Dear Editor,
Since the beginning of the year GGMC has been advertising the requirement for claim-holders to pay a reclamation bond on all valid claims, irrespective if there is any mining activity on these claims. As a claim-holder one questions this decision because, as GGMC is aware, only a few of these claims are presently being mined.
For those who are au fait with mining in Guyana, claims are referred to as the ‘poor man’s mining property.’ They were designed so that a prospective miner could take out a prospecting permit and walk the bush and ‘brand’ whichever small area where he may have seen some minerals. The cost for these claims is negligible as against the larger and more costly medium-scale blocks.
One does not argue with GGMC’s position regarding reclamation bonds for claims. However, it seems much more applicable to mandate reclamation bonds on claims that are presently being worked rather than on all claims. After all, as the name suggests, a reclamation bond refers to actual mining activities and the effects thereafter. The Mining Regulations, 238(1), clearly refer to a “reclamation bond for a claim disturbed by the mining.”
There are a number of questions regarding this reclamation bond:-
1) If the bond is in lieu of claims disturbed by mining then why is GGMC requiring this for claims with no mining activities?
2) If a claim-holder does not pay his reclamation bond for whatever claim/s he may own and which are not presently being mined, will his claim be forfeited? If it is, what time-frame exists before such forfeiture is implemented?
3) If a claim holder pays his reclamation bond and later expands into a medium-scale operation, thus needing an environmental bond, will his reclamation bond be refunded?
4) What happens if there is more than one operation on a claim for which the claim-holder has already paid his bond? Will the GGMC refund this original deposit in lieu of the other operations paying their bond?
Small miners are already heavily burdened with the new regulations being enforced and the additional costs attached to ensure compliance. It seems very unfair for GGMC to further burden this group with the requirement to pay reclamation bonds on every claim irrespective of them being mined or not.
If the claim is being worked, then the bond must be paid. But it seems a futile and wasteful investment to pay for claims not being mined without even knowing if/when those claims will ever be worked. For a small man this bond can be a financial burden, especially if the claim-owner owns a number of claims, as is often the case.
One hopes that GGMC rethinks this requirement and institutes measures that are more favourable to the small miner, but still fall within the requirements of the Mining Regulations.
Yours faithfully,
(Name and address provided)