IBANQROO and PROTUR

Pollution control strategies

It is interesting to observe how protur places administrative strategies for visitor control, referring to the regulation of the municipality for the provision of services in tourist sites of boats forgetting that there is a specific regulation by the relevant authority that in this case is the APIQROO and that establishes very clearly the way in which the boats can or cannot be operated, schedules and port infrastructure enclosures throughout the lagoon. Although the municipality can sanction boatmen, it is not the corresponding authority. For its spill prevention strategies here it is also evident the deficient knowledge of the regulation that already exists at the national level for the prevention of pollution in water bodies and refers to establishing rule 51 of the municipal tourism regulations where it is prohibited to spill the lagoon lubricating fuels, wastewater and garbage, ignoring that there are specific rules in Mexican legislation.

The document commits the sin of presenting supposed innovative proposals, product of inspiration, lacking technical foundation, which will represent a risk. We are not going to go any further because I think we have already made this point clear. It is also inconsistent with the discourse of environmentalists, of the triad itself, who advertise that pollution and impacts to La Laguna are generated mainly by runoff derived from agricultural areas or urban areas surrounding the Bacalar lagoon, and structure PROTUR as an instrument that seems solely and exclusively to be used to control the body of water, recipient of impacts, not sources of pollution. And beyond, it makes an enormous effort to delimit and control the number of people who enter the body of water and the tourism activities that will be developed to guarantee the enjoyment of the visitor, without an analysis or foundation of the complete environmental system.

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

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

148

SNAILS! NOW A CRITICAL HABITAT

The proposal to ban the Chivita snail (Pomacea flagellata) to impose a critical habitat.

When the 2017 Natural Protected Area proposal did not bear fruit due to the resistance of local inhabitants, the triad sought ANOTHER channel to try to establish its Protected Natural Area, and transformed it into a Critical Habitat proposal. On May 1, 2019, at the working meeting of the united commissions of the Congress of the State of Quintana Roo, an agreement was taken with which it was intended to declare the Bacalar Lagoon System as a Protected Natural Area, and to consider the Chivita snail (Pomacea flagellata) within the NOM-059-SEMARNAT-010. This initiative was promoted by the parliamentary fraction of the New Alliance party, headed by Delegate Ramón Javier Padilla Balam. In its exhortation, SAGARPA, SEMARNAT, and SEMA were requested to begin work to include the chivita snail (Pomacea flagellata) in NOM-059SEMARNAT 2010, under the category of threatened species, while a 10-year ban was decreed for its use and actions were requested to protect the stromatolites of Bacalar, that is, put a type of reservation. In this document, regardless of the sentimental arguments and the paraphernalia of statistics of consumption and fishing of snail, there was no scientific technical basis, in addition to citing three studies: one of population dynamics with a focus on aquaculture, one of perception of consumption and a journalistic note, it did not establish a solid argumentation for this proposal. The request to place Pomacea flagellata in protected status as a threatened species was NOT justified, given that in itself, the genus Pomaceae is quite common and very well distributed.

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

Other relevant aspects of the genus and the species are that they are considered of medical importance as they are transmitters of parasites that affect man and that generate bioaccumulation of toxins, which makes them a risky food; in this genus there are also species considered pests, there are governments that have control and eradication programs for some of their relatives. While P. flagellata in Bacalar is local, some of its relatives such as P. caniculata have proven to be very aggressive and cosmopolitan invasive species, decimating crops such as rice, in many regions of Latin America, Asia and Europe. With this proposal of closure and inclusion of the chivita as a species at risk, it was intended to give basis to another proposal for a control instrument in the Bacalar lagoon, the establishment of a Critical Habitat. This proposal arose as part of a project promoted by SELBA, AC, an ONGA, with funds from the Small Grants Program of the United Nations Development Program (UNDP PPD). Critical Habitat is an instrument of neoliberal environmental conservation –read control – that derives from the definition established in 1973 in the Endangered Species Act enacted in the United States of America. Yes, another import from the northern neighbor, as happened with the case of the Protected Natural Areas, the concept of Critical Habitat was taken as an adapted import of the legislation of the neighboring country. In Mexico, the concept of critical habitat was inserted in the General Wildlife Law, specifically in Title VI, which refers to the conservation of wildlife, and there, in its chapter II, which contains what is related to critical habitat, in two articles (63 and 64). The Law establishes as justification to decree a Critical Habitat: 1) That the conservation of the natural habitat of wildlife is in the "public interest".

