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“Countering Documents with Documents”: The Politics

of Independent Environmental Auditing in Mexico

Article  in  PoLAR Political and Legal Anthropology Review · November 2021

DOI: 10.1111/plar.12445

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Analiese Richard
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Analiese M. Richard
Universidad Autónoma Metropolitana-Cuajimalpa

“Countering Documents with Documents”: The Politics of

Independent Environmental Auditing in Mexico
Environmental impact statements are designed to enable rational calculation of the ecolog-
ical risks of proposed development projects and to serve as a basis for institutional decision
making. In Mexico, a neo-extractivist “boom” has led to massive ecosystem loss and envi-
ronmental activists are increasingly under threat of violence. Now these same activists and
the residents affected by development projects have targeted these bureaucratic instruments
as key points of legal intervention and political mobilization. This article analyzes how vol-
unteer scientists conduct independent audits of environmental impact statements and how
their work provides the grounds for critiquing the state’s performance of public reason.
Independent audit constitutes an innovative form of administrative politics that seeks si-
multaneously to hold bureaucrats accountable and open the decision-making process to
the participation of excluded actors. [expertise, governance, environmental movements,
science, Mexico]
On a bright spring day in 2016, I was holed up in the back corner of an ecology lab on
the campus of the National Autonomous University in Mexico City, peering at a split-
screen display as a young doctoral student explained the intricacies of her team’s project.
She laid out side by side two topographical maps of a mountainous region in southern
Mexico. On the left side of the screen was a digital version of an official map published
by the National Commission for the Knowledge and Use of Biodiversity (CONABIO, by
its Spanish initials). On the right was a map included as an appendix to the Manifestación
de Impacto Ambiental (hereafter MIA), an environmental impact statement filed with the
federal Ministry of Environment and Natural Resources (SEMARNAT) by a Canadian
company seeking permission for an open-pit gold mine.
“Look here,” she said, gesturing to the map on the right. “In the MIA they have to include
a map locating the mine—that’s the part in red—and also its ‘area of influence.’ That’s the
part in yellow.” She asked, “So what do you notice first about this map?” The mine, in red,
was located at the top of a mountain. Flowing down from the mountain was a system of
streams that formed a large river that flowed out to the ocean via a wide delta. The first
detail to catch my eye was that the yellow “area of influence” that should have marked the
zone within which the environmental impacts of the project—such as toxic runoff—were
likely to be experienced, included only the upper part of the river system. It excluded both
the main river and the delta where it met the sea.
“I am only an anthropologist, not a biologist or a geographer,” I answered cautiously,
“but this seems a little strange. Is this what the team picked up on?”
The doctoral student said:

Well, that’s a good first guess. I mean, yes, scientific studies and past cases
here in Mexico have shown that contamination of surface water by mining
runoff is nearly impossible to contain. But the law leaves it up to the project

PoLAR: Political and Legal Anthropology Review, Vol. 00, Number 0, pp. 1–17. ISSN
1081-6976, electronic ISSN 1555-2934. ©2021 by the American Anthropological Association.
All rights reserved. DOI: 10.1111/plar.12445.
Page 2 PoLAR: Vol. 00, No. 0

promoter to define the “area of influence,” in other words there is no existing

legal guideline to establish how an “area of influence” must be defined. So
technically there is no violation here, even though you and I look at this and
have to wonder whether the laws of gravity have magically been suspended in
this watershed. In a lawsuit, a judge may or may not take this kind of thing into
account.

“I see,” I replied. “So, what was it the team saw in this map?”
“Look over here,” she said, moving her cursor and clicking to expand the developer’s
map on the right. “Look, do you see these two small lakes in the delta? There is one shaped
like a sausage and another little round one. Now look at the other map. What’s different?”
I shifted my gaze to the left side of the screen, to the official CONABIO map, where I now
discerned three lakes instead of two.
She said:

You see here in the other map, they’ve painted over that third lake in another
color and erased its name. You can see the crooked marks, like they didn’t even
bother to Photoshop it. But that’s not the end of it. You’ve got to ask yourself,
why erase this lake and not the other two? The answer is on the left-hand side of
our screen. It shows the distribution of mangroves in and around that missing
lake, and mangroves are a super protected species, under both Mexican and
international law. And that is the kind of detail a judge would definitely be
interested in! I mean, we can prove that not only is the developer purposefully
lying in the MIA, but that they are doing it to cover up environmental impacts
and that some of those impacts will affect protected species.

Environmental impact statements are designed to enable rational calculation of the eco-
logical risks of proposed development projects. Such administrative tools form part of
what Sheila Jasanoff (2012) has termed “public reasoning,” the “institutional practices, dis-
courses, techniques and instruments through which modern governments claim legitimacy
in an era of limitless risks—physical, political and moral” (xi). Mexico’s national Environ-
mental Protection Law requires developers to present an environmental impact statement to
the SEMARNAT for approval before any major project can commence. Importantly, MIA
approval is also required by lenders to finance a project. In recent decades, a neo-extractive
boom accompanied by an upswing in public-private infrastructure projects and tourism de-
velopment has led to the growth of an entire consulting industry dedicated to the prepara-
tion of MIAs and management of the SEMARNAT review process on behalf of developers.
At the same time, an important strategy to fight official SEMARNAT resolutivos (deci-
sions) has become the filing of independent audits by scientific experts. There are few offi-
cial opportunities for public feedback on major development projects and none of them are
binding. However, a project that threatens ecosystems or communities can be halted legally
by alleging negligence on the part of SEMARNAT during the review process. The doctoral
student was teaching me that identifying faulty methods, legal lacunae, and outright fraud
in approved project MIAs is the first step in contesting SEMARNAT’s decisions, both in
the court of law and court of public opinion. The participating scientists put their inde-
pendent audits into written and signed reports that answer point by point SEMARNAT’s
resolutivos and cite published evidence (sometimes from the government’s own agencies)
and international standards. Beyond the bureaucracy, their reports circulate among multiple
audiences, including lawyers, judges, environmental groups, media, residents of affected
xxxx 2021 Page 3

