Proposed regulations for the mining industry are not just difficult, but in many cases, impossible to fulfill, miners argued in a paper given to a Norwegian-contracted team here to evaluate the forestry partnership with Guyana.
The Guyana Gold and Diamond Miners Association (GGDMA) also strongly reiterated their point that with the new rules miners will be forced out of business and said that the Low Carbon Development Strategy (LCDS) will “create, not reduce poverty”. “The advent of the LCDS and the Norway demands has (led) to the tightening of the noose around mining and the creation of new and impossible standards. In its present form, these new regulations will quickly and efficiently decimate the entire alluvial mining industry in Guyana”, said the document, a copy of which was obtained by Stabroek News.
Guyana has a US$250M, five-year forest protection agreement with Norway and over the past week, a team under the auspices of the Norwegian Government’s International Climate and Forest Initiative was here to carry out a real-time evaluation of the initiative. The Norwegian Agency for Development Cooperation (NORAD) Evaluation Department organized the evaluation. Among the objectives, the team was here to assess the results of the Initiative’s support (with regards to the general objectives of Norwegian development cooperation), on issues related to livelihoods, economic and social development and the environment.
The team met with various stakeholders including the GGDMA. In the document, titled ‘The Future of Alluvial Mining in Guyana’, it was pointed out that more than 50,000 Guyanese earn their living directly from mining and it is the best example of a poverty reduction strategy that has worked and continues to work for more than 200,000 persons who depend on the industry as a means of livelihood. The miners said that over 30% of the miners are Amerindians and it has been the greatest ladder with which they have been able to climb out of poverty and educate their children. “No other program or local or international social assistance scheme has done more or can do more than mining has done to empower people to take control of their lives”, said the document.
500 operations
It said that over the last year the livelihood of miners in Guyana has come under threat and this is directly linked to the proposed rules that fall under the auspices of the LCDS, which is sponsored by the Norwegian government. In outlining the events since the LCDS was announced, the document says that miners have experienced an increase in pressure, an upsurge in the harassment of miners and more than 500 operations were closed for “the simplest of infractions”. The miners also spoke of the “national consultancy charade” and said that at no time did the government ever attempt to consult with miners as a group directly but this become inevitable after their objections culminated in the “Bartica Protest”. The government has refused and continues to refuse to revisit the initial report of the Special Land Use Committee which failed to address the miners’ main concerns and also continues to ignore their main proposal for an area to be set aside outside of the LCDS arrangement specifically for mining, the GGDMA said. “After months of deliberating in the SLUC, it is becoming increasingly apparent to us that the Committee was mainly extended to further placate miners, to keep us quiet and to suppress further protest action. In the meetings we see no willingness by the government negotiators to compromise or listen to our main issues and suggestions and we get the impression that the agenda of Norway has superseded the concerns and welfare of the people of Guyana”, said the GGDMA.
It said that the proposed regulations are not just difficult, but in many cases, impossible to fulfill. One of these: that the turbidity level of all discharges into the creeks and streams must be under 30 microns (as clear as drinking water), at this level, the water will have much less microns (clearer) than probably any flowing water-body in Guyana, the GGDMA said. It also pointed to a provision that after converting a Prospecting Permit to a Mining Permit, miners have only five years to exploit the minerals on the property and after five years the land returns to the state.
Six months notice
Another is that the miners must give six months notice before mining can commence. The government’s position on this is that local alluvial miners must operate like large scale miners and prospect before they mine; they also argue that this will allow loggers who own concessions that overlap mining permits to extract logs before the area is mined, the GGDMA said. “Ultimately, this regulation makes no sense as most of the districts where mining takes place are in areas where there are no economic timber and in the instances where there are species that can be harvested and exported; the loggers…have stated that a six month period for extraction of logs is too short”, said the document.
Another regulation requires that miners prospect before they mine. “The government’s assertion that we must operate like large scale miners is based on the assumption that our operations can still be financially viable if we operate in a congruent manner. The key fallacy of this assumption is that small/medium-scale private operators cannot be expected to perform like large-scale multinationals for one obvious reason: the goals of their respective operations are fundamentally different”, says the document. It points out that the differences in the duration of these operations; the manner in which reserves are identified then mined; the fact that they require vastly different types of prospecting and mining technology and access vastly different financial sources of capital, all point to the absurdity of such an expectation, the miners said. The document says that for the small/medium scale miner there is no option of going to the financial markets and selling a story to investors and raising additional capital. It said that one of the main causes of bankruptcy in the small/medium scale industry is “down time” and the proposed regulations will drastically increase “down time” and pose serious hindrances to the survival of most of the small/medium scale miners. It is estimated that this regulation alone will cause the cessation of legal mining activities for over 80% of miners in Guyana and the numerous additional proposed regulations will destroy the businesses of the other 20%, the document said.
