Dear Editor,

THE Environmental Protection Act No. 11 of 1996 (EP Act) clearly states under Part II – Establishment and Functions of the Agency – the following:“In the exercise of its functions the agency shall (a) compile and amend from time to time, with the assistance of internationally-recognised 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 authorised to circumvent the EP Act. However, in spite of the legally established requirement detailed above, the EPA, under the jurisdiction of Executive Director Ramdass and Environmental Management Division Director Seebarran, has continually ignored this mandate of the EP Act by compiling and distributing a list of consultants and firms that 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 illegal 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 about the motives of Directors Ramdass and Seebarran.

Ground Structures Engineering Consultants Inc. (GSEC) has the largest portfolio of environmental compliance projects in Guyana, and 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 projects undertaken by GSEC include 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.

GSEC is 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 the 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, Ramdass and Seebarran have not seen it fit to include GSEC on the list of firms which they have 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, both Ramdass and Seebarran compound their illegal action by instructing firms to which the list is provided that no firm not identified on that illegal list would be acceptable to the EPA.

It can be stated without fear of contradiction that neither Ramdass nor Seebarran are adequately competent in the diverse range of disciplines required to prepare a proper ESIA to make that determination. The actions of both Ramdass and Seebarran are indicative of a continuation of the policy articulated by Dr. Luncheon during the Jagdeo/Kissoon libel trial, which clearly established that African-Guyanese are not qualified to work in certain areas in Guyana.

The EPA under Ramdass epitomises the implementation of the PPP policy as articulated by Luncheon, and is reflected by the absence of any African-Guyanese serving as a department head at that agency.

Ramdass and Seebarran are obviously not content with the effectiveness of their policy at the EPA, and are now apparently focused on extending that policy to the entire country by identifying firms/individuals as being qualified to conduct ESIAs, with the clear intent of excluding the most qualified firm in Guyana simply because it is owned by African-Guyanese.

GSEC is hereby requesting both Ramdass and Seebarran to publicly state their basis for contravening the AP Act, and to further identify the criteria they have used to determine the qualifications and experience of persons (or firms) to carry out environmental impact assessments.

It is expected that these individuals will justify their position by detailing a list of projects on which these firms have provided environmental compliance services.

It would also be helpful if Ramdass and Seebarran can justify their ability to identify suitably qualified individuals/firms by specifying exactly the area of environmental compliance in which these individuals have experience compatible with that of GSEC.

We trust no cries of “witch-hunting” will be heard now that Ramdass and Seebarran are being asked to address their failure to adhere to the professional standards associated with the responsibilities they have been tasked to discharge.
Regards,
CHARLES P. CERES