regions, and the public. By “countering documents with documents,” as one collaborator
put it, these scientists seek to intervene in environmental decision making in a way that
holds SEMARNAT accountable without undermining its authority, or their own.
Through initial contacts in 2014 with members of organizations such as Union de Cien-
tíficos Comprometidos con la Sociedad (Union of Socially Committed Scientists; here-
after, UCCS) and Asociación Nacional de Afectados Ambientales (National Association
of Environmental Victims), I began tracing networks of scientists who had provided expert
testimony in court cases, consulted with movement coalitions, or participated as experts
in the elaboration of environmental policy. From 2016 to 2019 I conducted ethnographic
fieldwork in Mexico City, including at the headquarters of SEMARNAT, with scientists
who pioneered the independent audit strategy, interviewing them about their experiences
with MIA auditing. I visited university laboratories like the one described above, as well
as government offices, and I participated in public fora organized by researchers, activists,
authorities, and media outlets around a series of controversial megaprojects. I spoke with
federal officials, environmental lawyers, and NGO representatives. I analyzed MIA case
files and supporting documents, and in 2017 I participated alongside Mexican scientists
and activists in a twelve-week online workshop designed to create a cadre of volunteer
experts capable of auditing MIAs and providing technical opinions to citizen groups. In
what follows, I explain how the MIA became a point of departure for forging new spaces
of accountability within technocratic processes of environmental governance, in a context
of deep distrust of bureaucracy.
I argue that independent MIA auditing constitutes both a political strategy and a form
of moral critique aimed at curtailing SEMARNAT bureaucrats’ discretion in their decision
making and the forms of strategic ignorance underpinning it. Independent audits use antic-
ipatory knowledge to elaborate an “informational counterweight” disputing the technical
information and risk assessments presented in the developer’s MIA. This strategy of coun-
tering documents with documents permits volunteer scientists to insert themselves into
the highly unequal power dynamics mediated by technocratic environmental governance,
producing a sometimes contradictory form of administrative politics.

The MIA as Artifact, Anchor, and Point of Entry

In recent years, anthropologists have examined how the simultaneous intensification of re-
source extraction and contraction of the political sphere have brought about new political
formations in Latin America. Bebbington and Bury (2013) highlight the traditional role of
the state as the owner of the subsoil as a key reason why many contemporary struggles
center on the state’s legitimacy as a steward of common goods. Under neoliberalism, this
stewardship role has been increasingly carried out via the implementation of technocratic
modes of environmental governance, implying a new role for scientific expertise in pub-
lic life. This shift has, in turn, influenced grassroots efforts aimed at opening new spaces
of accountability in which governments and corporations ideally answer to citizens for
the environmental risks and harms associated with development projects (Graeter 2017;
Li 2015; Sawyer 2004). Important work has focused on how the incommensurability of
ways of knowing and valuing territories and places contributes to environmental conflict
in contemporary Latin America (de la Cadena 2015; Liffman 2017) as well as how “par-
ticipatory” decision-making processes offered as a technocratic solution to such conflicts
ultimately work to soften and circumscribe opposition (Li 2016). However, my aim in this
section is to show how volunteer scientists carve out new spaces of accountability within
these very processes of environmental governance and how an administrative document—
the MIA—became their key point of intervention.
Page 4 PoLAR: Vol. 00, No. 0