Which means, as we saw above, that it can be imposed, and in this case, it can be determined unilaterally for the benefit of the "common good" (provided that the common interest is the interest of the triad). 2) That critical habitat should be established by secretarial agreement. Unlike the NAP, which requires the consensus of local actors, critical habitat is more like a Ramsar declaratory type, it only requires environmentallyrelated governance bodies (the government part of the triad) to agree. This was something that was tried to be done in the virtual forum of the Stromatolite Day, on July 15, 2020, where the three secretaries of environment of the states of Puebla, Coahuila and Quintana Roo, where there were stromatolites, positioned themselves and placed the same title to each of their presentations: "Alliance to conserve the Stromatolites of Mexico", with which they were giving the guideline for the inter-secretarial agreement, in the presence of the Federal Secretary of the Environment, who at that time was Víctor Toledo. The inter-secretarial declaration does not specify the need for consultation with the owners, only an agreement between secretaries. The Critical Habitat can be established, in this practically unilateral way, "when it comes to" Specific areas within the surface in which a species or population at risk is distributed at the time of being listed, in which biological processes essential for its conservation are developed. Or of specific areas that due to deterioration processes have drastically decreased their surface, but that still harbor a significant concentration of biodiversity. Also for specific areas in which there is an ecosystem at risk of disappearing, in case of continuing to act the factors that have led it to reduce its historical surface or in specific areas in which essential biological processes are developed, and there are species sensitive to specific risks, such as certain types of pollution, either physical, chemical or acoustic, or risk of collisions with land or water vehicles, which may lead to populations being affected. Obviously with data provided by the academic part and the NGOs of the triad, regardless, as happened in Coahuila and Bacalar, what the local population, scientists from other branches of science, inhabitants and historical users of resources and ecosystems thought about it. What the proposals to ban the chivita and the alarmist presentations of the day of the Stromatolites wanted to demonstrate with the media bombardment was that the authorities were making a unilateral decision for

the sake of something, because it was not a species of wildlife that was being reduced, and so in a foggy scenario they tried to impose a declaration of Critical Habitat to protect the stromatolites, but Critical Habitat does not apply to Stromatolites. This instrument is for wildlife species, that is, the law says that it serves to protect species and habitats of wildlife, and stromatolites are stones with bacteria and other microorganisms, they are not as such cataloged as wildlife species and it has not been shown that the species of microorganisms are in NOM 059, that would give its quality of wildlife, to something that is not flora, nor fauna.

Therefore it could not be covered with the declaration of Critical Habitat... except that at the same time the chivita was declared threatened, and then everything could fit perfectly. Without objective assessments that it was endangered they again tried to manipulate public opinion by presenting the image that it was an emergency, that the species was being decimated and it was the fault of the local inhabitants who were polluting and preying. That they had had to make that unilateral decision for "the common good" and the species. And even if the population had not been consulted, it acquired the obligation to submit to the conditions established as special measures on management and conservation in the management plans in question, as well as the corresponding preventive report. Such as a PNA or a Ramsar site declaration, with another name: Critical Habitat.

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

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

Fortunately, Bacalar's proposal had a number of inconsistencies and did not prosper. In the case of the Chivita (Pomacea flagellata) the proposal of closure and inclusion in NOM 059 SEMARNAT 2010 did not succeed, because the risk or threat to the species was not adequately founded. Why did the proposal for the inclusion of Pomacea flagellata in NOM 059 NOT proceed? Because it did not meet the requirements for inclusion in NOM059, it was not justified in the procedure established in paragraph 5.7 of NOM 059 to determine the degree of threat and according to the Risk verification process, there was no baseline of population studies to determine its status as "threatened" (if they did not have how to compare the size of the population previously) and they could not be sure what affected their status. population density not only in the Laguna de Bacalar, if they were going to propose its inclusion at the national level, the data should have been collected at the national level or at least within its national distribution range. Inclusion in a national NOM could not be argued for an application for a local body of water. Chivita is not on CITES, it was not on the IUCN Red List, it was not on NOM059. Because at the international level this genus is considered cosmopolitan, even a pest, transmitter of harmful parasites in free life and is a species of extensive management for commercial reproduction. The request for a ban and the creation of ADP or critical habitat, based on the inclusion of chivita as a threatened species, was based on several scientific investigations, which we analyzed and pointed out had serious sustainability deficiencies. They are listed below and explain what these deficiencies consisted of. At this point I want to emphasize something, the scientific academics who champion Western science as the only one capable of providing solid bases for proposals for protection, management or conservation, are human and in many cases subject to conflicts of interest and,

