Objection to Storage of Radioactive Device at Coverden East Bank, Demerara and Environmental Protected Act Needs to be Amended Now!

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Dear Editor,
It is my view that the pace in strengthening institutions; and updating laws, rules, and procedures relative to the Oil and Gas industry, is a bit too slow. The production and export of oil seems to be running way ahead of the capacity and capabilities of the relevant agencies.
A case in point, the Environmental Protection Agency (EPA) has published a ‘Public Notice’ for a company Non-Destructive Testers Limited (Guyana) Inc. to establish a ‘Storage of Sealed Radioactive Source – Industrial Radiography Device’, to be located at Lot 1 of Lots 1 and 2 Thuiste Te Coverden, East Bank, Demerara. This matter, I must indicate, is very personal, because Coverden is my village and I have over 200 blood family members in that village.

However, my concern is beyond the personal interest, the Environmental Protection Act was passed in 1998, I stand corrected; this was way before the Oil and Gas industry became functional. The Act states the following:
Section (11) (2) ‘Where it is  not clear whether a project will significantly affect the environment, the developer shall submit to the Agency a summary of the project which shall contain the information as required by subsection (1) and the Agency shall within a reasonable period publish in at least one daily newspapers a decision with reasons as to whether the project –  (a) will not significantly affect the environment, and therefore exempt from the requirement for an environmental impact assessment; or (b) may significantly affect the environment and will require an environmental impact assessment’.

Section (3) (a) of the Act states, ‘Any person who may be affected by a project exempted under subsection (2) (a) may lodge an appeal with the Environmental Assessment Board…within sixty days of the date of publication of the Agency’s decision, and the Environmental Assessment Board shall within reasonable time publish a decision confirming or setting aside the Agency’s decision’.

I think that the Environmental Protection Agency, is using the same process of assessment, which was used for a chicken farms, sawmills, clay brick factories (I stand corrected), to assess operations relative to the oil and gas operations.
Now Editor, this is the Environmental Protection Agency, they are the technical experts, however, according to the Section (3) (a) of the Act, the burden is placed on non-technical villagers and citizens, to file an appeal objecting to these highly technical projects. This to my mind is gross irresponsibility as a country. This is a ‘Storage of Sealed Radioactive Source – Industrial Radiography Device’, what will the resident at Coverden know radioactivity to file an appeal?

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Based on the high profile of the Oil and Gas sector to Guyana, its importance to the country’s development, and in the interest of the wellbeing of citizens, I hereby strongly recommend the following:

That Section (11) (2) of the Environmental Protection Act be immediately amended to read as follows: ‘Where it is not clear whether a project will significantly affect the environment [With the EXCEPTION of ALL projects related to Oil and Gas industry], the developer shall submit to the Agency a summary of the project which shall contain the information as required by subsection (1) …
Further, I recommend that the Environmental Assessment Board as currently constituted under Section 18 of the Environmental Protection Act, be reviewed, and be reconstituted as a Constitutional body under the Guyana Constitution. This will to a large extent guarantee greater independence and professionalism of the functioning of the Board.

I would also like to suggest that the position of the ‘Executive Director’ of the EPA be approved by a Constitutional Commission or Constitutional body.
Editor, I am of the view that the Oil and Gas industry could become a part of our problem, but it is undoubtedly, a huge part of our solution. I support investments, development; but it must be done sustainably. Our approach must be along the route of sustainable development and sustainable business.
I would also wish to state that many of the residents of Coverden support and are willing to consider investments in our community, however, we would like to set some limits as the kinds of investments, there is need for better planning for the location of these projects, and possible zoning should be done.

Since this is the second such project for the village, some of my technical colleagues have assisted in developing what can be used as a model; to be discuss with the EPA, if there is interest, for a more structured and collaborative stakeholder approach for putting a system in place for engagements, inclusive of members from communities, in monitoring and minimizing risks throughout the various stages of the operations of these projects.
Finally, Coverden has some unique historical and cultural features, for example, my family members are over 200 and have been residing in the village since 1842, over 178 years, in addition to other residents. I do not know of any other village in Guyana where one single family who reside in a village, is so large, as such, one the key considerations for investments in Coverden, should be to minimize exposure and additional burdens on one family, as well as on other residents.

Yours faithfully,
Citizen Audreyanna Thomas



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