miércoles, 4 de septiembre de 2019

AQUACULTURE AND "ASC GREEN SEAL"






CREDITS:


Researcher:
Jorge Varela Márquez
Goldman Prize 1999

Research assistant:
Martha María Varela

Collaborator
Fishermen of the Gulf of Fonseca (Honduras)





ACKNOWLEDGMENT

ADC: Through the professional in Eco Tourism Martha Varela, Manager of Environment, Development and Training (ADC) gave us all the logistics, office equipment, stationery, personnel, etc, free of charge, and accompanied us in the analysis of the information of the Social and Environmental Evaluation Studies as in all the field tours and writing of this document.

MAP: Through Mr. Alfredo Quarto for the revision of the English version of this document, and for his advice regarding content and writing. Mangrove Action Project (MAP), is a non-governmental organization established in the United States and with subsidiaries in other parts of the world; Its priority purpose is to carry out conservation tasks of mangrove forests around the tropical and subtropical zone of the Planet. As well as supporting artisanal fishermen in the defense of their rights

OEIDH: For being an "International Ecumenical Human Rights Observatory", which through its regional in the South of Honduras, which includes the shrimp aquaculture area, in a volunteer and interest action, formed a team led by the Mrs. Margarita Maradiaga and he accompanied us to visit three shrimp farms, of the Granjas Marinas San Bernardo Group (GGMSB), to appreciate their social and environmental behavior and the respect of the human rights of the fishermen who live near the farms or who work in the mangroves, estuaries and nearby beaches.

POLDER 22: Particularly to Amit Thavaraj, for his advice and to the rest of the comrades for their solidarity and constant struggle in favour of the artisanal fishermen and coastal communities of the World, and for their encouragement within the international NGO alliance (Polder 22 ), against the non-sustainable cultivation of industrial shrimp aquaculture. 

SSNC: Through Mrs. Gudrun Hubendick affiliated with the Swedish Society for Nature Conservation (SSNC), who suggested we carry out this research and collaborated with us financing transportation, lodging, travel expenses for us and some companions. We thank the SSNC and Mrs. Hubendick for their great interest in defending the environment and human rights of artisanal fishers.




INDEX

ACRONYM.................................................................................................................................6
GLOSSARY.................................................................................................................................7
CHAPTER I.................................................................................................................................8
1.1. FOREWORD.......................................................................................................................9
1.2. EXECUTIVE SUMMARY.................................................................................................12
1.3. BACKGROUND OF THE “GRUPO GRANJAS MARINAS” (GGM)............................15
CHAPTER II...............................................................................................................................26
2.1. ESIAs: ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT STUDIES.........27
2.2. ESIAs: “PERCEPTION OF NEGATIVE IMPACTS”.......................................................42
2.3. ESIAs: REGIONAL WORKSHOP....................................................................................43
2.3.1. Social Impact:.............................................................................................................43
2.3.2. Impacts on the Environment......................................................................................44
2.3.3. Recommendations of the Assistants to Workshop.....................................................45
2.4. ESIA: COMMUNITY WORKSHOP................................................................................45
2.4.1. Social Impact:............................................................................................................45
2.4.2. Environmental Impact:..............................................................................................46
2.5. EIAS: "MINUTE OF INTERVIEWS WITH KEY INFORMANTS” (p-SIA).................47
2.6. EIAS: DIFFERENCES BETWEEN THE DATE OF PUBLICATION AND THE 
INTERVIEWS...........................................................................................................................48
CHAPTER III ...........................................................................................................................49
3.1. “RT” MEETING WITH FISHERMEN FROM COMMUNITIES CLOSE TO GGM.....50
3.2. “RT”: SUMMARY OF IMPACTS DENOUNCED BY FISHERMEN............................53
3.2.1. Social Impact.............................................................................................................53
3.2.2. Environmental Impact...............................................................................................58
3.3. ORGANIZATION OF HUMAN RIGHTS: CONFIRMATION OF 
COMPLAINTS OF FISHERMEN ...........................................................................................60
3.3.1. COMMENTS ON THE GMSBG: GMSB, CADELPA AND LAS ARENAS:........62
3.3.1.1. GGM / GMSB............................................................................................................62
3.3.1.2. GGM / CADELPA.....................................................................................................65
3.3.1.3. GGM / LAS ARENAS..............................................................................................67
3.4. SUPPOSED DISREPECT TO THE LAWS OF HONDURAS.........................................71
CHAPTER IV.............................................................................................................................73
4.1. DEFINITION OF ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND FAILURE OF APPLICATION IN THE ESIAs.................................................................................................74
4.2. AUDIT................................................................................................................................75
4.3. CERTIFICATION...............................................................................................................82
4.4. RESPONSIBILITY OF THE AQUACULTURE STEWARDSHIP COUNCIL WHEN AWARDING CERTIFICATION AND LOGO, ASC.................................................................83
4.5. PRICE DIFFERENCE IN EUROS 1kg. SHRIMP WITH ASC SEAL AND WITHOUT 
SEAL...........................................................................................................................................84
4.6. GENERAL CONCLUSION...............................................................................................85
4.7. ABOUT THE ASC LOGO.................................................................................................87
4.8. APPENDICES....................................................................................................................88
4.8.1. List of Appendices......................................................................................................88
4.8.1.1. Request for Investigation on the ESIA, by the Fishermen that Support the Influence 
of the GGM....……………………………………………………………………………….....89
4.8.1.2. Rancherías, Location and alleged eviction authors....................................................90
4.8.1.3. Record of complaint # SG-SJDH-D-019-20130214..................................................91
4.8.1.4. Article: Oxidation lagoons.........................................................................................93
4.8.1.5. Central American Court of Water, and article: “Court of Water and Gulf”...............94
4.8.1.6. File # SP0404-2015: deforestation by the GGM / CADELPA and against its 
Manager, Mr. Jacobo Paz...........................................................................................................97
4.8.1.7. WWF Project / Certification......................................................................................98
4.8.1.8. Resolutions of the RAMSAR convention related to Aquaculture............................99


ACRONYM


ADC Development and Training Environment
ANDAH National Association of Honduran Shrimp Farmers
ASC Aquaculture Stewardship Council 
CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora
CODDEFFAGOLF Committee for the Defense and Development of the Flora and Fauna of the Gulf of Fonseca
ESIA Environmental and Social Impact Assessment.
a) b-EIA
b) p-SIA Evaluation of Environmental Impact and Biodiversity
Participatory Social Impact Assessment
BBC British Broadcasting Corporation
FUNDESUR Foundation of the Development of the South Zone
GGM Grupo Granjas Marinas S.A. of C.V.
a) GMSB
b) CRIMASA
c) CADELPA
d) AQH
e) Las Arenas San Bernardo Marine Farms 
Marine Breeders S.A.
Shrimp Farm of the Pacific-HONDUESPECIES
Aquaculture of Honduras
Las Arenas Shrimp Farm 
IAIA International Association for Impact Assessment
ICF National Institute of Forest Conservation, Protected Areas and Wildlife.
IDH Dutch trade initiative
IFC International Financial Corporation
NGOs non-governmental organizations
MAP Mangrove Action Project
“RT” Research Team
SAG Secretary of Agriculture and Livestock
Sea Farm de Honduras Honduran Marine Farm
TCA Central American Water Court
LCA Latin American Water Court
IUCN International Union for the Conservation of Nature
USAID United States Agency for International Development
WB World Bank
WWF World Wildlife Fund



GLOSSARY


1. Estuary: Penetration of the sea to continental land where it usually meets the mouth of a river or other source of water.
2. EIA: Environmental Impact Assessment 
3. Halophile: Organism related or resistant to salt.
4. “rainy lagoon” or “Winter Lagoon” or “seasonal lagoon”: Flat land, saline, desert in dry season and flooded in rainy season. With little or no vegetation, adjacent to mangrove or estuary. ("Salt flat" turned into a lagoon in the rainy season)
5. Mangrove:  Arboreal or shrubby ecosystem generally viviparous, halophilous and temporarily exposed to the tides
6. Playón:  Flat saline terrain between the wetlands and the mainland ("Salt flat"), usually forms lagoons or swamps during the rainy season.


CHAPTER I


... "The same countries that stimulate this abusive method of shrimp aquaculture will send consultants to erase the social and ecological footprint to justify their negative impacts" ... 

Statement by NGOs in the “Shrimp Aquaculture Dialogues” (ShAD, 2008).



1.1. FOREWORD


This study criticizes and calls into question a process that leads to legitimizing the granting of Shrimp Certification and confirming "logo", which the "Aquaculture Stewardship Council" (ASC) grants to the “Grupo Granjas Marinas S.A. of C.V. (GGM)”, from Honduras, which is a group of companies dedicated to the aquaculture production of "white shrimp" (Litopenaeus vannamei), whose sale and export is made from 2016 with the support of the "Certification" and "ASC Seal". Both instruments have been granted for the alleged compliance with the "ASC standards of social, environmental and biodiversity protection", which imply the certified shrimp farms benefit the environment, the artisanal fishermen and local communities who receive the overall impacts of the aquaculture farms of the GGM called: "LAS ARENAS" "CADELPA" "AQH" "GRANJAS MARINAS SAN BERNARDO” (GMSB)and "CRIMASA".

The present study is carried out by interest of the Biologist Jorge Varela Márquez, winner of the International Environmental Prize (Goldman, 1999), who is the coordinator of the research team ("RT") composed among others by Martha Varela, Danilo Gómez y José Ramos. Jorge he is an "interested party" for being the intellectual author, leader and promoter of the studies and actions that concluded with the designation of the "Ramsar Site 1000" (Ramsar Convention,   July, 1999), and with the Declaration of the “Subsystem of Protected Areas of the Southern Zone of Honduras” (SAPZSURH, Decree # 5-1999-E (approved in Dec.1999 and published in the Official Gazette ("La Gaceta") on January 20 of the year 2000). These areas are located in the Gulf of Fonseca, Honduras. This research is also due to the request of artisanal fishermen members of communities that are affected by the GGM shrimp farms (Appendix # 1). And in addition, it is done with the interest of verifying if human rights and the environment, including its biodiversity, are being considered in the aquaculture exploitation of shrimp; and if the "Certification" and "Green Seal" of the ASC is done respecting the "Standards of its Aquaculture Council for Shrimp Management" (ASC Shrimp Standard; Version 1.0 of March 2014), or these accommodate the interests of its client (GGM).

Between February 2017, and January 2018, the Research Team ("RT")   performed in office, the critical analysis of the "Environmental and Social Impact Assessments" (ESIA) that have been presented in 2016, by contracted consultants of the Granjas Marinas San Bernardo Group (GGM), to evaluate if their shrimp farms comply with the "ASC standards of social, environmental and biodiversity protection" which serve as the basis for a process that continues with other consultants who do an “Audit” and “Certification” to complete granting the “ASC Seal".

Likewise, the "RT" complements the critical analysis with field work, through meetings with the fishermen living in villages near the GGM shrimp farms, to confirm if the complaints they raised to the consultants still persist. This field verification is done with the important voluntary cooperation of the Honduran socio-environmental company "Environment, Development and Training S. de R. L. (ADC), whose General Manager is Martha Varela, who contribute free of charge with personnel, office and logistics. Further, a working group led by Mrs. Gudrun Hubendick, affiliated with the Swedish Society for the Conservation of Nature, SSNC, who asked us in January 2017 if we could follow the ASC certification process of farmed shrimp in Honduras, this due to his interest in the introduction of certified shrimp in the Swedish market. They wanted to know how the actual certification was carried out and if there had been any positive change for workers and the environment. The travel expenses to the zone of influence of the shrimp farms were a contribution of the SSNC.

In September 2018, the Research Team ("RT") carried out a new verification tour, this time accompanied by members of a Human Rights Observatory to confirm with these independent witnesses whether any change in the behavior of the GGM has been made or reconfirm the complaints of 2016 in the ESIAs and the "RT" until 2018. Regrettably, the complaints are the same and there is no social environmental improvement.

In the end it is left to the reflection of the reader, the consumer; and of the organizations that have promoted this Certification process: Aquaculture Stewardship Council (ASC); Dutch Trade Initiative (IDH); World Wildlife Fund (WFF) and Grupo Granjas Marinas (GGM) who must conclude, if the "ASC Standards" guarantee a marine food attached to such standards, or if not. In the second case, a great opportunity is lost to establish measures, policies and favorable laws, both to the aquaculture industry and to the communities, artisanal fishers, consumers, environment and its biodiversity.

This study seems repetitive, because it follows the process that leads to the ASC logo: First: Criticism of “Participatory Social Impact Assessment Studies” (p-SIA) and “Environmental and biodiversity Impact Assessment” (b_EIA) with which it is evaluated each company. (We will also call both of them Environmental and Social Impact Assessment Studies _ESIAs_), SECOND: It is analyzed the AUDIT that is done to each company based on the elements of the ESIAs to recommend the CERTIFICATION and this one the seal. For its part, the "RT" after studying the aforementioned documents goes to the area of influence of the GGM to investigate the veracity of what was affirmed in the consultancies; and if the reports of impacts on the part of the fishermen have been considered and solved by the company or by time, as recommended by the consultants. Regrettably, the complaints of 2016 when the certification and Seal are granted still persist in 2017 and 2018, so it could be concluded that the ASC Seal should have been postponed until improvements in the solution of impacts are demonstrated.

At the end:   Honduras is listed as one of the most dangerous countries for environmentalists and social activists .

We are aware of the risk faced by the author of this analysis, as a result of this study. But any event that occurs will be worthwhile, if it is useful for aquaculture companies around the world to consider the negative impacts they cause, and instead of covering them up, apply real, honest and fair socio-environmental measures, in favor of other users of wetlands, marine or continental waters. Likewise, International certifiers such as the ASC are expected to be more careful when monitoring compliance 
with their own "standards," because if they are not met, they can be considered accomplices of their aquaculture clients and found guilty of consumer deception.



1.2. EXECUTIVE SUMMARY


In this study several faults are perceived in the application of the ASC Standards, which call into question the reliability in their "Certification" and "ASC Seal". It includes a narrative of the background on the "social, environmental and biodiversity impacts" that arise due to the establishment of shrimp companies between the wetlands what impacts in neighboring communities, particularly with the artisanal fishing sector, since the beginning of the shrimp farming in 1972 until 2018, pioneering San Bernardo Marine Farms, which over the years comes to form with other companies the Marine Farms Group (GGM).

The consultants who prepare the studies "Participatory Social Impact Assessment" (p-SIA), and "Environmental Impact Assessment and Biodiversity" (b- EIA), to which we will call together "Environmental and Social Impact Assessment " (ESIA), unfortunately omit referring to the antecedents that acknowledge the social, environmental and biological diversity footprint, which are the essential bases on which the "standards" of the Aquaculture Stewardship Council (ASC) are based. neither the auditors, nor certifiers, nor the WWF in its condition of SUPERVISOR consider this fundamental omission. 

The "positive impacts" of the GGM compiled in the "ESIAs", in our personal opinion are insignificant as a contribution to development, by companies that for more than 40 years have stripped the communities of their natural resources, without significantly compensating them for the damage. Therefore, this deficiency is not analyzed in depth and, in this case, it is prioritized in analyzing the complaints about the negative impacts compiled precisely in the same ESIAs against the GGM companies. Although there are complaints against other shrimp farms, it is prioritized in the GGM for having received in 2016 the "Certification" and "Green Seal" of the ASC, supposedly due to "good social and environmental behavior", which seems not to be consistent with the historical documents and apparently neither with their current performance.

The promoters of the Certification and Seal process are: Aquaculture Stewardship Council (ASC) who grants the ASC logo; the financier of the studies, "Dutch Trade Initiative" (IDH); The Supervisor of the process, "World Wildlife Fund" (WFF); and the "Certification and Seal" Applicant, Grupo Granjas Marinas (GGM). On November 24, 2015, they announced the beginning of the process and hired two groups of 3 consultants each. The consultants prepared the Environmental and Social Impact Assessment Studies (ESIA), which are the basis for the subsequent Audit and Certification. The ESIA seem to have as its sole objective, to comply with a requirement to facilitate the achievement of the ASC Seal, consequently the impacts are minimized and it is concluded that they do not merit control measures, so the GGM is released from "assuming important decisions or commitments. " This goes against the definition of Environmental Impact Assessment, as explained below.
The ESIAs include a single Regional Workshop in December 2015 and a single Workshop with a group of communities, sometimes with only one community as in “Las arenas” for example. This occurs between December 2015 and January 2016; besides some personal interviews with other stakeholders. In both Workshops they collected the complaints of the fishermen containing the "perception of impacts." In less than three months, in mid-February 2016, the consultants delivered ten printed ESIAs to the Presidents of several Patronages.