as I show you below, have serious deficiencies in their research. Perhaps accustomed to the academic degree being sufficient validation for their saying. In the article Abundance, distribution and secondary production of the apple snail Pomacea flagellata (Say, 1829) in Lake Bacalar, a tropical karst system in southern Mexico, De Jesús-Navarrete, A., Ocaña-Borrego, FA, Oliva-Rivera, JJ, De Jesús-Carrillo, RM, & Vargas-Espositos, A, published in 2018 it is established as a result that the density (the number of chivitas per m2) ranged from 1.27 to .11 snails and it is discussed that there is relatively low snail density in comparison with other species of Pomacea. In Venezuela, P. dolioides densities were 100 ind.m-2; while Brazil's P. haustrum went 20-215 ind.m-2; P. canaliculata also had higher densities (130 ind.m-2) in Hawaii; and hong Kong (25.6–42.7 ind.m-2); Pomacea paludosa in Florida wetlands showed very low density (0.05–1.0 ind.m-2; 0.33–1.58 ind.m-2). It would seem logical to think that the basis of comparison was made for the same species or a species of similar ecology in similar habitat conditions, which would validate the comparison, and justify the concern that arose from the apparent low density of the chivita snail in Bacalar, but given that in this and the other two research papers carried out with chivita snail in Bacalar and Laguna Guerrero it is argued that the population density depended on the conditions of the medium, it was worth reviewing in detail the comparison references.

In Bacalar, the chivita is located in ecosystems adjacent to the body of water, of an oligotrophic lagoon (an unproductive ecosystem, characterized by nutrient deficiencies) you have a first idea of why the low density, however there is a certain impulse of urgency to see that compared to the other cases mentioned the density is very low. However, from the sources from which "the comparison" was obtained to justify the very low density of the chivita population in Bacalar:

• In the Venezuela study, P. dolioides densities were 100 ind.m-2 (Donnay &

Beissinger 1993). But the study was conducted in a flooded rice crop where Pomacea dolioides is an invasive species in a site with high primary productivity, shelter site, low depth, a lot of food. An anthropogenic ecosystem, where it is a pest and we know that the characteristic of invasive pests is precisely the ability to multiply and become a problem.

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

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

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

• Pomacea paludosa in the study of Florida wetlands showed very low density (0.05–1.0 ind.m-2, Karunaratne et al. 2006; 0.33–1.58 ind.m-2, Bennetts et al. 2006). These were ecosystems with significant variations in dryness and humidity at shallow depths, not a lagoon, much less an oligotrophic lagoon. Where was the scientific basis for comparison? Since it was argued in many cases in the studies of Pomacea flagellata that there was NOT much reference information, which is not entirely true, how were alarmist statements of low population density made with these references? Not satisfied with that, they continued to argue that in another lagoon in the area, Laguna Guerrero, a density of 1.43 snails was found, but it was immediately justified by arguing that it was due to the ecology and biology of the species, even so it was compared with data for P. canaliculata, an invasive species with pest strategies. It was obvious that large differences in the biomass of both snails were found in different studies. But it is not justified to make alarmist statements, much less conclude:

“…Given the slow growth rate of the species and the slow recovery of the population, we propose a total ban on the collection of P. flagellata snails for at least 10 years in Lake Bacalar. It will be important to implement aquaculture programmes to protect and conserve this resource…” Another article used based on P. Flagellata's proposal for a ban was: Ocaña FA, De Jesús-Navarrete A, Oliva-Rivera JJ, De Jesús Carrillo RM, VargasEspósitos AA. 2015. Population dynamics of the native apple snail Pomacea flagellate (Ampullariidae) in a coastal lagoon of the Mexican Caribbean. Limnetic. 34(1):69–78. But their research admits a terrible flaw in methodology. In his discussion of results he admits that the reported values were underestimated by an ERROR in the sampling method, because the offspring were transparent, small and confused with the substrate, but they

save the day by arguing the following: the locals said that there were fewer snails there; so in this case they did took into account the locals. ah ha! And although there was no previous data to confirm that suggestion, and the spatial distribution of P. flagellata could not be explained by any of the environmental variables studied because it was enough to say that the snail was threatened. So how to ensure that the chivita was in any danger? It was not even considered a risk species in the lightest categories of the red list of the International Union for Conservation of Nature, it is not located in CITES because none of the other countries where its distribution is located has requested that inclusion. It is absurd that there were those who proposed to include it within NOM 059 as a "threatened species", because there was no data on the danger in its natural distribution, from the southern United States to Colombia. There are many studies for a cousin of this snail, which is the Tegogolo de Catemaco, and many others for similar snails, because they are considered pests in America, Europe and Asia, or because they belong to a type of snails that are important transmitters of parasites, even transmissible to man; but it is also true that it is a resource for food use as a controlled crop and there are already many technological packages.

