BRIEF REPORT ON THE GAMA PROJECT FOR IMPLEMENTING A “MACRO CELLULOSE” FACILITY IN PALAS DE REI (LUGO, GALICIA, SPAIN) NEAR THE FRENCH WAY OF SANTIAGO DE COMPOSTELA

 

 

The ‘GAMA project’ for implementing a Macro Cellulose facility is being promoted by Greenfiber S.L. (see: https://greenfiber.es/gl/inicio/) in partnership with ALTRI (a company based in Portugal, see: https://altri.pt/en). It is important to note that Greenfiber does not have prior industrial and labour experience in the production of cellulose.  From March 5th, 2024, the GAMA project was under public information and assessment, including:

 

• the Application for Integrated Environmental Authorisation (AAI);
• the Environmental Impact Assessment (EIA);
• the Declaration of Public Utility;
• and the Project for the implementation of this large-scale industry and its associated infrastructures (366 hectares).

 

This public exhibition period closed on Wednesday April 17th, 2024. See Annex 1 for the official documentation.

 

The implementation of the GAMA project would directly impact the cultural and landscape heritage of the municipalities of Palas de Rei, Melide, Santiso, and Agolada (Galicia – NW Iberian Peninsula). These areas are rich in cultural heritage, standing out for example the late-medieval Castle of Pambre, located approximately 2km from the projected factory site. Regarding UNESCO’s World Heritage Sites, the French Camino de Santiago (WH since 1993, extended in 2015) is located between 1.4 and 2 km from the projected factory area (with part of its perimeter entering the buffer zone of this world heritage route). It is important to highlight here the allusion in its declaration of the “outstanding natural landscape” of this historical pilgrimage road. Additionally, the macro cellulose envisages by the GAMA project could also partially affect the Primitive Way of Santiago de Compostela.

 

This project envisages a large-scale factory with an extension of 366 hectares. And its facilities would have heights of:

• 75 metres for the chimney.
• 60 metres for the recovery boiler and the wood handling building.
• 50 metres high for the biomass boiler.
• Several 20-metre-high structures for the warehouses.

 

In addition, other structures will have to be built:

• A 12,426-metre underground pipe to supply water from the Portodemouros reservoir in the river Ulla (the second largest river in this territory, and the river in the North of the Iberian Peninsula with the highest number of invertebrate animals according to scientific research).
• Another 8,870-metre pipe for discharges into the river Ulla.
• Another underground pipe from Melide (municipality of the province of A Coruña, Galicia) to supply electricity to the factory. In the case of the latter, the Environmental Impact Study itself mentions the impacts that the works to open the trench for the underground power line will have on the Camino de Santiago, especially during the construction phase.

 

It should also be noted – as mentioned before – that part of the factory’s perimeter falls within the buffer zone of the Camino de Santiago, as indicated in the maps provided by the Environmental Impact Assessment (see Annex 1). Besides, the interventions that will need to be carried out on nearby roads to improve access to the factory will affect both this buffer zone and the Camino itself.

 

Due to its large size and the heights of its structures, the construction of this factory would have a considerable impact on the landscape of the area, especially for the surroundings of the Camino de Santiago, as well as other cultural heritage of the area, such as the Castle of Pambre (14th century) and the Castro de Remonde (Iron Age). In this respect, the Environmental Impact Assessment includes a Heritage Impact Assessment, which recognises this visual impact and how the factory would affect the ‘scenic beauty’ of these cultural assets (see Annex 1). In fact, this assessment includes a study of visual basins from 25 scenic points, concluding that the factory would be partially visible from several points, among them:

• Castle of Pambre (from where the chimney can be seen), a master symbol of the European Middle Ages.
• The access to the nucleus of Pambre, (from where the factory buildings will be seen).
• The Castro de Remonde (from where the factory buildings will be seen).

 

Additionally, this factory could be seen from the French Way to Santiago, which is crossed annually by more than 150 thousand pilgrims.

 

 

The conclusions of this Heritage Impact Assessment define the magnitude of the impact on:

• The French Camino de Santiago as ‘important’, considering the ‘general changes in the environment’.
• Castle of Pambre and its protection area were also considered ‘important’.
• And in the case of the Castro de Remonde as ‘moderate’.