The online auditing workshop I took part in taught participants how to map SEMAR-
NAT’s decision-making processes as well as how to diagnose errors and fraud in MIAs and
resolutivos. The award-winning Mexican research scientist who organized this workshop
had worked for the better part of a decade with several nongovernmental organizations to
pioneer the use of independent audits. “The impact statement [MIA] is the starting point
for all other permits,” he explained to me in an interview one year earlier in his lab. “So
it’s a strategic spot, but we soon noticed that it’s also a spot that’s really quite crippled,
hollow, shoddy. Everything is balanced on that one little point, the entire infrastructure
of the country is poised over this one little step that’s incredibly weak in every sense.”
The aim of the independent audit is to give this “weak” administrative process teeth and
to open up the decision-making process to the participation of actors—such as affected
communities—who are routinely excluded.
The MIA is a technocratic artifact, and its approval is a key moment both for the de-
velopment project in question and those who oppose it. The Mexican federal government
regularly dismisses concerns by residents about potential environmental degradation and
human health impacts by referring to MIAs and resolutivos that declare low to no risk as-
sociated with a project. Bureaucrats distinguish these documents as authoritative, with the
burden of proof placed on the complainant. According to Paz (2010), this is what originally
motivated communities involved in environmental conflicts to seek out scientific experts
as collaborators. Because presenting an MIA and getting it approved by SEMARNAT is
an established bureaucratic practice, independent audits provide a platform for introducing
technical evidence that can help the claims of activists and residents be “heard” by SE-
MARNAT, by the legal system, and by the general public. Independent MIA audits lend
legitimacy and authority to activists’ and residents’ counterclaims and over time have come
to reshape the legal and moral arguments of their opposition campaigns. The documents
produced via independent audit further serve as concrete anchor points for shifting coali-
tions of residents, lawyers, scientists, and environmental groups. As I show, independent
auditors’ documents also provide a relatively “safe” vantage point from which to analyze
and discipline the actions of environmental authorities.
Mexico is one of the most dangerous places in the world to be an environmental ac-
tivist. Between 2012 and 2019, there were 499 registered attacks on environmentalists;
and in 40 percent of the cases, the presumed aggressor was a government agent, most of-
ten local law enforcement officers or National Guard troops (Leyva et al. 2020, 27). Paz
(2014) argues that the sharp increase in environmental conflicts in Mexico is rooted in fail-
ures of environmental management within an authoritarian model in which decisions are
made in a top-down fashion and dissent is dealt with via a combination of repression and
paternalism. The stakes for private companies are very high—such ventures are incredi-
bly profitable and minimally taxed. They are even higher for communities that depend on
affected ecosystems for their survival. “Outsiders” who interfere are dealt with harshly,
usually through the auspices of local authorities who also stand to profit handsomely. In a
two-week span in spring 2020, three environmental activists (one a lawyer and another a
scientist) were killed in three separate incidents (Pradillo 2020). All of them were involved
in struggles against major development projects. Participants in the online workshop and
other scientists I interviewed recounted threats or incidents of violence committed against
themselves and/or against colleagues who spoke out against development projects. During
my fieldwork, on multiple occasions, I witnessed public accusations of bias or political par-
tisanship launched against researchers who collaborated with environmental movements,
attacking their reputations in professional settings or in the press. Independent MIA audits
xxxx 2021 Page 5

offered the possibility of avoiding direct confrontation, countering an official document

with another document, and speaking with the collective institutional voice of science.
Most contemporary work on experts and democracy focuses on their role in public de-
liberation, particularly around environmental policy and regulations (Brown 2009; Collins
2014; Kitcher 2011; Turner 2001). Work on accountability mechanisms in Latin Amer-
ican democratic transitions has also focused principally on how citizen ideas are “taken
into account” in the creation of public policy (Paley 2004). However, as Partha Chatter-
jee (2004) notes, in postcolonial contexts, important political questions are often worked
out at the level of administration—the infrastructure of government itself—where they are
seldom made visible as political. New forms of politics and emergent political questions
are increasingly grounded in governmental functions—engaged and negotiated at the level
of administration—rather than in formal means of political participation, such as ideo-
logically based parties (Mouffe 2005, Von Schnitzler 2016). Technical struggles over the
correct application of extant regulations then become politics in an administrative key,
“embedded in and prefigured by political struggles” (Schwegler 2008, 683), rather than a
displacement or depoliticization of politics (Escobar 1995; Ferguson 1994). Recent anthro-
pological work on the deployment of expert knowledge in environmental disputes in Latin
America has focused on the use of technoscientific data to substantiate political or moral
claims (Graeter 2017; Sawyer 2004) and has underscored the ways in which the form and
process of environmental review procedures actually work to limit state responsibility in
cases of conflict (Li 2015). I deepen this discussion by showing how independent audi-
tors insert themselves into what is intended to be a self-monitoring mechanism typical of
neoliberal accountability measures (Strathern 2000). They seek to hold SEMARNAT ac-
countable for following legally prescribed procedures and international scientific standards
in its decision-making processes and thus, by extension, they demand that the Mexican
state perform a more neutral role as mediator between citizens and corporations.
This form of administrative politics responds to the foreclosure of political space through
the violence mentioned above, as well as the marginalization of environmental issues
within the formal political agenda. In Mexico, environmental issues have never formed
part of any major party’s platform or the platform of any major electoral candidate.1 When
independent MIA audits provide technical grounds for legal injunctions, they participate
in the “judicialization of politics,” another aspect of the new political formations arising
out of neo-extractivism (Couso, Huneeus, and Sieder 2010). Political struggles are carried
out through legal institutions and discourses, and they take on new prominence through the
technocratic reforms brought about under neoliberalism (Comaroff and Comaroff 2006,
26). Bornstein and Sharma argue that law and policy have become sites of moral contesta-
tion as well, resulting in what they call “technomoral politics”:

By “technomoral” we mean the complex, strategic integration of technical and

moral vocabularies as political tactics. In mixing the languages of law and pol-
icy with moral pronouncements, state and non-state actors posture themselves
as defenders of rights and keepers of the public interest as they push their
agendas and stake out distinctive positions. (Bornstein and Sharma 2016, 77)

Independent MIA auditing is both a political strategy and a moral technology, whose
success rests on careful boundary work to demarcate the domain of scientific authority
and demonstrate its superiority while keeping the institutional authority of SEMARNAT
intact. Its immediate aim is to create what auditors call a contrapeso de información
(informational counterweight) that not only permits excluded actors to be “heard” in
Page 6 PoLAR: Vol. 00, No. 0

decision-making processes but also serves to expose and critique administrative practices
the auditors perceive as abuses of power. Volunteer auditors attempt to hold SEMARNAT
accountable on technical grounds, pointing out the strategic exclusion of technical details
from MIAs and resolutivos, and thus attempting to raise the political costs of institutional
disregard.

