolites, flat-headed and thrombolites (which look like giant broccoli).

Myth 1: They are "living stones", "bioconstructions", "living beings" They are not alive, they are stones. The entire structure is not a living being, only the "baba", the "mat" that is on top of the stone. According to the 206

Mexican Geological Survey, true stone experts, microbials are considered chemical sedimentary rocks. It means that they originate from accumulation of materials, in this case salts of calcium, magnesium, sulfur, dissolved in water that are deposited by chemical means, where the crystals are held together by chemical bonds, or intertwined within each other. The materials, already dissolved, are transported and concentrated forming minerals that accumulate in aggregates and are subsequently lithified (petrified), to form a rock. Almost all of these rocks originate from chemical precipitation in expanses of surface water, either by inorganic chemical processes or by the chemical activity of organisms. Rocks formed by the activity of organisms are known as biochemical sedimentary rocks.

But biologists are more romantic and define them as rocks bio constructed by the action of microorganisms that would seem to be practically the same, but it is not. It seems that placing the word bio- before something gives it the quality of "alive", but it is used in architecture as a synonym for construction that respects the environment and the health of individuals, but it is defined as an anthropogenic activity.

In fact, it was the geologists who were curious to discover the "stromatolytic lichen" as a mechanism for the formation of sheets of Calcium Carbonate that is then fossilized is called Calcreta laminar (another name given to the formed and fossilized stones that biologists call stromatolites); this was in the 1970s. “…The common occurrence of lichens on exposed surfaces of hardened calcretes... b) at first, it would appear to be incidental and of no importance to calcreta formation. However, a closer examination of lichen distribution and their effect on the colonized substrate in terms of textural and tissue changes has revealed several features that have relevance to calcreta formation and recognition (Kapla, 1979).

That is, the process of microorganisms generating the microbial, as biologists call it, lichen as geologists would call it, produces a mucilage (a slime) that "traps" the particles in the water and the sediment accumulates and remains hard (cemented); this sediment is composed of Calcium, Magnesium and the compounds that microorganisms have on hand because they float in the water around. This is a COMMON process around the world, it happens for millions of years, varying in the shape of the rocks, the type of organisms (they can be algae, cyanobacteria, protozoa, etc.), in the way in which the sediment is 207

deposited and the composition of the substances that the microorganisms take and paste to make the stone (accretion) and is the way in which 13% of the soil is created in the world, well not in Australia, there makes up 21% of soil in its territory.

But they are NOT living rocks, nor living beings. Let's clarify, the microbialites (as biologists tell it or microbials as geologists tell it) IS A STONE. The microbial mat (mat that forms the stone) is the only thing alive and is at the top – in the case of stromatolites. It is risky to baptize it as living stone because it gives the impression that the entire structure is a living being, and it is not so. Only the very fine microbial mat is composed of living microorganisms, mainly cyanobacteria (Graham, L. et al (2014), and can include algae (especially green and diatoms), fungi, crustaceans, insects, spores, pollen, rhodophytes (red algae) and fragments and sediments of all kinds, which harden and form the structure, in fact it is called cementation.

The speech must be as clear as geologists say, STROMATOLITES ARE CHEMICAL SEDIMENTARY STONES, they are not processed by living beings, they are not food, they are not excreta, nor are they a unique creation chemically transformed, they are stones formed by particles that are accidentally trapped in the drool of bacteria and the structures of other microorganisms, they harden, form stones and finally over geological time, end up in our quarries, as happens in the areas where there is an abundance of calcium carbonate, and that is in 13% of the entire surface emerged from the Earth.

Microbialites are stones produced by the cementation of calcium particles and other salts that were stuck in the drool of the most abundant organisms on earth and that cover practically all ecosystems of all kinds, in the world, that have resisted mass extinctions and the Chicxulub meteorite. How abundant are these stones? You just have to look for another name of these chemical sedimentary stones, formed in sheets, and we will find the term calcretas, and in the Yucatan Peninsula, you find them as the stones that are in any quarry.

They are also called microbial tuffs, a form of calcareous tuff, in Spain.

The facts must be told in their proper context. If not, they are half-truths.

And half-truths are lies.

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Myth 2: Bacalar's Stromatolites are 3500 million years old The initial discourse, before we began to protest and explain the falsity of the triad assertions they said, was that Bacalar's stromatolites were the oldest forms on the planet, at 3500 million years old as shown in the Semarnat page note of July 2020: “…Due to the importance of these fossils, which date back about 3,500 million years, and the concern of the Bacalarenses to conserve their habitat, the Cabildo de Bacalar established July 15 as Stromatolites Day; now it is sought that this date be recognized at the national level…”

That the stromatolites of Bacalar are 3500 million years old, was a half-truth, for the following reasons: what is probably 3500 million years old, because it is difficult to establish dating, are the evolutionary genetic lines of cyanobacteria. It is the genetic line of cyanobacteria that appeared 3500 million years ago (some authors say 2600 million years ago). There are more than 6,000 species of cyanobacteria identified globally, and distributed in every ecosystem in the world. There are some species in Bacalar, but the genetic line is cosmopolitan, it is distributed all over the world.

How was this intentionally transposed by the scholars of the triad? The discourse of urgency and relevance manipulated, fulfilling its function of creating alarm and urgency, so that the rest of society acted or let the rest of the triad, the NGOs and the government act; but if we exemplify it in another context, it was like saying that it was necessary to protect the human beings who live in Bacalar because they are two million years old, which is different from saying that the genetic line of the human beings who inhabit the Bacalar area, and the rest of the planet, is two million years old. Likewise, cyanobacteria, the genetic line of those of Bacalar and around the world, are 3,500 million years old.

Another factor to make it clear that Bacalar's stromatolites are not 3500 million years old, is that the Bacalar Lagoon did not have the conditions. It was created as a fissure by geological movements about 60 million years ago – not even a joke reaches 3500 million years – and it was quite a while before what we see now was clogged ith sediment and had shallow areas. Less than

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100 thousand years ago Bacalar was a fissure about 3 kilometers wide, which has been scourging little by little.

But above all because, at least the stromatolites of Bacalar, were already dated with carbon 14 test. The truth is that they are a thousand years old. Yes, a one, followed by three zeros (1000 years). The article explaining the dating of Carbon 14 says, at some point, that the results indicated an age of 6 to 8 thousand years, BUT that this was due to an error of the dating technique, known as "hard water error" that happens because the water of the Lagoon is hard water, with many particles coming from other parts and organisms.

Corroborating that these structures, at most were a thousand years old.

The Maya had many thousands of years living in the basin and there were no stromatolites in the Lagoon. Then, the lower and narrower areas of the Lagoon were azolvando and having less depth, until in some areas the conditions were given, around the year 1020 of our era, approximately, so that they began to sediment and create the microbialites and among them the stromatolites. The golden age of the Maya was almost over and there were still no stromatolites that we currently see in the Bacalar Lagoon.

Since the introduction of Gischler's research paper, which has been multi-cited by the triad to support the thousands of years old Bacalar microbialites, it should be clarified that Geischler is precisely the one who says they are approximately 1000 years old: I quote: "... Most of Bacalar's microbialites probably formed in the late Holocene (ca 1 kyr BP to the present day). According to 14C dating, microbialites settled 9 to 8 cal kyr BP ago; however, these ages may be too old as a result of the hard water effect.…” (Gischler, E., Gibson, Ma and Oschmann, W. 2008) Moreover, the maps of the eighteenth century show the body of water and a different Bacalar basin, not clogged with sediment, where you could navigate from the entrance of the area Lagunas de Raudales and Laguna Guerrero, entering from the north from Pedro A. Santos going down and being able to cross the lagoon and leave from Mariscal lagoon by Chac estuary towards Río Hondo and back to the Bay of Chetumal. You can still see the scars of those ancient water passages, in volume II we explain how the system of tartar accumulation by microorganisms (stromatolites) and the clog, which is turning Bacalar into swamps.

Bacteria do not live long, but they reproduce at a high speed. So, we have a new microbial mat, so to speak, every month, since algae, invertebrates and 210

other components of the mat reproduce and die at different rates. They continue to do what their predecessors did billions of years ago: produce oxygen through photosynthesis, and microbial species, produce mucilage (slime) to passively sediment carbonate, indirectly form stones and clog water bodies until they dry. But also, if we consider other research carried out on these mats, where it is established that only .3 to 7% of the components of it are photosynthetic cyanobacteria, the picture changes completely.

So Bacalar's stromatolites reduced their age from 3.5 billion years to a few thousand, so overnight, the triad found that they were indeed not that old.

But the myth had already been created and far from admitting the error and correcting it, they only changed the discourse, without clarifying anything. In this regard, Luisa Falcón herself, who had initiated the myth of the 3,500 million years, initiated the myth that the stromatolites of Bacalar were 8 or 9 thousand years old, others than 6 or 7 thousand years old.

Not only did the local media take the bait, other media outlets did too, mixing this headline with the triad's strategy for imposing its instruments of control, in the name of the environment, as can be seen in the headlines widely disseminated by the New York Times®, the BBC® and El País® which repeat all the myths exposed in this section, including stromatolites.

“Bacalar: the fascinating Mexican lake that houses the "oldest way of life on the planet" BBC News “…Bacalar is home to the world's largest freshwater microbial reef: rock-like structures made up of thousands of microbes that filter carbonated minerals. " Bacalar microbialites have an age range ranging from a few decades to more than 9,000 years," said the expert (Luisa Falcón).

But the microbial's living fossil counterpart, the stromatolites — which date back "about 3.5 billion years" — is what makes Bacalar's population the oldest evidence of life on Earth…”

The note says that stromatolites resemble cauliflower: large, padded beige structures that grow upward from the limestone bottom of the lagoon.

