Letters — 08 June 2019
BECOL’S response to BELPO’s letter — “20 years of misinformation”

Dear Editor,

As a responsible corporate citizen, BECOL wishes to hereby set the record straight on certain untrue allegations which were included in the “Letter to the Editor” referenced above.

Contrary to the claim by BELPO in their letter published in the March 30, 2019 edition of the Amandala newspaper, BECOL is very strongly regulated by law to protect the people and environment in its area of operations as evidenced by the Consolidated Environmental Compliance Plan (ECP) signed between BECOL and the Department of the Environment (DOE). As part of its obligations under the consolidated ECP, BECOL is required to conduct various studies to monitor possible human and ecological impacts of the hydroelectric facilities and to implement mitigative measures. Some of these studies have been ongoing since 2005. All of the reports of these studies are submitted to the DOE, Ministry of Health (MOH), and other relevant regulatory agencies, and can be viewed by the general public through the relevant ministries. BELPO has several times aired its allegations in the courts of Belize where the evidence was reviewed in depth and all the allegations were dismissed as baseless.

Pollution of River:

In its letter, BELPO claims that the Macal River is “polluted and people shouldn’t drink from it or swim in it.” But the author of the letter knows that it is not prudent to drink directly from any natural water source unless the water is properly treated to eliminate any micro-organisms that inherently form a natural part of the micro-flora of all natural bodies of water. This is why our national water utility has made significant investments in water treatment technology and infrastructure to treat and distribute clean potable water to all areas of the country, regardless of the water source.

In compliance with the consolidated ECP, BECOL conducts quarterly water quality and sediment monitoring at sample sites along the Macal River from the upper reaches of the Chalillo reservoir down to San Ignacio Town. Physiochemical and biological parameters studied over the last decade show no indication of pollution caused by the operation of the dams which would be harmful to human health. Many local residents and foreign visitors use the Macal River on a daily basis for swimming and other recreational activities and BECOL is not aware of any report of adverse health effects caused by  swimming in the Macal River. Certainly, we can confirm that there are no adverse health effects attributable to the dam or its operations.

The author of the letter speaks of high levels of E. Coli in the river, implying that the source of the E. Coli is the dams. Escherichia Coli (E. Coli) is a micro-organism used as a non-specific indicator species to detect bacterial contamination of water bodies. E. Coli is an organism found in the digestive tract of humans and animals and its presence in a sample is not necessarily indicative of human fecal contamination. This is especially true of water samples which are exposed to contamination from the wildlife present in the surrounding area. BECOL’s dams are located in the middle of natural ecological systems, and the E. Coli count in samples collected since 2005 to present has remained stable and well below the 126 cfu/ml standard cited in both the Belize EPA and the USEPA. The average E. Coli count has remained below 40 cfu/ml at all sample sites (Water Quality and Sediment Analysis of the Macal River, Safety and Environmental Services, 2016 – 2018). At these levels, the E. Coli count poses no risk to human health or the environment. This is not surprising since human activity is very low in areas upstream and directly around the hydroelectric facilities. BELPO is well aware that any significant levels of E. Coli or other disease-causing agents emanating from an anthropogenic source are only being found in areas downstream of the dams, in and around municipalities and other communities along the banks of the river.

Data collected since 2008 show that turbidity levels fluctuate widely and are heavily dependent on climatic and weather conditions, as well as water flow, at the time of sample collection. With respect to heavy metals in sediments, BECOL monitors the following heavy metals in sediments at various sampling points along the Macal River: arsenic, lead, mercury, cadmium, and iron. To date, no hazardous levels of heavy metals have been detected in sediments collected at the various sampling points and traces found are attributable to natural sources and not the dams (Water Quality and Sediment Analysis of the Macal River, Safety and Environmental Services, 2016 – 2018).