“Manifestations of Environmental Cynicism”: The Politics of Willful Ignorance

The instantiation of the MIA as an administrative tool is closely tied to the judicialization
of environmental conflicts in Mexico, a process spanning several decades. Mexico’s envi-
ronmental code, the General Law of Ecological Equilibrium and Environmental Protection
(LGEEPA) was first promulgated in 1988 and later reformed in 1996, as part of the tri-
lateral negotiation of the North American Free Trade Agreement. While new legal codes
in Mexico are normally hammered out between government authorities and professional
politicians, none of the major political parties—neither the official PRI nor the opposi-
tion parties of the PAN and PRD—developed platforms with regard to the LGEEPA. This
political vacuum ironically created an opportunity for environmental NGOs, then gaining
traction on the national political scene and supported by international networks. Moving
away from a hygienist vision of nature–society relations, their proposals focused on the
health of ecosystems, taken to have an intrinsic value and postulated in the law as the
“common patrimony of society,” for whose care and protection the state and citizens were
to be coresponsible.2
According to Azuela, “NGOs and environmental activists brought to the table not only
their ideas about the environment, but also about the law” and about how state power should
be exercised (Azuela 2006, 67; my translation). Civil society groups were portrayed as fun-
damental actors in what the World Bank was then calling “good governance” (World Bank
1989), a procedural model of democracy in which active citizens participate in decentral-
ized decision-making processes. The “transparent” production, access, and management of
information were seen as preconditions for the operation of this hegemonic model, permit-
ting rational citizen participation both in the design and implementation of public policies
and in their evaluation (Hetherington 2011). The LGEEPA was the first law in Mexican
history to include transparency and public consultation measures, centered on the fed-
eral environmental impact review process (Azuela 2006, 67). Thanks to the important role
NGOs played in the legitimization of the law, they were able to pressure the government
to adopt right-to-information guidelines during the 1996 reform of the LGEEPA (133).3
In Mexico, environmental impact review marked a radical change in administrative pro-
cedure because it was the first time any public enterprise was subject to evaluation by a
separate environmental authority. Previously, development projects were officially viewed
as sources of modernity and progress rather than a threat to national patrimony (Azuela
2006, 115).4 Despite the law’s progressive rhetoric, however, this procedure, once it was
transplanted into the Mexican legal system, became subject to the same broad range of
administrative discretionality inherent to that system.5 Nonetheless, the information con-
tained in MIAs and the resolutivos rendered by SEMARNAT, accessed through the new
transparency rules, became a key resource for environmental mobilizations from the 1990s
on.
As the MIA came to occupy a central place both in environmental regulation and broader
campaigns for transparency, it also emerged as an artifact of public reasoning (Jasanoff
2012), deployed to justify SEMARNAT’s adherence to legal standards. According to one
former SEMARNAT functionary I interviewed, by 2006 the length of the resolutivos
issued by the agency had more than doubled from their original format. The number of
xxxx 2021 Page 7

transparency requests filed by environmental NGOs skyrocketed, as activists sought to de-

cipher how particular decisions had been made, by whom, and on what technical grounds.
The agency’s director ordered his staff to “get out ahead of the NGOs” by including all of
the information possible in the resolutivos and thus producing documents that now com-
prised hundreds of pages. This was an unusual tactic from a branch of a federal government
known for concealing information (and it ended with this director’s tenure), but it failed to
silence critics, who increasingly scrutinized this documentation with help from volunteer
scientists.
In Mexico, interactions between citizens and the bureaucracy take place in an atmosphere
of deep distrust and opacity. In the postrevolutionary period, Mexican bureaucracy has
evolved as part of the political system, where patronage, patrimonialism, and the formation
of camarillas (political teams) takes place in and through public administration (Arellano-
Gault and del Castillo-Vega 2004). Thus, politics in the administrative register, of which
independent MIA audits are an example, must consider the intimate relationship between
discretionality in decision making and what might otherwise appear as mere bureaucratic
ineptitude. Contemporary environmental conflicts are overwhelmingly tied to the failure of
environmental agencies at the municipal, state, and federal levels to enforce existing laws
and regulations, which sometimes conflict (Paz 2014; Rojo et al. 2018; Ugalde 2010). But
this bureaucratic dysfunction is far from neutral. In their detailed study of conflicts over
infrastructure development in protected natural areas, Ávila et al. (2012) show how elites
bend the rules in their favor, selectively ignoring environmental regulations or pressuring
local authorities to relax planning requirements. When challenged by citizen groups, they
invoke political connections at the federal level to facilitate land use changes, effectively
deregulating protected areas on a case-by-case basis to suit their interests. According to
scientists and activists I interviewed, this pattern is amplified in cases where state agencies
are party to the development projects under review, as in the case of energy or transporta-
tion infrastructures. In the words of one interviewee, “son juez y parte” (the government is
both the judge and the litigant). It is thus common for political pressure to be exerted on
SEMARNAT functionaries, conditioning their decisions.
Nuijten offers important clues about the role bureaucratic procedures play in such power
struggles:

Although in Mexico it is generally acknowledged that power is concentrated

in the hands of regional elites and powerful political families who can easily
bend bureaucratic procedures to their own advantage, the state apparatus con-
tinuously propagates the idea that it operates in a modern, technocratic, profes-
sional manner. In this way … a systematic divide is created between national
ideology and actual power relations… . This leads to the fascinating situation
of a society in which “money and relationships” are to a large extent determin-
ing for what happens, but where at the same time continuous reference is made
to the importance of formal procedures and the civil order. (Nuijten 2004, 226)

Nuijten (2004) refers to the Mexican bureaucracy as a “hope-generating machine” (211),

where functionaries continually offer to initiate new administrative procedures when con-
flicts arise, making promises without ever resolving cases. This produces a perpetual lack
of closure, allowing conflicts to fester while development projects get underway. And, as
both scientists and environmental lawyers have learned through experience, once construc-
tion begins, a development project quickly becomes a fait accompli. Functionaries can thus
avoid ruling in favor of powerful elites on the record while permitting the latter to pursue
Page 8 PoLAR: Vol. 00, No. 0

their interests in the meantime. Their role is complemented by that of political authorities
at local, state, and national levels, who deal with dissent via a combination of patronage
and violence. Bureaucratic procedures such as MIA reviews not only hold out hope for a
peaceful legal resolution but also provide authorities with the means to exclude dissident
actors from official decision-making processes. In this context, it is no surprise that many
independent auditors suspect that SEMARNAT’s environmental review process is inten-
tionally weak. Indeed, independent MIA auditing provides them with a privileged vantage
point from which to question the role of technical expertise, and even of knowledge itself,
in Mexican environmental governance.
A developer who wants to carry out a project—a tourist resort, a mine, an industrial park,
a wind farm, a highway—must first prepare and file an MIA with SEMARNAT. The docu-
ment must describe the project in detail, describe the actual state of ecosystems and natural
resources located in the project area, analyze potential environmental risks and relevant
legislation governing them, and propose mitigation measures. While SEMARNAT (2002)
provides a guide for how to format an MIA and what kinds of information to include,
developers are under no legal obligation to follow it. Neither does SEMARNAT provide
guidelines on how to evaluate potential environmental risks. Given the technical complex-
ity and size of the task—MIAs can run to hundreds of pages and integrate information from
multiple legal and scientific disciplines—MIAs are typically prepared by teams of private
consultants hired by the developers. Upon receiving the MIA, SEMARNAT publishes it
online in an official gazette. By law, officials have three weeks to render their decision,
either granting permission or imposing additional conditions for approval. According to
interviewees, the only compliance oversight is through the developer’s self-reporting; SE-
MARNAT itself does not typically perform field compliance checks.
Projects are rarely rejected outright. Under routine circumstances, the only opportunity
for public comment on a development project must be triggered by a formal request for
nonbinding public consultation filed with SEMARNAT in the first ten days following the
publication of the MIA. Article 1 of the Indigenous and Tribal Peoples Convention, In-
ternational Labour Organization (ILO) Convention 169 (ratified by Mexico) recognizes
the right of Indigenous communities to be consulted about development projects that pose
risks to them or their territories. Nonetheless, attempts to implement this standard in Mex-
ico have been fraught with serious irregularities (Freide and Lehmann 2016; Gomez Rivera
2013; Rea Granados 2015).6 Most communities affected by development projects do not
find out about them until the MIA has already been approved—or when work crews show
up.
What kind of artifact, then, is the MIA? One former participant in independent MIA
audits told me:

The MIAs are an administrative tool, and different scientists have different
opinions about them. There are those who say that they are tools for justifying
changes in zoning and land use (to enable development projects) and others
who say that they are a way of slowing down the impacts because otherwise
they would be worse, but either way the MIA is a double-edged sword.

On the one hand, the “deficiencies” in the MIA review process and SEMARNAT’s near-
universal approval of projects have led some scientists to call the process a sham, a sim-
ulación, intended to legitimize decisions made based on political or economic interests
rather than technical criteria. One joked that the MIA acronym should be changed to MCA,
for manifestación de cinismo ambiental (manifestation of environmental cynicism). He
xxxx 2021 Page 9