Interestingly, the social and environmental complaints filed in the workshops, compiled and printed in the ESIAs, are cataloged by the same consultants as "low impact and easy to solve over time, so they do not merit further attention", although more than 40 years have passed since they were first presented, yet these same problems still persist. 

in less than 3 months a  group of 6 consultants conducted interviews, workshops, community meetings, issued documents, corroborated, elaborated, described, identified, evaluated, researched, consulted and copied bibliography, analyzed satellite images, visited shrimp farms, reviewed maps, "consulted" and printed 5 b_EIAs and 5 p_SIAs (one for each of the shrimp farms) etc. Total, 10 EIAS documents with more than 100 pages each. This load and speed of work can justify a number of errors and faults found in these documents, but it is not justifiable that the WWF as a supervisor does not acknowledge them, neither the Auditor, nor the Certifier.

To confirm the information, the "RT" studies all ESIAs within the framework of the "Shrimp Aquaculture Stewardship Council" (ASC Shrimp Standard, Version 1.0 of March 2014). It is concluded that there is consistency, persistence and similarity in the denunciations of impacts by fishermen from different communities, which could be enough reason to postpone the Certification and the Seal and to recommend a binding dialogue that achieves the solution to the problems posed. 

In the period February 2017 to January 2018, the "RT" and fishermen visited the communities under the influence of the GGM; they confirm that the complaints compiled in the ESIAs continue and coincide with the denunciations that fishermen and members of coastal communities offer again, similar to those impacts that have been denounced for decades. 

In September of 2018, a tour of consultation and verification of the complaints gathered in the ESIAs and by the "RT" is again made. On this occasion, looking into complaints of violations of human rights of the fishermen, they invited as witnesses members of the "International Ecumenical Observatory of Human Rights" (OEIDH, by its initials in Spanish), to verify among fishermen and other members of the community that the complaints compiled by the consultants and the "RT" are true, which is documented with videos and interviews. 


Next, the respective "AUDITS" that have been made for each farm were analyzed and serious errors were observed and noted within them, which is another reason to postpone the Certification and use of the ASC Logo. In the final process: The RT analysis of the Audit and Certification observed that in the AUDIT report to the ASC “the negative social, environmental and biodiversity impacts" simply do not exist in both instances. The final opinion of the ASC commissioned CERTIFIERS is that there are only two "non-conformities", related to administrative aspects of the companies, and do not consider any socio-environmental impact… The Certification is thus wrongly granted and the consumer tastes “guaranteed” GGM shrimp for the Certification and the ASC Logo. 

Two years (2018) after certification had been granted, the situation for fishermen and communities has not improved. Many fishermen have abandoned their livelihoods activity, decreased it, or work with fear. Communities have lost or are hindered access to food, firewood, timber, income, employment at sea, recreation ... while the environment is still contaminated and the damage to biodiversity is big but difficult to estimate. 

In Conclusion: When knowing the history of the GGM, and the faults committed in the b_EIAs, p_SIA, and Audit, it is concluded that the "ASC standards” "have not been applied correctly, so they do not comply with their state objective to "promote better aquaculture practices conserving the environment and biodiversity 

1.3. BACKGROUND OF THE “GRUPO GRANJAS MARINAS” (GGM)


The GGM (Marine Farms Group), has its roots in 1973 with the arrival in the Gulf of Fonseca, Honduras, of the United States company "Sea Farm of Honduras", in violation of the Constitution of the Republic of Honduras . Its establishment begins near "Punta Ratón", Municipality of Marcovia, Department of Choluteca. Later in 1984, with the incorporation of members of the national oligarchy, it took the Castilian name of "Granjas Marinas San Bernardo" (GMSB) and acquired in concession including a large part of the wetlands of the San Bernardo peninsula in Choluteca, constituted mainly by salt flat  ("Playones") and "winter lagoons", (More precisely, "lagoons of rainy season", which are usually the salt flat that in rainy season are transformed into productive lake ecosystems, full of biodiversity). The area that initially occupies Granjas Marinas San Bernardo, is surrounded and crossed in several parts by estuaries, with lush mangrove forests on its banks where the mangrove, estuaries or "winter lagoons" and where concession is not allowed, for Fisheries and environmental law, because these ecosystems are vital for the fishing activity, biological diversity, breeding or shelter of wild species, firewood, wood, etc. Thus, an Environmental Impact Assessment is needed with strong community participation that protects these naturally productive areas so that they are not concessioned as shrimp farms. However, the traditional, subsistence users of these ecosystems are adversely affected by transformation of these coastal areas to shrimp farms, pollution or access restriction, which subsequently leads to violation of human rights.
        
The first conflict of GMSB, that same year, (1984) with the fishing community of “Playa Negra” ( "Black Beach") which prevents then from building in the winter lagoon "El Jicarito" because in the rainy season this area provides shrimp and fish, in addition to housing thousands of birds and other wildlife. Biologist Jorge Varela, at that time regional chief of Fisheries, managed to reconcile the parties and GMSB by going back to the center of the peninsula of San Bernardo, between the estuaries “El Pedregal " and San Bernardo. A year later, in 1985 Jorge Varela was fired from his post because of his opposition to the destruction of mangroves and "winter lagoons” and for his position in favor of respect the human rights of artisan fishermen.


Encouraged by the United States Agency for International Development (USAID) and the World Bank (WORLD BANK / INTERNATIONAL FINANCIAL CORPORATION), among others, shrimp aquaculture spread without control, at first on the mangroves and then on the salt flats and winter lagoons, restricting or prohibiting fishing in the ecosystems adjacent to the farms, and evicting fishermen from their traditional fishing settlements, known as "Rancherías" (Appendix # 2). The project is transformed into a territorial enclave, hogging large extensions of territory and fulfilling the objectives of producing abundant cheap food for the export and enrichment of transnational and national oligarchy, but without considering the negative social and environmental impacts of the affected communities.


In a few years GMSB taking advantage of a lack of appropriate legislation that limits the number of hectares to concession, obtains almost the entire area of the peninsula of San Bernardo, (5.206 Has.) and then with the incorporation of other wetlands in contiguous areas formed The Marine Farms Group (GGM) which exceeds 8.000 ha.


Artisanal fishermen from the coastal communities, accustomed to working in national ecosystems such as the "winter lagoons", mangroves, estuaries and waters of the Gulf of Fonseca, see how these ecosystems are destroyed and turned into shrimp farms. 
The Environmental Impact Assessment Studies are simple procedures to obtain the Environmental License and are sometimes elaborated when the construction of the shrimp farm begins and they are publicly denounced. Precisely Granjas Marinas San Bernardo (GMSB) is reported in two cases to be built without the respective environmental license, this causes the fishermen in a crowded way to hinder the access road to the GMSB farm. Shrimp investors simultaneously make them feel their power restricting access to natural resources in several places and expanding to their will with the complicity of government officials on duty. Fishermen and other users are harassed in the estuaries, physically and psychologically attacked, there are wounded and unpunished murders; GMSB is related to some of them.

In 1988 the fishermen organized themselves and formed the NGO "Committee for the Defense and Development of the Flora and Fauna of the Gulf of Fonseca (CODDEFFAGOLF)", under the direction of the Biologist Jorge Varela Márquez, who under the strategy of observation and analysis of the problem, dialogue, proposed solution and not finding it… protest before competent authorities and fails, leading to continued public protest, hindering access roads to farms, and mass mobilizations to the capital, (Tegucigalpa) and the city of Choluteca.

"Massive protests"
The expansions of GMSB during 1995 to 1998 violated the MORATORIA to the shrimp expansion imposed by the Government between those years. One of these violations would include the construction of 12 production ponds in the southeast of the peninsula, on the site called "Palacios", such a project was financed by the International Financial Corporation of the World Bank (IFC / WB).

In 1998, Granjas Marinas San Bernardo (GMSB) and other companies formed the Grupo Granjas Marinas S.A. of CV (GGM), distributed along the coast in the Department of Choluteca. The Group is made up now of high-level government officials (President of the Republic Ricardo Maduro, Banco de Occidente, Banco Atlántida, politicians and powerful national and foreign businessmen from the USA. "SOLIDARISM" is imposed as a work contract with employees and prevents training of Syndicates.

The confrontation is common among fishermen and shrimp farms, but emphasized in the GGM that now occupies us, they stand out among several:

_ On November 14, 2000, a few days after the dry season began, the CODDEFAGOLF in a massive public demonstration in the city of Choluteca, denounces all the shrimp farms and the government for the unpunished destruction of the mangrove forests, lagoons and pollution of estuaries in the designated RAMSAR 1000 SITE and Protected Areas of the Gulf of Fonseca, and despite which, offers its full support to the government authorities to help them raise their morale and strengthen their authority to impose the Law... Surprisingly, during the speeches a fisherman publicly denouncing GMSB had 7 tractors and other machines working in the peninsula of San Bernardo.

_The fishermen of the communities surrounding GMSB (“Playa Negra”, “Los Prados”, “Guamerù”, “La Cuchilla” among others) expressed their displeasure at this new expansion (on almost 1000 hectares), due to the fact that they have not been consulted and the harassment to which they have been subjected by the vigilance groups of GMSB, to whom they relate among others, with the unpunished murder on October 8, 1992, of the fishermen Gertrudis Fúnez Guevara in Estero El Tigrón, next to the GMSB concession. (Official note to the Direction of Evaluation and Environmental Control DECA, dated November 13, 2000).

_On November 21, 2000, the DECA was reiterated, the opposition of CODDEFFAGOLF and the communities to the expansion of GMSB.

_ On December 18, 2000, the Environmental Prosecutor's Office and officials in charge of Protected Areas and the CODDEFFAGOLF, verify the fishermen's complaint, but they cannot stop the destruction.

_On February 6, 2001, faced with the impotence of stopping the expansion of GMSB, the communities block access to GMSB for more than 8 hours, denouncing it for having expanded without an Environmental License, and for the damages that are expected to come with such expansion on about 1000 hectares. The blockade persists until hundreds of police, brought from different cities, and present since dawn that day come at 12:00 to violently evict the protesters with tear gas and garottes, leaving several injured and prisoners. The company obtains its Environmental License after the violent eviction, with the complicity of the police, prosecutors and environment authorities.

"Repression in front of GMSB, and in other shrimp farms"
Recently, fishermen living in communities near Granjas Marinas San Bernardo (GMSB) denounce that "in 2015 GMSB has deforested to expand hundreds of hectares. In a project called "La Posta 01", adjacent to Hondufarm ". (When Jorge Varela worked in the CODDEFFAGOLF the communities did not allow the expansion of GMSB on the site), now after this new expansion, fishermen denounce that they are prohibited from traditional transit, access to their food in nearby wetlands and estuaries, extraction of firewood, wood, harassment in mangroves and estuaries, etc.


Among the unpunished murders that are attributed to GMSB, at less another one of them is accepted by the GMSB manager, Eng. Héctor Corrales, in declarations to the British Broadcasting Company (BBC) of London, which in 2004, motivated by the international scandal of the bad behavior of aquaculture in Honduras, makes a long documentary in this country, attracted by the conflict between shrimp farms and communities; In this documentary the conflict is presented, providing a clear image that the situation is conflictive and not as the GGM intends to demonstrate. Among his statements, Mr. Corrales, GMSB executive accepts the murder of fisherman Cristóbal Almendarez (RIP) by GMSB guards; it also confirms the attack with bullets or metal shot on a boy who walked in the mangroves and the subsequent offer of employment (or bribery?) to his father in GMSB, with the supposed purpose of silencing his protest. In both cases, impunity prevails. Also, in the same video is documented the commitment of GMSB not to expand beyond what has been built up to that moment, which ends in a lie, because its expansion has continued even in 2015.

IN 2004 THE GGM / GMSB AFFIRMS THE BBC: "CATEGORICALLY WE WILL NOT EXPAND MORE"  , IN 2015 THEIR LIE IS CONFIRMED


Another unpunished murder with the confirmed participation of GMSB guards occurs on August 31, 2012. According to legal and public complaints, the minor Yelson Gabino García Mendoza is captured in the mangroves and murdered on the grounds of GMSB. The CODDEFFAGOLF transfers the complaint to the corresponding authorities, but they file the case, so what is reported to the Secretary of State in the Offices of Justice and Human Rights, who confirm the information with the authorities of Choluteca, but the case, does not move forward 3 and impunity prevails. (Appendix # 3)

"Young people and children killed and / or injured"
Another case of violation of human rights: For almost a year, from the beginning of 2001 until the beginning of 2002, thousands of people from the city of San Lorenzo, Department of Valle, are subjected to breathing fetid odors of ammonia air that are spread through from the rooms of the populous San José neighborhood and for several kilometers from the city. The air pollution comes from "oxidation lagoons" built by GMSB adjacent to the houses of Barrio San José, to receive the waste from their packing plant. “Empacadora San Lorenzo", in a clear violation of Human Rights and sacrifice of the inhabitants. Several local and national institutions, civil and governmental, require GMSB to solve the problem, but GMSB demonstrates its power and does not attend to them.

On August 4, 2001, the "Directorate of Environmental Assessment and Control" (DECA) of the Secretariat of the Environment (SERNA) in its Technical Report 509/2001 concludes that "The treatment plant of the San Lorenzo Products Packer" generates impacts of pollution by the emission of bad odors to the atmosphere ... and that it was built WITHOUT ENVIRONMENTAL LICENSE and that instead of an environmental audit what comes is the Environmental License ... Recommends to the legal advice to take action against GMSB for having committed a "SERIOUS ENVIRONMENTAL FAULT". This environmental crime goes unpunished.

On October 8, the CODDEFFAGOLF demanded that the International Financial Corporation of the World Bank (WB / ICF) take responsibility for the damage to the health of the inhabitants since the ICF gave the loans for such a project. The (WB / ICF) sent an expert whose recommendations were applied, but though after a few months the smells were lessened, not before having harmed the population for almost a year ... This is another case of impunity on an obvious and serious environmental crime. (Appendix # 4).

In March 2004 the CODDEFFAGOLF internationally denounced the destruction of wetlands, pollution and violation of human rights, before an ethical and moral body known internationally as the "Central American Water Tribunal" (now the Latin American Water Tribunal), where it accused the company of violations and obtained condemnatory verdict against GMSB, El Faro shrimp farm, the Honduran government and the World Bank (WB / IFC) for financing projects without considering the socio-environmental impact. The Court in that case was composed of 9 honorable lawyers of Colombia, Costa Rica, Panamá, Uruguay, El Salvador, Nicaragua, Guatemala, Cuba y Honduras. (Appendix #5)

Then, February 29, 2012, the Granjas Marinas San Bernardo Group (GGM / CADELPA) is caught deforesting without environmental license, a high quality mature mangrove area (Rizophora mangle), in the place known as "La Jagua" # 2; the crime is reported in all media and under pressure, on March 5, 2012, the Forest Conservation and Wildlife Conservation Institute (ICF) of the Pacific Regional Forestry Office confirms the crime. After continuous and intense public denunciation and before the authorities, on May 6, 2013 the GGM is condemned to pay a fine of L.681, 000.00, (approximately = US $ 31, 955.00), and its General Manager Mr. Jacobo Paz, is required for the Environmental Prosecutor´s Office. The political and economic power of the GGM seems to be demonstrated once again when on January 24, 2014, despite his background, Mr. Jacobo Paz is appointed Minister of the Government Cabinet of President Juan Orlando Hernández, (2014-2017 ), in the Secretariat of Agriculture and Livestock (SAG), Institution that also directs Fisheries and Aquaculture (!), with which the aquaculture and fishing activities remain under its administration, and its judgment passes to a "special treatment", in the Supreme Court of Justice under the responsibility of Judge Natural Ligia Sagastume Sandoval and his assistant Secretary Josué Padilla. At the end of 2017, the General Prosecutor of the Environment says that it ignores whether the GGM has paid the fine, while Mr. Jacobo Paz continues as Minister.  (So far, In May 2018 I cannot confirm if the case is still filed or if a sentence has been handed down) (Appendix # 6)

Newspaper articles about Mr. Jacobo Paz, former manager of the GGM for the crimes of deforestation and damage to fauna:    
  
In the period of the former manager of GGM Mr. Paz, the "Law of Strengthening Shrimp Farming"  was approved, through which all the thousands of hectares concessioned for shrimp aquaculture are treated as private property by the shrimp farms, who then accommodate the Law to obtain the right to sell the concessions, rent them, mortgage them, inherit them, or tax them in their own interest with the sole obligation of notifying the State of their transaction.

