Dear Editor,
Reference is made to actions by APNU during its press conference held on Friday, October 25, 2013 to deflect attention from their failure to support the Government’s calls for sustainable development and advancement of a Green Economy. Two recent examples: APNU failed to commit and support regulations for the Government proposed Environmental Tax for all plastic receptacles which is a means to tackling the garbage situation in our country; and non-support for major Low Carbon Development projects including the Amaila Hydropower project which will replace more than 95% of fossil fuel for the generation of electricity.
For the benefit of the civil-minded Guyanese public, the Ministry of Natural Resources and the Environment (MNRE) would like to provide the following clarifications to dispel the inaccuracies being peddled by APNU. It should also be noted that the MNRE has an open door policy, and members of the public, including APNU, are welcome to visit our Offices to better inform themselves, voice any concerns, and to seek clarifications.
Pollution
At this time, enforcement by the EPA is done, as stipulated by its Act of 1996, through the Courts. The deficiencies of such an approach are well recognized, including the long time for decisions to be made by the Courts. It is for this very reason that the EPA has moved to the drafting of Environmental Protection (Enforcement and Compliance) Regulations, which are expected to be completed in the near future. In preparing for these regulations at an institutional level, the EPA established a new Division in June 2013 to deal with Enforcement and Compli-ance. This Division is designed to undertake the exact measures that APNU is only now talking about.
The issues related to hazardous wastes and air quality pollution have also been recognized, and back in 2011, the EPA established a Hazardous Wastes/Materials and Air Quality Management Unit. Since then, the EPA secured an air quality field meter to measure and monitor particulate matter, and which has been deployed to resolve a number of complaints.
The dust pollution issue at Hack Rice Mill, Cane Grove, was one such complaint which was successfully resolved by the EPA’s intervention and persistence. The numerous recommendations which were made by the EPA and implemented by the Rice Mill were scientifically tested with the acquisition of the Particulate Matter meter. Results from the Air Quality Monitoring which was conducted from February 20, 2012 to March 18, 2012, revealed that particulate matter concentrations were below the World Health Organisation Guidelines, and thus the complaint issue was successfully resolved.
The Agency continues to investigate and monitor several other operations with air pollution issues, among them Kissoon Dyal Rice Mill. Further, the Agency has developed an Air Quality Monitoring Protocol for Linden, and plans to implement this shortly. The EPA is well aware of the constraints of having only one meter for monitoring air quality, and intends to acquire two other field instruments in 2014 to further support its investigation and monitoring operations.
Just two years in existence and with a staff complement of three Officers, the Unit is still in the incipient stages of administering the Hazardous Wastes Regula-tions. However, environmental guidelines for the implementation of the Regulations have been completed for the proper storage, transportation and occupational handing of biomedical waste. These guide operators of medical-care facilities in the sound management of biomedical wastes.
Improved Hazardous Waste/ Materials Management has received no less attention by the Agency, over the years. Since the Unit’s establishment, the Agency has developed a number of protocols and guidelines.
In addition, consultations were conducted with different Private and Government Agencies on their roles with regards to the management of hazardous wastes. Further, the Agency has been actively collaborating with the Ministry of Local Government in establishing a hazardous waste cell at Haags Bosch in recognition of the need to dispose of hazardous waste in an environmentally-safe manner.
On the issue of water pollution, the Agency is moving to establish a Water Quality Unit which will have a dedicated role in this area. Additional field instruments are being acquired currently, so the Agency would have more capability to address issues of water pollution in a more scientific manner.
To support the efforts of the EPA, the Guyana Geology and Mines Commission has been actively conducting water quality and turbidity tests as a component of its monitoring and enforcement exercises in the various mining Districts of Guyana. The Commission undertakes monthly and quarterly water testing to ensure that water quality is maintained as outlined in the Memorandum of Understanding between the Guyana Geology and Mines Commission and the Environmental Protection Agency (EPA).
In addition, the Commission continues to work closely with the EPA and the Guyana Gold and Diamond Miners Association (GGDMA) to reduce water contamination and to ensure that water sources and bodies in the hinterland communities and mining areas are not contaminated or compromised. In this regard, mining operations are often times issued with Cease Work Orders when instances of water contamination are identified.