They look like rocks, but they are actually living things. In fact, stromatolites resemble sandwiches layer by layer, those that look like cauliflowers are called Thrombolites.

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He mentions the sedimentation process and then makes assertions: "...

Cauliflower-shaped stromatolites (they are not stromatolites then, they are thrombolites) only exist in a few places globally, and the Bacalar population reveals a history frozen in time, such as the temperature or geochemical composition of water millions of years ago.

That's because they actually conserve the physicochemical conditions of the water in their incredibly slow sedimentation process. This would need to be demonstrated because there is no research to prove it and his specialty is genetics of stromatolite cyanobacteria; if there are the stromato-thing-lithos, infrastructure and human artifacts that have been clogged in sediment or petrified by the action of the same microorganisms in Bacalar, to demonstrate that it is not an "incredibly slow" process as the note asserts.

Fundamentally, stromatolites also help to recycle elements. It's the microbial mats, not the stromatolite. It is the layer of biofilm a millimeter or less thick on the stone that functions as an incidental capturer of calcium carbonate and other sediments.

Microbes that form a stromatolite take carbon from carbon dioxide in the air and place it in the carbonate at the bottom of the lake to store it. Like trees but in water, stromatolites actively improve our environment. The problem stromatolites face is twofold, Falcón says.

The lake is fed by a 450 km underground river that is part of the world's largest system of tunnels and water caves along the Yucatan Peninsula.

In fact, Bacalar is fed by a system of 4 aquifers that come from different parts of the Yucatan Peninsula, and not all contain calcium carbonate and magnesium.

This is really good for stromatolites: carbonated rock from the tunnels is thought to make them grow larger than normal, forming a pillow on the surface of the lagoon. Dr. Falcón really makes a hodgepodge of her original speech and description of how the geohydrological process really works in Bacalar, without really understanding it.

And so far, we stop, we believe that it is demonstrated how it is easy to manipulate public opinion, that a recognized media is involved in an unverified note, even if the self-proclaimed expert in stromatolites – whose expertise is really genetic of cyanobacteria in stromatolites – says so, and that as has been demonstrated time and again, is incredibly adept at manipulating half-truths.

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It seems incredible that such prestigious media have fallen into this type of yellowish tricks and unfounded sensationalist statements, but it is easy to fall when it is such a novel topic with a group of "experts" who are not investigated their conflicts of interest and who manipulate the discourse at convenience.

Myth 3: Bacalar is a unique case.

That is, there are few places in the world with that "privilege", so it is urgent to decree a critical habitat or a sanctuary. To answer this assertion, it is enough to be very clear about what some researchers who have worked with these formations in other parts of the world say: Microbials are found around the world in a wide variety of aquatic habitats (for example, freshwater, hypersaline, marine).

Gischler, who researched Bacalar's microbialites, says they are very similar to those in Chetumal Bay, that's right, there are also in Chetumal Bay. What's more, the structures of Chetumal Bay are OLDER; the same author also says.

Triad promoters say there are two other sites similar to Bacalar: Cuatrociénegas and Shark Bay in Australia, but those in Cuatrociénegas have different microorganisms; and those in Shark Bay are of a different type (they are marine). However, says Gischler, the ones that do look a lot like bacalar's are those in Lake Clifton, in Western Australia! Or to the structures of the brackish Bay of Chetumal located about 15 km to the southeast, since the morphologies and sizes are the same, although the internal textures and microbial consortia are different. And because the structures of Chetumal Bay are probably older and were formed when the growing Holocene Sea flooded the area around 2 or 3 thousand years ago before the present.

So, we wondered if there was a possibility that similar formations existed in other Lagoons in Quintana Roo, and we found data from Laguna Chunyaxché, Laguna Chichankanaab, Laguna Azul; and other loopholes that scientists are "discovering" (they even want to declare Quintana Roo a Sanctuary of microbialites). Even José Zúñiga, Director of the PNA of Calakmul, in the neighboring state of Campeche, told us that they had located stromatolites in various bodies of water in the reserve, located almost 200 kilometers west of Bacalar.

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In other forums, the half-truths of the promoters of the myth of Bacalar as the only site of stromatolites in the world (and two other places), have changed their discourse, where they know that they will not be able to tell half-truths, as is the case of their statements in the publications of their investigations. And to finish complicating the matter, The Great Mayan Aquifer, an ENGO is taking up this flag and seeking to decree Quintana Roo as "Stromatolite Reserve".

Before continuing, it is necessary to be very clear about the consequences of decreeing, as is the intention of these "scientists" of the triad, Quintana Roo as a Sanctuary of Microbialites. I quote from a note from the newspaper La Jornada: “…Gran Aquifer Maya promoted an initiative to declare Quintana Roo a world sanctuary of stromatolites. And he stressed that together with the Ministry of the Environment and Natural Resources (Semarnat) is working on the regulatory aspects "because if there is no legal and legal framework to conserve these microorganisms we are disarmed”.

The head of the Semarnat, Víctor Toledo, said that the presence of cyanobacteria with an age of 3,500 years, "is a jewel that we have to take care of, study and protect. If we think that this should be the case, we must look for the appropriate mechanism. There is talk that perhaps we should decree a critical habitat…”.

La Jornada, July 15th, 2020.

Is the case of Quintana Roo really so extraordinary? or the intention of these declarations is unfounded, perhaps due more to the myopia of a specialist and a desire to transcend so desperate that it does not matter if they do not verify the basis of what they try to justify at the expense of the locals, at the cost of more regulations and the sacrifice of the people who live in these places and who will see their actions limited.

Returning to the point, only in Quintana Roo are there stromatolites – microbialites?? With what we have explained so far in other points, the answer is definitely NO. At the end of the book, we leave a list of scientific articles where we have worked with modern stromatolites (with active mat) and fossil stromatolites (which no longer have an active mat).

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We must also consider that when one looks for information about places with stromatolites, there are other denominations to look for them: microbials, laminar calcretas, tufas, stromatolytic calcareous tuffs, travertines and we can realize that there is a lot of information, many more scientific articles, many places to find stromatolites. Modern and ancient microbials are everywhere, for billions of years and will continue here.

So, the answer is: NO, Bacalar is not the only place in the world, microbialites are found all over the world, they are stores of calcium carbonate and other compounds, and the bacteria on them are among the most abundant organisms on the planet, and they exist from Russia to Antarctica.

Location of modern and ancient microbials (fossils) according to literature review.

Own elaboration. 2020.

Myth 4: The cyanobacteria of Bacalar's microbialites are the main oxygen producers that exist Answer: If they contribute to generating oxygen, but their relevance is not decisive either in volume, surface or oxygen production.

Microbial mats help generate oxygen, stromatolite is the stone. The microbial mat, like many ecosystems of cyanobacteria, diatoms, which are also sites to coexist with red algae, protozoan, annelids and ostracods, which in fact exist throughout the world, contributes to releasing oxygen. But so do all the plants on the planet. The issue is more about context and scope.

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How much surface area of the stromatolite does the mat occupy? An average of 30% to 90% of the part exposed to the sun, per millimeter to 2 centimeters thick.

How much surface area of stromatolites and thrombolites is there in Bacalar?

About 46 hectares (460,000 m2) of an approximate ecosystem of 5,000 hectares (50,000,000 m2), that is, .9% (point nine).

Is there anything else that fixes CO2 and releases oxygen in Bacalar? Yes, wetland ecosystems on the margins and microbial mats on mangrove roots.

Approximately 9,000 hectares (90,000,000 m2) with an area occupation of approximately 30 to 40% (27 to 45,000,000 m2).

How much surface area of the microbial mat in stromatolites are oxygenreleasing organisms and CO2 capturers? .3% (point three) at 7% Will there be oxygenation problems if bacalar's stromatolites disappear? NO. First, because not even the Chicxulub meteorite made them disappear; nor did the weeks and months that Bacalar's microbialites were covered with cut trees that walled the lagoon 50 to 80 years ago.

Second. Cyanobacteria, which generate the slime where the particles of calcium, magnesium that are in the water generated by the stones are cemented, are among the most widely distributed organisms in the world. In fact, they EXTINGUISHED other organisms, they were the cause of the "Great Oxidation" (GOE, also called Oxygen Catastrophe, Oxygen Crisis, Oxygen Holocaust or Oxygen Revolution), which was a very important environmental change that probably occurred over the Syderic period, which was 2500 million years ago and lasted about 200 million years. The emission of dioxygen (O2) into the environment by the growth of cyanobacteria populations worldwide caused a mass extinction for the biodiversity of the time, since molecular oxygen (O2) is toxic to the anaerobic microorganisms that dominated then.

There are about 5000 to 6280 species of cyanobacteria, in Bacalar 2 were identified: Homeothrix and Leptolyngbya.

Currently the production of oxygen dependent on microorganisms, it is estimated that 70% of oxygen is produced by marine organisms (phytoplankton, algae and plankton), and among them two species of phytoplankton, Prochlorococcus and Synechococcus. 25% of global 216

photosynthesis can be accounted for by these two marine cyanobacterial genera. Neither is related to Bacalar's stromatolites.

This simplistic statement exemplifies that mania of generalizing to inflate figures and perception, to manipulate public opinion by creating an exaggerated relevance of something that does not have it. It is true that cyanobacteria contribute to the generation of oxygen, but it is more than 6 thousand species worldwide. Not specifically those found on Bacalar's microbialitic mats. And the two genera that do contribute to 25% of atmospheric oxygen are not located on microbial mats, but in ocean waters, all over the world.