argued that the consulting firms that prepare flawed or fraudulent MIAs and the SEMAR-
NAT functionaries who take them at face value share a basic contempt for truth. Others
I interviewed saw this bureaucratic process as flawed but improvable. Their independent
auditing work was aimed at holding SEMARNAT accountable, exposing conflicts of in-
terest, and ideally reforming the MIA process to reduce the level of discretion in decision
making. Both idealistic and more pragmatic approaches were used to expose technical and
procedural “flaws” and make their ecological and legal consequences visible.
One aim of the online workshop mentioned earlier was to map out current bureaucratic
procedures associated with environmental risk assessment in Mexico, illuminating how
the process works in practice. Some of the participants were environmental activists; some
were scientists working for environmental consulting firms; some had worked at state agen-
cies and were familiar with the parts of the process that they themselves had been respon-
sible for; and yet others were academic research scientists with no previous experience
in environmental impact assessment. The group drew on both their personal experiences
and a limited “how-to” literature consisting of manuals put out by government agencies.
Their collective mapping was aided by a fact that many of them considered to be another
deficiency—in Mexico, there exists a single set of guidelines for environmental impact as-
sessment, regardless of the type of project (from open-pit mining to highway construction)
or type of ecosystem (from mangrove marshes to mountain forests to deserts). This pre-
cludes regulations from specifying methodologies for estimating anticipated impacts. The
workshop participants related this ambiguity to another set of problems associated with
conflicts of interest. One person expressed it this way:
Basically, if you read the LGEEPA and the regulations, you’ll notice there are
no clear guidelines for how to do an MIA. Yes, it tells you what information
the MIA should contain, but not how to generate it. All of this is left up to
the consultants to determine. And the consultants can basically come up with
any method they want to define the impacts, right? So if they are being paid
by a corporation that wants to build a project, then obviously they are going
to want that company’s project to be approved. So obviously they are going to
use whatever method they can to get a result that SEMARNAT will approve.
The lack of clear criteria was seen by the group as enabling the consultants’ discretion
to prepare MIAs according to their own criteria, which reinforced the SEMARNAT func-
tionaries’ discretion to not independently verify the information presented in MIAs. The
same person also explained:
Part of the problem is that … the evaluation that SEMARNAT carries out is
done from behind a desk. They don’t do field visits.7 So basically SEMARNAT
has no other option than to believe (take as fact) whatever the consultant puts
in the MIA.
Participants of the online workshop noted that sources of important information about the
potential environmental risks of proposed projects were excluded or obscured from view
by the rules of the process. They cited the extremely limited opportunities for public in-
put as well as the nonbinding nature of those opportunities. Even independent experts,
they pointed out, have a hard time weighing in. SEMARNAT can solicit expert opinions
from universities or other federal or state agencies, but the strict twenty-day limit prohibits
detailed information-seeking. Further, the technical opinions rendered by these outside
experts are nonbinding and seldom made public unless through a transparency request,
Page 10 PoLAR: Vol. 00, No. 0

after the fact. All of this enables both project promoters and SEMARNAT officials to min-
imize, ignore, or exclude serious potential impacts from the MIA and from SEMARNAT’s
formal decision on it. For many of the scientists I interviewed, these omissions and opacity
appeared as opportunities for functionaries in high positions to deny responsibility for il-
legal or immoral acts by denying knowledge of them. Many told me, “Se hacen pendejos”
(They play dumb). I observed high-ranking officials, when they were questioned in public
fora about environmental conflicts resulting from approved projects, shift blame onto sub-
ordinates or side-step the issue entirely by insisting that the minimum legal requirements
for MIA approval had been met.
Part of the moral politics of independent MIA auditing is precisely to reduce the ef-
ficacy of such “strategic ignorance” (McGoey 2012). Since the nineteenth century, the
management of information, through the creation and organization of documents, has been
considered evidence of the “ethical competency to rule” (Osborne 1994, 290). Contempo-
rary calls for transparency and documentation index this moral imperative of bureaucracies
to knowledge—and self-knowledge (Riles 2006, 6). Independently auditing an individual
MIA and undertaking a systemic critique of the “deficiencies” of the administrative pro-
cess within which the MIA is embedded is a way of puncturing and countering a state
performance of public reason.
By questioning the rational-technical means through which SEMARNAT carries out en-
vironmental reviews, the participants in the workshop questioned the state’s claim to reason
on behalf of both the people’s and Mexico’s environmental future. They saw the MIA not
only as a potential means of avoiding or mitigating the environmental harm caused by spe-
cific projects but also as a key component of environmental planning and management.
Ideally, the MIA would provide the state with knowledge to help make strategic planning
decisions about collective futures in scenarios of great complexity. However, the image of
the state that emerged from my conversations with scientists involved with independent
MIA reviews was that of a powerful entity that sought to achieve plausible deniability
rather than produce or use knowledge in a way that promoted the common good. Func-
tionaries who failed to question a missing lake or ask why a watershed “magically defied
gravity” revealed an administrative logic that was not only morally debased, as Akhil Gupta
(2012) has suggested in his ethnography of Indian bureaucracy, but also that allowed them
to intentionally distance themselves from reality by being willfully ignorant.
Nonetheless, scientists performing independent MIA audits thought it unwise to openly
challenge the authority of SEMARNAT functionaries. If the legitimacy of environmental
review procedures was questioned outright, developers would have few, if any checks, on
their activities. At best, a public slight would risk closing channels of communication and
possible negotiation with the institution. At worst, a direct frontal attack on SEMARNAT’s
credibility might also run afoul of powerful elites, inviting reprisals. In the next section, I
show how this moral critique of strategic ignorance manifests during an independent audit
report.

To “Defend What We Know Best”: Science and Anticipatory Knowledge

Many of the scientists I interviewed were first motivated to conduct independent MIA
audits because of threats to their own field research sites and its inhabitants (human and
nonhuman) posed by a development project. For many, this field site was the place in and
through which they had first become scientists, and whose broader significance for un-
derstanding life on the planet had been articulated in a master’s or doctoral thesis. They
felt called as experts about the site as well as through their personal connections to it, to
“defend what we know best,” as one biologist put it. By virtue of these same connections,
xxxx 2021 Page 11