Further, the Minister of Natural Resources and the Environment on behalf of the Government of Guyana has signed on to a new international pact to control mercury emissions; the Minamata Convention on Mercury. This was done during an international conference organised by the United Nations Environment Program (UNEP) and held in Minamata, Japan from October 9-11, 2013. This commitment reaffirms the Government of Guyana’s recognition of the environmental and human health risks of mercury use and supports the implementation of a global legally binding instrument on mercury that will examine its supply and trade, mercury-added products, manufacturing products in which mercury compounds are used, artisanal and small scale mining, emission, releases, storage and mercury wastes.
Coastal Zone Management
Coastal zone management is a cross-sectoral matter involving many groups of stakeholders. The Agency has moved to develop a digital coastal zone map with the assistance of the National GIS Committee established under the MNRE. Such a task is monumental but it is expected that at the end of the day, environmental hot spots would be identified and appropriate mitigating measures would be undertaken. The Agency also intends to update the previous Coastal Zone Management Action Plan.
It should also be recalled that the Agency was the lead body, with funding from the German Government, to develop the National Protected Areas Act through which the Protected Areas Commission was established, and to have Shell Beach (and the Kanuku Mountains) declared as a protected area. This area is the last remaining stretch of Guyana’s coast that still has large stretches of pristine black, white and red mangroves. Conserving these mangroves, along with the associated flora and fauna, is key to the Government’s integrated coastal zone management strategy, and is now a reality because of the Government backed landmark Protected Areas Act of 2011.
Deforestation
Mining as a driver of deforestation has also been receiving attention by the EPA. Currently, the Agency is developing a proposal with UNDP to mainstream biodiversity in the mining sector. As a first step, the current legislative measures and practices would be examined with a view to integrate biodiversity concerns. A second phase would undertake pilot activities to reforest degraded areas.
Guyana has over the past years, developed a robust mechanism that governs forest utilization at the level of forest concessions. Among some of the mechanisms that are implemented are the National Log Tracking System, the Codes for Practice for Timber Harvesting and Processing and the Guidelines for Annual and Management Planning. These have been developed against strong policy as well as legislative guidance including the National Forest Plan and Policy 2011, as the Forest Act 2009.
Additionally, a new programme for independent assessment of performance of the forest sector in terms of forest legality and sustainable forest management, including Independent Forest Monitoring, has concluded that the systems in place in Guyana’s forest sector are effective in ensuring that sustainable forest management (SFM) is practised at the level of forest concessions. Strong forest governance in timber concessions is further evidenced by the recently released deforestation rates from the driver of Forestry, which recorded a mere 240 hectares deforested annually and this has been found to be mainly forest roads. Additionally, the reported rate of illegal logging is below 1% annually.
The overall total deforestation for the recently reported period of 2012 is below 0.1% (reported at 0.079%) which is well below the agreed benchmark on the Guyana Norway Agreement of 0.275% and overall, among the lowest in the world.
The GFC has taken active steps to engage and build capacity at the stakeholder level to effectively execute SFM. This was advanced in a number of programmes including the establishment and operating of the Forestry Training Centre which provides training to large and small operators in the forest sector. This Model is being replicated for the Mining Sector to build the capacity of stakeholder.
Over the course of 2012, a number of programmes have been developed that are aimed at strengthening natural resources management including in the mining sector.
Accompanying projected developments in the sector is a programme of work that has already started and that will be further advanced in the next few years. These efforts are systemic interventions to improve the REDD+ model. There are two main initiatives which between them have the foundations of an outline programme to reduce degradation from the mining sector. These are the implementation of the Ministry of Natural Resources and the Environment of Guyana (MNRE’s) Draft Strategic Framework 2013 – 2018 and the mandates of the committees that are implementing the recommendations of the Sustainable Land Use Committee (SLUC).
