Dear Editor,
The Environmental Protection Act No 11 of 1996 (EP Act) clearly states under Part II ‒ Establishment and Functions of the Agency ‒ “In the exercise of its functions the agency shall (a) compile and amend from time to time with the assistance of internationally recognized environmental groups a list of persons who have the qualifications and experience to carry out environmental impact assessment”.
I served on the very first Environmental Assessment Board (EAB) established in Guyana and am aware that neither the EPA nor the EAB is authorized to circumvent the EP Act. In spite of the legally established requirement detailed above, however, the EPA has continually ignored this mandate of the EP Act by compiling and distributing a list of consultants and firms who, in their opinion, are qualified to conduct environmental impact assessments. This clearly contravenes the intent of the EP Act. A further disturbing trend is the absence of African Guyanese owned firms from this list. This coupled with the clear intent of the EP Act to identify persons (not firms) who have the qualifications and experience to carry out environmental impact assessment, raises serious questions.
Ground Structures Engineering Consultants Inc (GSEC) has the largest portfolio of environmental compliance projects in Guyana. GSEC has completed several ESIAs in Guyana including the Maple Creek Diamond Mine, Amaila Falls Hydropower Project, Skeldon Estate expansion, Peters Mine, Aurora Gold Mine, Marudi Mountain Hard Rock Mine, Alluvial Mining at Marudi Mountain, Sandspring Resources Gold and Copper Mine, Petroleum Refinery at Crab Island and for the Haags Bosch landfill. Environmental compliance undertaken by GSEC includes audits for Omai Gold Mines for Cambior Resources/Iamgold, the privatization of Linmine and Bermine for the Adam Smith Institute, the closure of the Omai Linden yard and for Reunion Manganese. We are currently involved in providing environmental compliance services to several projects in Guyana including Guyana Goldfields, Sun and Sand Resources, Romanex and to Ion Geoventures as sub-consultants.
GSEC has also provided environmental compliance services to Chevron for gas stations located in Guyana, Suriname and Grenada and has served as sub-consultants to Environmental Resources Management (ERM) on several projects in Guyana and Suriname including the red mud stacking proposed for Suralco. GSEC has also provided training to EPA staff in exposure assessment and to the GGMC staff in earth and rock slope stability.
In spite of the experience and qualifications demonstrated by successful completion of the projects listed above, the EPA has not seen it fit to include GSEC on the list of firms which it has identified as being qualified to conduct ESIAs in Guyana.
While the compilation and circulation of this list continues to contravene the intent of the EP Act, the EPA’s action is compounded by its statement to firms, to whom the list is provided, that no firm not identified on that list would be acceptable to the EPA.
It can be stated without fear of contradiction that the higher echelons of the EPA are not competent in the diverse range of disciplines required to prepare a proper ESIA to make that determination.
These actions seem to indicate the continuation of the policy articulated by Dr Luncheon during the Jagdeo/Kissoon libel trial, that African Guyanese are not qualified to work in certain areas in Guyana. Now the policy appears to be extended to the identification of firms/individuals qualified to conduct ESIAs.
GSEC are consequently hereby requesting that the EPA publicly state its basis for contravening the EP Act and further identify the criteria it has used to determine the qualifications and experience of persons (or firms) to carry out environmental impact assessments. It is expected that the EPA will justify its position by detailing a list of projects on which these firms have provided environmental compliance services. It would also be helpful if the EPA could justify its ability to identify suitably qualified individuals/firms by specifying exactly the area of environmental compliance in which these individuals have experience which mirrors that of GSEC.
We trust no cries of ‘witch hunting’ will be heard now that the EPA is being asked to address its failure to adhere to the professional standards associated with the responsibilities it has been tasked to discharge.
Yours faithfully,
Charles P Ceres