In addition to this Decree, a new Law on Fisheries and Aquaculture  is approved, despite the opposition of the country's fishermen, who are mocked by a false "SOCIALIZATION" or "CONSULT” from the government...Not enough to strengthen their "Law of Camaricultura" including it in the Law of Fishing and Aquaculture, adding also within this same Law the creation of the "Foundation for the Development of the South Zone" (FUNDESUR), (Without fulfilling the bureaucratic procedures that must approve those aspire to have a Foundation), under the responsibility of the Association of Shrimpers (ANDAH), to capture national funds and private enterprise, and international cooperation, and a contribution of 2 cents per pound of exported shrimp. Its function is to "promote" environmental "and" development "measures; what facilitates them to present a better image of the shrimp industry before international trade. The GGM places Mr. Joaquín Romero in the Executive Directorate of FUNDESUR, who is the GGM INSTITUTIONAL AND ENVIRONMENTAL RELATIONS MANAGER.

OBSERVATION: These are some examples of the history of the GGM, whose social and environmental footprint is not considered in the p_SIAs and b_EIAs, nor in the Audit that leads to Certification and affixed Logo. Such precedents are sufficient reasons to postpone the award of a socio-environmental logo and take the opportunity to suspend the granting of the Certification and logo, until impact mitigation measures are taken, aimed at resolving conflicts. But the participants in the "process" seem to be more interested in granting the Certification and Logo than in applying the ASC Rules, and they seem to be conspiring to "clean up the image" of a company, even if that leads to consumer deception. The social and ecological record of the GGM is erased and awarded with the ASC logo.


CHAPTER II


ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA):

“These Environmental and Social Impact Assessment Studies (ESIA) do not recommend that GGM adopt any measures or commitments to protect the environment and collaborate with other users of the ecosystems adjacent to its shrimp farms.  The ESIAs are not precise enough to be considered in an Audit.

(“RT”)

2.1. ESIAs: ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT STUDIES


The p_SIA and b_EIA of the GGM present little difference between them, for this reason and to avoid redundancy they are agglutinated to both as ESIA. Most of the analysis prioritizes in the b_EIA, and its main subtitles are referenced and criticized.

The ESIA are the first step towards the Audit, Certification and Seal ASC.

The ESIA must comply with the requirements imposed by the "ASC Shrimp Standards (Version 1.0, 2014), which are expressed by means of “Criteria". The "RT" refers to several of them.

What is published in the ESIA or the ASC Criterion is stated in quotation marks ("") and then the "RT" COMMENT:

"EXECUTIVE SUMMARY" IN THE ESIA
“Collectively, the requirements seek to minimize or eliminate the negative social and environmental impacts of shrimp farming, while allowing the industry to remain economically viable”.

COMMENT: In reality, "the negative social and environmental impacts" are eliminated by applying a convenient evaluation that deserves them, to the point of recommending that it be time, without applying any action which corrects them. Thus, the company remains viable without compromises and without applying any correction measures.  Thus, the ASC Standard guarantees that the company GGM, with more than 8,000 Has. in production, does not cause any socio-environmental impact worthy of consideration so there is nothing to eliminate, but to stimulate its economic viability by improving market prices by granting a "green seal"

…"the product of an Environmental Impact Assessment will provide the means to obtain an understanding of the findings and the support of their proposals by non-specialists to clarify the past and current impacts of any agricultural operation."

COMMMENT:  The Environmental and Social Impact Assessment (ESIA) studies in the case of the GGM do not provide means or support for proposals, nor do they mention the past impacts and minimize the current ones. 

…” The purpose of the ASC Fish Farming Standard is to provide a means to significantly improve the environmental and social performance of shrimp farming operations”.

COMMMENT: The ESIA do not recommend improving the socio-environmental performance of the GGM operations, precisely because the impacts caused by their operations in the external environment surrounding their farms are minimized in the ESIA to the point of disappearing. 

In the environmental field, for example, they give a list of animals, copied from the bibliography of the IUCN and CITES but do not express whether they have suffered or suffer some impacts; if there has been loss of biodiversity and how to recover it.  In the social, they report on several disagreements of the fishermen and perceive them as impacts, but later they are "purified" or minimized by the consultant. So there are no mitigation measures or recommendations to improve the company's environmental and social performance.... 

"The Shrimp Standard of the ASC considers that the maintenance of biodiversity is of critical importance, since it is a key to the conservation of healthy ecosystems”

COMMENT: In this case, the ESIAs offer initial information about damages to biodiversity denounced by the fishermen, but they do not present any study or measure of conservation, nor commitment to improve the situation.

The constant contamination of the ecosystems by the drainages that flow directly into mangroves and estuaries obviously causes damage to the ecosystems but the ESIAs do not recommend anything in this regard.

The ESIAs do not consider plant species as part of biodiversity, as they do not even present a list of vegetation that cohabit with the mangroves in a halophytic environment; so they leave a significant gap that gives the impression that the flora is not part of biodiversity.

According to ESIA…” The first list of impacts was submitted to consultation with interest groups (GGM and Interested Parties) and they were refined according to their importance, in a process of discussion and selection, excluding those that did not merit entering the assessment or detailed evaluation, considering the following premises ... "

COMMENT: The "first list of impacts" is drawn up from each Workshop but the Consultants do not reconvene the attendees who do not participate in the "discussion and selection of impacts". However, the consultants meet with the GGM affirming in another paragraph that:

“…is with the GGM that were refined (the impacts) according to their importance in a process of discussion and selection …” 

COMMENT: This "debugging of impacts" between consultants and the GGM could explain in part why the "Non-conformities" or impacts reported by fishermen are considered unimportant and are "purified".

In the ESIAs the Debugging is done ... "Considering the following premises: Impacts that have measures for their elimination or mitigation at acceptable levels ... Impacts whose probability of occurrence and minimum impact do not merit the application of controls".

COMMENT: According to the consultants and the GGM all negative social, environmental and biodiversity impacts denounced, "are considered of" low "or" compatible "magnitude, that do not merits the application of controls".  Consequently, the causes of social conflicts that occur between the GGM and the communities remain under a regime “that allows the GGM, to go to their security guards, the police, the army or the courts as necessary, while the fishermen are defenseless against such ostentatious abuse of power. If the impacts "do not merit the application of controls", why is there so much control? This is a contradiction.

OF THE INTRODUCTION IN THE ESIA:
…”In April 2014, the Congress of the Republic of Honduras issued the Law on the Strengthening of Shrimp Farming”  (Decree 335-2013), in order to establish a set of regulations aimed at strengthening the shrimp industry cultivated in its different stages.” 
COMMENT: In this case, the consultants are right because the shrimp farmers, using their political power, manage to strengthen the shrimp farming by creating Laws at their own convenience. For this reason, they are not believed when they say they have no power to make laws that protect the environment and biodiversity. 

...”The Shrimp Standard ASC recognizes the need to conserve biodiversity at the level of ecosystems, habitats and species.”

COMMENT: The ESIAs do not give a single recommendation to "conserve biodiversity to a level of ecosystems, habitats and species”
OF THE METHODOLOGY IN THE ESIA:
…”Other related ASC principles are Criteria 5, 6 and 7. They have to do basically with predator control, diseases and management of exotic species”.

COMMENT: CONTROL OF PREDATORS: The b_EIA reports that "until recently" the GGM uses "lethal control" to eliminate predators on their farms. After the Auditor ignores this information and declares that there is no "lethal control” and recommends the Certification. (In 2018 the fishermen denounce that lethal control is still used!).

DISEASES: They are only controlled within the farms but they are not supposed to know if diseases are transmitted to other wild species.

“EXOTIC SPECIES”: There is no management of exotic shrimp species. Again the Auditor falls into an error by declaring that the "white shrimp" (Litopennaeus vannamei) is an exotic species in the Pacific.

…”The purpose of the Norma Camaricultura ASC is to provide a means to significantly improve the environmental and social performance of the operations of shrimp farming”.

COMMENT: The GGM has not formalized any commitment or provided a means to mitigate the social impacts, biodiversity and the environment caused by its operations.…” On the contrary, its consultants conclude by denying that significant impacts of this type occur.

... "The GGM sponsored a participatory b-EIA"

COMMENT:  According to the b_EIA and the p_SIA Methodology, paragraph 15 documents that: "On February 15, 2016, the draft of the Participatory Social Impact Assessment was sent to the GGM for review and comments, which were incorporated into the final version of the document "(!) ...

The action of sending "the ESIA to the GGM for review, and incorporation of comments in the final version of these documents", ignoring doing the same with the institutions, regional NGOs and with the communities that participated in the Workshops, is exclusive of the social sector, and it can explain in part why, the reports of impacts end up being "compatible" or of "low intensity" and "do not merit control measures". This incontrovertible fact takes away legitimacy from the process.

… “the draft was sent to the GGM on February 15 for review and comments”.

COMMENT: Another mistake? The EIAS are published on February 16th. One day later.
… “The methodology followed for the evaluation of environmental impacts is known as "Criteria for Evaluation of Environmental Impacts.”

COMMENT: In our particular criterion: As this methodology is applied, it tends to be subjective and "purifies" all socio-environmental and biodiversity impacts. As a result, the situation continues the same or worse than when the ESIAs were drawn up, as the social sector related to fishing continues to denounce harassment, attacks against biodiversity, environmental contamination, and destruction of wetlands.…

… ”Hence, three major categories of impacts have been defined according to the means that can be impacted”.

COMMENT: Lack of seriousness or hurry of the Consultants because they speak of "3 major categories" and only present 2 Categories of impacts. (b_EIA, CRIMASA)

…” Elaboration of multi-temporal maps …”

COMMENT: Both b_EIAS and p_SIAS do not present multi-temporal maps as they indicate: They simply show in a single image of a single year, the evolutionary changes supposedly occurred in different years in companies, which besides being absurd has nothing to do with "Multitemporal maps".

COMMENT: Both b_EIAS and p_SIAS do not present multi-temporal maps as they indicate: They simply show in a single image of a single year, the evolutionary changes supposedly occurred in different years in companies. , which has nothing to do with “Multitemporal maps ".

The consultants say they are based on a study carried out by the WWF that they did not want to show us. The "RT" finds information about a project for the GGM of Honduras and SONJA of Ecuador with a duration of 18 months, (Appendix # 7), which was to begin in January 2016... But it is February 16, 2016 when GGM delivered the 10 voluminous impressions of ESIA printed... If the project was approved by the WFF, could the WWF have made the selection and hiring of staff, office rental, purchase of supplies, general project planning and within the implementation of the same, the multi-temporal study in less than a month? ... And the GGM consultants, could incorporate in these studies their own interpretation of the multitemporal analysis of companies and have time to print them?

... Socialization of the Impacts Identified in the ESIA:
“A Workshop on Socialization of positive impacts is carried out with its empowerment measures and the negative impacts with its mitigation or compensation measures” 

COMMENT: In both Workshops, the consultants do not commit or hold the GGM responsible for executing "measures of empowerment, mitigation or compensation". The socialization is then made only with the GGM. 

…”In this event (Workshop) a copy of the report of this Environmental Impact and Biodiversity Study (b-EIA) was distributed to FENAPESCAH, a civil society organization that represents and unites organized and unorganized artisanal fishermen”. 

COMMENT: The only workshop that attended FENAPESCAH was to the Regional and did not attend any community workshop, and there was no distribution of b_EIA copy in any case, because the events were to provide inputs to the consultants who would later develop the b_EIAS. 

FENAPESCAH does not unite the fishermen nor is it known in the communities that are under the influence zone of the GGM companies, although it appears in the Audits as an important witness in the status of "Participant by community".

FENAPESCAH It has no office, personnel, equipment, logistics and has never presented a narrative report of its activities to the government as required by the URSAC Law. But it serves the interests of the GGM when it requires it. As in this case, in which they "appear" accompanying in their false condition "Participant by community" in 4 of the 5 Audits. 

…Very badly do the consultants, auditors and process supervisors, by using a "Fishermen's Federation" that does not function as such to usurp the representation of true fishermen and has no presence in the communities that surround the GGM companies and perhaps in no way place more than in your neighborhood. 

…Evaluation and Description of Impacts in the ESIA:

“After the construction of the positive and negative impacts with the groups of interest, it proceeds to its evaluation and prioritization, following the Methodology for Evaluation of Matrix Impacts of Cause-Effect Relationship”. 

COMMENT: As a result of such "Valuation", all the impacts regarding the environment, biodiversity and social of the communities practically lack "Value" or "Priority" solution. 

The ESIA gives way to the Auditor and the Certifier who only find 2 "minor Nonconformities" related to the administration within the GGM: 1) Payment receipts to the GGM workers and 2) Overtime of working hours. Nothing about impacts to society, environment and biodiversity, which according to the ASC are their fundamental purposes.
LOCATION IN PROTECTED AREAS

ASC Criteria 2.2.1: Dispositions for the establishment in -Protected Areas.
... "The farms were established before the declaration of the Sub-System of Protected Natural Areas of the Southern Zone” 

COMMENT: The ESIAs do not indicate the date when the GGM shrimp farms were established and expanded. Inclusive: The above statement is based on "ICF Opinions”, which also do not indicate the year in which the farms were established and extended. Therefore, they are incomplete and their conclusions are not credible but very convenient for the GGM: None of the shrimp farms except for GMSB indicate the date of establishment, so it cannot be assured if the other farms were established before the declaration. of Protected Areas neither if they did it and expanded during the Moratoria, so there is no way of comparison, nor validity of such instruments that appear to have been elaborated with great urgency and on request.

…” Maps are shown as a result of a multitemporal evaluation carried out by WWF in 2016, where it was determined that the shrimp farm was established in the concession given by the state of Honduras, mostly on a sandy beach with little shrub vegetation and with mangrove in the shores of the estuaries.”

COMMENT: Comments were already made on this "multi-temporal study" but it is added that: Suspiciously they do not indicate the date in which "the WWF did the Multitemporal Study". None b_EIA presents a summary with images of different years, of multitemporal analysis of spatial type, which would have been done by comparing the coverage interpreted in several satellite images, or in maps of the same place in different dates, allowing to evaluate the changes in the situation of the hedges that have been classified...

…The consultants mention that their conclusions are based on a multi-temporal study carried out by the WWF. The bibliographic citation does not lead to find such a study and the consultant Mario Espinal, coordinator of the b_EIA, promises to give us the information and does not comply. The "RT" after intensive search finds on the internet a PROJECT PROFILE called: "ASC Shrimp Certification January 2016, June 2017", prepared with the financial support of IDH FIT FUND, and technical support from WWF Guatemala / Mesoamerica and WWF Ecuador  ... which has the objective of granting the Certification to the GGM and another group in South America. NOTE: If the project profile is presented in January 2016, how long does it take to approve and start the project and how much to provide results to the consultants that publish their EIAS in February 2016?

NOTE: If the project profile is presented in January 2016, how long does it take to approve and start the project and how much to provide results to the consultants that publish their EIAS in February 2016?

The b_EIA presents ... "MAPS of the mangrove area established in 1999 in CRIMASA and in other farms in years close to 1999.”

COMMENT: The image presented by the ESIA for CRIMASA is not from 1999 nor do the other farms present the true year of its establishment.

LOCATION IN CRITICAL HABITATS

ASC 2.3.1 CRITERIA: “Provisions for the establishment of farms in critical habitats for threatened species such as those defined in the IUCN Red List, national lists or other official list".

COMMENTS: In these Environmental and Social Impact assessments (ESIAs) consciously ignores the social, economic and environmental importance of contiguous ecosystems adjacent to these mangroves, such as the "winter lagoons" (more properly "rainy season lagoons"), which are formed on thousands of hectares during the rainy season in the salt flat lands known as "Playones", which, covered in water, form beautiful landscapes full of aquatic, wild birds and terrestrial biodiversity. The water coming from rivers, runoff and sea floods the winter lagoons and feeds thousands of fishing families and tens of thousands of birds, also allowing several species to return to repopulate their natural ecosystems.

When on 1999 the Protected Areas are proposed, it is understood that the shrimp farmers and the government will respect the integrity of the winter lagoons by applying Environmental Impact Assessments (ESIA), and the National Environmental Impact Assessment System law (SINEIA), which includes the consultation to the authorities, communities that may be affected, NGOs and genuinely representative organizations, incorporated by Law in the "National System of Protected Areas of Honduras" (SINAPH).

The SINEIA is a group of consultation to regional authorities, local and civil society that works in the environment that may be affected, and that receives and studies the EIA, visits in a group the area to be concessioned, and expresses its opinion regarding the project, which is of faithful fulfillment prior to granting or denying the License. 

Nor is there comment on the sum of the impacts of all the shrimp farms that have destroyed a large part of Ramsar Site # 1000 and Protected Areas.

"Winter or rainy season lagoon."