Mercury in fish:

Since 2008, BECOL has been conducting annual testing along the Macal River at several sample points, from the Chalillo Dam down to Cristo Rey Village in order to monitor mercury concentrations in fish so that the relevant regulatory agencies may subsequently advise the general public on safe consumption levels. BELPO is well aware that studies have shown that mercury levels in some fish were above WHO safe consumption levels even before construction of the Chalillo Dam: “Prior to the operation of the Chalillo Dam, baseline data collected as part of the Environmental Impact Assessment of the Chalillo Dam in 2001 (AMEC E & C Services Limited, 2001) indicated highest levels of Hg concentration of 1.2 mg/kg in the Baysnook (Petenia splendida) sampled upstream of San Ignacio, with overall average concentrations of 0.71 mg/kg Hg recorded from 15 specimens. Similarly, samples of Blue-eye Cichlid (Cryptoheros spilurus) upstream Mollejon had average levels of 1.21 mg/kg.”

These levels documented before the construction of the Chalillo Dam were above the recommended limits of Hg in fish of 0.5 mg/kg for herbivorous and omnivorous fish (Blue-eye Cichlid – Cryptoheros spilurus) and 1.0 mg/kg for highly carnivorous fish (Baysnook – Petenia splendida) (FAO/WHO, 2011).

Those results were consistent with the published results by the Pan American Health Organization (PAHO) & Ministry of Health Belize (2005) in collaboration with the Fisheries Department (FD) and the Department of the Environment (DOE). Hg levels reported for baysnook were 0.53 mg/kg Hg. So the author of the letter is well aware that levels of mercury in baysnook were barely within the upper limits recommended for highly carnivorous species, and has been a health concern for communities living along the Macal River even before the construction of the dams. (Analysis of Mercury Trends in Fishes from the Macal River Watershed, W&Q Services, October 2016). While most species recorded a spike in mercury levels above the 0.5 mg/kg level immediately after the construction of the dams, testing since 2012 has shown a clear decreasing trend for all fish species sampled at all five Macal River sampling sites.

The latest results from 2017 and 2018 show all fish species at all Macal River sampling sites to be safe, with mercury levels below the safe consumption level of 0.5 mg/kg (Analysis of Mercury Trends in Fishes from the Macal River Watershed, W&Q Services, October 2017). Since 2016 BECOL has begun studying mercury levels in fish from other rivers not affected by the dams. These include the Mopan River (Western Belize), the Belize River (Central Belize), the Rio Grande River (Southern Belize), and the New River (Northern Belize). Data results from 2016, 2017, and 2018 sampling in the Mopan River, which is not influenced by the dams, show that mercury levels in some species of fish are at or just above the safe consumption level of 0.5 mg/kg — similar to the levels in the Macal before the dams were constructed.

Fish samples tested from the New River in 2016 showed very high levels of mercury in some fish species, in some cases more than double the safe consumption level, but 2017 and 2018 results showed the levels just below the 0.5 mg/kg threshold. The Rio Grande samples have shown similar fluctuations, with some species being above the 0.5 mg/kg threshold in both 2016 and 2017. Samples from the Belize River have also shown fluctuation from 2016 to 2018 but for the most part have remained below the safe consumption level. These data sets are showing that moderate levels of mercury exist in other rivers in different areas of the country which are not impacted by dams which, in turn, leads to the conclusion that other environmental and anthropogenic factors such as soil erosion, forest fires, and agricultural use contribute to mercury availability in natural waterways, including the Macal River. These results are not surprising because mercury accumulation in man-made lakes occurs as a result of rotting vegetation and the levels of mercury naturally reduce over time as the rotted vegetation gets eliminated.

