The PNA Management Program does not solve the problems

The PNA Management Program does not solve the problems

As ironic as it may seem, the argument that it is necessary to establish a Protected Natural Area so that, through its Management Program, the problems of pollution, uncontrolled and disorganized development in its vicinity are solved and economic activities are regulated, has no bases.

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

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

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

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

Within this complexity are the processes of public consultation to submit the

Management Programs of the NAPAs, in which the problem of the representativeness of the economic sectors, of the "community" and of the federal, state and municipal dependencies is presented. Another problem is that of the continuity of consensus and "appropriation": making own or sharing responsibilities on the part of the sectors involved. Generally, the social sectors orient responsibilities in a unidirectional way, leaving the total solution to the government. And on the government side, it is the municipality that often does not adopt the responsibilities and capabilities that correspond to it. The problem of communication and negotiation has to be considered not only in terms of the governing bodies and their different levels, but also of NGOs taking into account their strong dependence on the moments and actions of the agencies that finance conservation and development activities…(Arellano et al, 2008)” Two of its authors, Alfredo Arellano Guillermo and Rafael Robles de Benito have extensive direct experience on governance and this type of instruments in PNA, the first was an official of the Commission of Protected Natural Areas for more than 12 years, later he was Secretary of Environment of the State of Quintana Roo (from 2016 to 2020); the second is currently (2021) Director of the Institute of Biodiversity and Natural Areas of the State of Quintana Roo.

However, occupying these positions, their arguments are the opposite. In the case of Bacalar, they argued that the establishment of the PNA and, consequently, its management program, would "save" the lagoon from the impacts of tourism, knowing that there is no PDU (Urban Development Program) in Bacalar, that the process of updating the Ecological Management Program has not been concluded and that many municipal instruments are missing, where local actors insist on investing first.

113

PROTUR

For 2019 the proposal of PNA, returned "transformed" into an instrument called PROTUR, a short way of calling the "Common management program for tourism use in the Bacalar Lagoon", a supposed voluntary program, product of a simulated consultation and a poor design, due to the haste of creating an instrument that was something close to a Management Program of a PNA (of which it has all the structure and zoning) although it is call it another way and promote tourism. That year it was already very clear the inclusion of the region in the Megaproject Tren Maya, promoted by the federal government. One could think and have the "very suspicious" (concept that means having an enormous amount of suspicion or a very powerful suspicion, and that was used in his 2017 article, by Rafael Robles de Benito, now director of the Institute of Biodiversity and Natural Protected Areas of the State of Quintana Roo) that with the proximity of development projects and the improvement of opportunities for the southern zone of the state of Quintana Roo, it was urgent for the State to consolidate its NAP in order to "save nature". We would not have space here to argue that the insistent interest of the State to take control of the body of water seemed to be purely economic or political thumping, given that the Federal Government, promoter of the Mayan Train project belonged to an opposing political party, and the policy of republican austerity at the country level, established since 2018, had restricted many of the discretionary funds with which the state government was accustomed to operating. Given the strong resistance of the communities towards the idea of the Protected Natural Area or the Ramsar site, a new proposal appeared where the argument was that a regulatory and zoning instrument was urgently