…” The farms of the GGM, although it is neighboring of these mangroves, do not constitute part of any critical habitat for the wild fauna of the region of the Gulf of Fonseca. (ICF Opinion, 2015)”








COMMENT: The ICF, in its haste to issue its favorable opinions to the GGM, makes unusual statements such as: "The GGM farms are not part of any critical habitat for wildlife" which is obvious, because if there was a critical habitat, it disappeared and is now part of the aquaculture infrastructure.

No environmental authority or ESIAs propose or indicate critical habitats for threatened species (2.3.1); nor do they establish or recognize critical habitats inside or outside the farm for any species, therefore, they do not recommend conservation measures either (2.3.2). 

GMSB has in its interior a small site with a sign that refers to a "nesting area", which includes birds, which ironically are subject to "lethal control" within their own farm.

In the AQH and CRIMASA b_EIAs, no reference is made to the “winter lagoons” and in none of the studies are these wet ecosystems mentioned as critical "critical habitats" for "threatened species".

Although the ICF has as one of its functions, to protect the biodiversity of the winter lagoon ecosystems and to avoid deforestation, it does not speak of the mangrove deforestation that they themselves confirmed, and which resulted in the condemnation of the GGM and his Manager in 2012.

…” The GGM is in accordance with the Ramsar Convention, since this convention includes artificial wetlands such as artificial ponds and salt pans, rice fields and other water storage areas…

COMMENT: The consultants cite the Ramsar Convention with apparent knowledge, but they do not analyze why the GGM does not comply with the application of the Resolutions of that Convention, for example with COP 7: Resolution VII.21 Articles 13, 14 and 15. Nor do they cite the publicized case in COP 8, which denounces the usurpation of the official delegation of Honduras by an employee of the GGM and does not comply with Resolution IX.4 of COP 9 ARTICLE 31. (Appendix #8)

…”dykes and dams, represent a significant proportion of wetland resources in many regions and serve as habitat for wild species, particularly migratory birds”.

COMMENT: ... Again, the consultants giving an out of context opinion make such a statement. If they refer to shrimp farms as "habitat for wild species", then instead of aquaculture farms they would have "shelters or parks for birds and other wild animals". As one of the main founders of the GMSB, Ralph Parkman, expressed some years ago when asked about his considerations in the conservation of birds:

…“Jorge: I'm raising shrimp ... I'm not raising birds”.

How many thousands of hectares of wetlands have been converted into shrimp farms? Wildlife has simply lost thousands of hectares of its natural habitat due to the uncontrolled expansion of the GGM and other shrimp farms on wetlands.

The shrimp farms of the GGM, with their huts and dams, hinder the transit of wild species and humans to mangroves, estuaries and the sea, restricting the passage near them; These Assessment Studies do not make any comments aimed at mitigating these phenomena. On the contrary, they try to justify it with misplaced comments like the previous one.

ENDANGERED SPECIES 

CRITERIA ASC 2.3.2:” Maintenance of critical habitats for endangered species within the boundaries of the farm and implementation of protection measures for those areas. "

COMMENT: The ESIA do not recognize critical habitats inside or outside the farms, logically there are no protection measures either. (GMSB maintains a sign indicating a "nesting area" that is not congruent with the "lethal control" that is practiced on all GGM farms).

…"The complex of ecosystems that form the ecological system of the Gulf of Fonseca, presents a wide diversity of plant and animal species. More than 65 species of fauna threatened with extinction have been found in the vicinity of the shrimp farm, as part of the wetlands that make up both the mangroves and "WINTER LAGOONS " close to the GMSB"... 

COMMENT: "65 species threatened with extinction in the vicinity of GMSB"?. This data is consistent with the destruction of wetland ecosystems, within and in the vicinity of GMSB. This is one of the rare times they mention the "winter lagoons" and accept that there is a wide variety of animal and plant species in them. This observation is late for such lagoons because almost all of them are now shrimp farms.

…” Some species are considered seriously affected, and even several of these are classified as probably extinct or in the process of total extinction. The case, for example, of jaguar populations, of which people say that it previously existed in the region, now it is possible that it is completely extirpated from the Gulf of Fonseca. Other cases such as sawfish, coatis and guaras are in verification of their extinction due to lack of sightings in recent years”.

COMMENT: The loss of biodiversity is recognized, particularly the "Jaguar" (Panthera onca), "Pizote" (Nasua Narica), "Guara" (Ara macao), "Sierra fish (Pristis pristis), but they do not give any measure aimed at recovering it. On the other hand, villagers confirm that almost all wild mammals have disappeared, and the main cause - not the only one - is the massive destruction of wetland ecosystems. But the consultants only copy and report, but they do not investigate or recommend mitigation measures.

…”In the same way, the bivalves known as "curiles" are very hard pressed species throughout the year due to their high commercial demand. These species live outside the farms in the “ñanga” or mangrove ecosystem on silty substratum.”

COMMENT: This is incomplete information and shows the partiality of the consultants favorable to the GGM: In the workshops, the fishermen argue that the loss of these species particularly "curiles" (Anadara tuberculosa), "clams" and mangrove crabs of different species is due, among other things, to the drainage waters of the shrimp farms. They carry chemicals and are dumped without treatment into the estuary. But the consultants prefer to blame the "commercial demand" rather than comment according to the information obtained in the workshops, and much less, according to scientific research.
(It is important to inform that for about 5 years several post-larvae breeders and shrimp breeding companies have been buying these "curiles" and other bivalves to feed their breeding shrimp). 

…”With regard to birds, as a result of the literature evaluation of the avifauna”

COMMENT: There is no evaluation of the literature on birds but a "copy and paste" of the Lists of IUCN, CITES and Honduras, the 3 Lists with more than 10 years old. In these studies, consultants do not recommend conservation measures for species, habitats or ecosystems. There are neither mitigation nor scheduling measures for its execution. They are simply copies of lists and brief comments.

…”Table 5: Synopsis of the composition and wildlife conservation indicators in the vicinity of CRIMASA, based on the IUCN Red List, CITES and the List of Species of Special Concern in Honduras.”

COMMENT: The current status of populations due to the loss of ecosystems for more than 10 years after the lists have been prepared by other sources is not evaluated, and the birds have been subjected to their elimination with "lethal control", in addition to not recommending measures of conservation, neither for critical habitats nor for species.

CUSTODY ZONES, BARRIERS AND BIOLOGICAL CORRIDORS

CRITERIA ASC 2.4.2: “Riparian buffer zones with a minimum of width and natural vegetation between the farm and the aquatic environments / brackish environments ".

2.4.2: In almost all the GGM farms (with the exception of the eastern side of GMSB), buffer zones have not usually been left between the farms and the mangroves and estuaries, whose perimeter walls for the most part reach as far as the humidity hinders the construction and maintenance of boards.
The fringes of natural vegetation are reduced due to the expansion and in some cases they become so narrow that the fishermen complain that they sometimes have to walk along the shore of the estuaries. Likewise wild animals lose space to prey or are predated

“Construction of shrimp farms up to the edge of the highest mangroves.” and “Mangroves next to huts.”


NOTE: The lack of buffer zones, when approaching the huts to the vegetation or the aquatic 
environment facilitates the theft of shrimp and directs the harassment of the guards of the farms against the fishermen in general. Therefore, the GGM restricts or prohibits access to wood, firewood and food sources in mangroves and aquatic environments. To avoid this harassment, fishermen have been demanding "buffer zones" for decades.” 

CRITERIA ASC 2.4.3 Corridors: Vegetation with a minimum width or permanent vegetation through the farm and that provides the movement of humans or native wildlife through agricultural landscapes”.

COMMENT: 2.4.3: If GGM prohibit or restrict the movement of humans off the farm, much less allow it inside... No "corridors" have been left through the farm that allows fishermen to move to their fishing sites. The traditional corridors have been eliminated when establishing or expanding the farms involving such corridors. The vegetation has grown naturally on the banks of the embankments between ponds and ponds where the community transit is forbidden by said streets, and if they go to fish or extract any product in the nearby estuaries they are harassed. There is also no free movement for terrestrial wildlife, which has practically disappeared, as recognized by the consultants.

…” Some connectors traced, and that act in low level of corridor ... "

COMMENT: Between the ponds, streets have been built for the workers to walk through the farm. On the sides of these streets, are the banks of the ponds where the mangrove grows naturally, providing them support and protection against erosion. The movement of wild species such as crocodiles, coyotes, raccoons etc. is not allowed, because they are not "biological corridors" or "connectors".

...They are transit streets for employees and vehicles. If there were wild animals, the ESIA do not say how to handle them, nor do they present any recommendation to avoid "lethal control" against birds.

... "In the maps we can see the grid of thin vegetation connectors (in white color) on the huts that make connectivity with sectors of thin forests, shallows and estuaries that belong to the neighboring protected areas.”

COMMENT: Only "a map is appreciated". As stated before, these "connectors" are the streets built between the ponds and the transit of GGM operators and vehicles, and there is no natural or artificial connector created for that purpose. The periphery of the huts and streets, reaches where it is not profitable to build more, or where are mangroves or estuaries, fact that makes them vulnerable to thefts because it allows criminals to hide in the forest or adjacent to the huts ... While the honest fishermen suffer the consequences of the greed of the GGM. For this attack on their human rights, fishermen and NGOs have demanded a thorough investigation into the theft of shrimp, but shrimp farmers have been totally opposed to such request, so it is whispered that the executives, chiefs of police and guard act in complicity with the thieves or speculate on the motivations of their refusal.

CONTROL OF PREDATORS

CRITERIA ASC 5.2.1. Official provisions for the lethal control of predators of protected species.

CRITERIA ASC 5.2. 2.
Provisions for the use of shot or chemical substances for the control of predators.

…“Currently the control of predators in Honduras is not regulated and there is no rule that established at that time and with what methods you can control predators as a management tool”. 

COMMENT: It is observed how the consultants justify the killing of predators. But they do not say that GMSB first, and the GGM later, for more than 40 years they have built a political and economic legal framework at their interest and convenience but they have not created that regulation for the control of predators.

... "GGM has handled the problems of shrimp predators selectively and until recently used pyrotechnics and metal pellets.

COMMENT: Although the consultants admit that "... until recently" metal pellets were used "they do not specify date, and according to the fishermen in 2016, metal pellets are still used as "lethal control of predators". The "RT" confirms the same denunciation during several meetings held with the communities in 2017 and 2018. 

…”However, at present, the policy of the GGM is not to make use of lethal control for the control of predators, for which the management and acquisition with equipment suppliers are being carried out to implement the control of predators with new techniques of repelling that include small noisy boats operated with remote control (RC boats), as well as the use of "drones" to scare away birds”

COMMENT: “The policy of the GGM is not to make use of lethal control “?  First, they say that until recently "lethal control" was used and then they express that "they are making efforts to implement other techniques of repelling" (2016) ...Two years after making these declarations and having achieved the Certification and Seal, the fishermen denounce that GGM has not yet incorporated the promised alternative techniques of "repelling".

…PHOTO IN THE b_EIA: "Cormorants in the middle of fishing in production lagoons of a shrimp farm”

COMMENT: Is it intended to demonstrate that these predatory shrimp birds (Phalacrocorax sp ), can eat freely within the production ponds? According to the ESIAs, thousands of pounds of shrimp are eaten by these birds. It gives the impression that this bird is posing for the reader but does not represent reality.

…PHOTO IN THE b_EIA: "Blue Heron (Egretta caerulea), consuming shrimp”

COMMENT: They present the photo of this bird eating shrimp in a harmless way, but under normal conditions this heron would be executed; only serves the purposes of influencing reader awareness.

IDENTIFICATION OF CIVIL SOCIETY ORGANIZATIONS RELATED TO BIODIVERSITY

FENAPESCAH:

COMMENT: FENAPESCAH is not known in the communities that are under the influence of the GGM, a company that in this case uses FENAPESCAH as a reference, usurps the representation of the fishermen. The farce is specified by using it as a "participant in the community" in 4 of the 5 Audits that lead to Certification.

CRITICISM ON THE "ESIA DECLARATION:

- Both the b_EIA Workshop and the p_SIA Workshop run simultaneously for 2 or 3 hours and in the same place.
- There is only a "Regional Workshop" of a few hours with institutions, NGOs, ANDAH, and with "leñateros" to know or "identify impacts". There is no other meeting for "review and incorporation of comments" as is done with the GGM.

Only a community workshop of a few hours to obtain information and know or "identify impacts". There is no other meeting for "review and incorporation of comments" as is done with the GGM.
- - In both cases there is no second workshop to discuss the results of the first as recommended by the ASC
- The consultants prepare the studies of p_SIA and b_EIA and "send them for review, and incorporate comments to the GGM" but do not do the same with those who participated in the Workshops.
- - The representative of the community is given the final documents already printed. It is said that they are also given to a usurper "representative” of fishermen who do not know in the area (FENAPESCAH).
- - Most of the impacts collected are related to social and environmental problems, particularly of artisanal fisheries, but these are sub-estimated on the ESIAs and are not considered at the time of the Audit and give the Certification.

CONCLUSION: 
- The p_SIA y b_EIA seem to follow the order of the ASC Standards but they are not always correctly applied and several errors and ambiguities are committed.
- - The ESIAs are not precise enough to be considered in an Audit.

RECOMMENDATION: The consultants must be hired by an entity different from the company they are going to evaluate. The p_SIA and b_EIA should be repeated and added more time to perform them. Greater participation of genuine fishers and environmental advocates should be incorporated into the team of consultants.

2.2. ESIAs: “PERCEPTION OF NEGATIVE IMPACTS”


The "perception of impacts" of the GGM companies is expressed in a section of the ESIA, which documents several complaints and observations of Institutions and NGOs, collected in a Regional Institutional Workshop held on December 15, 2015. And in a Community Workshop close to each of the companies between December 2015 and January 2016. 

In each workshop of two and half hours duration on average: Simultaneously, information is collected about the ESIAs (b_EIA and the p_SIA), such as environmental and social  conditions, biological diversity, economic situation, community problems, potentialities ...; it is assumed that several concepts of the vocabulary  are also explained as perception of impacts, EIA, p-SIA, b_EIA, Audit, Certification, Green Seal, ASC Standards, purpose, objectives, motivations ... etc. and what is the purpose of the GGM when requesting a Certification and "ASC Green Seal" for their product, and the benefits that these instruments can bring to the company, to the communities, to the fishermen and to the environment, and biodiversity… as an essential part of the Workshop, they are recorded and printed in the ESIA the denouncements of the assistants regarding their "perception of the negative impacts" that the GGM causes to fishermen, environment and biodiversity; It is a great job for so little time!. 

Later in office work, the consultants take the impacts collected in the Workshops and apply a "technical evaluation", which concludes cataloging them as "low or compatible magnitude, that does not require the application of controls and it is time that solves them". Consequently, the GGM is free of responsibility and does not acquire any commitment to mitigate the reported impacts. _Though complaints have been repeated for almost 40 years peacefully or violently, time still does not solve them.

The "perceived impacts" in the Workshops and printed in the ESIA in 2016, are confirmed in community meetings and visits to the surroundings of the farms by the "RT" in February 2017 and persist in January 2018.

In September 2018 the "time has not yet resolved the impacts" reported and are again confirmed, but this time with the accompaniment of honorable witness’s members of the International Observatory of Human Rights, sector of Choluteca, who document their visit with videos and interviews. 

Following are comments on the Regional and Community Workshop carried out by the consultants and then verification by the "RT" in meetings with the communities.

2.3. ESIAs: REGIONAL WORKSHOP


In the Regional Workshop between the Association of Shrimpers (ANDAH), government institutions, NGOs, some fishermen and lumbermen ("coachmen"), conducted by the consultants on December 15, 2015, the RT perceives the following impacts, with their comments in parentheses:

2.3.1. Social Impact:

- Violation of Human Rights …

- …By harassment of the private security of the company against the fishermen. (In mangroves, estuaries or other adjacent ecosystems outside the boundaries of farms)

- For preventing or restricting fishermen's access to food sources. (Attack on food sovereignty)

- For preventing communities from accessing their energy sources (firewood) for cooking. (Attack on food sovereignty).

- For preventing communities from accessing their wood sources to build or repair their homes or other necessities (Attempt against livelihoods)

- For accusing artisanal fishermen of "shrimp thieves", including nearby communities . (Slander Offending the honor of the people)

- For discriminating against local community members by accusing them to be thieves, and preferring to hire personnel who are not from the community. (Discrimination)

- Age Discrimination: For discrimination when there is an opportunity to work, by preferring to hire young people.

