James Wolfensohn
President
World Bank Group
1818 H Street NW
Washington, DC 20433
July 7, 2003
Dear Mr. Wolfensohn,
On May 7, 2003, Ghana’s National Coalition of Civil Society Groups Against Mining in Forest Reserves issued a declaration demanding that the Government of Ghana rescind any permission already granted to mine in the country’s forest reserves (see attached). The declaration also calls upon the World Bank Group and other international financial institutions “not to finance or support the Ghana Government and the five companies [seeking mining permits] to carry out mining in the forest reserves in the country.” We support this declaration and are writing to request a formal response from the Bank to the Coalition’s appeal.
Since the early 1980s, the World Bank appears to have provided over $100 million in financing for the mineral sector with the primary goal of accelerating private investment in mining. According to the World Bank, the main thrust of its 1988 Mining Sector Rehabilitation Project was “to support the Government’s efforts to establish an enabling environment for attracting private investment into the mining sector” (see the Implementation Completion Report). Similarly, the Bank’s 1995 Mining Sector Development and Environment Project emphasized “the liberalization and rationalization of sector policies.” It also argued that “if the [mining] sector is to continue to expand, there is now a pressing need to expand the Government’s general exploration work to locate additional likely deposits and publicize the findings of that work in order to attract new investors” (see the Staff Appraisal Report). This emphasis on liberalization and deregulation reflects the guiding principle of the Bank’s 1992 “Strategy for African Mining.” The Strategy asserts that “the main objective of donor intervention in African mining—whether through technical assistance or investment financing—should be to facilitate private investment and help reduce the country and project-related risk for the private investor.”
We believe that a parochial emphasis on reducing “the country and project-related risk for the private sector” fails to adequately address crucial social and environmental considerations. We acknowledge that the Bank’s Mining Sector Development and Environment Project did include provisions to reduce the “negative environmental impact of mining through improved regulations and more effective environmental monitoring and enforcement” and incorporate “environmental aspects into application for exploration rights.” Apparently, however, these important objectives met with only mixed success. The Bank’s own assessment of the project notes that “the environmental components of the project were not implemented, as envisaged by project design, in full partnership with the EPA [Environmental Protection Agency] and the mining institutions” (see the Implementation Completion Report).
The World Bank has also invested heavily in the forestry and natural resources sector in Ghana, providing nearly $80 million to support environmental projects and programs over the past twenty years. For instance, through its Forest Resources Management Project (1988-1997), the Bank was involved in the elaboration of a Forest Protection Strategy that was apparently designed to promote biodiversity conservation and counteract environmental degradation. Most notably, the ongoing Natural Resources Management Program (a joint IDA-GEF undertaking) seeks to “address the conservation of tropical forest ecosystems by strengthening the network of conservation areas in Ghana” and “[improve] the policy and regulatory environment for high forest management.” The World Bank has committed to provide $30 million of the total $90 million project cost through 2008, while GEF will finance $8.7 million. Additionally, there are two other active Global Environment Fund projects in Ghana representing an additional investment of almost $18 million. Both of these projects explicitly address issues of biodiversity conservation and sustainable resource management.
However, the Bank’s environmental efforts are diminished and even contradicted by its historical focus on supporting a rapid expansion of mining in Ghana. It does not appear that a healthy balance has been struck in Ghana between promoting private investment and ensuring the social and environmental well-being of future generations. A decision by the Government of Ghana to allow mining in forest reserves will send yet another signal that maximizing investment continues to be of greater priority than maximizing the quality of life for Ghanaians and sustainability of development. Furthermore, such a decision will undermine the World Bank’s efforts to improve environmental protection and performance in Ghana’s forestry and mining sectors and threaten the Bank’s existing investment in the sound management of the country’s natural resources and its own mission of reducing poverty through sustainable development.
Some local communities in villages surrounding the reserves have begun to question the logic of allowing surface mining where they have long been prevented from farming or harvesting wood in the reserves. They have therefore vowed to resist any attempt to conduct surface mining in the forests, expressing heightened concern about the detrimental legacy of surface gold mining in villages like Atuabo, Damang, Teberebie, Kyekyewire, Abekoase, and Sansu, to name but a few. The Aboduabo Farmers Association submitted a petition to the World Bank’s Ghana office in February 2003 asking the Bank to encourage the government to rescind mining licenses in the Tano-Suraw Reserve. Several other communities have also expressed their commitment to resist mining in the Bonsa and Supuma Forest Reserves.
Despite concerns expressed by potentially affected local communities and Ghanaian civil society organizations, Ghanaian government representatives have claimed that they fear a backlash from the international market and international financial institutions - such as the World Bank - if the government prevents the companies that have already carried out some exploration from mining ore located in the forest reserves. Under these circumstances, and given the Bank’s significant involvement in both the mineral and forestry sectors in Ghana, we call upon the World Bank to clearly state that it does not and will not support the authorization of mining in Ghana’s forest reserves.
We look forward to your response,
George Awudi
Friends of the Earth-Ghana, Ghana
Abdulai Darimani
Third World Network-Africa, Ghana
Mike Anane
FIAN, Ghana
Lambert Okrah
Institute of Cultural Affairs, Ghana
Daniel Owusu-Koranteng
Wassa Association of Communities Affected by Mining (WACAM), Ghana
Donkris Mevuta
Friends of the Nation, Ghana
Inketia Andersen
GreenEarth Organisation, Ghana
Augustine Niber
Centre for Public Interest Law, Ghana
Ms Rose Mensah-Kutin
ABANTU for Development, Ghana
Kennedy Appiah
Integrated Social Development Centre (ISODEC), Ghana
Shannon Lawrence
Environmental Defense, USA
Payal Sampat
Mineral Policy Center, USA
Nikki Reisch
Bank Information Center, USA
Diana Ruiz
Project Underground, USA
Carol Welch
Friends of the Earth-US, USA
Joan Kuyek
MiningWatch Canada, Canada
Pam Foster
Halifax Initiative
Ruth Rosenhek
Rainforest Information Centre, Australia
Peter Sinkamba
Citizens for a Better Environment, Zambia
Nur Hidayati
WALHI (Indonesian Forum for Environment), Indonesia
Miguel Palacín Quispe
Coordinadora Nacional de Comunidades del Perú Afectadas por la Minería
(CONACAMI PERU), Peru
Leon Spencer
Washington Office on Africa, USA
Michael A. Schrick
Partnership Berlin Treptow-Köpenick-Cajamarca, Germany
Emira Woods
Co-Director Foreign Policy In Focus
Institute for Policy Studies, USA