Dear Editor,
The Open Letter below from fifty-four (54) Guyanese was addressed and delivered by Email and by Hard Copy to Mr Kemraj Parsram, the Executive Director of the EPA and to Mr Omkar Lochan, Chairperson of the EPA Board of Direc-tors; and to Ms Pradeepa Bholanath, EAB Chairperson and EAB Members Dr Garvin Cummings and Mr Joslyn McKenzie, on Monday, 29th August, 2022.
We the undersigned are dismayed that a US$1 million dollar grant from the World Bank to strengthen the monitoring and enforcement capacity of the Environ-mental Protection Agency (EPA) was not fully utilized and failed to achieve the intended outcome. This grant, along with other funding, was intended to establish a corps of personnel including 34 highly specialized and experienced petroleum, geological and environmental engineers to be employed by the EPA.
We note the many failings of the EPA, which has a duty under the EPA Act “to provide protection,manage the natural environment and assess impacts of development activities on the environment by conducting, promoting and coordinating research on pollution and prevention; formulating standards, guidelines and codes of practice for improvement and maintenance of the environment including the release of contaminants into the environment; monitoring and coordinating natural resources and how they are being impacted, advising key stakeholder on the content and applicability of environmental control instruments, and providing general information to the public on the state of the environment.“
We believe that by failing to accept and use these grant monies, the consequential result is the inability to employ and train the necessary expertise to fulfil the mandate of the EPA. Guyanese citizens, communities and workers are therefore more at risk of exposure to pollutants, known and unknown.
This lack of capacity is, in itself, a failure by the EPA to protect the Guyanese people and our environment. Further our constitutional right to access information and our right to participate in environmental decision making have been violated.
As such we call on the EPA and the Environmental Assessment Board to implement the following without delay:
● Stop the waiving of Environmental and Social Impact Assessments (ESIAs) and ensure that these are done for all onshore facilities receiving, storing and disposing of hazardous, radioactive and other types of oil, gas waste and any other chemicals, gases and materials associated with oil and gas production.
● Ensure that environmental permits that are granted are fixed for a period of no more than 3 years; and that renewals are dependent on a comprehensive, transparent, consultative process.
The track record of companies awarded permits must comply with international best practice, standards and norms and with the EPA’s own law and regulations, as Independent monitors must have verifiable credentials.
● Ensure that comprehensive consultations are held with communities and residents residing in the vicinity of all on-shore facilities receiving, handling, storing and disposing of hazardous and radioactive substances. This needs to be done not only as part of the ESIA process but on a continuing basis to ensure that no harm is meted out to citizens or the environment.
● Ensure that on-shore facilities comply with a process for registering harmful air emissions, noise levels and dust pollution, and that the structural damage they cause to roads, homes and businesses be investigated without delay.
● Ensure that all reports on type, quantity, frequency, containment and classification of wastes and that destinations to and from waste management facilities are complied with and made available to those communities directly affected, workers and the Guyanese public.
Ensure collection of baseline data as well as continuing monitoring of air emissions and other sources of radioactive contamination, including exposure to workers and residents, particularly children living in close proximity to such facilities. These monitoring results must be publicly disseminated.
Ensure all environmental and operating permits for offshore and onshore oil & gas operators and facilities are published on the EPA website and that the public is notified in a proper and timely manner and that citizens have the opportunity to examine and raise matters and concerns before any such permits are granted.
Publicize without delay all the companies that have environmental permits to receive, handle, store, treat oil & gas wastes or operate mud plants and their waste management plans, to ensure compliance with international best practices. Where these are deficient or absent, we call for a stop notice / cease order until compliance is met, subject to inspection by suitably qualified experts.
Publicize permits for all vessels certified to transport offshore wastes to onshore facilities and inspect such vessels to ensure they have the necessary facilities to safely store and transport a range of hazardous wastes including naturally occurring radioactive wastes.
Publicize permits for all road transportation vehicles and the companies owning such vehicles that are certified to transport sealed radioactive sources and other hazardous wastes, and ensure they have the necessary training, capacities, experience and clearance to safely store and transport them.
Ensure that notices of application for all oil & gas projects are advertised prominently more than once in all major newspapers, TV and radio stations and extend the time for all objections to a minimum of 60 days.
We call on the EPA and EAB to respond to this letter, point by point, within thirty (30) days by open letter and/or by placing your responses on a page on your website.
Yours truly,
Danuta Radzik
Vanda Radzik
Janette Bulkan
Jocelyn Dow
Alissa Trotz
Maya Trotz
Elizabeth Deane Hughes
Karen De Souza- Red
Thread
Wintress White- Red Thread
Joy Marcus, Red Thread
Vanessa Ross- Red Thread
Halima Khan – Red Thread
Susan Collymore – Red
Thread
Vidyaratha Kissoon
Raphael Singh
Denise Murray
Immaculata Casimero
Nicole Cole
Breadfruit Collective
Charlene Wilkinson
Hollis France
Leila Jagdeo
Alfred Bhulai
Darshanand Khusial
Sherlina Nageer- The
Greenheart Movement
SASOD Women’s Arm
(SWAG)
Society Against Sexual
Orientation Discrimination
(SASOD)
Joel Simpson
Sinikka Henry
Laura George
Amerindian Peoples
Association (APA)
Pauline Bullen
Sandy De Freitas
Duane de Freitas
Charlie Harley
Diana Cruickshank
Danny Ramnarine-Our
Wealth Our Country
Athalia Bynoe
Gabby Saudi
Jaya Takhar
Yousef Altarouti
Alison Smith
Mosa Telford
Michael Adams
Charmaine Narine
Pamela Fraser
Zeinab Jaidi
Elton McRae
Alma O-Connell
Colin Klautky
Salima Bacchus-Hinds
Rev Patricia Sheerattan-
Bisnauth
Darin Chan
Mellissa Ifill