 

Although the report presented by the company takes into account the most relevant examples of the surrounding cultural heritage (mentioned above), it lacks any mention of other types of heritage that should be taken into account. For example, the Living Heritage and the Immaterial Cultural Heritage of the Area classified and catalogued by the anthropologist Xerardo Pereiro and with registration in the Consellería de Cultura of the Xunta de Galicia (Autonomous Regional Government of Galicia) since 1995.

 

As already pointed out by the Spanish National Committee of ICOMOS in their statement (17/04/2024), an independent Heritage Impact Assessment should be carried out. This assessment should studied in depth the impact of this industrial project on the diverse heritage of the area, and especially the visual impact of the projected structures in the Camino of Santiago as it passes through this area, between the Provinces of Lugo and A Coruña.

 

Beyond the visual impact, other aspects derived from the construction and the production process should be taken into consideration, since they would affect the environment of the cultural heritage, as well as their perception. These aspects are briefly reflected both in the Integrated Environmental Authorisation and in the Environmental Impact Study, mentioning:

 

• Noise.
• Vibrations.
• Gases (PM5, sulfur, C02, nitrogen…)
• Factory lighting (which also has a visual impact).
• Odours.
• Pollution and atmospheric emissions (which also has a visual impact, but the Environmental Impact Study does not take this aspect into account when carrying out the study of visual basins).
• Increased road traffic. In this respect, it is envisaged that the Average Daily Traffic Intensity (as foreseen in the Integrated Environmental Authorisation) will be 550 vehicles per day circulating around the plant, most of them trucks. However, other estimations calculate that there will be 1000 trucks per day during the 3 years of construction and 550 trucks with eucalyptus wooden for the factory after that.

 

In fact, as a result of all this, the report presented by the company recognises as part of the cumulative effects of the creation of this factory the ‘perceptual alteration’ and the ‘loss of international exceptional value of the area, as a heritage and tourist resource’.

 

Possible measures to mitigate the impact proposed by Greenfiber include:

• The projection of a green ring completely surrounding the factory, as a measure to mitigate the impact (they hope that this will compensate for the intrusion of elements such as the chimney or the buildings). However, the above-mentioned hights reach the 60 and 75 meters high. Also, the earth under construction is a NATURE Network 2000 area classified and protected by European Union (called Serra do Careón) where the serpentine floor (unique in the Iberian Peninsula) limit the grown of high trees.

 

 

 

 

 

 

For all the above-mentioned reasons we conclude that the GAMA project presents in their current form many problems and negative effects on the cultural heritage of the area, especially in the French Way to Santiago and the Primitive Way on its passage through Melide. Thus, we urge UNESCO to conduct a thorough report about the GAMA project with the aim of protecting the Ways to Santiago de Compostela and their environment, as World Heritage.

 

 

 

Authors:

 

Xerardo Pereiro (Associated Professor of Anthropology at the University of Trás-os-Montes and Alto Douro, UTAD, Vila Real, Portugal. Mail: xerardopereiro@utad.pt)

 

Sara Carreño López (Assistant Professor of Art History at the University of Santiago de Compostela, USC, Santiago de Compostela, Galicia, Spain)

 

Silvia González Rodríguez (Predoctoral Fellow of Art History at the University of Santiago de Compostela, USC, Santiago de Compostela, Galicia, Spain).

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANNEX 1

 

 

Official documentation:

 

 

Diario Oficial de Galicia (04/03/2024): ANUNCIO do 20 de febreiro de 2024, da Secretaría Xeral de Industria, polo que se someten a información pública a solicitude de autorización ambiental integrada (AAI), o estudo de impacto ambiental (EIA), a declaración de utilidade pública e o proxecto para a implantación dunha industria de fibra téxtil a base de celulosa e as súas infraestruturas asociadas, promovido por Greenfiber, S.L. e declarado proxecto industrial estratéxico (PIE) polo Acordo do Consello da Xunta de Galicia, do 29 de decembro de 2022, que se vai implantar no concello de Palas de Rei:

 

https://www.xunta.gal/dog/Publicados/2024/20240304/AnuncioG0692-200224-0017_gl.pdf    

 

 