- For lack of compliance with agreements among others, for example: "For this group,” (But they do not specify for which group) there was a social commitment to throw larva to repopulate the sea, to provide employment, and 5% of their earnings in social works", but that is not fulfilled. (Lying and cheating))

- For acting with arrogance, while humiliating communities by not considering them in making decisions that may affect them. (Disrespect to the surrounding society)

2.3.2. Impacts on the Environment

- Mangrove deforestation due to establishment or expansion of shrimp farms

- Use of chemicals (Whose use is prohibited according to labels, such as muriatic acid (Audit does not declare the use of muriatic acid, which is forbidden to use in water sources).

- Poor handling of chemicals such as sodium bisulfite and chlorine among others, for not waiting long enough for them to be degraded)

- Decrease in some species such as bivalve molluscs, ("churrias", curiles) Crustaceans ... (by draining contaminated water used in farm operations directly to adjacent ecosystems)

- Use of numerous water suction pumps to drive it to the channels that supply the production ponds… but they also suck the aquatic biodiversity that is eliminated in the process). 

"Suction pumps of water and biodiversity from the estuary" and “Introduction of water and biodiversity to supply channel"

2.3.3. Recommendations of the Assistants to Workshop  

- That a buffer zone of the outside perimeter of the farm is established inward, and that the surveillance is carried out inside the farm. (This is a request made by fishermen for decades, but neither the GGM nor any other company has wanted to implement it)

- That the surveillance accompany the fishermen, and that they should be issued an identification card and that they fish during the day. (This may be a recommendation of the ANDAH, but the law requires fishermen to carry an official identification card, on the other hand, fishing in the Gulf of Fonseca, as in all estuaries or shallow coasts of the World, is performed according to the tides and not to the hours of the day or night).

- The fishermen recognize that there is shrimp theft, and recommend that a thorough investigation be conducted, so as not to raise false accusations. (This is also a request made by fishermen for decades, but neither the GGM nor any company have wanted to implement it).

2.4. ESIA: COMMUNITY WORKSHOP


 In the community workshop held in communities close to each shrimp farm, between December 2015 and January 2016 by the GGM consultants, they report the following perception of negative impacts:

2.4.1. Social Impact:


Violation of Human Rights and others, by:”

- By restricting access to the estuaries and mangroves adjacent to the limits of the farms.
- .For causing loss of access to fishing sites, and the distances to reach the few that remain are longer, because the GGM shrimp have appropriated large tracts of territory along the coastline, and not enable transit through the traditional routes that have been fenced).
- By restriction of artisanal fishing in the mangroves and estuaries near the farms; when some fishermen do they are mistreated or treated like shrimp thieves.
- By harassment of the security guards of the GGM against the fishermen in the mangroves and estuaries, breaking the nets with the powerful engines of their boats.
- By harassment of the security guards of the GGM against the fishermen in the mangroves and estuaries. The GGM has been linked to at least 2 murders.
- For violating the Human Rights of fishermen and communities by accusing without investigation and without proof all fishermen being "shrimp thieves".
- For causing loss of Food Sovereignty, by prohibiting, harassing or restricting the extraction of fish, crabs, bivalves and other foods in areas near the farms.
- For attempting against food and quality of life, by restricting or preventing the extraction of wood and firewood from mangroves, even though these ecosystems are not part of their concession and are from the State.
- For attempting to prevent community development. The GGM does not allow fishermen to make shrimp farms in other areas, but they themselves establish shrimp farms where they want and then take the permit.
- The hoarding or diversion or containment of water by all shrimp companies has had a strong impact for the fisherman and biodiversity because that water and fish no longer reach the few "winter lagoons" that have remained, and among other evils, with that the fishing time is decreased.
- By expansion on protected areas, winter lagoons or salt flats without timely environmental license. (This causes communities to protest publicly and massively).

Hoarding and transformation of "winter lagoons" in shrimp farms. In "El Tulito" near the GGM-CADELPA there is only the "La Alemania" lagoon that is threatened, and there are businessmen interested in developing the area for shrimp farming;

- When they harvest they throw the fish to the sea and they do not give it to the community
- Their cars at high speed raise a lot of dust, along the road in front of their homes.
- The streets are in poor condition due to the heavy traffic of the company's vehicles and they do not maintain them.
- They generate little employment affecting their economy, besides denying them permission to fish in the supply channels of the farms at the end of the harvest. (This would be a gesture of goodwill, a compensation measure and a show of corporate responsibility).

2.4.2. Environmental Impact:

Deforestation of mangrove forests, (impacts on biodiversity and food security of communities).
The majority of wild mammals and mangrove species have disappeared due to the destruction of wetlands and the misuse of chemicals (among other causes).
The birds inside the farms are killed by "lethal control". (The consultants include this complaint in their EIAS (Feb. 2016) but they minimize or conceal it stating that: "The GGM manages since 2015 the purchase of alternative technology to lethal control." (In September of 2018 it has not purchased it and continues with his lethal method.)
Pollution by direct drainage of water with chemicals (chlorine, muriatic acid, sodium metabisulfite ...) to the natural environment; When water is exchanged or when shrimp is harvested, contaminated water kills or scares the species in mangroves and estuaries. (Either they are drained immediately or the chemicals are not given enough time for their degradation.)
Contamination by direct drainage of waters used in production (sometimes causing eutrophication and massive fish deaths).
When the supply channels are dry they do not allow the community to take advantage of the fish or shrimp that are stranded in the puddles, but they treat them chemically to kill all the species. (Lack of corporate social responsibility)
The negative impacts perceived and printed in the ESIA are strengthened with the statements of government executives. Here are some examples taken from the b-EIA:

2.5. EIAS: "MINUTE OF INTERVIEWS WITH KEY INFORMANTS” (p-SIA)


- Mr. Miguel Suazo / HEAD OF THE ARTISAN FISHERIES DEPARTMENT; February 17, 2016:

…“On the positive side, employment and currencies are generated ... On the negative side, biodiversity is impacted because the mangrove area is a breeding ground for many species, for example the shrimp larva that spends a cycle of its life in these ecosystems ... to improve the shrimp farming, the Law on Fisheries and Aquaculture and the Law on Incentives for Fish Farming have been promulgated, but what is missing is to further technify the projects and reduce the impacts on the environment ... a new Management Plan comes along where we would have to see protected areas where these projects are developed, because unfortunately many protected areas have been impacted … 

(About shrimp theft)... "The estuaries must be freely accessible, there should not be any type of restriction or any law establishes it, there is a conflict between fisherman and aquaculturist .... "(...! The government is afraid to intervene and departs from the problem!)

- Ms. Carolina Cardona/ AQUACULTURE DEPARTMENT; Feb, 22/ 2016:
….”In the case that they do not let fishermen into the estuaries, that should not be, but it is because of shrimp theft ... We have been presented with complaints by fishermen that they want to enter but do not let them…

…In some shrimp farms that I have visited, I have seen that in the filters for water intake they use very fine meshes that look like mosquito nets and there a large amount of accompanying fauna is killed …”

2.6. EIAS: DIFFERENCES BETWEEN THE DATE OF PUBLICATION AND THE INTERVIEWS


The ESIA show on its cover as DATE OF PUBLICATION ON FEBRUARY 16, 2016.

The p_SIA in their section of appendices: "MINUTES OF INTERVIEWS WITH KEY INFORMANTS", SHOW THAT:
Mr. Miguel Suazo / HEAD OF ARTISAN FISHERIES DEPARTMENT is interviewed on February 17.

- - It also shows that Mr. Joaquín Romero, Manager of institutional and environmental relations of GGM and also Executive director of FUNDESUR, is interviewed on February 18, 2016. 
- ... and the MS. Carolina Cardona / DEPT. OF AQUACULTURE; she is interviewed on February 22. 

THE INTERVIEWS ARE ENHANCED 1, 2, AND 6 DAYS AFTER BEING PRINTED AND PUBLISHED!
“p-SIA dated February 16, 2016.” and “B-EIA, dated February 16, 2016. "

CHAPTER III


…."We demand employment from the shrimpers! ... They have come to take away our livelihoods, our mangroves, lagoons and estuaries ... now we can not work calmly in these places because they" shot "us by accusing us of thieves. We are not thieves ... They are the thieves who have come to steal our resources ... "

(Anonymous fisherman)

3.1. “RT” MEETING WITH FISHERMEN FROM COMMUNITIES CLOSE TO GGM
(2017 AND 2018)


“Fishermen denouncing their problems with shrimp farms of GGM / CADELPA."


In February 2017 the "RT" proceeds to confirm or dismiss the reports of the "Perception of Negative Impacts" section published in the ESIAs of February 2016. The "RT" proceeds to confirm whether the companies "or the time" have solved the impacts reported by fishermen or have improved some attitudes and activities in around the communities    . This investigation takes place in February 2017 and January 2018 and is confirmed with witnesses of the "International Ecumenical Observatory of Human Rights" in September 2018.

The results confirm those reported by the consultants in their ESIA, that is to say that the complaints are repeated and with some additions. Regrettably, these consultants, although they report the impacts, end up justifying them, minimizing them and eliminating them; On the contrary, the "RT" considers that such impacts are of great social and environmental importance and that they should not have been eliminated, but rather caused the suspension of the process of awarding the certification and logo, until the corresponding mitigation measures have been applied.

Below is a SUMMARY of the complaints obtained during field trips, during 2017 and 2018, during meetings with artisanal fishermen members of the communities studied by the GGM consultants. Some of the allegations include events that occurred in the 2000s but that fishermen consider important not to forget. They are ordered according to the perception of social, environmental and biodiversity impacts as indicated by the ASC and with our own comments in parentheses. 

The summary indicates date, location and number of people who were interviewed;

DATE LOCALITY No. OF INTERVIEWS
February 2017
El Tulito 11
La Cuchilla   5
Las Arenas   15

January 2018
Las Arenas.....18
El Tulito 17
Guameru y La Cuchilla 11

September 2018 
With the company of 4 members of DDHH Guameru, San Bernardo 17
El Tulito 34
Las Arenas 16
TOTAL INTERVIEWS 144



NOTE: Respondents are presented with the complaints compiled in the ESIAs and asked if they are true, if they have already been resolved and if they have other claims to make.



"Fishermen of the “Tulito” denounce their problems with the shrimp farms of the GGMSB".


3.2. “RT”: SUMMARY OF IMPACTS DENOUNCED BY FISHERMEN.

A list of fishermen's complaints reported by the consultants in the ESIAs is taken as a basis for consultation and fishers are asked if there have been any changes or if they have something to add. 


3.2.1. Social Impact

“Fishermen denouncing their problems with shrimp farms of the GMSB / CADELPA. "

VIOLATION OF HUMAN RIGHTS

For loss of access to resources: Since 2015, GMSB, with its new extension, has hindered movement with its new fence, restricts or prohibits the transit of fishermen to the estuary "La Barillosa" and further restricts fishing activity in other estuaries such as "Pedregal" and "El Garcero" 

..., Fishermen and other users have to travel along the seashore or through the large estuaries, which hurts them when the tide rises.

According to GGM companies, nearby communities and fishermen are thieves, but the company refuses to do the "exhaustive investigation" to verify its claims, which is being demanded by the fishermen.

There is a conflict between the guards of all the companies members of the GGM and the community, because in the swamps sail patrol boats with "hooded soldiers" (covering their faces), who harass them, cut their nets, or pass at great speed by them on purpose of causing them to capsize or intimidate them.

In the estuaries sail boats with company guards or uniformed military harass and demand to inspect the product of people who are fishing in the area.
Fishermen are also harassed in mangroves, crab pickers ("puncheros") and bivalve mollusks collectors ("curileros", clams) are forced to risk entering mangroves through difficult but more secure sites.

“The weapons handled by GGM / CADELPA are: R15, 30/30, M16”. (Weapons prohibited for military use?)

They indicate that they do not let the artisan fishermen fish because the safety boats bother them: It is always the same, they limit the access since they do not let them go fishing or to the shore. In the sector of GGM / Las Arenas, Mr. Juan Núñez was taken out of the estuaries when he was " cackling" (extracting bivalves) with his children.

The "security guards" of Las Arenas, threatened a fisherman because he was fishing at night, had to lift the trammel before his time and leave for fear of being shot.

The fishermen are afraid to go fishing freely, expressing that they have been threatened and cannot approach the "ñanga" (mangrove), which is a good place to fish, for fear of being shot.

Worse yet, the guards of GGM / Las Arenas for no reason caught two children of approximately 12 years old who were searching for seafood and were held inside the farm for several hours, being interrogated intensely and then left in freedom without any explanation or apology. The poor parents of the children felt powerless to bring accusations against them.

Artisanal fishermen say they have been threatened, they say they are not thieves, they do not have big boats, engines or cars that are essential for thieves. Thieves can infiltrate among honest fishermen but watchmen do not know how to distinguish them. The company has never done a thorough investigation to identify who the thieves are; the attitude of the government through the National Service of Health and Agric-Food Safety (SENASA) is suspicious because it knows the problem, and they know that the stolen shrimp is transported to the port city of San Lorenzo but they do not act.

The fishermen recommend that the company fix the situation of "security" with the fishermen, they say they have never had a dialogue with any high representative of the shrimp farm, and that they have been threatened with removing their nets or shooting them.

Revenues in the community, after the farm began to operate have worsened, because they can no longer fish in the estuaries or in the mangroves near the farm, they have lost access to mangroves and estuaries.
There is conflict between the GGM and the fishermen due to the harassment and lack of respect towards the fishermen by the vigilantes.

The community of El Tulito accuses GGM / CADELPA of having cheated them by asking permission to open a well and extract fresh water from the well of their community, in exchange for installing the pipe to their homes but the company did not comply with their stated promise. They no longer want CADELPA to continue to draw water from their well, for having cheated them and do not receive help from it.

GGM / CADELPA offered to manage a "posta" (house with military) to safeguard the security of the settlers; nobody signed a paper that would guarantee that the community agreed with said "post", which is now installed, at the entrance of CADELPA. The fishermen no longer want this "posta", because it only serves to take care of the farm and harass them by checking them hostilely when it passes near the entrance. (The military is paid by the people to "take care of peace, sovereignty and alternation in power", which they do not comply with, but they do obey the businessmen, which is illegal and unfair). During the interview the fishermen comment that things are getting worse since the Post was installed there is no pass even for the neighboring shrimp farms; The fishermen cannot reach the other estuaries and cannot walk near the post. They can go to the estuary called El Pedregal because they leave by the lagoon called Germany that is the only lagoon that has not been destroyed and is free at the moment.

In the village of El Tulito, close to GGM / CADELPA, fishing still takes place in the area's last "winter lagoon", "La Alemania", but unknown investors are coming to inspect it.

The limits of the "vigilance" of the GGM extend from the perimeter borders to the mangroves and estuaries. That is, they exercise property rights beyond their concession limits.

In many areas within the mangroves fishermen can no longer make their temporary fishing camps for several days because they are prohibited, (which implies eviction)

In other areas they are not allowed to extract firewood, timber, wild animals, among other benefits of the wetlands, (which means dispossession).


The perimeter borders of the GGM / GMSB that are to the east of the farm are far from the San Bernardo estuary and the fishermen can go fishing there almost freely, (which shows that a large buffer zone avoids conflicts and thefts) But on the west side, the perimeter borders are very close to the stream El Pedregal and surrounding smaller ones so the GGM / GMSB is exposed to theft because it has few buffer zones and its solution is to restrict, prohibit or harass all who approach.

In some shrimp farms like GGM / CADELPA, they force workers to buy all the things from the shrimp store, so they do not contribute to community trade. 

USURPATION OF RIGHT

Fishermen say they do not know the NGO FENAPESCAH, since no representative of that organization has come to the communities to dialogue with them; They do not know who Mr. Felix Paz (leader of the group) is, who has not met with the fishermen of the communities either. (However, it is included by the GGM consultants as recipient of the ESIA studies and as a representative of the fishermen of the area in a "participant in the Audits" condition, usurping the right of genuine fishermen and conveniently serving the GGM).

(INTERESTING FACT: The President of the National Congress, pressured by fishermen during a propaganda tour prior to presidential elections, was forced to declare having given 20 million Lempiras (US $ .850, 000.00) to FENAPESCAH to channel it to the fishermen, but after of 3 years, these have not seen that money. 

(¡An investigation into this type of "hoarding" of financial resources is urgent”!).

USURPATION OF AUTHORITY: The fishermen do not agree with the use of a “License” issued by the shrimp farms (this is usurpation of authority) because they are not an authority and because the license is issued by the Directorate General of Fisheries.

A fisherman cannot fish only during the day (as recommended by the Regional Workshop where ANDAH participates) because fishing in shallow waters of the Gulf is governed by the tides). 

JOB: 
¡“We demand employment from the shrimpers! ... They have come to take away our livelihoods, our mangroves, lagoons and estuaries ... now we can no longer work in these places because they "shoot" us by accusing us of being thieves. We are not thieves ... They are the thieves who have come to steal our resources…”

The communities near the farms complain of lack of employment, and the fishermen lose their sources of work in the wetlands, snatched by the shrimpers.