In addition, cyanobacteria occupy a wide range of terrestrial, marine and freshwater habitats, including extreme environments such as hot springs, deserts, bare rocks and permafrost zones, even some cyanobacteria, in their natural environments, are often exposed to the highest rates of UV irradiation known on our globe.

Myth 5. They fix carbon dioxide Yes, they precipitate it in the form of calcium carbonate, but again the issue is the context. At some point one of the adherents of the triad myths questioned me that I did not support the idea of encouraging an accelerated process of precipitation of calcium carbonate to combat climate change, such as accelerating the formation of stromatolite in Bacalar. My answer? Because then we would end up with a gigantic pile of tartar or calcium carbonate, a bank of material, in what was a Lagoon.

Unless we find what to do in a sustainable and well-evaluated way with the amount of calcium carbonate that would be generated from forced precipitation, let's not force it. There's a lot to do to combat climate change, so this is one of the most recent myths the triad has begun to distribute, preand post-COP26 .

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Myth 6. Stromatolites take thousands of years to grow a few centimeters Anyone who has lived long enough or spent a couple of months in Bacalar knows this: The microbial mat is everywhere and growing continuously. It is that slime that petrifies anything that is in the water, in the Lagoon. Poles, piles, boats, anchors, buoys, logs, anything that stays long enough underwater (especially in the southern part of the lagoon, where the water contains a higher proportion of calcium carbonate, magnesium and other salts) will "petrify".

From there, and asking the historical users of the lagoon, some of whom have docks or boats, how long does it take to petrify something that stays in the water? They will tell you that from a couple of months to a couple of years.

Some springs that have not been cleaned in more than ten years have grown up to two centimeters of stone cover (product of the accretion of the microbial mat). These have been called stromato-thing-lites (things petrified by layers of sediment).

Related to the supposed fragility of the microbial mat, it is also enough to make the observation that business owners and inhabitants of the coast of the lagoon, have fought for years to remove the slippery slime, which they call "verdín", which petrifies their steps and boats, using washing with metal brushes to remove it from steps or docks and prevent accidents with visitors or damage to boats ... and the microbial mat grows back almost immediately.

Locals know there's no way to stop it from developing on top of anything in the water, so they already take it as a matter of course and see how it petrifies their steps or docks. So also, that it is fragile and dies if you step on it, is a myth.

Myth 7: Stromatolites are endangered by tourist activity and pollution This is one of the favorite headlines of the media that have fallen into the triad game. Here we just have to ask ourselves a couple of questions.

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How strong are microbial mats? and how quickly do they adapt to really adverse conditions? The answer is simple: They are the most resistant organisms that exist since the beginning of life, they can resist any adverse conditions and always return.

We are not talking about the pollution of the lagoon, whether or not people stand on the microbialitic mats, we are talking about the mass extinctions of life on Earth, we are talking about what was the first thing that resurfaced almost immediately after the impact of the Chicxulub meteorite, equivalent to having a nuclear explosion of 50 thousand megatons endured (Hiroshima had 15 megatons). The meteorite that collided and contributed, according to some theories, to extinguishing dinosaurs and almost all life on Earth. “…The Chicxulub crater was formed by an asteroid impact at approximately 66 Ma. ... In the immediate hours or days after impact, ocean resurgence (the sea back) flooded the crater and a subsequent tsunami deposited debris from the surrounding carbonate ramp. The deposited material, including the diagnosis of biomarkers for land plants, cyanobacteria and photosynthetic sulfur bacteria, ... As that energy decreased, days or months later, the blooms of single-celled cyanobacteria were fed by terrigenous nutrients….

In case there were still doubts about the survival potential to extreme environments that cyanobacteria have, it would be enough to give a read to the research of De la Torre, R (2016) called "Survival of lichens on Mars", which lists a series of experiments of atmospheric simulation and environmental conditions similar to those of the planet Mars, to lichen specimens, which included cyanobacteria. They describe experiments where samples of these lichens were left 18 months outside the international space station, exposed to very high doses of ultraviolet radiation, no oxygen, no food (speaking of extreme conditions) and experiments of that type, result: "These data, together with the previous results, show extraordinary levels of resistance to the environmental parameters of space and planetary environments (de la Torre et al., 2010; de Vera et al., 2010a, 2004a, 2003; de Vera and Ott, 2010; Onofri et al., 2012; Raggioet al., 2011; Sancho et al., 2009, 2007)…”

But what if they step on them and kill them? Or if the activities cover them with sediment? Well, there is several scientific investigations into the photo physiology of cyanobacterial stromatolites in the Bahamas, which are subject to being buried under sand, by the waves and continue to function.

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Stromatolytic mats possess the ability to inactivate their photosynthetic electron transport but only when oxygen concentrations decreased to low levels.

After being unearthed, the stromatolytic cyanobacterial community reactivated its photosynthetic activity in 1 to 2 hours, depending on the availability of light. These studies prove the ability of cyanobacteria to survive and recover from sediment burial, which has helped them survive even the explosion of the Chicxulub meteorite impact.

Conclusion, the Answer: No. They will not be extinguished by tourist activity.

However, do not confuse the natural cycle of microbial mats, as they grow above the water and give way to areas of swampy vegetation.

Myth 8: The proposal for a protection instrument is a community demand That it was the community, the local people who were asking to protect the stromatolites. Following the collective hysteria that the members of the triad with the help of many media built around the stromatolites, on July 15, 2020, by means of a call via email, the "allies for the conservation of the stromatolites of Bacalar and, now, of Mexico", organized by Selva and Laguna de Bacalar, were invited, AC (SELBA, AC)" to a forum where stromatolite experts gathered to highlight their importance.

In this invitation via email, academics, members of NGOs, some private owners, many environmentalists and federal government agents were informed that there would be a webinar of an hour and a half with the aim of decreeing the day of the Stromatolites and in passing "... Establish the secretarial agreement of the "critical habitat for the conservation of stromatolites in Bacalar Lagoon System", through management strategies (including carrying capacity), which allow achieving the economic, social and environmental sustainability of the recreational tourist use of the Lagunar Bacalar System, conserving the critical habitat for the stromatolites..." That is, to score a goal to the locals with a disguised declaration of Critical Habitat.

SELBA, AC, promoter of the event, had obtained funding from the UNDP Small Grants Programme to carry out a basic study whose objective was to 220

declare the Bacalar Lagoon "Critical Habitat" and among its objectives was to create such an inter-secretarial agreement. Citing the document of its proposal funded by the UNDP Small Grants Programme, the expected results included: “Selected management strategies and definition of carrying capacity, based on the current tourist visitation in the federally owned management units in the critical habitat for the conservation of stromatolites of the Lagunar Bacalar system" whose objective is: "To conserve in perpetuity the "critical habitat of the stromatolites"”.

Another thing that stands out in the invitation of SELBA is to whom the invitation is addressed: ORGANIZED and UNORGANIZED Society of Bacalar. The analysis of the discourse of the members of the triad and of their self-conception as members of society above the rest is taken up more broadly in Volume III of this collection.

At first glance the forum included only participants from one of the sectors of the triad, although an attempt was made to give the image of openness and community participation by including two exhibitors who did not belong to the triad: Alfonso Ek Poot, President of Kabi Habim SPR of Bacalar.

Beekeeping Alliance of Quintana Roo, and Javier Jiménez González, President of Apicultores del Cerrito, both from community beekeeping organizations.

When you listen to the videos of the exhibition carefully: Beekeeping, an activity suitable for the conservation of stromatolites and Rural tourism, an activity suitable for the conservation of stromatolites, it becomes clear that the portion of the title of your exhibitions dictates "...__, an activity suitable for the conservation of stromatolites..." was placed by the organizers as validation and forced insertion of the exhibition.

It could well be community forestry, the elaboration of handicrafts, the Mayan milpa or volleyball, an activity suitable for the conservation of stromatolites.

This strategy of generating forums for public opinion, given that they have institutional support, funds and communication channels is often used as a preamble to validate the imposition of some instrument that is frequently used (See What happened to the Valley of Cuatrociénegas, in the 1990s? later).

A sample of the self-conception of the members of the triad as a type of modern messiah or feeder; at this point it was SELBA, AC, an environmental 221

organization, created by partners from the privileged part of society, newcomers to the Bacalar area, who felt they could determine the fate of an entire basin, of thousands of people with the support of the governmental and academic part.

Demystifying What happens in Bacalar with stromatolites?

We are going to detail it in a much broader way and based on Volume II of this collection, but we could anticipate that we must understand that stromatolites are part of a geological process of formation of substrate, soil, and that they are the basis for the construction of earth. This is how the Yucatan Peninsula was formed and 13% of the soil on the entire planet.

The microbial mats when accumulating calcium and magnesium carbonate and building these stones allow vegetation to be established, when the vegetation is established on the stones, either by the accumulation of soil, by the activity of other bacteria and microorganisms, by the absorption of nutrients from the plants that are growing, and because when covered with substrate the sun is covered, then the microbial mat ceases to fulfill its function and gives way, in this ecological succession, to the establishment of wetlands (such as the mangrove) that, with the passage of time, will evolve into more "dry" forms of ecosystems.

Because as bodies of water fill with stromatolites, thrombolites (broccoli) and oncolites (pellets), there is less space for water to flow, and the territory becomes dry land. It changes course and floods other areas. This is a process that has been happening for millions of years in Bacalar (and in other parts of the world), it can easily be seen in the areas of lake soils that exist. The fate of Bacalar, with the phenomenon of microbialites will be to dry up and become swamps, and jungles... but that's a few years away. What can be easily seen in Bacalar.

It is true that the microbialites of Bacalar, are extraordinary geological formations and, in that sense, they are unique and a tourist attraction worthy of properly managing, conserving and protecting for the benefit of all, but not at the cost of creating a myth around them, it is not justified to create myths to manipulate public opinion, because this is done for the benefit of a few groups.

