Dear Editor,

There is no doubt that Guyana is on the right path and has taken a bold step in offering its forest as a token of concern for the ailing environment. One cannot, however, ignore the fact that a recent proposal which seeks to subject miners to a six months waiting period pending a no-objection by the Guyana Forestry Commission is simply a manifestation of the fact that the LCDS lacks the essentials to be respected as a strategy document, particularly as it relates to the mining sector.

When one considers that the LCDS is seeking to preserve the forest within a performance-based mechanism, and promises not to affect the opportunities of the sectors which are dependent on the forest, some serious doubts arise. As a mining engineer I was inclined to examine the true implications of the LCDS for the mining sector and had attempted to point out why the LCDS was not in fact a strategy document. I had pointed out in a letter to the Prime Minister a number of concerns, and had made suggestions aimed at ensuring the survival of the sector in the Low Carbon Credit environment.

The current proposal of having the GFC preside over the mining sector’s activities is an example of what will not work. I am therefore of the view that miners should be concerned given the fact that they will scarcely survive and will unwittingly be forced out of operations.

When one contemplates a strategy that intends balance and seeks to protect the opportunities for the land rights of agriculture, logging, mining, and eco-tourism, which are opposed to each other, one must understand the value of social and economic variables associated with land use. A strategy document should be able to quantify these and make comparisons in terms of quality.

The mining sector has once again proven its brass in its record declaration of more than 300,000 ounces of gold, surpassing forestry and agriculture. Purely from an economic standpoint, the mining sector cannot be subordinated, notwithstanding the fact that the sector must do its due diligence in seeking to protect the rights of other land users. It goes without saying, however, that the logging  and other economic sectors which yield benefits from the forest cut by miners, should have an opportunity to exploit those resources, or due consideration should be given to the opportunity cost associated therewith, as part of a viability assessment.

Viability assessments are, however, not possible given the fact that the opportunity costs associated with the various sectors may not have been quantified as part of the strategy.  It is apparent, however, that the mining sector, given its proven contributions to the local economy, has a right of passage, and the burden of proof should rest with the GFC and other potential land right claimants to quantify their economic capabilities and assess quality, within a given forest. In this regard, GGMC should in fact ask GFC to show reason why a given parcel of land should not be mined and not the other way around.

The entire process seems to be a clandestine means of changing the guard before his shift is up. The Commissioner of GGMC will in fact be subordinated under the process and strategic mining decisions will be made by persons unqualified to manage the affairs of the sector. If the proposed six months waiting period is indicative of the level of thinking of those identified to preside over a strategy framework for the mining sector, miners should be very afraid.

A prudent strategy position should in fact cause the following to be done:

(a) base-line surveys to quantify and appraise the social/economic variables of potential mining areas;

(b) quantification of the opportunity costs associated with logging, agriculture, tourism and mining, etc, within historic or perceived mining areas;

(c) classification of areas based on appraised social/economic variables;

(d) development of zoning criteria to regulate the rights of passage for each of the conflicting sectors with land rights based on social/economic variables and optimal benefits derivable by each sector;

(e) development of a prudent permits’ process to foster best practice modes of operation that protect the opportunities of other land rights claimants identified under the classification regime;

(f) due diligence on the part of GGMC in making exploration services available to miners as a step towards increasing the viability of and quantifying the true potential of the mining sector. GGMC will in fact be responsible for providing assurance for proven reserves;

(g) due diligence on the part of GGMC in exploring and introducing improved methods of recovery;

(h) credit schemes developed from the LCDS earnings to finance local mining operations in developing efficient mining and recovery methods to become compatible with reasonable expectations for sustainable practices.

At this juncture there should have been a base-line reference map available to the public, identifying viable logging, agriculture and tourism blocks, based on the value of economic variables and established criteria for classifying the various areas.

Sensitive logging areas, for example, should be quantified and and have quality assessments based on forestry audits, the existence of or planned road infrastructure to ensure harvest-to-market access.

Areas identified as strategies for agriculture on the other hand, should be protected with due requirements for protecting organic cover and effective enforcement of reclamation, as a written condition under a site-specific mining permit.

It goes without saying that GGMC should be allowed to re-invest in the local mining sector in the same way the Government of Guyana invested in shoring up the local agricultural sector, in order to make the sector compatible with the LCDS. Exploration and viability assessments are strategic to this necessary transformation and will be the foundation for sustainability.

Yours faithfully,
Peter Hutson
Mining Engineer