many had also been closely involved in various ways with the federal environmental protec-
tion agencies whose procedures and decisions they critique via independent MIA audits.
Several of them had participated in official projects to generate or reform environmen-
tal codes or management protocols. Their detailed familiarity with official administrative
practices—a product both of personal experience and the generalized judicialization of the
environmental field over the past twenty years—made it possible for them to counter doc-
uments with documents constructed in the very same bureaucratic style, answering point
by point, and citing paragraphs and subsections of the federal environmental code as well
as relevant scientific literature. The purpose of this mimesis was to influence the decisions
of SEMARNAT bureaucrats and provide lawyers with potential technical arguments, pro-
ducing an alternative performance of public reasoning. As one independent auditor put it,
“You are not trying to usurp their role as decision makers, you have to be more subtle,
like, ‘Look, we’re going to help you out, because you may not have realized everything
that could happen’ [if you approve this project].” Another interviewee pointed out that
the methodology of the independent audit mimics the scientific practice of peer review.
Independent auditors felt most comfortable when defending what they knew best in the
way they knew best. Most preferred to think of themselves as “referees,” rather than as
activists, performing the role of neutral arbiter that the state, in their view, was incapable
of or refused to take on. Countering documents with documents enabled them to produce
simultaneously a moral distinction and a form of distance intended to preserve both their
professional authority and their safety.
The production of independent audit reports closely resembles what Schwegler, in her
study of neoliberal policy reform in Mexico, termed “anticipatory knowledge,” which is
a strategy used by rival policy teams within the federal bureaucracy to “recast their …
proposals on the basis of their ideal-type anticipations of what a rival team will present”
(Schwegler 2008, 686). Anticipating the rival’s approach enables a team to couch its own
arguments in the technocratic language of the other, pointing out defects and errors in the
original language and format. This aligns with the underlying logic of Mexican bureau-
cratic power as discussed earlier and aids in understanding key features of independent
audit documents, as the following example will illustrate.
In 2013 a group of concerned citizens from Tampico, a port city in the eastern state of
Tamaulipas, contacted the UCCS for help in auditing the MIA of a proposed “ecological
park” slated for development by a public-private partnership that included the municipal
government and several powerful corporations. The citizens became concerned when a
city crew showed up one day with heavy equipment and began to deforest the northern
portion of the Laguna del Carpintero, an important mangrove located where the Pánuco
River meets the Gulf of Mexico, and one of the few remaining natural areas in Tampico.
They subsequently learned that the proposed park would completely drain and fill in the
mangrove, paving it over to create a tourist attraction with a “green” theme. As it turned
out, the well-connected developers had not even bothered to submit an MIA to SEMAR-
NAT. With advice from the UCCS, the citizen group filed an injunction, forcing the city
and its partners to submit an MIA, and then solicited a public hearing on it. A team of
volunteer scientists from National Autonomous University (UNAM) in Mexico City and
the Institute of Ecology in nearby Xalapa (known for its expertise in coastal wetland ecol-
ogy) produced a point-by-point refutation of both the data and analysis presented by the
developers. Its format followed exactly that of the MIA, beginning with a legal preamble
that cites the federal environmental codes relevant to the case, establishes the volunteer
auditors’ right to participate in the public hearing, and makes clear the legal obligation of
SEMARNAT to take their findings into account. They also solicited a formal response to
Page 12 PoLAR: Vol. 00, No. 0

reduce the discretionality of SEMARNAT functionaries and simultaneously to signal their

institutional location and authority by listing a UNAM correspondence address.
The audit identified grave risks to endemic and endangered flora and fauna that had been
severely underestimated in the MIA. In addition, the independent auditors highlighted the
loss of ecosystems services implied by the development. Excluding these from the MIA
obscured the increased risk of flooding and wind damage from hurricanes and storms the
development would cause. The UCCS team also found sloppy methodology and contradic-
tory information in both species counts and hydrological studies. Most important, however,
the developers were using the fact that the mangrove was damaged—damage they them-
selves caused—to argue that there were few native species remaining in the site and thus
the environmental impact of the development would be negligible. To counter this claim,
the UCCS auditors first cited recently published studies attesting to the abundance and
importance of the biodiversity in the Laguna del Carpintero. They then dismantled the pro-
moters’ argument, couching their objections in the exact legal and procedural terms used
in the MIA and foregrounding information excluded from it:

Given that Mexico’s mangrove ecosystems are protected by NOM-022-

SEMARNAT-2003, NOM-059-SEMARNAT 2010 and Article 60 of the Gen-
eral Wildlife Law, it is crucial to point out that the project promoter illegally,
deliberately, and clandestinely deforested of all the site’s vegetation in 2013,
including mangrove communities that were recuperating from previous illegal
logging. Subsequently, the promoter presented to SEMARNAT the MIA of the
project “Lago del Carpintero Thematic Ecological Park” which stated, con-
veniently, “the predominant species in the site are weeds, principally grasses
such as Bermuda grass (Cynodon dactilon) and highway grass (Bothriochloa
pertusa)” (MIA-IV 2.2.1.3). Therefore, if SEMARNAT approves this project,
it will be in violation of the LGEEPA as well as its own codes and procedures,
which clearly specify that MIAs should be presented and reviewed prior to the
start of any project.”8