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How much cyanobacteria are worth?

A reflection. In the course of this research, we learned to keep an open mind, trying to understand the motivations of some of the actors in the triad. We learned that the local or regional vision falls short if it does not expand to what happens globally in highly specialized sectors. Where people see stones and bacteria, some scientists, decision-makers and members of ambitious environmental organizations see a lot of profit potential. A fortune.

The genetic material of the cyanobacteria in them is ground gold for insatiable biotechnology companies that seek to develop patents from the genetic material, a business that led many of these companies to ally with academics and environmental NGOs and one or another government, to create protected natural areas to preserve the base material. An example? The genetic material of cyanobacteria is a potential bargain for the production of biofertilizers, for example, it is estimated that it can be worth two billion dollars. So, we must be careful with biopiracy disguised as altruistic interest in the protection of a natural resource that is everyone's heritage.

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WHAT HAPPENED TO THE VALLEY OF CUATROCIÉNEGAS, IN THE 1990s?

Lessons so that it does not happen to Bacalar.

The Institute of Ecology of the UNAM, through Dr. Luisa I. Falcón, as the main promoter of the protectionist initiatives for Bacalar since 2011, had previously 224

been involved in this type of imposition of exclusionary instruments and criminalization of local populations, so that they and other actors of the triad would take over entire territories under their control and exclusive use, where appropriate, by assuring them of "natural laboratories" for their research; in these territories, which had historically belonged to indigenous or rural communities, territories that were placed as PNA, as an RMASAR site, where tourism is promoted and projects are financed, to academics, NGOs and government, and where locals and other historical users were not only dispossessed, but are no longer welcome. As we have seen in numerous previous examples, the members of the triad reserve these territories for their benefit, with the justification that only in this way, under their supervision and administration, can the ideal characteristics of the sites be preserved. Only they can save nature.

The academic part of the triad benefits because its only self-centered goal is its vision of science as it gives rise and lately, science as negotiation. With these actions he not only positions himself in the public eye as a redeemer and possessor of the only truth, from his science, but as a modern colonial commander, who obtains areas where to exclusively carry out his research, from which they obtain funds, generate publications, and whose "contributions to the sciences" (such as astrobiology or evolutionary ecology) yield multiple individual and institutional benefits.

Research with which they argue is helping the environment, to save the planet, but in reality it positions them academically, it gives them advantages to climb positions in their institutions, for example, in the National System of Researchers, which translates into monthly economic incentives of between $ 16,346.70 and $ 38,142.3 additional to their salary, which in turn can mean, hypothetically, a monthly benefit for researchers of between $50,000.00 to $100,000.00 pesos, not including projects, recognitions, other stimuli for projects, and even biotechnology patents, that they may receive.

Reviewing the background of the Institution of the PNA Bacalar promoter group since 2011, it was found that the IEUNAM had been participating since 1999 in similar initiatives in the Cuatrociénegas Valley, in the state of Coahuila, in a place where there are also stromatolites, under the leadership of Dr. Valeria Souza, mentor of Luisa Falcón. Although the Institute of Ecology of the UNAM (IEU) was not the promoter of the original initiative of PNA del Valle de Cuatrociénegas in Coahuila, it was another academic member of the triad, 225

and a foreign member, who promoted the creation of a reserve on ejido and private lands. It was the Desert Fish Council (an American ENGO of scientists that studies desert fish).

IEUNAM was incidentally involved in the area due to the need of foreign researchers to be able to count on Mexican permits to collect samples in national territory and comply with the requirements of their funders. Two members of the triad supporting each other regardless of the biocultural aspects, land tenure and respect for the way of life of the locals, to do science as it happens, their science.

Wendell "Minck" Mincley promoter of the Desert Fishes Council organization "discovered" the Valley of Cuatrociénegas for the scientific world in the late 1950s. From their purely academic interest, the researchers permeated urban society, governments and decision-makers with the proposal for a NAPA. To strengthen its initiative, the Desert Fish Council promoted two Symposia, one in 1983 (from November 18 to 20, 1983 at the University of Arizona) and another in 1993 (held in November 1993, at the Autonomous University of Nuevo León), to achieve alliances and position the four points of the media strategy that PNA promoters always follow: 1.

2.

3.

4.

A count of natural resources or species that is "urgent" to save, with very general statements without justifying these statements with data.

One or more groups of actors that are criminalized and pointed out as a cause.

An imminent danger, and The mention that their instrument is THE BEST SOLUTION.

When the abstracts or the contents of the papers in these symposia are reviewed, from the point of view of discourse analysis, the common strategy arises, among the apparent objectives of highlighting the importance of the flora and fauna of the Valley, to show that something is being done, that it is being investigated, to convince other researchers, decision makers, government officials at all levels and public opinion using the points of the media strategy, mentioned above.

The 1983 Symposium was an account of studies of biological and ecological elements of Cuatrociénegas, which established the peculiarity of the Valley and the urgency of protecting it.

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In 1983, Paul Marsh, editor of the Memoirs of the Symposium held by the Desert Fish Council, stated: "... The purpose of the symposium was to bring together scientists who have worked at Cuatro Ciénegas to discuss the changing character of this area and the future of its unique habitats and biota. It is an opinion of many biologists in both Mexico and the United States that Cuatro Ciénegas is one of the most important natural areas in North America, and that its resources are being lost or could soon be lost to development. The content of these proceedings summarizes and updates Cuatro Ciénegas' research on plants and animals to emphasize the needs of preserving this outstanding ecosystem... It is only through the rational use of knowledge like this that the unique characteristics of Cuatro Ciénegas ecosystems can be understood and preserved for future generations (Marsh, 1983).) …”

An article written by Minckley in 1992, with all the media articulation and through the use of photographs taken by him over 30 years of "studying and visiting" the Valley of Cuatro Ciénegas, seemed to him enough justification to promote the creation of the PNA in the media. It is an article where he places photographs taken, supposedly, 30 years before and a comparison of the same site around the date of the article. The writing has an anecdotal cut that includes their opinions and quotes from other people's opinions, we assume that local inhabitants, but without detailing or justifying or trying to elucidate with scientific data or a methodologically acceptable evaluation, the processes that gave rise to the supposed changes generated. It is shown more as a strategy, as he states in the conclusions of the article and in his own words, to "add fuel to the fire".

Minckley used the American strategy of justifying the creation of reserves as places reserved for people tired of technology, where to find spiritual refuge, that policy that led to the creation of his system of protected natural areas and the dispossession of communities of original peoples, in the late nineteenth century.

The initiative to protect the Valley through a PNA was taken up in the early 1990s, by the academics, Minckley and Contreras, within the Desert Fishes Council (DFC), and by Gómez Pompa, of the Mexican American Science Foundation. Counted as his first result of this stage was the symposium of 1993, whose objective was to "...

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gather biological-ecological information to define the possibilities of use in different parts of the valley, the areas and levels of protection, as well as knowledge deficiencies…” So it was that in November 1993 the second Symposium on the Cuatrociénegas Valley was held. In November of that year, the DFC Board of Directors voted on Minckley's proposal to congratulate, exhort and support the Mexican authorities for the establishment of the NAPA. A foreign NGO/academic pressuring Mexican institutions to place a national territory under protection.

Resolution... 1. Proposed by W.L. Minckley: Regarding fish conservation in the Cuatro Ciénegas Basin. Moved by C.O. Minckley, seconded by Clark Hubbs.

Approved without a dissenting vote …

RESOLUTION OF THE COUNCIL OF FISH OF THE DESERT, 1993-1: Relative to the conservation of fish in the basin Cuatro Ciénegas.

•

•

•

•

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WHEREAS the Cuatro Ciénegas basin and its environments in central Coahuila, Mexico, has been internationally recognized as one of the most unique biological areas in North America for many years; and • CONSIDERING THAT extractive development in Cuatro Ciénegas and adjacent areas, and in the region, poses a threat to its integrity and existence; and • WHEREAS conservation efforts in favors of the area and the region and its biota are making progress and there is considerable evidence that it will bear fruit; RESOLVED that the Desert Fish Council, an international society dedicated to the protection of desert aquatic biota, commends and congratulates individuals and private, municipal, state and federal agencies in Mexico for their efforts and progress in conserving and perpetuating the area; I also RESOLVE that the Desert Fish Council, as a unit and joint actions of its members, offers any and all assistance it can provide to support this effort and thus ensure the sustainable maintenance of the local and regional ecosystem(s) in the Cuatro Ciénegas area; and also RESOLVED that the Desert Fish Council favors and urges individuals and private, municipal, state and federal agencies that relate to the Cuatro Ciénegas basin to redouble their efforts so that this sample of biodiversity

for Mexico, the Chihuahuan Desert, and for the World is not damaged or lost, but conserved for future generations.…”

As a result, without the population being able to intervene, in 1994 the PNA was decreed: Area of Protection of Flora and Fauna Cuatrociénegas, whose objective in the decree was: "... preserve the region's natural habitats and the most fragile ecosystems; ensure the balance and continuity of their ecological evolutionary processes; rational and sustained use of its natural resources; safeguard the genetic diversity of species, particularly endemic, threatened and endangered species; and provide a conducive field for scientific research and the study of the ecosystem and its balance…” unilaterally by academia, government and researchers, national and foreign, without considering the local producers and the historical inhabitants (although the decree states that the Secretary of Social Development carried out consultations with the local inhabitants without referring to other information).