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

Proposing a ban and a protection zone with studies of this type did not help much to the Pink Snail, which was placed in NOM 059 and was decreed in a PNA (Banco Chinchorro). It did what researchers, environmental NGOs and the government said was required to preserve the species; the result? Researchers continue to investigate, environmental NGOs continue to receive money to make more reserves and their restrictive and exclusionary proposals, the government continues to receive applause for protected areas

and their conservation "efforts", but local people lost an economic source that sustained them for generations, they lost a source of food for their families, which was in their traditions, many lost their freedom at the behest of the reservation directorates, and they lost their heritage while trying to regain their freedom, the illegal fishermen reached a better price and more incentive because now they had a "forbidden" product and now they have protected reserves to obtain it. To paraphrase Cristopher González Baca, regional director of CONANP, in 2019 – "the illegal fishing of this marine specimen is carried out, mainly, in the State Protected Natural Areas". And the pink snail continues to reduce its populations. What happened to this proposal of the chivita? The arguments mentioned in this section were provided, and the proposal was frozen, although it has not been completely abandoned, because it appears to be used to reinforce the proposed Ramsar site declaration in 2021.

158

THE PMOTEDU, LIKE FRANKENSTEIN'S MONSTER

Or as a POET or a POEL is not equal to a PMOTDU and a PMOTDU is not the same PMOTEDU, the trap is in a letter.

The local population and historical users learned to live with the Territorial Ecological Planning Programs - POET - (based on the General Law of Ecological Balance and Environmental Protection). These regulatory instruments have been operating some for more than 20 years. What local populations and groups have been calling for is the updating of these instruments. In the interim, a few years ago the Territorial Planning and Urban Development Programs (based on the General Law on Human Settlements and Urban Development) or PMOTDU emerged. As background, it happens that since the creation of the municipality of Bacalar, in 2011, a legal vacuum had been generated in terms of territorial planning, mainly due to the fact that the instrument that regulated its territory had been that of the municipality of Othón P. Banco, a municipality from which they became independent. But once Bacalar achieved its autonomy as a municipal entity, the portion that included them was left as an ordinance that did not include the municipality, but an area of influence around the lagoon. The community began to insist to the authorities the urgency of having a Territorial Ecological Planning Program for the entire municipality, such as the one already had in the municipalities of Othón P. Blanco, Solidaridad, Tulum, Cozumel and Benito Juárez. At some point, someone in the government of the State of Quintana Roo thought it would be a fantastic idea to add an additional component to this instrument: the ecological, and we ended up with a Municipal Program of

Territorial, Ecological and Urban Development Planning, which was not only confusing, but also threatened to further complicate the regulatory framework that was already overlapping and disjointed. If I could summarize it would be:

• POEL and POET are to order the entire territory outside of Human

Settlements (whose UGA are referred to the corresponding Urban

Development Program -PDU• PMOTDU, created at the federal level by the Secretariat of Agrarian,

Territorial and Urban Development (SEDATU), orders all the instruments of the Human Settlement and its planned growth zones: PDU and all instruments. • PMOTEDU, created by the government of the state of Quintana Roo, is a mix of POEL, POET, PDU and PMOTDU. That not only overlaps them, but duplicates them and in some points contrasts them. The PMOTDU was originally thought to order human settlements, that is, to fill that vacuum of territorial planning that were the localities and their growth reserves, where the Urban Development Programs were the instrument to which the Territorial Ecological Ordinances referred us when one or more UGA fell into a human settlement. In the federal law they are well defined, but in the state of Quintana Roo they wanted to do something innovative and a Frankenstein-type monster was created that brought together in a crude and disjointed way the instruments of urban and territorial planning and development of the human settlements law, and the ecological ordering of the General Law of Ecological Balance and Environmental Protection, and their respective state counterparts. And it has not gone well. What's wrong with this instrument? Taking as an example the instrument that in 2020 was being developed for the municipality of Othón P. Blanco, it used the same design and implementation strategy as with the instruments that we have already been discussing (Ramsar, PNA and PROTUR) in which a consultant was assigned and he structured it through a review of literature and pre-existing instruments as a diagnosis, for the selection of the criteria and the structure, the approach, the strategy, and then tried to validate with some consultations and workshops or meetings with different actors that basically belonged to the government and subsequently tried to convene the solidarity of the community by making a series of consultations at the end.