At the national level, the Government spearheaded the passage of the Protected Areas Act 2011, and the subsequent creation of the Shell Beach and Kanuku Mountains Protected Areas. With this important step, the Government, for the first time in Guyana’s history, created a national system of protected areas, which together with the Community Conservation Area in Konashen, accounts for almost 9% of Guyana. This is a major step in ensuring that important areas of forest and biodiversity are maintained for both current and future generations.
As part of the ministry’s planning processes, MNRE collaborated with Strategic Environmental Advice (SEA) to prepare a Strategic Framework for the Ministry for the period 2013-2018. The objectives of this report were to conduct a thorough review and analysis of the regulatory and institutional landscapes to help MNRE shape its strategy to address environmental and natural resource issues within the framework of Guyana’s LCDS. This activity resulted in the development of the Ministry’s Strategic Framework Document and Strategic Plan. The Strategic Framework makes a number of recommendations, including those that relate directly to the mining sector such as activities to improve reclamation of mined out areas, and initiatives to address impacts on deforestation and forest degradation from mining.
Marine Litter
As it relates to marine litter and its impact on coastal resources, Guyana ratified the Cartagena Convention and its three main protocols in June 2010. The Land Based Sources of Pollution (LBS) Protocol concerns pollution from land-based sources and activities; the Oil Spill Protocol aims at strengthening national and regional preparedness and response capacity of the nations and territories of the region to oil spill events which may result in, or which pose a significant threat of, pollution to the marine and coastal environment of the Wider Caribbean Region; and, the Specially Protected Areas and Wildlife (SPAW) aims to protect rare and fragile ecosystems and habitats. This ratification signalled Guyana’s commitment to address coastal and marine pollution issues. While the implementation of this commitment is still at its early stage, the Ministry, being the focal point and implementation Agency for this Convention, is working with the Protected Areas Commission and moving towards the establishment of the Water Quality Unit within the EPA to ensure the implementation of the Convention and its associated Protocols.
Solid Waste Management
Integrated Solid Waste Management has been on the front burner of the MNRE’s agenda since its establishment. To this end, the Ministry has spearheaded the preparation of proposals on mechanisms to reduce the use on non-biodegradable packaging (plastics & Styrofoam) in Guyana through Economic Incentives and Disincentives Wastes Policies and on the Implementation of Wastes Policies mechanisms for Reduction in use of Non-Biodegradable Packaging (plastics & Styrofoam) in Guyana which was taken to Cabinet and additional stakeholders’ consultations will soon be hosted prior to the implementation of measures to reduce the use of plastics and Styrofoam.
Further, the Ministry’s EPA supports the Ministry of Local Government and Regional Development in addressing the infrastructural needs for improved solid waste management by assisting in the identification of suitable sites for establishment of landfill sites across the country and in providing relevant guidelines for the proper establishment of these sites. This is one component of a systemic approach being developed by the Ministry of Local Government (MoLG) in dealing with SWM. Another component is the finalisation of the Waste Management Bill. The EPA is supporting the MoLG by working directly to incorporate the Agency’s recommendations in the Bill which aims to establish a Solid Waste Management Authority.
The Pick It Up Guyana campaign was launched in June 2012 to support the Ministry’s drive to address solid waste management. Since its launch, the Pick It Up Guyana has continued to engage Guyanese from all walks of life to take action for a clean and healthy environment through partnerships, collaboration, and individual action. Having successfully engaged in public awareness, education, and empowering a number of environmental volunteers for community action, there has been a significant increase in public participation and action. While there have been a number of clean-up exercises organised by Pick It Up Guyana, several others have been done in different parts of the country on a small and large scale by various entities which have opted to execute activities in support of the goals of the initiative. Pick It Up Guyana continues to receive a good response from a wide cross-section of Guyanese, as more volunteer and community groups, and religious and political organisations are coming forward to support the initiative.
Meanwhile, the Environmental Protection (Litter Enforcement) Regulations which are currently before the National Assembly will institute tough penalties and fines to persons caught littering by the implementation of a ticketing system. This would allow for the prosecution of persons guilty of improper waste disposal.