27 years later we wanted to use the same strategy in Bacalar. In 2020, triad groups that were seeing their initiatives to impose a PNA or similar instrument on Bacalar curtailed, sought to organize four similar events: •

•

In July 2020, a virtual forum was held, called National Stromatolite Day (See section Demystifying Stromatolites and Stromatolites Day, in this document).

In November 2020, organized by a local NGO, Agua Clara, The Forum 2020 was convened. Current situation of the Bacalar Lagoon.

At the end of 2020, faced with the strengthening of the capacity for analysis and argumentation of the Community Council of the Bacalar Lagoon Basin, a grassroots organization composed of local inhabitants and historical users of the basin, and seeing the triad jeopardize credibility before public opinion, they came out with the idea of creating their Citizen and Scientific Council PRO restoration and preservation of the aquifer and lagoon system of Bacalar, made up of members of the triad, in an attempt to position themselves as "members of the community, organized and selflessly concerned", but promoting the same strategies.

•

The Citizen and Scientific Council PRO restoration and Preservation of the aquifer and lagoon system of Bacalar carried out, on March 1, 2021, the Citizen and Scientific Meeting for the proposal of care of Laguna Bacalar.

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•

On March 12, it held a second meeting, just 11 days later.

As the community groups were strengthening their arguments and discourses, the alarmist tone and discourse of the triad was adapting and making their own the statements that years ago the communities had been defending, arising from local ecological knowledge and intuition, wanting to make it seem that the triad had discovered the black thread with its scientific method.

In Volume III we expose the arguments of these groups, built with half-truths and manipulated information, through the sect kind of brain wash of young people and the complicity of Environmental Civil Society Organizations of Bacalar, composed mainly of foreign and national individuals newly arrived in the locality or outside the communities, organizing "academic" events where the importance of disjointed and basic research was highlighted, forcing a fanciful idea of coordinated scientific research, which was nothing more than an individual presentation of isolated research, some of which were only methodological reviews and not concrete investigations, to build the fantasy of coordinated working on the situation, as a way to forge a forced credibility for their assertions and accusations, while including the urgency of creating a PNA in their message and the image that anyone who was against it did so for criminal, selfish reasons and far from the common environmental good. The same strategy that was used in the Cuatrociénegas Valley years before.

In Cuatrociénegas, with the reserve established in 1994 Wendell "Minck" Minckley continued to do his research, but it did not seem to him that his natural fish laboratory had sufficient protection, since the producers of Cuatrociénegas continued to make use of the aquifer and build channels for agricultural activities (since generations ago) so fearing that "his" research area would end he joined James Elser, Water chemistry specialist also from ASU (Southern Arizona University) to support him to involve NASA (National Aeronautics and Space Administration), which could have enough weight to prevent producers from continuing their activities. In this way both submitted a project to this institution that had just founded its Institute of Astrobiology, in 1998. What did NASA and its Astrobiology Institute have to do with it?

From the seminars of 1983 and 1993, and in his expeditions to the pools of Cuatrociénegas, Minckley noticed the microbial mats on the stromatolites that grew there, in the pools that were always crowded with locals, bathing.

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Since he could not make the inhabitants and tourists understand about the importance of not using the pools to conserve their fish, he decided to promote a research project of the mats of microorganisms, which were already investigated in other parts of the world by cyanobacteria with genetic lines of the beginning of life, and thought that they would be of interest to NASA, that also had resources and "media weight" with its newly created Institute of Astrobiology, to learn what life could look like or how to create life for humans, on other planets when we got there. But they were ichthyologists and chemists, NASA demanded that to support their project they must include experts in microbiology and evolution, and that they must be Mexican, as a strategy to ensure obtaining collection permits. Since there were not many Mexican candidates at the time, they went to the Institute of Ecology of the UNAM where they involved Dr. Valeria Souza and her husband Dr. Luis Eguiarte Fruns.

The PNA already existed, but it was not enough. Over the years, the motivations that led these and other environmental researchers and NGOs, and in the case of IEUNAM To Dr. Souza to single out and criminalize the producers of the Cuatrociénegas Valley, similar to those that motivated Minckley and Elser, could be considered Conflict of Interest if we count the economic and academic benefits they have obtained over the years, the academic position and advantages that this has brought him . Valeria Souza got involved like this, incidentally. But in the 1990s she became the staunch promoter of control of the Valley for the triad no matter what dirty war strategies she had to use. She and her team were involved in a controversy for pointing out that farmers were overexploiting the aquifer, part of the justification for their research proposals, funds and protectionist initiatives, and for pressuring companies that buy the products the region produced (such as LALA) to no longer acquire them. This left hundreds of families in the Valley, jobless.

The story of how the owner of LALA gave in to blackmail, media pressure and harassment suffered by his daughter, as a result of Dr. Souza's "campaign", has been narrated in the voice of Dr. Souza herself, including at the event on Wednesday, July 15, 2020, during a presentation convened by the groups that were promoting Bacalar's initiative, and appears again and again as soon as a forum or interview you have the opportunity to tell it.

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Dr. Souza has recounted on multiple occasions, publicly, how the media harassment led by her directed at entrepreneurs, producers and those who did not support her ideas, permeated enough to achieve her objectives. In a specific case, he has no qualms about how he managed to get the owner of LALA to cancel the purchase of alfalfa from the Valley from the producers.

According to his own words, the triumph of LALA abandoning the producers of the valley was due to a girl: the daughter of the owner of the company.

The media bombardment resulted in a fierce harassment of the child by colleagues and friends, because her father's company "was destroying the valley" – a message spread by Valeria Souza and her team. The girl in turn reproached the father and he had no choice but to leave 300 families defenseless so that his daughter would stop being harassed.

He always presents it triumphantly as an achievement, without realizing how criminal it is to think about that type of dirty war tactics against producers, against a minor just because she relies on being a NASA collaborator and proclaiming herself "a myth" in Cuatrociénegas without fear of mocking the locals saying not knowing if for them, she is a dragon or unicorn, referring to herself as a kind of omnipresent and powerful being, instilling fear, with this self-perception of having power over people's destiny, a kind of God or Messiah complex.

The real controversy was the fact that other scientific teams specialized in geohydrology found that the aquifer that was in reduction came from other areas and that the causes of its reduction were not entirely clear. However, the media pressure of the group of this bacteriologist and her people had more weight for the companies and authorities, who did not want to continue being singled out, and the farmers (who no longer wanted to continue being criminalized) had no choice but to leave their productive activities and see how to survive.

This is even more alarming if one considers what in his thesis, Bernal (2007), relates about the role of Dr. Souza and her team, in the controversies that arose around water, in the Cuatrociénegas Valley, below. “…This situation (referring to the desiccation of wells in the valley) is causing a strong debate whose main actors are various government bodies such as the National Water Commission (CONAGUA) and SEMARNAT, groups of private entrepreneurs, and several groups of natural scientists from the National 232

Autonomous University of Mexico (UNAM). One of these groups is led by Dr. Valeria Souza who assures that the exploitation of water in the Hundido valley is the main cause that the water level in the protected natural area of Cuatrociénegas has decreased significantly in recent years causing the drying of wetlands and channels in addition to cracking in the ground (LJ, 12 August 2006).

Dr. Valeria Souza is a specialist in Evolutionary Ecology in bacteria and who coordinates since 2002 the project of the National Aeronautics and Space Administration of the United States (NASA) in the Valley of Cuatrociénegas called Evolution in ecosystems of living nature (LJ, January 21, 2004). Souza and his team, through this research, claim to have shown that the valleys of Hundido, Calaveras and Cuatrociénegas are part of the same sea because there is a great diversity in the localities studied and similarity in the bacterial communities of the aforementioned valleys and affirm that if the group of dairy farmers of the lagoon contaminate or end up with the water, Cuatrociénegas dies (LJ, January 21, 2004).

However, another group of hydrogeologist scientists from unam led by Dr. Oscar Escolero have a different vision…The result of the hydrogeological study that consisted of mapping, measuring and analyzing the hydrological system of Hundido and Cuatrociénegas was that there is no interconnection between these valleys (AC, Dr. Oscar Escolero, July 13, 2005) ... Not only did Dr. Escoledo's research show that the assertion of Dr. Souza and her team had no support. In 2005, the Institute of Water Technology (IMTA), SEMARNAT, the National Institute of Ecology and the National Water Commission published with the collaboration of 13 specialists (Mathematical modeling, surface hydrology, hydrogeology, geology, geophysics, isotopic hydrology, hydro geochemistry, underground hydraulics. Climatology, meteorology and tectonics and structural geology, with advice from specialists in environmental isotopy and hydro geochemistry from Germany) concluded, among other things, that:”…the piezometric levels measured in the observation network show that it is impossible for there to be underground flow from Cuatrociénegas to El Hundido... the salinity of groundwater in both valleys is due to the dissolution of rocks of marine origin and not to the contribution of seawater components from a fossil sea. The isotopic composition of the waters of both valleys confirms the above...