As expected, the members of the communities who had the opportunity to attend these presentation meetings and supposed pre-validation of the instrument, found a deficient document where the complete model was not included or provided for prior review, there was a lack of management units within the planning units that were key within the model that they wanted to promote for in this case Othón P. Blanco, especially close to the Bacalar lagoon and no plans or basic files – the diagnosis – were provided that could be reviewed in advance in order to evaluate the basis of the proposals and the scope of the zoning. During the presentation of the model by the consultants, there were a series of questions and requests for information channeled through writings by groups of local actors and their technical bodies, but which were not answered by the corresponding authority that was the municipality, which was the entity in charge of the instrument. Something similar happened in the process of preparing the PMOTEDU Bacalar. For this case it is necessary to point out that the demand of the community for an updated POET, and they were shown as saying, there is what they asked for... and they were given the PMOTEDU, which obviously caused widespread anger for what was presented to them. On August 10, 2020, the Congress of the State of Quintana Roo received a document from the Secretary of the Environment Efraín Villanueva Arcos where he promised to stop pushing institutionally to create a Protected Natural Area but to promote the consolidation of the ordinance. Far from updating the existing ordinance, which was the request of the communities, the state government presented them with a PMOTEDU (Municipal Program of Territorial, ECOLOGICAL and Urban Development Planning), the Frankenstein of Quintana Roo that they tried to pass off as the POET to the population that the community was requiring, and as PMOTDU -without the

E.

Again, the communities responded technically and politically with a generalized refusal. The level of disarticulation, cynicism and pettiness of the government bodies for taking over mechanisms to have their slices of the planning and control of territories is exemplified in this conversation we had with the state director of ordinances, in October 2020, regarding the scope of the PMOTEDU Bacalar, which they were promoting:

¿ This instrument (the PMOTEDU Bacalar) integrates all planning instruments? Yes If then, the integrated instruments are going to be repealed? No So they're just going to double? Yes Why aren't you just coordinating and articulating what already exists? It’ not easy So is it easier for everyone to make their own instrument? Yes

October 2020. At a meeting convened by the Secretariat of the Environment of the State of Quintana Roo.

There is a closure, disguised as the total inability of the government agencies to really generate articulating efforts, because nobody really wants to let go of their instruments, which give them that control and power, and obviously access to financing, and even to the benefits of non-legal acts. We are getting complicated with overregulation because there is no willingness, nor the sensitivity to really agree and articulate all these instruments. Or there is all the intention of, above any common sense, placing another brick on top of the wall of controls and power that the members of the triad really seek to translate it into benefits, by splicing another instrument, managed by an instance that previously had no such juicy slice in the neoliberal environmental business, in this case the state SEDATU and the municipalities.

For the ordinances to work they require other operational instruments, and in the case of Bacalar the missing ones are under the responsibility of the municipality: Urban Development Program not only of the population of Bacalar, but of Buenavista and Pedro A. Santos, which are located on the shore of the Lagoon; nor have they been in a hurry to create municipal building regulations, strengthen environmental regulations, regulate garbage dumps or make effective management to solve the pollution problem. To regulate the boats and everything related to the nautical in the body of water, the Integral Port Administration of Quintana Roo (APIQROO) was granted in 2014 the concession of the administration of the Bacalar Lagoon. Already by 2014, before having the regulation approved, it was publicly announced: that Bacalar already had an instrument that regulated the

operations of vessels, infrastructure for these activities and port areas, guaranteeing the protection of the body of water. When it was validated that same year, the rules and zoning included the designation of areas for berths, spaces for transit of small boats, jet skis and the delimitation of buffer zones, where navigation is not allowed to any type of boat. Municipality and APIQROO implement since 2014 the regulation to verify that the boats that provide tourist services, have the corresponding permits. Although this regulation has been in force since 2015, when in 2017 the proposal for a Protected Natural Area was issued by CONANP, the lack of communication and inter-institutional coordination was evident when the director of APIQROO declared that the federal institution (CONANP) did not know that the Lagoon was already concessioned to APIQROO for its administration.