Public Health (Mercury)
Mercury amalgamation is currently the preferred method used for the processing of gold in Guyana’s small and medium scale mining industry (best estimate of mercury use is in the range of 10-25 tons/year locally). Mining has not exploited the numerous mercury-free techniques due to the high cost of equipment and the required technical skill. However, of recent there have been a number of mining companies and individual miners investing in mercury free equipment and technologies.
The Guyana Geology and Mines Commission (GGMC), the World Wildlife Fund (WWF) Guiana’s and proponents of the CIDA sponsored Guyana Environmental Capacity Development Project (GENCAPD) have sought to change attitudes, behavioural patterns and practices in the industry by introducing alternative technologies. However, these efforts have been hindered by a number of factors, including costs and insufficient technical skills, training and capacity building.
Further the Ministry has mandated the GGMC to advance work in developing and implementing Codes of Practice on Mining. The codes include those relating to avoiding environmental degradation form mining. GGMC is currently revising the codes of practice, e.g. on the use of mercury and wastewater management. The draft codes of practices have been reviewed. The drafts have also been shared with the mining community, so that they understand future compliance requirements by the GGMC and the Guyana Gold and Diamond Miners Association.
To complement these efforts, there has also been development on the operational end. The improvement of technology and mining practices are very important to (1) shift miners away from the use of mercury and (2) to improve the recovery efficiency mining operations. New technologies such as centrifuge systems can increase recovery rates in mines from 30% to 80% compared to traditional practices. This means that a mine need only be worked once, after which it can be closed and the forest restored. Inefficient traditional practices encourage sites to be reworked a number of times, thus not allowing the forest an opportunity to recover.
The Government of Guyana continues to focus technical and financial resources in the gold mining sector in order to address the issues surrounding mercury use. However, the scale of the problem demands collaborative action between pertinent stakeholders and it is increasingly being realized that international action and support may be vital to any effort aimed at eliminating mercury use in Guyana’s mining industry.
While the use of mercury in the mining industry is significant and widespread, the health and industrial sectors in Guyana use a relatively limited quantity of mercury.
The Government of Guyana recognizes the environmental and human health risks of mercury use and pollution and supports the implementation of a global legally binding instrument on mercury in order to prohibit its production, export and use. We also concur that the mercury instrument should deal with small and medium scale gold mining separately from other industrial processes in which mercury is used and we support efforts to reduce and, where possible, eliminate the use of mercury in mining.
Nevertheless, it must be understood that gold mining contributes 12.5% of Guyana’s Gross Domestic Product (GDP). The small and medium scale mining industry in Guyana directly employs between 30,000-35,000 persons who support approximately 105,000 family members in the coastland and hinterland regions of Guyana. In addition, the gold industry’s contribution to the economy extends beyond its direct contribution to GDP and employment. Through a multiplier effect, mining supports approximately 70,000 persons through other local businesses such as transportation services (small aircraft operators, boat operators, truckers) and the food industry (farmers, food suppliers, wholesalers). Thus, the industry directly contributes to the wellbeing and quality of life of approximately 30% of Guyana’s population.
Citing the dependence of Guyana’s gold mining industry on the use of mercury, a ban on mercury before 2022 would threaten financial and fiscal stability and would result in decreased economic growth in an already fragile economy.
As such, the Government of Guyana proposes a phased approach which should give parties time to prepare for the implementation of the procedures and provisions that prohibit the production, sale, distribution or use of mercury and associated compounds after the entry into force of the convention.
The Ministry of Natural Resources and the Environment was created out of a recognized necessity by the Government to provide policy directives and oversight to ensure the sustainable management of the natural resources of Guyana for the benefit of all. While there has been marked progress, more will be done through the collective efforts of all stakeholders to bring about behavioural change.
The Ministry takes its mandate very seriously, and although we are open to advice from all groups, the APNU must show that it is capable of rising about partisan politics for the benefit of Guyana’s development and sound environmental management. Without tangible support including parliamentary measures, these recent public pronouncements amount to nothing more than lip service. The Government through the Ministry remains committed to genuine partnerships, as we lead the way towards effective environmental management and sustainable development in Guyana.
Yours faithfully,
Joslyn McKenzie