This passage accomplishes several things simultaneously. Imitating the format and termi-
nology of the original MIA assures the independent audit document is legible to and usable
by SEMARNAT functionaries, lawyers, and judges. By providing scientific evidence ex-
cluded from the MIA—and making it available to the public via the hearing and online
circulation of the audit report—and highlighting the legal obligations of SEMARNAT, it
reduces functionaries’ ability to “play dumb,” and thus restricts their discretion in their
decision making. Reversing the dynamics mentioned by Paz (2010), it places the burden of
proof back on the developer and by extension on SEMARNAT. But the content and form
of this passage is also an attempt at moral ordering. If SEMARNAT violates its own proce-
dures and ignores the evidence and technical analysis presented in the independent audit, it
forfeits the ability to legitimate its decisions by attaching them to scientific expertise (see
Gieryn 1999). As Jasanoff reminds us, that which is “not science” is “mere politics” that
at best lacks cognitive authority and at worst is a sham (Jasanoff 1990, 14). To participate
in such simulation, the UCCS audit document implies, is to engage not in ignorance but
in criminal negligence. Indeed, SEMARNAT eventually denied permission for the project.
The developers pushed on via legal and extralegal means until the case ended up in the
Mexican Supreme Court, where the justices found in favor of the concerned citizens in a
landmark decision.
xxxx 2021 Page 13

Conclusions
The doctoral student who walked me through her team’s independent audit of a mining
MIA came of age as a scientist in an era when Mexican environmental politics had long
been thoroughly judicialized. The problems that drew her attention—like the outright era-
sure of a lake that includes the habitats for endangered, protected species—were legible
and actionable through a juridical frame. In a strict sense, what she and her colleagues
were contesting was not the technical faults themselves but rather the failure of SEMAR-
NAT to detect them. Rather than confront a foreign mining corporation head-on, they chose
to help make a legal case against flawed administrative decisions by a public agency. Their
intimate knowledge of such procedures and documents made this kind of work possible,
but also made it necessary for these scientists to continually distinguish themselves from
others involved in the same processes. They contrasted their role as experts “defending
what they know best” to the moral degeneracy of a state that prefers to “play dumb” in the
face of overwhelming environmental destruction. Even while critiquing the “simulated”
nature of bureaucratic practices, they nonetheless uphold the authority of environmental
governance institutions they see as having abandoned their moral and civic responsibilities.
Like the technoscientific interventions analyzed by Sawyer (2004), Li (2015) and Graeter
(2017), independent auditing corroborates the political and moral claims of residents on
technical grounds and provides a means of legally contesting development projects that
threaten the ecosystems on which they depend. As these and other authors have pointed
out, this technocratic approach often undermines alternative forms of knowledge and pol-
itics. Nonetheless, given the contraction of the political sphere and the very real dangers
associated with more traditional means of creating political pressure, independent MIA au-
diting has become an important component of a judicialized political strategy that remains
one of the few means of creating traction for environmental issues in Mexico. It is both a
political strategy and a moral technology aimed squarely at the apparatus of the state itself
and its performance of public reasoning. It engages with the “hope-generating machine”
that is the Mexican bureaucracy while it attempts to turn its own logic against itself and to
hold the functionaries accountable for their decisions on technical grounds. Rather than a
displacement of politics, it constitutes a transformation of its form and contents.

Notes
The research for this article was carried out with support from a Fulbright García-Robles
scholarship and a grant from the Mexican Education Ministry, and was made possible by all
those who welcomed me into their spaces and agreed to be interviewed. I am grateful to the
members of the Taller de Etnografía en/desde México, whose comments on an early draft
of this article helped me to sharpen its focus and enrich the ethnography. Sandra Rozental,
Victoria Bernal, Ana Spivak L’Hoste and three anonymous reviewers offered keen insights
and helpful suggestions. Finally, revising this article amid a global pandemic would have
been impossible without the expert childcare provided by Anayeli Matías. Any errors that
remain are mine alone.

1. Mexico’s “green party,” Partido Verde Ecologista, founded in the 1990s, is widely ac-
knowledged to be a “wedge” party, designed specifically to split the opposition vote
and ensure electoral victories by the official PRI party, while advancing the political
and financial ambitions of its operators. See Simonian (1999).
2. See LGEEPA, http://www.diputados.gob.mx/LeyesBiblio/pdf/148_050618.pdf
Page 14 PoLAR: Vol. 00, No. 0

3. A generalized right-to-information law was not implemented in Mexico until 2002,

after the democratic transition.
4. For an explanation of how nature was refigured as national patrimony at the end of the
twentieth century, see Durand (2017).
5. While lack of space precludes a detailed analysis here of the levels of administrative
“discretionality” implied by the structure of the Mexican legal system, curious readers
should consult Azuela (2006) and Ugalde (2010).
6. ILO 169 defines Indigenous identity as self-identified. However, the Mexican Constitu-
tion, in which the right to consultation was enshrined in 2001, stipulates specific criteria
and documentation for establishing identity. This discrepancy affects the legal standing
of communities opposing development projects in their territories.
7. In recent years, SEMARNAT has experienced a series of budget cuts that crippled its
field-operating capacity and limited its ability to enforce environmental laws (Durand
2017). These have deepened under President López Obrador. Madrid Ramirez (2020)
argues that the cuts and ongoing “reorganization” of SEMARNAT and sectorial envi-
ronmental agencies amount to a full-scale dismantlement of environmental protection
in Mexico.
8. UCCS, “Análisis de la Manifestación de Impacto Ambiental del proyecto “Parque
Temático Ecológico Laguna del Carpintero,” MIA-28TM2014HD13 [Analysis of the
environmental impact statement of the project “Laguna del Carpintero Thematic Eco-
logical Park”], (2014, 3), in possession of the author (my translation).

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