The few jobs they offer are given to young people by discriminating against adults and old people.
When they have established or expanded they have promised employment, aids in Health (latrines), Education (classrooms), drinking water, etc. And they do not comply or they do little.

The workers of the companies that have work contracts in writing, work from 06:00 to 18:00, and the extra hours are paid with a holiday day. Every year they make new contracts, they do not pay for the months they do not work and they lose seniority rights. (What will become of them when they are dismissed or if they reach old age without retirement?).

It is not allowed to organize in Trade Unions.

BUSINESS RESPONSIBILITY: The GGM farms do not share with the community the shrimp and fish that remain in the left-over pond puddles inside the farm after the harvests, they prefer to kill them with the chemicals they use in the lagoons. Sometimes they give them to the workers or to the executives and their friends.

Some companies promised to give them a supply channel to fish after the harvest and do not comply.
Foreign people come to the farms to fish in the supply channels, until they make "tours" with tourists charging the entrance, (but the communities deny them this right which is also a measure of compensation for the damages that the company causes them).

Those who fix some schools, make stoves and latrines is FUNDESUR. Because CADELPA does not cooperate with the community; It takes away responsibility for the problems of the community, sending them directly to FUNDESUR, which currently finances part of the construction of ecological stoves, but with financial support from a German international NGO and the community.

The problem of dust and mud in the communities persists due to the intense traffic of the shrimp farms and their lack of responsibility in repairing them, thus harming the communities.

WORKSHOPS: The GGM consultants only gave one workshop to each group of communities and did not meet again to discuss the results, they simply handed over two books (ESIA) to the president of the Board, without being subject to discussion with the communities that attended. They simply delivered them and left...

3.2.2. Environmental Impact 


DEFORESTATION: Deforestation continues. Shrimp farms destroy mangroves to make drainages and channels. GGM/GMSB has also done it to expand as it did in 2015 in "Posta 01" next to the shrimp farm “Hondufarms”.

POLLUTION: They continue to throw contaminated water directly into the natural environment. (Almost all of the GGM lacks oxidation lagoons).

They continue to use chemicals, which are released immediately after using them or without giving them the necessary time to degrade. For example, in most cases the Sodium Bisulphite mixes it with ice, and ending the harvest, they empty it directly through the drainage channels, which kill the species that are outside. 

If these waters splash the operators, sodium bisulfite causes them to itch, lose their skin and cause nosebleeds.

Operators only use masks as protection when they apply the chemicals, whose contaminated water drains mangroves and estuaries, killing fish, crustaceans and other animals in their journey.

They continue to use strong chemicals to kill the "phantom shrimp" and other species; Sometimes they do not give the chemicals enough time to dissolve and they drain it directly into the estuary, killing everything in its path.

When they harvest the shrimp, the fish that remain in the lagoon are not left for the community, but they put a chemical to make the fish die, they open the floodgates and everything goes to the gulf affecting other species. Other times, before adding, the chemical, they capture the fish and distribute them among the operators or executives of the GGM.

In the farms there is no treatment system for the waters that drain into the estuaries, the water from the shrimp farms drains directly into the estuaries. (some fishermen estimate that after more than 40 years GMSB has begun to make some oxidation lagoons in the new expansion)

BIODIVERSITY LOSS: According to the complaints in the ESIAs, the GGM continues to scare the birds with fireworks and the ducks and other species kill them with shotguns. (That is to say that the "lethal control" continues and the Audit informs only of the "use of noise"”).

Loss of bivalve molluscs, fish, crustaceans and any animal that lives in mangroves or estuaries near the drainages, due to pollution.

The fishermen insist that the decline in fish, crabs, curiles (type of local mollusc), etc. continues, due in large part to the chemicals that shrimp farmers throw into the waters, which impacts their diet and income.

Fishing continues to decline because, among other causes, large pumps suck small species into the supply channels of the farms.

In some "nurseries of larvae and reproducers" they feed the shrimps with Bivalves bought from the fishermen (mussels, churrias and curiles). (The fishermen do not know who the owner of the nursery is or if they sell them to the GGM. (Among those who buy these bivalves is the nursery "Oro larva”)
"Fishermen denouncing their problems with GGM shrimp farms."


3.3. ORGANIZATION OF HUMAN RIGHTS: CONFIRMATION OF COMPLAINTS OF FISHERMEN

Officials of "RT" and "DDHH"

INTERNATIONAL ECUMENICAL OBSERVATORY ON HUMAN RIGHTS

HUMAN RIGHTS REPORT, ON THE SOCIAL AND ENVIRONMENTAL BEHAVIOR IN THREE SHRIMP FARMS OF THE "GRANJAS MARINAS SAN BERNARDO GROUP”

CONSIDERING: That   the International Ecumenical Observatory of Human Rights ("OEIDH" for its acronym in Spanish) is a non-governmental, non-profit project that ensures compliance with and respect for the human rights of individuals.

CONSIDERING: That Human Rights are inherent rights of all human beings, without any distinction of nationality, place of residence, sex, national or ethnic origin, color, religion, language, or any other condition. We all have the same human rights without discrimination.

CONSIDERING: That there are national heritage and assets of public domain, the hydrobiological fishing resources contained in the bodies of water, located in the territory of the State of Honduras and in other spaces where it exercises sovereignty or holds rights. it is the responsibility of the State to exercise the faculties of the domain of the hydrobiological resources through the planning, ordering, regulation of its protection, use and management. The state rector in these areas is absolutely non-delegable and inexcusable. It is recognized the use in private areas of hydrobiological resources under controlled management for fishing and aquaculture is subject to licensing and the granting of spaces when it occurs on national lands.

CONSIDERING: That fishing activity may be carried out by Honduran individuals or legal persons legally incorporated in the country.

CONSIDERING: What is meant by Artisanal Fishing: Fishing activity carried out in the coastal belt in smaller vessels, without navigation facilities, applying low-tech fishing methods and implements.

CONSIDERING: That, the Subsistence Fishing: is the one destined to the feeding of the family, of the coastal towns, the exchange of those products without mediating act of profit

OBJECTIVES OF THE OBSERVATION TOUR:
Visit three shrimp farms of the Granjas Marinas San Bernardo Group (GMSBG), to appreciate their social and environmental behavior and the respect of the human rights of the fishermen who live near the farms or who work in the mangroves, estuaries and farms near them.

To appreciate if the denunciations made by the fishermen and compiled by the Biologist Jorge Varela and Martha Varela in February of 2017 and January of the 2018 and assure that they are in conformity with the reality.

Support any binding dialogue on the human rights of fishers of the Gulf of Fonseca between fishermen, GGMSB and others.

3.3.1. COMMENTS ON THE GMSBG: GMSB, CADELPA AND LAS ARENAS:

3.3.1.1. GGM / GMSB

"Human Rights Officials Documenting Complaints"


Guamerú, Municipio de Namasigue, Departamento de Choluteca.
September 3, 2018
Time: 10:00 a.m. to 12:00
Assistance: 17 people

After a visit in the company of a team of Defenders of the environment composed by:

MARTA LIDIA MARADIAGA, GERSON JOEL AGUIRRE AGUILERA, ELSA JANETH ESTRADA belonging to the International Ecumenical Observatory of Human Rights; led by biologist JORGE VARELA and in direct contact with fishermen from the community of Guamerú, the existing concern caused by the social and environmental impact that the activities undertaken by the large shrimp companies of the Granjas Marinas San Bernardo Group (GGMSB) to which the companies farms: Granjas  Marinas San Bernardo (GMSB), CADELPA and LAS ARENAS, among others, were discussed; It is our duty as faithful defenders of human rights, to ensure respect for the human rights of the most vulnerable people. In this sense we observe and document:

The Participatory Methodology applied in this consultation by the biologist Jorge Varela to the attendees, residents of the area closest to GMSB consists of:

a) Invitation to fishermen for the consultation meeting
b) The biologist used a laptop to project and expose the complaints collected among residents of "La Cuchilla" in February 2017; and from "La Cuchilla", San Bernardo and Guamerú in January 2018.

c) At the beginning, the biologist explains to the attendees that at any time, they can interrupt to correct, request clarification, modify or cancel any complaint that has not been well interpreted and copied or that they do not agree with it. Inclusive can propose additions
d) Video of the participations is taken
e) Finally, complaints can be denied, modified or reconfirmed.

CONCLUSION:
The fishermen's complaints done in february 2017 and january 2018 are confirmed by the assistants, who at this september meeting of 2018 add other complaints, inclusive threaten with the taking of the access to the finca GGMSB.

WE OBSERVE:

FIRST: The company Granjas Marinas San Bernardo (GMSB), dedicated to the field of shrimp farming in the area of San Bernardo, La Cuchilla, Guamerú, Costa Azul and Playa Negra, in the municipality of Namasigue, Department of Choluteca, Honduras, has had an excessive expansion of its shrimp lagoons, as explained by fishermen and citizens of the Guamerú area, the shrimp company has been granted the right to expand their lagoons in areas that previously the residents of these communities could freely carry out their artisanal fisheries that allowed the subsistence of them and their families.

SECOND: According to the fishermen and neighbors of these communities, the right to exploitation of the areas that for decades has been of national utility, as a public good, has been lacerated by these shrimp companies that have prohibited or restricted access to mangroves, "Playons" and estuaries and therefore puts at risk the subsistence, quality of life or welfare of the coastal communities.

THIRD: It is of great concern what is reported by the fishermen and neighbors who suffer from the great pollution of the estuaries, since such companies do not have sedimentation systems in their lagoons, they do not give the chemicals enough time to degrade and they drain their contaminated water directly into the mangroves and estuaries, which cause irreparable contamination to the maritime territory, causing the death of aquatic beings due to the strong use of destructive chemicals in the environment. Some fishermen say that the new expansions do have oxidation lagoons, but the old expansions are the most extensive.

FOURTH: The fishermen denounce that even now GMSB scares the birds with fireworks and eliminates them with lethal weapons.

FIFTH: The artisanal fishermen denounce that they have lost free access to estuaries, swamps and mangroves due to the strong repression they experience and suffer under GMSB, which has placed security fences, and contingents of heavily armed people, with high caliber weapons (who claim to be members of the Honduran Naval Force, which is a crime of usurpation), who patrol the aforementioned public sites and intimidate, compel and coerce the fishermen, depriving them of a source of food, firewood, or wood and other benefits that these ecosystems provide for their families, and that these companies in an inhuman way have appropriated such spaces that are not part of their concessions, destroying in this way the means of subsistence and quality of life of these people.

SIXTH: It is testimony of the fishermen, the lack of interest on the part of the governmental entities, since they declare to have presented the corresponding denunciations before these organs, which have ignored the clamour of these citizens who ask for their right to subsist through fishing and mangrove resources.

SEVENTH: Like a deception the fishermen classify the actions of Granjas Marinas San Bernardo (GMSB) since this company, after the harvest of the shrimp, extracts the fish that remain in the puddles of the pool to be buried and wasted, preventing the inhabitants from accessing them, or in other cases harvest to distribute them up among the operators or executives. They also report that at one point the company made a collection of signatures in the communities declaring that the purpose was to establish a system for the distribution of the fish extracted after the harvest of the shrimp. But this was a deception according to the fishermen, who feel cheated because the list was not used for the stated purpose but used for a totally different action that is considered as unjust and inhuman, burlesque and illegal. (The marine biodiversity in eggs, larvae or juveniles are sucked by the water supply pumps to the lagoons, so as a measure of compensation or corporate responsibility should give them to the community).

EIGHTH: Since its beginnings in the area, the company Granjas Marinas San Bernardo (GMSB) promised the community's inhabitants to support the development of the communities, promises that have been forgotten by neighbors, have been deceived, restrained by their rights, intimidated. Two of the attendees said that GMSB had supported them with the construction of a Kindergarten and improvement of the School, which in addition to being questioned by two fishermen, represents an insignificant help, especially considering that the GMSB shrimp farm is perhaps the largest shrimp farm in the world and compared to the millions of dollars in profits generated by the production and commercialization of shrimp for more than 30 years.


REPORT


3.3.1.2. GGM / CADELPA


El Tulito, Marcovia Choluteca
September 3, 2018
TIME: 2:30 p.m. to 5:30 p.m.
Assistance: 35 people

"DDHH documenting interviews"

In the same way, we proceeded to visit the community of El Tulito, municipality of Marcovia, Department of Choluteca, several interviews were held with community residents and fishermen to discuss the social and environmental impact of the company CADELPA / GRANJAS MARINAS SAN BERNARDO GROUP (GGMSB / CADELPA) and its relation with respect to the human rights of the fishing population.

The Participatory Methodology used by the Biologist Jorge Varela is the same as that practiced in GMSB, LAS ARENAS and CADELPA.


CONCLUSION:
The denunciations of the fishermen made in February 2017 and January 2018 are confirmed by the attendees who at this meeting in September 2018 add other complaints.

OBSERVATIONS:

FIRST: The enlargement of the lagoons of the marine farms group has been a problem for the community, since the source of food and subsistence of the inhabitants has been affected by not having access to the estuaries or the fishing banks, making it impossible the activity of artisanal fishing. CADELPA denies or restricts community access to the fishing area, and they only have to reach them nia the only gap fortuitously left that is the lagoon of “La Alemania”.

SECOND: The GGM farms, have made promises of help for the community, promises that are only in words, such a community does not have a potable water system that guarantees healthy subsistence, the shrimp group has repeatedly promised to the residents to carry out the drinking water project. In this community there are two water wells, one that uses the community and another very close that the community authorized CADELPA in exchange for the installation of drinking water, which the company did not comply. Said well is sealed and is for the exclusive use of the shrimp company, it is for this reason that the inhabitants are totally dissatisfied.

THIRD: The strong military vigilance, and people of private surveillance, that in total give support to the shrimp company is an unacceptable practice against the inhabitants, which in reality equates to intimidation, violation of the right to free movement, as reported by the settlers. In an agreement with the community, the Marine Farms Group agreed to build a police post on the grounds that the primary objective was the protection of the population of the community, the villagers report that it was a terrible deception since the security post has only come to intimidate, violate rights, coerce fishermen by forbiding them to transport wild shrimp that they take out of the estuaries. Nobody signed any agreement on the matter and questions why the military, as an institution the State and paid by the taxpayers, offers their surveillance services to a private company.

FOURTH: The inhabitants of the community relate the stigmatization that has been made by GGM , labeling them as thieves, a title that has been the justification for harassing them in general in the mangroves and estuaries in a clear violation of human dignity.

FIFTH: The fishers and the general population were consulted about how the shrimp group treated the fauna and flora that surrounds its lagoons, their responses were disappointing. It is alleged that the shrimp company drains their ponds directly to the estuaries, including the chemicals implemented in their shrimp ponds, which end up going into the lagoons, thus destroying marine life, it was also reported that the company uses shotguns for the annihilation of birds such as ducks, herons, and other birds that inhabit and frequent the coastal and marine areas.


SIXTH: Regarding the care of the workers, it was said that the shrimp company does not provide a protective clothing for the workers, the direct manipulation of chemicals is a real practice in the company, we could observe the hands of some workers of this company. Who were denoted the physical abuse of the skin because the company does not offer them protection."

REPORT

3.3.1.3. GGM / LAS ARENAS


Las Arenas, Marcovia
September 4, 2018
Time: 09:00 to 12:00
Assistance: 30 people (16 inside the house of the President of the Board and 14 more outside).



In a meeting with more than thirty (30) fishermen and the general population, information was collected regarding the social and environmental impact of the shrimp GRANJAS MARINAS GROUP in the community "Las Arenas", where the shrimp farm of the same name is located (GMSBG / LAS ARENAS) community of the municipality of Marcovia, Department of Choluteca, the interviews are reflected literally in this document:

The Participatory Methodology used by the Biologist Jorge Varela is the same as that practiced in GMSB, LAS ARENAS and CADELPA.

CONCLUSION:
The fishermen's complaints done in february 2017 and february 2018 are confirmed by the assistants who at this september meeting of 2018 add more complaints.

OBSERVATIONS:

FIRST: GGM, is a company violating Human Rights, as reported by the residents of the community, since it restricts access to the mangroves and estuaries that are the source of subsistence for the villagers who use artisanal fishing for their survival.

SECOND: The strong presence of security agents hired by GGM, and the excessive use of force by the security guards who have resorted to the intimidation and coercion of the fishermen, and the destruction of fishing material. According to reports by the fishermen themselves, the security personnel of the shrimp group has destroyed the fishing nets of the fishermen as a measure of intimidation so that the citizens of the community desist from the fishing activity.