The content of dissolved salts in El Hundido is significantly higher than in Cuatrociénegas. Therefore, the waters of Cuatrociénegas cannot be recharged by El Hundido... geochemistry and isotopy allowed us to conclude that the water in both valleys is of pluvial origin... even multiplying the extraction in El Hundido by ten, there would be no significant effect on Cuatrociénegas for 500 years. Of course, the effects on the Sunken would be both significant and immediate..." Imta, C. N. A., & 233

SEMARNAT, I. (2004). Hydrogeological study of the El Hundido and Cuatro Ciénegas aquifers, Coahuila. Ed. CONAGUA. The debate about the lower and lower water levels in Cuatrociénegas is still very heated because Dr. Souza does not stop talking to the media trying, as she herself said in an interview with Elena Poniatowska, to "make a great scandal [...] to stop the overexploitation of water in the valleys neighboring Cuatrociénegas" (LJ, January 21, 2004). For their part, the farmers of The Hundido, although with more difficulty because the federal government has extended the ban to exploit water in the valley, continue with their alfalfa crops (LJ, April 25, 2007). Meanwhile, the politicization of this situation has diverted the central objective of the protected natural area, which is to protect the ecosystems of Cieneguenses and seek possible solutions to the water problem. Instead, what is sought is who to hold accountable and create uproar among society…”

Despite the fact that they do not have the qualifications or the specialty for opinion on geohydrology (their specialty is evolutionary genetics of microorganisms) and that the specialists of the same institution of the Institute of Geology of the UNAM, specialists in groundwater, demonstrated the opposite to their accusations, "the scandal" of Dr. Souza and the interest of NASA to establish in the valley a "laboratory to understand the origin of life" for its Institute of Astrobiology, weighed more for the criminalization of the producers of the valley of Cuatrociénegas and the obtaining of the favor of the public opinion.

But the PNA and the media harassment and criminalization did not seem effective enough to preserve their natural laboratories against the inhabitants and in 2002, Susana Moncada (municipal president of Cuatrociénegas by the PRI when the PNA was decreed in 1994, and director of the PNA from 1996 to 2010, president of Desuvalle, AC), Cristino Villarreal (CONANP staff in Cuatrociénegas) and Arturo Contreras (UANL researcher who ten years later would make a complaint against the team of IEUNAM) proposed the PNA as a Ramsar site.

While the control of the Valley and its heritage sites was in the hands of the Directorate of the Reserve, managed by personnel "from influential families of Cuatrociénegas" hired by CONANP and some of the sites of tourist attraction under the control of local environmental organizations, such as Desuvalle, AC, which has conflicts of interest because it is related to the 234

management of the Reserve, or by regional environmental organizations such as PRONATURA Noreste where Dr. Valeria Souza is part of the Board of Directors.

Their wrong actions, jealously guarded between them while everyone is on the same side, are easily exposed when they have disagreements when even between them their interests are affected.

As an example, reviewing the publications we found a publication made on social networks almost a decade ago, where Arturo Contreras Arquieta, a researcher based in Cuatrociénegas who promoted the PNA, in charge of the aquarium and herpetarium W.L. Minckley, publishes in the social network of Cuatro Ciénegas the following post, where he questions the unfounded and alarmist opinions among others of Dr. Falcón, now the main promoter of the initiative of PNA Bacalar, in this writing clarifies the assertions that she and Dr. Eguiarte made to discredit the region and its local actors, a strategy that we see is very much their way, and responds to them: January 10, 2012 Recently, Luis Eguiarte (husband of Valeria Souza) and Luisa Falcón disseminated a writing entitled THE 7 ENVIRONMENTAL SINS OF CUATROCIÉNEGAS and today I want to comment on it repeating in quotes their writing and later my comment starting with letters of the alphabet in capital letters. Those who like can search for the full version on the Internet. “(sin 1) ... The drop in the level of the water table and all water bodies in Cuatrociénegas is clearly a multifactorial problem, but the most likely direct causes are the increase in the number of wells and in the rate of water extraction in the Cuatrociénegas Valley and its two contiguous valleys, Ocampo-Calaveras and El Hundido, all for the production of alfalfa associated with the milk production of the groups related to the Laguna region (i.e., Lala). In particular in El Hundido, despite our protests and concerns, a large number of wells have recently been opened and the opening of an impressive number of these has just been approved (about 250, since CONAGUA estimated that it is an unlimited aquifer). The ecological irresponsibility of allocating our fossil water and destroying Cuatrociénegas to produce milk (which almost no adult Mexican can really digest) is something we cannot allow...”

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A.- Technically most of the water goes to Sacramento, Nadadores and Frontera, Coahuila, where it does not matter so much the water that comes out, but the one that is wasted. Profauna's studies revealed that the Saca Salada Canal that reaches Frontera takes out 1100 to 1500 liters per second, equivalent to 34.65-47.25 million cubic meters per year (=mmca). But the plots reach a maximum of 250 (7.87 mmca). That is, up to 39.38 mmca are lost. The solution is to pipe it but the investment would require almost $100,000,000 equivalent to the 125-year fiscal budget of the PNA Directorate. On the other hand, the main producer of alfalfa in the Sunken Valley is Beta Santa Monica, at the time Lala Competition. And the water that is used 100% in those plots is only slightly higher than the amount that is wasted in the Saca Salada. It is true that too many wells were opened, but the minority of them were productive. Many did not give enough water or were very salty. I agree with the use of water.

Sin 2 "... the imminent reopening of the gypsum production plant at the entrance to the Cuatrociénegas Valley. One of the main initial achievements of when the Protected Area was decreed was that the extraction of the gypsum dunes was stopped. We cannot understand how the reopening of this factory in the protected area was approved, but its environmental effects throughout the region will be disastrous and spectacular, so it is essential that the change of land use is not allowed for any reason.”

B.- Yeso del Bajío does not extract gypsum from the dunes (sw of the town) but from the plasters located at the E of the town, the lowest part of the valley and had not stopped working until it fell into the trap of the authorities of CONANP and CONAFOR that it should have resolution of environmental impact and land use change of forest lands. This use of gypsum has a mining concession, which is above the forestry law. The land had already been authorized as a mining use and was blocked by corrupt federal authorities.

Sin 3 "... For a long time, canals were built to take water from the springs of Cuatrociénegas and send the water to other parts, within the same valley or to other valleys, to ca. 80 km, like the town of San Buenaventura. The channeling of this water has implied the loss of wetlands and the gradual desiccation of the entire floor of the Cuatrociénegas Valley. We believe that the operation of these canals should be reviewed to prevent evaporation, as well as the water use agreements that have allowed their irresponsible removal in the region. These actions are essential to allow the regeneration, at least partial, of the ancestral wetlands of the valley and so that the aquifer can be recharged again.”

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C.- It goes hand in hand with what was said in the first. But when it comes to reviewing concessions, the law is not retroactive. When declaring the NAP, the rights previously established must be respected and encouraged to save water. A ban will not allow new uses, and if we want farmers to use less water, so that the surplus stays in the pools, then it must support them to improve their irrigation infrastructure or productive reconversion. But they will not change to other products if they are not guaranteed the market and equal or better income.

"The fourth environmental sin is uncontrolled and ecologically irresponsible tourism.

The number of visitors has increased incredibly, mainly on holidays such as Easter, and with them the garbage they leave, the destruction or environmental alterations with works to capture this tourism (for example the baths and other works recently carried out in the Churince pool), the amount of beer bottles and garbage that are found throughout the valley, the "all-terrain" vehicles that run at full speed destroying the vegetation and the thin layer of cyanobacteria that gives structure to the ground, with apparent approval of the authorities. Undoubtedly, ecotourism is a very important source of income, but this must be done in a respectful and controlled way, as the government of Ecuador has developed in the Galapagos.”

D.- I explained it before. Tourism can be managed to make it more responsible and tourism is responsible only for minimal changes in ecosystems. Aquatic species are disappearing because of the problem of water use and removing tourists from the 4 traditional tourist areas is like giving an aspirin to cure cancer.

"A fifth major environmental problem is the recent invasion of organisms, in particular Arundo donnax, the giant reed, which increases water loss, modifies habitat and increases the likelihood of fish extinction and the proposal to use a powerful herbicide for its control (glyphosate, with ammonium sulfate as a surfactant), of which there are reports of its toxic effects on the ecosystem, by killing all plants that are in contact with as well as photosynthetic bacteria and their possible toxic and perhaps carcinogenic effects on animals and humans. Other invasive organisms, such as jewelfish, are also found to place additional stress on endemic fish populations."

E.- In my opinion, the Jewel Fish is more dangerous than the reed, since it is more distributed and its direct effects on native fish and on the invertebrates that serve as food will be seen in the short term. The effort being made to control it is insufficient "The sixth environmental sin has been the lack of transparency and the attitude of certain authorities, who have not allowed water conservation actions to be 237

implemented or effective and ecological measures to be implemented in a series of environmental and conservation problems, an attitude that has been very exhausting for independent researchers and NGOs interested in the area. We could be wrong, but the Protected Area seems to serve mainly to ask for work or collection permits and to charge the entrance to visitors to the restricted regions of the valley (for example, the Poza Azul and the gypsum dunes).”

F.- The attitude of the PNA Management to work only with the AC's Profauna and Pronatura Noreste (note Dr. Valeria Souza is a member of the Board of Directors of this organization) means that they monopolize all the budgets that can be allocated to various projects and that local organizations cannot work. Example: They used the name of my company and my volunteers as collaborators to request permission to catch jewelfish before SAGARPA and whenever I asked for the traps to go on my own, they never provided them to me. My name being on the permit.

On the other hand, La Poza Azul and the dunes are owned by Desuvalle AC and have nothing to do with the federal government. You can't even get the benefits of collecting duties.

"The seventh environmental sin is land tenure and the status of the Protected Area, which have not helped its conservation by being a complex mosaic of land tenure, with several supposed owners, clearly undefined boundaries and complex water rights, so responsibilities are diluted and active management and conservation programs cannot be unified. It is urgent that an effort be made to define the boundaries of the properties, that more areas are really fully protected (as is the case of the Rancho de Pozas Azules, administered by Pronatura) and restructure the status of the protected area.

