Dear Editor
The NALCO Champion episode has exposed several glaring structural deficiencies in the decision making apparatus in Guyana.

John Fernandes claims to have been provided with authority to construct this facility based on a letter issued by the Central Housing and Planning Authority (CHPA) in 2014.
The CHPA was created by the Housing Act Chapter 36:20 and is provided with various responsibilities under the Town and Country Planning Act Chapter 20.01. Section 7(1) of Chapter 20.01 mandates “The Central Authority may by resolution decide (a) to prepare a scheme with respect to any land within the area specified in the resolution or, (b) to adopt with or without variations, a scheme proposed by all or any of the owners of such land or (c) to adopt with or without variation, any scheme forwarded to the Central Authority under Section 6.” Chapter 20.01, however, also requires “Notice of the resolution shall be published within the prescribed time in the Gazette and a local newspaper at least once in each of two successive weeks”.

This mandate precludes the CHPA from granting any change in land use status to John Fernandes Limited without notification to all affected parties. Numerous requests to both CHPA and/or John Fernandes Limited have provided no verification of the publication of any such resolution in the Gazette or any local newspaper. This is a structural deficiency which must be addressed for future development. NALCO Champion claim, supported by Go-Invest, the Ministry of Finance and CHPA, that all chemicals to be stored at the facility are benign. These chemicals include Benzene, a non-threshold chemical substance. Go-Invest, the Ministry of Finance and CHPA collectively have no expertise to evaluate the consequences of threshold or nonthreshold chemicals on health and the environment.
These entities and the Environmental Protection Agency are strongly advised to consult research conducted by my former co-worker at Woodward Clyde Consultants, Professor Jeff Evans of Bucknell University and Dr David Daniel of the University of Texas on the permeation of clays by organic chemicals. Further confirmation of threats to the environment is demonstrated by the work of Professor Pinder of Princeton University who documented the contamination of aquifers in Connecticut by organic pollutants discharged to groundwater in Long Island in his book Subsurface Hydrology. Further, the clays in Guyana’s coastal plain are montmorillonitic and have a negative charge.

Substitution of lower valence Sodium Ions by higher valence cations ions will further increase the permeability of these clays. The permeation of clays by chemicals stored at Nalco Champion facility can threaten groundwater resources in the vicinity of any of their developments. Claims of lost investments occasioned by Nalco Champion move to Trinidad fail to factor the consequences of the environmental costs of development. Go-Invest, the Ministry of Finance and CHPA are advised to read the Asian Development Bank publication “Economic Valuation of Environmental Impacts”. Consultation of that document will confirm that projects should only proceed if the environmental benefits are greater than the environmental costs. Despite of claims of “lost investment” by Go-Invest, the Ministry of Finance and CHPA, none of these entities have qualified the environmental cost and/or benefits of this project. Guyanese should be reminded of the elevated mercury levels in employees of GGMC created by similar considerations in the past.

I suspect that Go-Invest, the Ministry of Finance and CHPA were similarly concerned with lost investment and paid absolutely no attention to the environmental consequences of their action. To date no analysis has been conducted to examine the environmental costs of that operation. Those consequences will extend over the life of GGMC employees and can be transferred to their children and grandchildren. My objections to this facility being sited in my neighborhood is driven by sound technical considerations, some of which are herein identified. Trinidad and Tobago has an industrial park in Pt Lisas, zoned for these developments. Go-Invest, the Ministry of Finance and CHPA should work along with the Department of Energy and the EPA to develop a similar park for these facilities in Guyana. Further, all development, as demonstrated by the mercury contamination issues at GGMC, do not necessarily create added quality of life. Nalco Champions are welcome in Guyana, however, the facility and other likely to create similar impacts should be sited in areas where threat to human health and the environment can be effectively managed.
In closing, I refer you to New Castle County, Delaware. The landfill, created by the county, is now a superfund site and pollutants from the landfill have contaminated a sole source aquifer. The landfill was created with the best of intentions. We face similar outcomes in Guyana if we fail to understand the complex interaction between development and environmental consequences. Lamentations about lost revenue is confirmation of Go-Invest, the Ministry of Finance and CHPA failure to comprehend this relationship.

Regards
Charles Ceres