THIRD: The use of high-caliber firearms is the intimidating tool for fishermen not to go to the estuaries to do their fishing, according to the fishermen many of them have abandoned their boats and all their belongings, due to intimidation that they have themselves suffered by the actions of the security agents of the shrimp company.

FOURTH: The violation of human dignity, the violation of the rights of the child, as reported by fishermen: The shrimp company GRANJAS MARINAS, outrages children under age who work with their parents in fishing. As reported by Mr. Juan Núñez, minors Ivan Rodríguez Núñez, 14, and Humberto Rodríguez, were physically abused by the security guards of the shrimp company.

FIFTH: All fishermen have been stigmatized; the shrimp company treats them as thieves, thus violating the right to dignity and honor of the people, this is a natural practice of the company to avoid contracting the inhabitants, and / or attribute production losses or theft to them allegedly in complicity with the company. The company brings workers from other places. The real thieves walk with powerful weapons and high horsepower engines, while the fishermen ose small and rudimentary boats. Fishermen have long demanded serious and exhaustive investigations into the theft, but corporate executives do not agree to this.

CONCLUSIONS:

From the field work that was carried out in the communities we visited, we concluded:

- GRANJAS MARINAS SAN BERNARDO GROUP, is a company that violates human rights, which puts at risk the food security of people residing in communities near the company, due to the violation of the right to free movement violation to the rights to enjoy the national assets (the estuaries, beaches, national fishing banks), which the fishermen suffer, this causes a detriment to the standard of living of the people who resort to emigration from their coastal villages.

- The fishermen suffer persecution by the company, as a common denominator in all the communities visited, the excessive use of high caliber weapons, destruction of fishing material, property of the fishermen, are practices that violate the rights of the people.

- The fishermen suffer persecution by the company, as a common denominator in the communities visited we receive complaints about the excessive use of high caliber weapons, destruction of fishing materials and personal property of the fishermen- all of these are practices that violate the rights of the fishermen. 

- The shrimp companies, through their practices that harm the environment, are destroying marine life, because their harmful effluent discharges reach the estuaries directly, most do not have oxidation lagoons and the chemicals used end up contaminating the water of the estuaries, therefore causing death to marine life and threatening biodiversity.

- .It is also worth mentioning about the practice applied to the killing of aquatic birds by the company by using shotguns to kill ducks, herons and other animals that frequent the extensive concessions.

- The places where the multimillion-dollar shrimp business has its lagoons, are impoverished places, there are no significant sources of employment, nor enough subsistence resources, since the GGM does not promote economic development for the people who day after day have to abandon their villages that for years have been home and provided a means of traditional livelihood from generation to generation.

SUGGESTIONS

From the International Ecumenical Observatory of Human Rights we suggest:

- That the state bodies that oversee the defense of Human Rights perform periodic audits in the shrimp group facilities, lagoons, communities, mangroves and estuaries, to prevent violations of the human rights inherent to the human person. 

- That due judicial process be given to cases of violation of human rights by "Granjas Marinas San Bernardo Group". 

- Pledge to support of international organizations that ensure the protection of human rights and the environment, which are the most violated by the "Granjas Marinas San Bernardo Group". 

- Set frequent relations by the GGM with the inhabitants of the communities neighboring its lagoons. 

- Immediately establish a binding dialogue between the GMSBG, fishermen, human rights defenders, the intellectual author of the designation of Ramsar Site # 1000 and Protected Areas as a recognized defender of artisanal fisheries and biodiversity in the wetlands of the Gulf of Fonseca, and other entities genuinely interested and competent.



(SIGN WITH SEAL IN SPANISH VERSION:)



     Carlos del Cid                                     Martha Lidia Maradiaga
National Coordinator         Regional Coordinator


3.4. SUPPOSED DISREPECT TO THE LAWS OF HONDURAS


Some articles of the Constitution of the Republic allegedly violated by the GGM:
Article 59: The human person is the supreme end of the Society and the State. Everyone has the obligation to respect and protect it. The dignity of the human being is inviolable. 
Article 60: Any discrimination based on sex, race, class and any other (age) that is harmful to human dignity is declared punishable.
Article 61: The Constitution guarantees Hondurans and foreigners residing in the country the right to the inviolability of life, to individual security, to freedom, to equality before the law and property.
Article 65: The right to life is inviolable. 
Article 66: The death penalty is prohibited.
Article 68: Everyone has the right to have their physical, psychological and moral integrity respected.
Article 70: No person can do justice by itself, or exercise violence to claim their right
Article 76: The right to honor, personal, family and personal image is guaranteed. 
Article 81: Everyone has the right to move freely, leave, enter and remain in the national territory.
Article 84: No one may be arrested or detained except by virtue of a written mandate from a competent authority, issued with the legal formalities and for reasons previously established in the Law. However, if the offender is caught at the same time he commits the crime. may be apprehended by any person for the sole purpose of handing it over to the authority.
Article 107: of the Constitution 
Article 347: Food rights

“Article 66. The death penalty is prohibited. Yelson Garcia (17 years old) Another murder unpunished? "


OBSERVATION: These Impacts, together with those recorded in the ESIA, are sufficient to postpone the Certification and the ASC logo. This presents a great opportunity to demand a solution to the situation GGM / fishermen and environment, before giving continuity to a commercial relationship with the aquaculture product endorsed by an "ASC Seal”.

CHAPTER IV


“The Shrimp Certification "is done to clean up the image of destruction, contamination, death and violation of Human Rights, left by the shrimp farms in the Tropical and sub tropical zone of the Planet" ...

(Civil Society in the "Shrimp Aquaculture Dialogues" (Shrimp Aquaculture Dialogue, Shad / 2007) that led to the creation of the ASC).


4.1. DEFINITION OF ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND FAILURE OF APPLICATION IN THE ESIAs.


The Environmental and Social Impact Assessment Studies (ESIA) of the GGM or do not find any impact caused by the GGM or do not meet the definition of the "International Association for the Impact Assessment" (IAIA, 1999) (http: //www.iaia .org), which defines an environmental impact assessment as:

"The process of identifying, predicting, evaluating and mitigating the biophysical, social and other relevant effects of development proposals before making important decisions and making commitments."

The GGM ESIAs are untimely because they are carried out on projects already established and in full operation.

They "identify" but do not "predict" the impacts, which have already been presented and many continue to occur; the worst is that by "evaluating" the current social and environmental impacts, they are minimized to the point of concluding that they do not merit "mitigation" measures”.

The "biophysical and social effects, are considered at the end of the process of Environmental and Social Impact Assessment (ESIA)," of little importance, do not merit corrective measures and can be solved by themselves or in a short time "... which is why GGM don’t make decisions or assume commitments in this regard.

Logically, a "Monitoring" calendar is not prepared, so it is not known "how and with whom actions are implemented and monitored to meet social and biodiversity objectives"; There are also no proposals for Control, Mitigation, Monitoring and there are no objectives to achieve. 

With the exception of one shrimp farm, neither the b_EIA nor the p_SIA, nor even some "Opinions" very convenient for the GGM, on behalf of the government Institute of Forest Conservation Protected Areas and Wildlife (ICF), neither presents the date of establishment nor expansion of each farm, so the EIAS "do not provide reliable information and interpretation of the ecological implications of the project from its inception to its operation". Thus, very conveniently, the GGM "does not make any important decision or assume commitments", and for this the socio-environmental situation persists to the detriment of a social sector of the population, of the environment and favorable to the GGM.



CONCLUSION:
After two years of having been awarded the ASC Seal, allegations of human rights violations and impacts on the environment persist, which indicates that the ASC does not fulfill its purpose of guaranteeing the best social and environmental conditions in the operations of its clients, least in regard to artisanal fishermen.

Only if the GGM works perfectly at 100% can it be believed that it does not generate any impact. 

The "Environmental and Social Impact Assessment Studies" (ESIAS) seem do not meet the requirements of their definition established by IAIA in 1999, and include many mistakes, so it is perceived that they are not reliable, do not meet the definition of Impact Evaluation and do not can contribute to approve an Audit that deserves the Certification and the Green Seal according to the ASC Standards.

4.2. AUDIT


The audit documents of the GGM companies are analyzed, which are based on the information that comes from the ESIA and maybe from some field observations.

The Sub title of the topics analyzed by the Audit is placed in bold type, and its text is enclosed in quotation marks (" "). And then our COMMENT:

OF THE METHODOLOGY
…“Control Union Peru (CUP), a member of the "World Union Control Group" is an inspection and certification body and is accredited by ASI on behalf of the Aquaculture Stewardship Council (ASC) to carry out inspection and certification in accordance with certification standards for ASC farms”. 

“Based on the information provided by the auditor and the client, the certifier reviews and evaluates all the information provided and certifies the products when all the conditions of the regulations are met. The result of the evaluation is documented in Chapter 7. Audit work by the auditor and certification by the certifier are clearly separated activities”.

COMMENT: The information provided by the client and the Auditor is mainly based on the Social, Environmental and Biodiversity Impact Assessment Studies, (p_SIA and b_EIA respectively) which, as has been demonstrated, suffer from the faults already indicated and from others that we have not aimed at not making our appreciations more voluminous. 

Apparently, there is no capacity to review and evaluate all the information provided in the b_EIA and p_SIA (ESIAs). The "Non-conformities" of the fishermen and environmental damage and biodiversity as well as ecological footprint, are ignored and in the end the Certification is reduced to mentioning two "minor non-conformities" related to administrative work aspects within the GGM company such as: 
1. "Maintain the wage payment receipts, signed by the workers "and... 
2. " In some of the verified cases, overtime exceeds 12 hours”.

Of the social, environment and biodiversity that are the essence of the ESIA do not mention any "Non-conformity", No impact! ... so, or has not made a good process towards the Certification or the GGM deserves a prize international environmental and social, for not causing any impact with the operation of more than 8,000 hectares in production.

Thus, the Certifier concludes that: "After the review of evidence and action plans for non-conformities, it is decided to grant the ASC certification.”

REPORT: 
“This certification report is made in accordance with the ASC Certification and Accreditation requirements, Version 1.0, Appendix C.”

COMMENT: The theoretical steps indicated by the ASC have been followed, but its Criteria have not been fully met, as has been demonstrated in the analyzes on the ESIAs, and as shown later

…” there is no water treatment through sedimentation ponds prior to discharge to the estuary” …

COMMENT: ¡RIGHT! but he does not give any recommendation about it. It is inadmissible that after more than 40 years of having settled in Honduras the first shrimp farm, is still releasing untreated water discharges into the natural environment ... Is it possible that more than 8,000 Hectares containing "sewage" are discharged into the natural environment without causing an impact? ... Is this not an attack on the environment and biodiversity that they receive those waters and reason to postpone the ASC Certification?

“The BEIA and the PSIA were prepared by qualified experts and financed by the IDH (The Sustainable Trade Initiative) and the process monitored by the WWF (World WildLife Foundation) "…

COMMENT: The faults that are shown in the ESIA question the effectiveness of the contracting mechanism of the consultants by the same company that they are going to evaluate and puts in doubt the effectiveness of the Supervision by the WWF (World Wildlife Found).



SUMMARY: 

COMPLY WITH ALL APPLICABLE NATIONAL AND LOCAL LAWS AND REGULATIONS
“San Bernardo complies with all legal requirements related to the environment, work, commercial management and animal welfare”. 

COMMENT: The background shows that San Bernardo has not always complied with all the "legal requirements", particularly during its extensions;
The lack of interest in "animal welfare" is shown by the "lethal control" and the discharge of water to nature without prior or effective treatment.

In a country where high degrees of corruption are manifested, large companies constituted by powerful politicians, former presidents, officials, bankers, national and international businessmen, etc. as could be the case of the GGM, it is easy for them to accommodate the measures, policies and laws to their interests, as can be seen in many shrimp farms with the harassment of fishermen; the impunity manifested in the case of Environmental Licenses after being extended; with the unpunished killing of fishermen; with deforestation in flagrant violation of the Law on the Strengthening of Shrimp Farming, the Fisheries and Aquaculture Law among many examples. 

The consultants do not mention the case or the final result of the fine imposed on the GGM in 2012 with a fiscal requirement for its general manager, a case that is still unpunished when the ESIAs are drawn up and which still persists in 2017.

LOCATION IN ENVIRONMENTALLY APPROPRIATE SITES WHILE CONSERVING BIODIVERSITY AND NATURAL ECOSYSTEMS OF IMPORTANCE. 

COMMENT:
a) When the B_EIA is done, all GGM farms have been located and expanded; biodiversity has been impacted and important natural ecosystems have disappeared. For this reason the ESIAs do not meet the definition of the "International Association for Environmental Impact Assessment" (IAIA, 1999) 
b) The Auditor is not aware that even conservation measures of biodiversity or natural ecosystems are not suggested.

… “Although the farm is located in protected areas and critical habitats for endangered species” …

COMMENT: They accept that "the farm is located in protected areas and habitats critical for endangered species." But, GGM proceed to use government institutions such as the ICF and its "Opinions" to justify interventions on these areas. 

…” there is the technical decree DAP-059-2014, in which on April 30, 2014 ... to perform a cross-check and define the San Bernardo farm…”

COMMENT: There is no "DAP-059-2014 for San Bernardo farm! 

…” the ICF Decrees for other shrimp farms indicate that the farms were established before the Declaration of Protected Areas …”

COMMENT: Another false appreciation: This is an inaccurate statement of the ICF because its Opinions do not specify the date on which each shrimp farm is established and that disqualifies them, since there is no comparison term between a before and after the establishment of said Areas. The ICF Opinions also do not indicate the dates of farm expansions.

…” Only shrimp farms are located in the area, no agricultural activity in the surrounding areas, saline soils is the main feature of this environment”.

COMMENT: It is tendentious to ignore that the GGM farms are surrounded by a saline or hyper saline environment in which conditions for agriculture are almost impossible.
  It is an insult to consciously ignore the most dynamic economic activity in the surrounding areas of the GGM shrimp farms, such as artisanal fisheries! and the activity of collecting bivalves, crustaceans, wood, firewood, etc.- that occurs in the mangroves, and the fish that occurs in the estuaries and in the few lagoons that still exist. The auditor insists on ignoring the existence of such an important item in the economy.
DEVELOP AND OPERATE FARMS WITH CONSIDERATION FOR THE NEIGHBORING COMMUNITIES

… “In some shrimp farms more than 50% of the workforce comes from the district of San Bernardo. In interviews with the representatives of the community there were no comments on conflicts and that the relationship between the San Bernardo farm and the communities is positive.” 

COMMENT: It seems that the Auditor does not read the complaints compiled in the ESIAs, and that they are confirmed by the RT in 2017 and 2018. A proof of the lack of appreciation of the Auditor is observed in the information offered by a national newspaper called "La Tribuna" of the August 01, 2017. 

“Authorities mediate in conflict between shrimpers and fishermen of Choluteca”



OPERATING FARMS WITH RESPONSIBLE LABOR PRACTICES

COMMENT: Due to the strict control measures in the shrimp farms and the aggressiveness of their guards, the RT could not be investigating inside the farms. 

Employees of farms still outside of them, refuse to give interviews for fear of their bosses.

When we tried to take pictures of the entrance to Granjas Marinas San Bernardo, a tanker truck was placed in front of us so that we would not do it, and then we were verbally assaulted by the armed guards who approached us screaming in a threatening and aggressive manner. With these conditions, it was decided not to ask permission to go to dialogue with executives of the company. A fisherman who accompanied us commented: "notice how they have treated you in public and think about how they treat us when we work among lonely mangroves or estuaries” …  

“Tank truck standing in front of GMSB sign to prevent photographs.”


MANAGE THE HEALTH AND WELL-BEING OF PRODUCTION IN A RESPONSIBLE WAY
“The control of predators is made by noise that frightens with a device with compressed air that produces a sound as a weapon which scares off birds” … 

COMMENT: The above is not a verification of the Auditor but is an explanation of the EIAS consultants on "lethal control" to justify that: "GGM, has handled the problems of shrimp predators selectively and until recently "Used pyrotechnics and metal pellets" ... the denunciations of the fishermen insist otherwise on the "RT". 

...”currently, the policy of the GGM is not to use lethal control for the control of predators, so that the management and acquisition with equipment suppliers are being carried out to implement the control of predators with new techniques of "repelling" that include small boats noisy controlled by remote control (RC boats), as well as the use of "drones" to scare off birds”. 

COMMENT: This observation has been discussed extensively in previous sections. According to the complaints, the procedures for the purchase of this equipment continue three years later

…” The farm does not use antibiotics or probiotic products as evidenced by on-site inspection and interviews with workers. The main chemicals are: fuels, lubricants, fertilizers based on nitrogen, lime, and sodium metabisulfite. The only chemical that could require neutralization is Sodium Metabisulfite, but it is prepared and transported to the collection center at harvest and is not discharged into the farm's drainage system. ". 