The operating rules of APIQROO are supervised and updated by an Operation Committee, regulate aspects such as the areas and facilities of the port, port schedules, port navigation, port services, maritime maneuvers in the lagoon, the availability of statistical information, everything related to safety and hygiene in port facilities, docks, boats and in general in people, environmental control and pollution prevention and aspects of surveillance and protection, as well as the sanctions to which users and concessionaires become creditors for non-compliance with the instrument and applicable regulations. In an attempt to demonstrate that it was not a lack of regulation that the Bacalar Lagoon suffered, we carried out an extensive review of all the regulations of mandatory application in environmental matters, we found 87 instruments of regulation or environmental planning. When evaluating existing regulatory instruments, we find that for the issues of waste, water, flora, fauna, construction, operation of projects or activities, fishing, tourism and environmental health, at least 6 out of 10 instruments regulate one or more of these issues. In the same way we review all the mandatory regulations on safety and health applicable to companies, organizations and the development of any economic activity that is developed, a total of 133 applicable instruments that touch on aspects of construction, operation, if they refer to people, buildings, boats or other facilities.

As we already had the opportunity to review when we talked about Ramsar, since 1999 the international agreements, conventions or treaties that Mexico has signed are only below the Constitution and above any other regulatory instrument. In this regard, there are at least 47 policy instruments that cover issues of atmosphere, ozone, climate change, biodiversity (flora and fauna), urban development and housing, forestry, environment and sustainable development, cultural and natural heritage, fisheries, population, health, social, desertification, agriculture, plant health, food. It is not a question of lack of regulation in the lagoon, it is about the urgency of the articulation of the existing instruments and the creation of the missing instruments that help solve the problem of urban planning, in this case the Urban Development Program. The analysis carried out if it provides the need to create or update several key instruments to order the territory and several activities that have legal gaps. The town of Bacalar that adjoins the lagoon, is a municipal seat and does not have an instrument that plans and regulates its urban growth, requires a coherent Urban Development Program, which considers the challenges of balanced and fair development that arise in the current framework of regional impulse, with a long-term vision, with care and foresight for environmental issues, but without neglecting the social, so as not to become another instrument that privileges sustainable development from the neoliberal vision, as often happens, y como ha venido sucediendo en los polos de desarrollo turístico en otras localidades del estado, donde se privilegió la calidad en el diseño urbano y servicios para los grandes capitales mientras se invisibilizaban las necesidades del resto de la población que terminó ubicada en las famosas regiones con enormes carencias o en cinturones de miseria, bajo condiciones de vida paupérrimas.

Taking into consideration that there are two municipalities that share the Bacalar Lagoon, it is necessary to carry out coordinated actions to establish coherent mechanisms and instruments, because the body of water works as an integral system. Currently 70% of the lagoon, on the side of Othón P. Blanco, to the east, has a protection policy, while 30% of the body of water, to the west, on the side of Bacalar has a policy that allows its use. Both polygons divided by an imaginary line that departs practically through the middle of the body of water.

It is urgent to articulate the existing instruments, build the missing instruments, update those that require it and establish a coordinated implementation strategy, from real participation and not, as continues to happen, from the simulation of participation.

166

MYTH BUILDING

What is a myth? It is an imaginary story that alters the true qualities of a person or a thing and gives them more value, or less, than they actually have. The members of the triad require the creation of myths through media manipulation of public opinion to validate their proposals and become adherents who support them. In a study of this type, where it was sought to find objective bases of a socioenvironmental phenomenon to propose solutions, it was necessary to investigate, even briefly, the origin of these half-truths or blatant lies elevated to the level of myths. Because the modern myth, more with the influence of social networks and the capacity for dispersion / current communication, is more than mere story, for human groups it becomes a fact, and from there the myth / hypothesis, builds realities. Each of the myths created, which we found lacked bases, was and continues to be used as a tool to achieve followers, credibility, increase the sense of urgency, the need to acceptance, as it gives rise to the proposals of the triad, because they provide the groups that support them, their explanation of the world and life, and from there the myth builds social and psychological identities, strategies and actions, movements, policies, decisions and creates a current of public opinion that although uninformed, without foundations and manipulated to point out culprits, to benefit a few, in the name of "the common good" and exert pressure for the benefit of triad objectives.

If you ask yourself, why have promoters created these myths? The answer is simple: With the creation of myths they create their version of the world and position themselves in it as the solvers, as heroes, to impose their protectionist instruments of the territory and perpetuate the colonialist vision, where the groups of power take control of the sites or the benefits of