G.- In reality the tenure is mostly well defined, few lands do not have deeds for dying the intestate owners, but there are heirs or irregular sales. Most of the surface has well-defined owners, whether they are individuals, companies, civil associations or ejidos. The real problem is that the ejidatarios and other owners are selling because they have been told that even to build a house on such land requires environmental impact studies and that is totally false. As they feel that they can do nothing on their land because they sell them at ridiculous prices. Others buy them and resell them more expensively. But only those who sympathize with the authorities receive support for the projects and actions that the CONANP authorities want. If a project does not seem to them, they do not support it as beneficial for the economy and for the environment. Example: The ejido 6 de Enero was about 96% within the PNA

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and most of the Ejido was bought by the Carlos Slim Foundation. Previously Desuvalle had bought the gypsum dunes (800 Has) In 1999 the Management Program of the Cuatrociénegas Flora and Fauna Protection Area was decreed, who were the actors? Julia Carabias Lillo, Secretary of Environment, Natural Resources and Fisheries; Enrique Provencio, President of the National Institute of Ecology; Javier de la Maza Elvira, Head of the Coordinating Unit of Protected Natural Areas and Susana Moncada, Director of the Cuatrociénegas Flora and Fauna Protection Area.

The objective of the Management Program is: "... Preserve the region's natural habitats and the most fragile ecosystems; ensure the balance and continuity of its ecological evolutionary processes, make rational and sustained use of its natural resources; safeguard the genetic diversity of species, particularly endemic, threatened and endangered species; and provide a field conducive to scientific research and the study of the ecosystem and its balance..."

Who manages Cuatrociénegas? La CONANP Rational use refers to water, gypsum and landscapes. PRONATURA receives a lot of money a year for pressuring the authorities to limit the use of water to producers and "guarantee" water for the pools, but to date there is no strategy to achieve this, except projects to "restore" wetlands and advertises on its page: “…During this period, Pronatura Noreste and its conservation partners managed to restore 51.6 hectares of wetland by carrying out works of installation of gabions, cleaning and declogging, modernization of works of taking and closing of disused canals; in addition to providing the ecological flow in the wetlands through the concession for environmental use. In 2020 alone, 3.5 hectares (has) of wetlands were restored in Poza Escobedo and 2.6 hectares in Tío Julio, which retained a flow of 3.1 million cubic meters of water for conservation... In addition, the restoration of 12 hectares of wetlands of the Mezquites River was achieved, becoming a transcendental milestone; with this action, the river's water mirror was increased by 120 centimeters and a volume of 7.8 million cubic meters per year was preserved. Pronatura Noreste has managed to recover a total volume of 29.78 million cubic meters of water per year (equivalent to 4,613 Olympic pools).”

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Far from these organizations and the authorities having organized themselves to provide the local population with sustainable development alternatives, as promised, this has not been possible given that there are conflicts of interest between them, because they "fight" the clientele of members of the community that justifies their efforts of funds for their training courses, their sustainable development projects (handicrafts) or wetland restoration, their tours, their courses to local schools, while researchers continue to shout that the basin continues to dry up.

To date, neither the PNA, nor Ramsar's declaration, nor the closures or regulations and the harassment of producers by researchers has managed to stop the "desiccation" of the valley, nor the contamination in the water or around the pools, and the supposed benefit derived from tourism that was supposed to save the Valley after the declaration of Cuatrociénegas as a Magical Town in 2013, it is highly questioned by researchers from various specialties (obviously not by microbiologists who continue to boast and generate projects of "their" natural Astro biological laboratory). Ironically, even with the closures and the desertion of agricultural activities, the Cuatrociénegas valley continues "inexplicably" to dry up, which without a hint of reluctance the same promoters who 20 years ago assured that they would save the Cuatrociénegas Valley with the establishment of the PNA, continue to make more requests for funds to save it.

In another volume we will see how those same strategies of media scandal and manipulation of information are being taken up by the proponents of the Natural Protected Area in Bacalar, led in some points by Dr. Luisa Falcón, a pupil of Dr. Souza, to point out those responsible and create political pressure, without scientific foundations other than their own limited vision of the way the world works, at the expense of whatever, in order to maintain the status quo of their way of life, the benefits of recognition.

Souza acknowledged in an interview for Milenio Magazine that: "... the case of Cuatrociénegas has generated awards for me, because I am a beast that defends the ecosystem..." These recognitions, it should be specified, translate into financing, with its partial and over-specialized vision of the world, manipulating information, criminalizing the inhabitants, producers and businessmen and manipulating half-truths, modifying its discourse depending on who it is directed, to gain followers among young people and public opinion.

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What his pupil has been trying to repeat in Bacalar.

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A FEW FINAL WORDS In the end, what we learned from this research was that the way in which neoliberal environmentalism was constructed and its supposed environmental struggle was based on the benefit of those who gave rise to it. Far from being a humanitarian issue, the monetary and power interests for control that have been developing as neoliberal environmental groups have been strengthened and positions have created increasingly complicated and positioned networks of actors who in direct or indirect collusion know that they will obtain a benefit by stripping the locals of control of their areas in favor of big money.

Whether to obtain areas to do research, benefits of projects, financing, recognitions, awards and rise as saviors of the planet or to pretend that international commitments to protect the environment are being fulfilled, with intentional discourses and images that are bombarded towards public opinion, they are nothing more than a masquerade to act in a pernicious way towards local populations, communities of indigenous peoples, historical users of natural resources and dispossessing them while criminalizing them.

We hope it will be much easier for the local population to identify early the attempts at domination and dispossession of the different actors of the triad.

Because knowledge is power, and that power must remain in the original peoples, local inhabitants and historical users to take the baton in the environment and do what we have done for generations: take care of our natural resources, our biocultural heritage and conserve the environment from local knowledge, with total governance and empowerment.

While outsiders believe that the lagoons and jungles have been magically preserved, the local populations and those who live day by day with our natural environment are aware that it has been the result of a work and a generational commitment of families, inhabitants and production groups that

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acquired a historical moral responsibility, not as a business that is the case with the triad, but as a moral commitment out of love.

How it was then, today knowledge, identity and information and an enormous feeling of belonging, dignity and Justice moves the population of the Bacalar Basin to come to their defense.

Dedicated to all local actors, historical users and indigenous peoples who continue to fight to regain control of their territories taken away by neoliberal environmentalism.

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RAMSAR. 2011 – 2014 Proposal for the inclusion of Bacalar in Ramsar 1. Arnstein, S. R. (1969). A ladder of citizen participation. Journal of the American Institute of planners, 35(4), 216-224.

2. Bernal, D. G. (2007). ¿Y nosotros, qué? Incorporacion del Ejido La Vega al Area de Proteccion de Flora y Fauna de Cuatrocienegas. Tesis Universidad de los Angeles en Puebla) 3. Gobierno de México, 2015. Informe nacional sobre la aplicación de la convención de Ramsar sobre los humedales. Informes nacionales que se presentarán a la 12ª reunión de la conferencia de las partes contratantes, Uruguay, 2015 4. DECRETO por el que se adiciona un artículo 60 TER; y se adiciona un segundo párrafo al artículo 99; todos ellos de la Ley General de Vida Silvestre. Artículo 60Ter de la Ley General de Vida Silvestre. DOF 1/02/2007

247

5. De Groot, R., Kumar, P., van der Ploeg, S., & Sukhdev, P. (2010). Appendix C: Estimates of Monetary Values of Ecosystem Services.

6. Diegues, A. C. S. A. (2000). El mito moderno de la naturaleza intocada. Editorial Abya Yala.

7. Falcón, L., et al. (2014) https://docplayer.es/91713838-Designacion-internacionalRamsar-solicitud-de-designacion-para-el-corredor-transversal-costero-Bacalar bahia-de-chetumal.html 8. Farrier, D., & Tucker, L. (2000). Wise use of wetlands under the Ramsar Convention: a challenge for meaningful implementation of international law.

Journal of Environmental Law, 12(1), 21-42 9. GEF (2018) Declaración del Secretario General Adjunto de la Convención de Ramsar relativa a los Humedales ante la Asamblea del FMAM https://www.thegef.org/sites/default/files/council-meetingdocuments/Ramsar%20Convention.pdf 10. Geoalternativa (2020). Programa de gestión común para el uso turístico de la Laguna de Bacalar .

140pphttp://www.geoalternativa.com/acervo/PROTUR_2020.pdf 11. Hernández-Arana, H. A., Vega-Zepeda, A., Ruíz-Zárate, M. A., Falcón-Alvarez, L. I., López-Adame, H., Herrera-Silveira, J., & Kaster, J. (2015). Transverse coastal corridor: from freshwater lakes to coral reefs ecosystems. In Biodiversity and conservation of the Yucatán Peninsula (pp. 355-376). Springer, Cham.

12. Russi D., ten Brink P., Farmer A., Badura T., Coates D., Förster J., Kumar R. and Davidson N.(2013) The Economics of Ecosystems and Biodiversity for Water and Wetlands. IEEP, London and Brussels; Ramsar Secretariat, Gland.

13. Secretaria de medio ambiente y desarrollo territorial del estado de Jalisco, SEMARNAT, CEPAHJ, CONANP, Presa La Vega, Rmsar, GEOALTERNATIVA y PROCMA (2014). Programa de Conservación y Manejo (PCyM) Presa La Vega Humedal de Importancia Internacional. 414 pp.

14. SEMARNAT (2017) Informe Nacional para la COP 13 15. ten Brink P., Russi D., Farmer A., Badura T., Coates D., Förster J., Kumar R. y Davidson N. (2013) La Economía de los Ecosistemas y la Biodiversidad relativa al agua y los humedales. Resumen ejecutivo 16. Toledo, V (2020). El ambientalismo neoliberal sale del clóset. Nota en la Jornada 16 de junio de 2020.

17. Villarreal-Sonora, M (2021) En Defensa de Bacalar. Tomo II ¿Qué sucedió en Bacalar? En edición

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Literature consulted on sites with modern microbialites (stromatolites) with active microbial mats, in the world.