COMMENTS: The ESIAs document the fishermen's complaint about the use of chemicals and the drainage of contaminated water directly into the environment. On some occasions during the harvest drops of water fall to the operators that leave them with itching and / or nose bleeding. Also, the EIAS report that the Farms use Sodium Metabisulfite, Chlorine, muriatic acid and sometimes other chemicals to kill the "phantom shrimp". All these chemicals and not only the bisulfite require neutralization and must be given a reasonable time before emptying them to the sea. The auditor makes a mistake by stating that: "The only chemical that may require neutralization is sodium metabisulfite." 

MANAGE THE ORIGIN OF THE BREEDING SHRIMPS, SELECTION OF LOTS AND EFFECTS OF LOTS HANDLING…” The Pacific white shrimp Litopenaeus vannamei is an specie introduced in Honduras at the beginning of 1970 "... 

COMMENT: This false information appears in the Audit of CADELPA-AQH and Granjas Marinas San Bernardo. How is it possible that Consultants, WWF supervisors, Auditors and Certifiers have not noticed this big mistake! ... They really were in a hurry to grant the Certification and the Seal.

4.3. CERTIFICATION


DECISION:

“Based on the result of the evaluation and the closure and dispatch of the action plans by the applicant, The San Bernardo estate is awarded the ASC certification of shrimp”.

COMMENT: This same decision appears in the other "Audits to the other companies. The Certifier seems to focus only on the operations inside the farm and does not consider the impacts outside of it. As has been demonstrated, the bases that lead to this Certification are very weak. The b_EIA, p_SIA and Audit studies contain many errors; they do not adhere always to the truth. The negative socio-environmental impacts are reported, but are finally ignored, which is why no "action plan" is considered aimed at improving the social and environmental issues. Neither does the GGM acquire commitments to improve the relationship with fishermen or for the conservation of the environment and its biodiversity. Therefore, the awarding of the "ASC Seal" to the GGM, may lead one to conclude that its "Standards" are met almost 100% or… that they are a farce to deceive the consumer. 

As detailed, the Auditor acts hastily and commits several errors. On these faults in the previous steps of the process the Certification does not notice nor the Supervisor either.

EIAS, Audit and Certification Consultants, and Supervisor seem to act accelerated and very favorably with their client and do not have the time, capacity or interest to corroborate the information of the ESIA. For all the above, many readers could conclude that this ASC Certification and Seal is only useful to the interests of commerce and the GGM, does not benefit fishers, environment and biodiversity, deceives consumers and leaves credibility on the ASC Certification and Seal.

The Certifier concludes that he has reviewed the evidence presented by his predecessors ...There may be "evidence review" but it is obvious that "there is no confirmation of the evidence" This Certification, contradicts the purpose of the ASC Standard, because: it "does not provide the means to significantly improve the environmental and social performance of operations of shrimp farming ". It simply puts these impacts aside, so it does not provide the means or assume commitments to mitigate them. Consequently, the ASC Certification and Seal, do not comply with what they proclaim as “certified” to the general public and particularly the consumer.  


CONCLUSION
Thus, the Certifier concludes that: "After the review of evidence and action plans for non-conformities, it is decided to grant the ASC certification."

4.4. RESPONSIBILITY OF THE AQUACULTURE STEWARDSHIP COUNCIL WHEN AWARDING CERTIFICATION AND LOGO, ASC


The ASC is primarily responsible for allowing the use of its seal in shrimp packaging produced by the GGM to a consumer public, who relies on its seal. 

The GGM shrimp farms now use the "Seal" of the ASC in their shrimp export packaging despite the fact that the social and environmental impacts were eliminated in the process of awarding the certification and seal, which is reiterated: purpose that guarantees and offers the ASC to the consumer. The following images indicate price differences favorable to the holders of the "ASC Seal"                                            

“Honduran shrimp sold in Germany with the ASC seal”

4.5. PRICE DIFFERENCE IN EUROS 1kg. SHRIMP WITH ASC SEAL AND WITHOUT SEAL

“1kg. of shrimp with ASC seal, costs € 33.30 " and “1kg. without the ASC stamp, it costs € 28.14 "

4.6. GENERAL CONCLUSION


Some of the proposals of the ASC are annotated in quotes ("") and bold letters

a) "Promote the best social and environmental choices when buying seafood" 
 The ESIAs, the Audit and Certification do not consider or recommend Then it could be concluded that: any measure that promotes social and environmental aspects, that when applied allow to choose a product genuinely attached to the ASC Standards. Worse yet, they minimize them to the point of ignoring these essential aspects of their "Seal" .

b) “contribute to the transformation of seafood markets towards sustainability”. 
_In general, this is difficult to accept as this monoculture periodically resorts to more chemicals, technology, constant expansion on new wetlands, or government assistance (through exonerations, debt cancellation or re-conditioning, subsidies, loans or accommodation of laws ...). Whenever production is attacked by epizootics, natural or commercial events that threaten the industry, the government or international entities come to their aid.   
  
 c)… “promotes the best social and environmental performance of aquaculture”.
This does not manifest itself outside the GGM farms.

d) “"Sending through a "seal" the message to consumers about the social and environmental integrity of the product they are buying."”. 
The process that leads to the awarding of the seal shows several faults that make one doubt its social and environmental integrity of the product they are selling.

e) The effectiveness of the ASC Standards aims to "minimize the social and environmental footprint of commercial aquaculture”: 
In this case, not only the "social and environmental footprint" is minimized ... it simply does not exist ... no consultant mentions it. So the "ASC Standards" in this case, not only minimize the social and environmental footprint, but erase it.

f) “The ASC label helps promote responsible practices”
As far as the ASC is concerned, it does not help to promote any practice that makes the GGM take responsibility for the damage to fishermen to the environment and biodiversity.

The reader could conclude that the ASC LABEL, instead of "promoting responsible practices" helps to promote better prices and sales, in a market where people trust in "green seals".

g) “The ASC fulfills its objective of providing a means to measure the improvement of environmental and social performance of shrimp aquaculture operations”
 _ Neither the EIAS nor the Audits or Certification mention the means to measure the improvement of the environmental and social performance resulting from the aquaculture operations of the GGM. 
In the analysis of the ESIAS, and the Audits, which lead to the Certification, errors, omissions, lack of appreciation, etc. are shown. Then it could be concluded that:

- The IDH invests its money in studies of little seriousness; that the WWF does not supervise the process effectively; that the GGM hires very "convenient" consultants to evaluate it; that the fishermen and the environment continue to receive the negative impacts, and ... that the consumer is deceived.
- Another conclusion may be that, with the complicity of the ASC seal, the food sovereignty of a large sector of the communities that work near the GGM shrimp farms continues to be put at risk; the environment is violated and the human rights of the artisanal fishing population are violated_

It is expected that by granting the Certification and the ASC Logo to the GGM, the situation of the fishermen will improve, but as you can see this does not happen. While in the process benefit consultants, companies, international consulting NGOs and the GGM, which now with the Certification and the ASC logo sells better its shrimp internationally. Other companies with very poor performance may be looking for this “seal” at this time.


4.7. ABOUT THE ASC LOGO


The ASC awards its "credible consumer logo" (ASC Seal) to GGM in 2016, but in 2018 there are still reports of violations of fishermen's human rights, environmental pollution and biodiversity loss.

When analyzing the process of awarding the ASC Seal, its credibility is left in doubt, and in general compliance with its Rules.


IT IS UP TO THE READER, IDH, WWF, GGM AND THE ASC, REFLECT AND CONCLUDE IF AWARE OR UNCONSCIOUS, THEY ARE DECEIVING THE CONSUMER WITH THE "ASC CERTIFICATION AND SEAL".

AT THE END…

SHOULD, IDH, WWF, THE ASC AND THE GGM CONSIDER TEMPORARILY SUSPENDING SUCH CERTIFICATION AND SEAL, UNTIL IMPACT DECLARATIONS ARE CONSIDERED AND SUBMITTED THROUGH A BINDING DIALOGUE BETWEEN PARTIES IN CONFLICT, INCLUDING THE ORGANIZATIONS MENTIONED, FISHERMEN, COMMUNITIES, AUTHORITIES AND THE RESEARCH TEAM ("RT") OF THIS CERTIFICATION PROCESS?



4.8. APPENDICES 


4.8.1. List of Appendices


1. Request of Investigation on the part of the Fishermen who support the influence of the GGM. (P. 88)
2. Rancherías, Location and alleged eviction authors. (P. 89)
3. Complaint File # SG-SJDH-D-019-20130214. (P. 90-91)
4. Oxidation Lagoons, Article. (P. 92)
5. American Central Water Court and Article Tribunal del Agua y El Golfo. (P. 93-94)
6. File Deforestation of the GGM / Jacobo Paz; GGM / CADELPA. (P. 96-97)
7. Project WWF/ Certification. (P. 98)
8. Resolutions of the Ramsar Convention Related to Aquaculture. (P. 99)

4.8.1.1. Request for Investigation on the ESIA, by the Fishermen that Support the Influence of the GGM



4.8.1.2. Rancherías, Location and alleged eviction authors.



4.8.1.3. Record of complaint # SG-SJDH-D-019-20130214 

- Report on the Assassination of Yelson Gabino before the Secretary of State in the Offices of Justice and Human Rights. 





- WALTER ORTIZ, ANOTHER ALLEGED VICTIM OF THE GGM



4.8.1.4. Article: Oxidation lagoons


4.8.1.5. Central American Court of Water, and article: “Court of Water and Gulf”




4.8.1.6. File # SP0404-2015: deforestation by the GGM / CADELPA and against its Manager, Mr. Jacobo Paz


On February 29, 2012 the GGM / CADELPA is caught deforesting without permission a high quality mangrove area (Rizophora mangle), in the place known as "La Jagua" # 2, of the GGM-CADELPA farm, which is reported by the environmental organization of the area (CODDEFFAGOLF), and on March 5, 2012, the offense was confirmed by the Forestry and Wildlife Conservation Institute (ICF) of the Regional Forest Office of the Pacific, which is why, after intense public and official complaints, on May 6, 2013 the GGM is condemned to pay a fine of L.681,000.00, (approximately = US $ .30,955.00), and its general manager Mr. Jacobo Paz, required by the Office of the Prosecutor. In the Environmental Prosecutor's Office they say they do not know if they paid the fine. 

Offense: Deforestation of mangrove forest, on February 29, 2012, being Mr. Jacobo Paz, Manager of GGM / CADELPA

On March 5, 2012, Mr. Ronald Alexis Castillo, technician of the Regional Forestry Office of the Pacific, presented a technical report, confirming the denunciation of Mr. Román Fúnez Guevara, Sectional President of CODDEFFAGOLF. The event occurs at the site known as La Jagua # 2 of the GGM / CADELPA. 

On May 6, 2013 the Public Ministry requires the GGM Manager Mr. Jacobo Paz and the GGM is condemned to pay a fine of more than L.681, 000.00 (the Public Ministry does not know if he has paid them) and reforestation of the same amount deforested. (Which is not yet confirmed on August 7, 2017). While Jacobo Paz is required and is free with provisional.

Dismissal but on January 24, 2014, despite his background, Mr. Paz is appointed Minister of the Government Cabinet of President Juan Orlando Hernández, in the Ministry of Agriculture and Livestock, an institution that also directs Fisheries and Aquaculture. Shrimp and fishing activities are under his administration, and his trial goes to a "special treatment" for what is in the Supreme Court of Justice under the responsibility of the Natural Judge Ligia Sagastume Sandoval and his assistant secretary, Josué Padilla. File # SP0404-2015.


 4.8.1.7. WWF Project / Certification


ASC SHRIMP CERTIFICATION
Implementing partner: World Wildlife Fund (WWF)
Other partner(s): Granjas Marinas Group (GGM), Sociedad Nacional Galapagos (SONGA)
Country: Ecuador, Guayas River, Guayaquil
Species: Litopeneaus vannamei
Targeted volume: 31,026 MT (large-scale farms)
Target: ASC
Project duration: 18 months (January 2016 – June 2017)

PROJECT SUMMARY
Following the successful certification of 90% of the shrimp sector in Belize, WWF Guatemala/Mesoamerica and the IDH FIT Fund are partnering again to replicate this work in the region. With financial support from the FIT Fund and technical support from WWF Guatemala/Mesoamerica and WWF Ecuador, two shrimp producer groups, Granjas Marinas Group (GGM) in Honduras and Sociedad Nacional Galapagos (SONGA) in Ecuador will seek ASC certification of ten Pacific white shrimp (Litopeneaus vannamei) shrimp farms.

GGM directly employs an estimated 3,392 people, often coming from poor rural areas. GGM consists of five farms, one shrimp hatchery and two shrimp processing plants. In 2014, GGM produced 14,592 MT of shrimp, with exports valued at more than €88.7 million.

SONGA employs 1800 people across their five shrimp farms, research facility, two hatcheries, and a processing plant that has the capacity to process 110 tons per day. In 2014, SONGA, produced 14,000 tons of shrimp, and in doing so attained its position as one of the main exporters in Ecuador, as well as a reliable and consistent supplier to the European, North American and Asian markets. Both groups have other international certifications such as HACCP, BRC, BPM and Global gap.

Competition in international markets for sources of sustainably certified fish and shellfish has grown steadily over the past few years as retailers search for a consistent product. The ASC Certification will give these shrimp producers in Honduras and Ecuador a competitive advantage and privileged access to this high-value market demanding ASC shrimp products.

Partnering with the main shrimp producer and exporter group in Honduras, and one of the main shrimp producers and exporters in Ecuador, WWF and IDH FIT Fund will expand ASC certification in the Latin American Region in order to promote and ensure more environmentally-responsible production.

Statements: “The success of our work in Belize has motivated other shrimp producers in Latin America to work hand in hand with WWF and IDH to produce responsible produce shrimp protecting the natural resources and minimizing the social and environmental impacts”.
WWF Guatemala/Mesoamerica: ¨Through this work, we hope to encourage more Ecuadorian producers of shrimp to join this initiative and implement best aquaculture practices in their processes to help them reduce impacts and to ensure a responsible production¨. WWF Ecuador.
4.8.1.8. Resolutions of the RAMSAR convention related to Aquaculture

COP 7: RESOLUTION VII.21
13. URGES Contracting Parties to review and modify existing policies that have a detrimental effect on wetlands in tidal zones, to try to adopt measures for the long-term conservation of these areas, and to provide information on the success or not of those actions in the National Reports that are prepared for Ramsar COP8;

14. FURTHER URGES Contracting Parties to identify and include in the List of Wetlands of International Importance a greater number and extension of wetlands located in intertidal areas, especially low tidal, prioritizing those sites that are important to indigenous peoples and local communities, and those that harbor endangered species worldwide, as requested by Resolution VII: 11; and in our final report of March, put as an annex in the part where Ramsar is talked about.

15. ALSO URGES all Contracting Parties to suspend the promotion and creation of new infrastructures for aquaculture activities that are not sustainable and harmful to coastal wetlands, including the expansion of existing ones, until they are identified, through assessments of the environmental and social impact of such activities, together with appropriate studies, measures to establish a sustainable aquaculture system that is in harmony with the environment and with local communities.

RAMSAR COP 8
Employee of GMSB denounced for supplanting official delegate of the government of Honduras in the Ramsar Convention, COP 8 DE VALENCIA, Spain. The President of the Republic Ricardo Maduro, linked to the GGM, refrains from commenting on the international public denunciation, expressed during the development of the convention and then at the national level in Honduras
See The Link:https://wrm.org.uy/es/articulos-del-boletin-wrm/seccion1/honduras-camaronero-como-delegado-oficial-ante-ramsar/

RAMSAR COP9
Resolution IX.4, page 5         
31. URGES Contracting Parties to carefully control aquaculture practices (eg in ponds and cages) at Ramsar sites and in areas that are likely to influence Ramsar sites and other wetlands, in order to prevent adverse changes on the ecological characteristics of wetlands, applying the provisions of the FAO Code of Conduct and its Guidelines

Techniques for Responsible Fisheries - Development of Aquaculture - 1997 and the Bangkok Declaration and Strategy of 2000 for the development of aquaculture (Network of Aquaculture Centers of Asia and the Pacific (NACA / FAO));

32. STRONGLY URGES each Contracting Party to apply the policies and laws in force to prevent any encouragement, creation of new facilities or expansion of unsustainable aquaculture activities harmful to wetlands, in accordance with Resolution VII.21 on wetlands located in inter-zone areas.

No hay comentarios.:

Publicar un comentario