Thank you for your efforts in providing me with an obviously thorough view of my submission, albeit from a wider perspective than my document was intended. Firstly, and of most significant note, is that my views were expressed on the basis of, and limited to, the 'environmental' impacts of the mill as they may relate to the river environment. Any topics related to the 'process', 'policy', 'community engagement', or socioeconomic issues involving governments and/or IFC to get to the present development stage, is not of my interest or expertise. I would have thought that was abundantly clear, if you had absorbed the context of what I had presented.
I have studied the impact of pulp mills on river environments my entire 35-year career and have at least some idea of what events in these environments (biological, chemical and physical) will be affected by wastewater discharges from this industry. As an example, we have the Fraser River in British Columbia with three re-fitted ECF (Elemental Chlorine Free) pulp mills discharging more waste materials into the system at greater volume (three and one-half times greater) than the combined two mills that were originally planned at Fray Bentos. The treatment systems of the Fray Bentos mills were/are superior to the Fraser mills. The average flow of the Fraser is 1400 m3/s ... average flow of Rio Uruguay is 6000 m3/s. The dilution potential of Rio Uruguay greatly exceeds that of the Fraser. I have studied the system since the early 1970's and have found that impacts, overall, have been inconsequential with no effects on fish, benthos (perhaps some enrichment), salmon runs or tourist-related issues. I call upon this experience when looking at the Rio Uruguay situation. I firmly stand by my assertions that provided the mill operates according to 'engineering design specifications', the mill will not impact the environment, fisheries or tourism.
Relating to other points you make, I wish to clarify/correct your impressions. Regarding the Riachuelo-Metanza Basin, it was reported in the press that, in fact, the situation in the Basin came to light when the Government of Argentina (GoA) initiated their review of the Fray Bentos mills. From this statement, I expressed my opinion that the people of Argentina are 'NOT so ignorant' that they would believe the GoA's rationale for ignoring the pollution problem there... I did not say the people of Argentina were 'ignorant' as you have intimated ... you are blatantly wrong on that point. I have more respect for the Argentine people than you grant me.
On the issue of 'missing information', yes there were data gaps and requirements to upgrade the original impact statement. This was done to our satisfaction. Again, you introduce the 'process' by which supposed 'terms of engagement were not given to stakeholders'. I reiterate here, 'process/protocols' were not the subject of my document ... clearly my 'subject' appears to have escaped you.
Perhaps you should re-read my document from my perspective and in the context it was written, rather that interject issues, perhaps related in the greater scheme of things, but not integral or pertinent to my assessment.
Dr. Wayne Dwernychuk
Sr. Environmental Scientist & Advisor
Hatfield Consultants (Retired)
West Vancouver, BC, Canada