Further, it pointed out that the vast majority of citizens involved in alluvial mining in Guyana have been involved strictly in mining, one way or another, as a profession for their entire adult life. Many of them are either high school drop outs or finished high school with less than exemplary grades. To expect that they will be willing or even capable of drastically transforming the way in which they conduct their activities in a relatively short period of time is foolhardy, the association said, adding that such changes would only come gradually for some and not at all for others.
It said that another proposed regulation, which is partially being implemented to aid with compliance under the LCDS, involves filling out forms stating personal information and information relating to the location of the operations in the interior. Over the past few months, hundreds of operations have been stopped and large amounts of money lost due to “down time” as a consequence of either the operator’s unwillingness or inability to fill out these forms. “These forms are just the beginning; the additional proposed regulations pertaining to documentation of operations are so convoluted that it will require operators to employ technical specialists to complete them as they pertain to expected recoveries based on assays, GPS coordinates etc”, the document says. “Ultimately, these types of regulations are just another means through which to frustrate miners and put them out of business by forcing them to drastically increase their cost of mining and also requiring of them information that they are incapable of providing”, the document says.
It also pointed out that over the years and more recently many small miners have invested heavily in upgrading their earth moving equipment while other individuals have invested their life savings and have used family monies in order to enter the industry. “The exodus of the vast majority of miners from the mining industry as a result of their inability to comply with additional regulations under the LCDS will result in a financial meltdown and runaway bankruptcy for many Guyanese families”, it says. The document also said that there will be an increase in unemployment and loss of disposable income. Pointing to the economic figures, it said that the impact of this industry closing or downscaling will have serious consequences for Guyana’s economy and a catalyst for rampant poverty and starvation.
It points out that from the money gained through the LCDS, Guyanese are promised jobs in the Information Technology and sustainable agriculture sectors but said that a significant percentage of those in the mining industry will not be able to participate in these fields for lack of qualification or aptitude. The bigger question is how long will it be before these plans come to fruition, the document said and adds that during this unknown period, what alternatives will be offered to unemployed miners and other members of the society.
It reiterated that excessive regulation will force most local miners out of business. “We estimate that over 80% of our miners are ill equipped to implement existing regulations, much less new ones”, the GGDMA said adding that the only survivors of this situation will be the large multi-national corporations. “The LCDS with its funding support from Norway is promising to do one thing for sure; close the door of opportunity to Guyanese and create an opportunity for the re-colonization by the multinational corporations and foreign governments”.
In a ‘Message for the government of Norway’ the GGDMA said that NORAD has as one of its mandates to “administer the agency’s grant schemes so that development assistance provided through Norwegian and international partners contribute effectively to poverty reduction”. This is not what the LCDS is planning to do, the GGDMA said. “It is promising to take bread out of our mouths to ensure that the Norwegian people feel good about conserving a few trees (in) some far off exotic land”, the association said adding that that it is going to “create, not reduce poverty” and “conflict and starvation”. “In the mining sector of Guyana (the LCDS) is promising to put in excess of 100 000 people back into poverty and starvation by systemically taking away their ability to exercise their right to earn a living though the only means by which they know how”, said the miners. They said that they will not benefit from the Norwegian money and on the contrary, it will do more harm than good “as it has already started to do”.
Solutions
The association outlined some solutions and suggestions saying that a cumulative four percent exclusion of lands from the “compensation of standing forest arrangements between Guyana and Norway” to preserve the lives and livelihood of local miners is the only viable solution. It also said that to start the process of improving environmental sustainability of the industry, miners will commit to backfilling the lands once they have completed mining. “This will ensure that there is rapid regeneration of the forest, to the extent where the canopy cover of the forest is reestablished within two years”, it said. The document says that in its present form, Guyana’s alluvial miners are in no way prepared to comply technologically nor financially with the strenuous environmental requirements proposed under the LCDS.
“For us to be able to comply with all that is required under the LCDS may take decades and will require the government to continue to work with miners to achieve and also to facilitate an atmosphere of good faith in their dealings with all parties involved. It is not that we do not want to change, but due to the finances required, technological advancements and general culture/background of many persons involved in the industry, progress in this direction, while possible, will be slow. We do not believe that this can be accomplished if our work grounds are scrutinized under the eyes of international monitors and the rules of the LCDS. We can all do well however to reduce the impact our actions have on our environment. However, the necessary steps taken should be gradual and the capabilities of locals must be of paramount consideration”, it says.