Pavillion lake, British Columbia. Canadá 1. Laval, B., Cady, SL, Pollack, JC, McKay, CP, Bird, JS, Grotzinger, JP, ... y Bohm, HR (2000). Análogos modernos de microbialitas de agua dulce para antiguas estructuras de arrecifes dendríticos. Nature , 407 (6804), 626-629.

Lake Van, Turquía.

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2. Chagas, A. A., Webb, G. E., Burne, R. V., & Southam, G. (2016). Modern lacustrine microbialites: towards a synthesis of aqueous and carbonate geochemistry and mineralogy. Earth-Science Reviews, 162, 338-363.

Fayetteville Green Lake, Estado de Nueva York, Estados Unidos. Great Sal Lake, oeste de Estados Unidos. Cuatrociénegas, Coahuila. México. Alchichica, Puebla.

México. Lago Satonda, Indonesia. Vai Lahi y Vai si’i, Isla Niuafo’ou en TENGO. Lago Salda, Turquía. Lagos la Preciosa, Quechulac y Atexcac, a 10 km de Alchichica.

Puebla, México. Lago Clifton, Suroeste de Australia. Lago Walyungup, oeste de Australia. Lago Fellmongery, Sur de Australia. Lago Vermelha, Rio de Janeiro, Brasil. Laguna Pirata, Archipielago Los Roques. Venezuela. Atolón de Kiritimati, República de Kiribati. Pacífico Central.

3. Arp, G., Helms, G., Karlinska, K., Schumann, G., Reimer, A., Reitner, J. and Trichet, 4. J., 2012. Photosynthesis versus Exopolymer Degradation in the Formation of 5. Microbialites on the Atoll of Kiritimati, Republic of Kiribati, Central Pacific.

Geomicrobiology Journal, 29(1): 29-65.

Lago de la Isla Eleuthera. Bahamas 6. Dupraz, C., Visscher, P.T., Baumgartner, L.K. and Reid, R.P., 2004. Microbe– mineral interactions: early carbonate precipitation in a hypersaline lake (Eleuthera Island, Bahamas). Sedimentology, 51(4): 745-765.

Zirahuen, municipio El Salvador. Michoacán. México.

7. Zeyen, N., Daval, D., Lopez-Garcia, P., Moreira, D., Gaillardet, J. y Benzerara, K. (2017). Condiciones geoquímicas que permiten la formación de microbialitos lacustres modernos.

La Alberca, Villa Jiménez. Michoacán. México. Quechulac, Guadalupe Victoria. Puebla.

México. Alberca Los Espinos. Municipio de Jiménez. Michoacán. México. Pátzcuaro, Michoacán. México. Aljojuca, Puebla. México. Joya de Yuriria, Guanajuato. México.

Laguna de Atexcac, municipio de Guadalupe Victoria. Puebla. Rincón de Parangueo.

Michoacán. México.

Laguna negra. Provincia Catamarca. Argentina 8. Gomez, FJ, Kah, LC, Bartley, JK y Astini, RA (2014). Microbialitas en un lago andino de alta altitud: múltiples controles sobre la precipitación de carbonatos y la acreción de lámina microbialitas de lacustrina de alta altitud. Palaios , 29 (6), 233249.

Atolón Tikehau, Tuamotu, Polinesia Francesa.

9. Abed, RM, Golubic, S., García ‐ Pichel, F., Camoin, GF y Sprachta, S. (2003).

Caracterización de cianobacterias formadoras de microbialitas en una laguna tropical: Atolón Tikehau, Tuamotu, Polinesia Francesa. Revista de Phycology , 39 (5), 862-873.

Cayo Highborne, Bahamas 10. Mobberley, JM, Ortega, MC y Foster, JS (2011). Análisis comparativo de diversidad microbiana de esteras trombolíticas marinas modernas mediante pirosecuenciación con código de barras.

Pantanos de Islas Andros, Bahamas y Golfo de Spencer, Sur de Australia 11. Burne, RV y Moore, LS (1987). Microbialitas: depósitos organosedimentarios de comunidades microbianas bentónicas. PALAIOS, 2 (3), 241. doi: 10.2307 / 3514674 Sonda de Exuma, Bahamas: incluyendo cayos Schooner, Isla Lee Stocking, Isla Stocking, Cayo Highborne y la Isla Darby 278

12. Dupraz, C., Reid, RP y Visscher, PT (2011). Microbialitas, moderno. Serie Enciclopedia de Ciencias de la Tierra, 617–635. doi: 10.1007 / 978-1-4020-92121_195 Lago Thetis, Cerca de Cervantes, lakes on Rottnest Island 13. Reitner, J., Paul, J., Arp, G. y Hause-Reitner, D. (1996). Microbialitas del lago Thetis domal. Globale und regionale Steuerungsfaktoren biogener Sedimentación .

Colombia 14. Becerra Real, L. M. (2016). Evaluación del perfil metabólico de un consorcio de cianobacterias bentónicas arrecifales del Caribe colombiano bajo condiciones cultivo. Posgrado Interfacultades en Microbiología.

Varias islas en las Bahamas también tienen lagos hipersalinos con esteras microbianas y estromatolitos bien desarrollados, incluido el lago Storr en San Salvador. El lago de Storr alberga acumulaciones estromatolíticas y trombolíticas alternas 15. Mann and Hoffman, 1984; McNeese, 1988; Neumann et al., 1988; Mann and Nelson, 1989; Pentecost, 1989; Zabielski, 1991.

Lago Tethys, Australia Lago Richmond y diferentes lagos en Rottnest Island (Australia), 16. Dupraz, C., Reid, RP y Visscher, PT (2011). Microbialitas, moderno. Serie Enciclopedia de Ciencias de la Tierra, 617–635. doi: 10.1007 / 978-1-4020-92121_195 Kelly and Pavillon lakes (British Columbia, Canada), Lakes on Bonaire Island, Netherlands Antilles, Sur del Caribe, Lago Sarmiento (Patagonia, Chile), Poza Azul lake (Cuatro Cienegas, Mexico), Yellow Stone National Park (USA), (siliceas), Green Lake (Fayetteville, New York, USA).

Lago hipersalino Petukhovskoe Soda, Rusia 17. Samylina, OS y Zaytseva, LV (2019). Caracterización de los estromatolitos de dolomita modernos del lago hipersalino Petukhovskoe Soda, Rusia. Lethaia , 52 (1), 1-13.

China 18. Fuxing, W., Jianhua, C., Lideng, J., Junfa, H. y Jifu, H. (1994). Cueva de estromatolitos en zona kárstica. Gu Sheng wu xue bao = Acta Palaeontologica Sinica , 33 (2), 172-179.

19. Cao Jianhua Wang Fuxing He Shiyi Huang Junfa (Instituto de Geología Karst, CAGS, Guilin, Guangxi); Efecto hidrológico y significado kárstico de los líquenes endolíticos en la superficie de las rocas carbonatadas en la reserva natural de Longgang, Guangxi [J] ; 1995-04 20. Wen Zhi-Feng, Zhong Jian-Hua, Li Yong, Guo Ze-Qing, Gao Jian-Bo, Xu Xiao-Lin (Facultad de Geo-recursos e Información, Universidad del Petróleo (Este de China), Dongying 257061, China); Estudio actual sobre la génesis y las condiciones de formación de los estromatolitos [J]; Revista Geológica de las Universidades de China; 2004-03 21. Wang Fuxing Cao Jianhua Huang Junfa (Instituto de Geología Karst, Mgmr, Guilin 541004); Biokarst en zonas de crepúsculo de cuevas [j]; carsologica sinica; 199801 22. Ran Jingcheng Chen Huiming (La Administración De La Reserva Nacional De Maolan, Provincia De Guizhou, Libo 558400); Encuesta De Estudios Espeleobiológicos En China [J]; Carsologica Sinica; 1998-02

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España 25. Santos, F., Pena, A., Nogales, B., Soria-Soria, E., del Cura, M. Á. G., GonzálezMartín, JA y Anton, J. (2010). Diversidad bacteriana en estromatolitos secos modernos de agua dulce del Parque Natural Ruidera Pools, España. Microbiología sistemática y aplicada , 33 (4), 209-221. África Oriental (Etiopia, Somalia, Kenia) 26. Casanova, J. (1986). Estromatolitos del Rift de África Oriental. Sociedad Geológica, Londres, Publicaciones Especiales, 25 (1), 201–210.

Laguna Mormona (Baja California. México) y Sahkha Gavish (Sinai) – Golfo de Elat – Mar Rojo 27. Kazmierczak, J. y Krumbein, We (1983). Identificación de cianobacterias cocoides calcificadas que forman estromatolitos estromatoporoides. Lethaia , 16 (3), 207213.

Monte Pieniny, Polonia 28. Szulc, J. y Smyk, B. (1994). Calcificación bacterianamente controlada de esquizotrix-estromatolitos de agua dulce: un ejemplo de Pieniny Mts, sur de Polonia. En Phanerozoic Stromatolites II (págs. 31-51). Springer, Dordrecht.

Lago Tanganica, Africa 29. Cohen, AS, Talbot, MR, Awramik, SM, Dettman, DL y Abell, P. (1997). Nivel del lago e historia paleoambiental del lago Tanganica, África, según se infiere del Holoceno tardío y los estromatolitos modernos. Boletín de la Sociedad Geológica de América , 109 (4), 444-460.

Islas Canarias 30. McMaster, RL y Conover, JT (1966). Estromatolitos de algas recientes de Canarias.

The Journal of Geology , 74 (5, Parte 1), 647-652.

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