Emergency Preparedness:

BELPO’s claim that there is no workable dam break early warning system is totally false. In December of 2004, a Dam Break Inundation Study for the Chalillo Dam was completed by Gilbert-Green and Associates on behalf of BECOL. This study assessed the downstream impacts of a dam failure event under several climatic conditions and made relevant recommendations. As part of its emergency preparedness plans, since 2008, BECOL has installed and maintained a network of early warning sirens in vulnerable communities and resorts along the banks of the Macal River, from Black Rock Resort to San Ignacio town. This siren network serves as first notice of an impending emergency flooding situation on the Macal River and forms only one component of the wider emergency response mechanism for the impacted areas. In addition to this, BECOL has developed an internal Emergency Preparedness Plan (EPP) to respond to a dam emergency, which functions as an initial response and notification mechanism that coordinates with and complements the emergency plans of the National Emergency Management Organization (NEMO) for the impacted areas. BECOL’s EPP is available to the public through any of the regulatory agencies, as well as the San Ignacio Public Library, San Ignacio Town Council, and other local public entities. BECOL takes the safety of the public very seriously and works very closely with NEMO to coordinate and execute full scale and internal simulation exercises on an annual basis.

These exercises and relevant recommendations are carefully documented. As a result of these exercises and BECOL’s own internal assessment, a plan has been developed for the upgrade and improvement of the early warning siren network and will be implemented over the course of the next four years. BECOL has also commissioned an update of the Dam Break Inundation Study, which is already underway, and this report should be available by July 2019.

BELPO claims that the proponents of the dam were not truthful about the geology of the area. There was indeed an error when the contractors that did the geological study mistakenly classified the rocks in the river bed as “granite” instead of “granatic sandstone”. This occurred because the sandstone was formed from granite sediments and thus had similar properties to granite. BELPO is well aware that from a technical/engineering point of view, the misclassification is irrelevant. What matters is that the load-bearing properties of the materials were clearly very competent for the purpose of building a dam.

Since the dams have been built, Belize has experienced many earthquake tremors, some of which caused significant damage to infrastructure in the country, but all the dams withstood the events with no adverse effects.

BECOL does enjoy tax and duty free concessions, but these concessions are applicable to all the Independent Power Producers of electricity in Belize and also to power imported from Mexico. The benefits from these concessions are directly passed through to BEL’s customers. In addition, contrary to BELPO’s assertions, BECOL is fully liable for any damages it causes as a result of its operations. The exemption BELPO refers to is a typical indemnification for force majeure conditions outside of a developer’s control.

Cheaper electricity:

All the rate applications made by BEL are available to the public through the Public Utilities Commission. BELPO can easily verify that none of the rate increases were initiated as a result of the Hydro Projects. All the increases have been driven by higher oil prices and/or higher rates from Mexico. BECOL provides a little over 40% of the electricity that the country uses, which has helped to offset the increases being driven by higher oil prices. If the electricity provided by BECOL had to be generated in-country with diesel, or purchased from Mexico, electricity rates would have had to be increased even higher.

Dissemination of information:

BECOL considers the dissemination to the public of all information and data gathered to be of paramount importance in its efforts to safeguard the lives and wellbeing of residents living in its area of operations. Therefore, BECOL, in collaboration with the Department of the Environment, the Ministry of Health, and the National Emergency Management Organization (NEMO), hosts public meetings in the following communities once every quarter as mandated by the ECP: San Ignacio/Santa Elena, Cristo Rey Village, Bullet Tree Village, Santa Familia Village, and Calla Creek Village.

Notices of these public sessions are widely advertised in national newspapers as well as national and local radio media. All relevant information pertaining to studies conducted by BECOL and other ECP requirements, such as emergency preparedness, are presented at these public sessions. The public sessions are an open-discussion forum where community members are free to voice concerns and ask questions on anything pertaining to the operation of the hydroelectric facilities.

BECOL also coordinates with the DOE, MOH, and NEMO to develop and publish public advisories on any and all issues related to the ECP as deemed appropriate by these agencies.

BECOL submits copies of all study reports to the DOE and other relevant government authorities, as required by the ECP. Official copies of these reports are available to the general public, by request, from any of the relevant government departments. In the interest of transparency, any request for information received by BECOL from the general public is re-directed to the relevant government agencies.

Yours truly,
Belize Electric Company Ltd.
(Lynn Young) President & Chief Executive Officer

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