See the Application for Integrated Environmental Authorization (AAI) and Environmental Impact Assessment (EIA):

 

https://economia.xunta.gal/transparencia/informacion-publica/proxectos-industriais-estratexicos?content=expediente_0005.html&fbclid=IwAR3f14YXzsksBS2ckfjJP24-04lbqlMaMjW8jdp06TRUsClgEGhQ6iLOi1Y_aem_AW7mRU7AVfy-VX8R1NPTrRzQgn7op1nWMOLgMhATsKNuIxnF1VEklQ9JTRNem4KS2djJoH2nZZ6kNWeTvetcAfey

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANNEX 2

 

Xerardo Pereiro (University of Trás-os-Montes and Alto Douro –UTAD – Vila Real – Portugal. Email <xerardopereiro@utad.pt>) holds a European PhD in Social Anthropology from the University of Santiago de Compostela (Galicia – Spain) and another International PhD in Tourism from the University of La Laguna (Canarias - Spain). He is associated professor with habilitation (tenure) of anthropology (by ISCTE- Lisbon) and cultural tourism (by the University of Coimbra). He conducts research about tourism and cultural heritage in CRIA (Network Centre for Research in Anthropology - https://www.cria.org.pt/pt). He was the Head of Applied Anthropology First Degree and the Tourism First Degree Course of UTAD. It is member of the Editorial Board of several international journals as Pasos, Cultur, Agália, PH, ATLAS Tourism and Leisure Review and so on. He was awarded with 1994 Vicente Risco Award of Social Anthropology and Social Sciences, 2007 FITUR in research tourism and 2011 Sol-Meliá - University of Balears Islands Awards for Tourism Research.

 

http://orcid.org/0000-0002-6298-5701 

 

Sara Carreño is Assistant Professor in the Department of Art History at the University of Santiago de Compostela. In this same university she carried out her academic training, which culminated with the award of her PhD degree in April 2020. Previously, she worked as a predoctoral fellow for this same department (Xunta de Galicia, 2016-2019) and as an R&D promoter at the Vice-rectorate for Research and Innovation of this same university (2019-2021). In 2021 she joined the Department of Cultural Heritage of the University of Padua as a postdoctoral researcher, where she developed her activity until 2023 in the framework of the ERC-project SenSArt, led by Professor Zuleika Murat (https://sensartproject.eu/). Throughout her career she has visited several research centres, such as the Warburg Institute (University of London), the Centro de Investigação Transdiscipinar ‘Cultura, Espaço e Memória’ (University of Porto), the University of the Basque Country/Euskal Herriko Unibertsitatea, and the Instituto de Estudos Medievais (NOVA University of Lisbon), where she is an associate researcher. Her research focuses on the experience and reception of late medieval sacred art, with a special emphasis on its sensory components, approaching the functions of religious images and spaces and the relationships they establish with their audiences. In addition, she has worked on issues related to memory and identity construction, investigating the uses and interpellations of religious images and spaces and the relationships they establish with their audiences.

 

https://orcid.org/0000-0003-3804-5733

 

 

Silvia González Rodríguez holds a degree in History of Art from the University of Santiago de Compostela (USC), as well as a Master’s Degree in teaching in Higher Education with a major in Social Sciences at the same institution. She is currently working on her thesis titled: "Experience of contemporary sacred and museum spaces and its affinities with Eastern thought: A case study of Iberian architects", which is supervised by Miguel Anxo Rodríguez González, Senior Lecturer at the USC and Jesús Ángel Sánchez García, Professor at the USC. At the moment, she is working at the Art History Department (USC) as a Predoctoral Fellow with a PhD Scholarship funded by the Xunta de Galicia (2022-2026). She is also a member of Research Group Called IDEAH: Investigación y Desarollo en Artes y Humanidades (GI-1510), of the USC coordinated by Jesús Ángel Sánchez García. In this year, 2024, she is carrying out an international research visit under the tutorship of Prof. Marco Borsotti (ABC Department) at Politecnico di Milano. Her main lines of research are Contemporary Architectural Heritage, with focus on Religious and Museum Architecture, as well as Artistic Expressions and Historical Processes, focusing on the aesthetic and phenomenological study of spaces.

 

https://orcid.org/0000-0003-1207-7905