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NCOM Statement by the National Coalition on Mining (NCOM) on the Galamsey Problem

The National Coalition on Mining, which was formed in 2001, comprises community groups from mining areas, NGOs working on various aspects of mining and development issues as well as organisations of small scale miners. NCOM works for policies that advance the exploitation of Ghana’s non-renewal natural resources in a manner that prioritises the development interests of Ghanaians and recognise the rights of people in mining areas to sustainable livelihoods and respect for their rights and the natural environment.

The NCOM organized its quarterly review and strategy meeting in Accra on Wednesday 17th and Thursday 18th April, 2013. As part of its review of the mining and development issues in the country it deliberated on the current state of the artisanal and small scale gold mining (ASM) sub-sector.

Condolences to galamsey dead

The NCOM extends its condolences to the families and friends of the seventeen (17) people who died on Monday 15th April, 2013, at Kyekyewere, near Dunkwa in the Central Region as a result of the caving in of an abandoned pit in which they were mining for gold. The Coalition will also like to express its utter amazement at the callous and irresponsible attitude of the Upper Denkyira DCE and public officials in abandoning rescue work in the name of a custom against working on Tuesdays. This is not only a flagrant disregard for human life but also raises questions about whether these officials understand their roles and responsibilities under the Constitution and laws of Ghana as opposed to the customs of a particular area. Would they have taken this attitude if the trapped persons were their relatives or government officials?

The Kyekyewere incident is only the latest in a chain of fatal accidents involving illegal small scale gold miners. These incidents, the influx of illegal Chinese operators, the accelerating rate of pollution of water bodies and general environmental degradation by illegal small scale miners/galamsey, the increasing incidents of confrontations between state security personnel and illegal miners and other issues have made small scale gold mining one of the hottest topics in current public discussions.

It is appropriate that that there is such a lively public interest in galamsey. In the view of the NCOM however these public discussions of as well as public policy towards the “galamsey problem” have tended to be fragmented and lacking the holistic understanding and approach required to deal with both the short as well as the long term issues posed by the explosion in the activities of illegal small scale gold miners.

The roots of galamsey

The roots of galamsey lie outside the mining sector. The explosion in galamsey is just one element of the increasing resort of the overwhelming numbers of Ghanaians to the informal economy for a living – the galamsey operators risking their lives in unsafe pits and the youth risking their lives in the middle if traffic in Accra selling imported junk are just two instances of the same problem: the manner in which the Ghanaian economy is growing is not creating decent jobs or livelihood opportunities for a growing number of Ghanaians.  Whilst our politicians are congratulating themselves on Ghana’s leadership in the global growth league table, millions of Ghanaians despair of when they will benefit from this growth.  The economic policies of successive governments are forcing an increasing number of Ghanaians out of agriculture and to seek alternative livelihoods in non-farm activities but these policies are not offering enabling conditions for sustainable alternatives.

 In the gold mining areas the general crisis of the agrarian economy has been intensified by the loss of huge tracts of land to large scale mining companies without any systematic planning for the future livelihoods of the immediately dispossessed and future generations. Gold is the sector attracting the most foreign direct investment into Ghana and successive governments have gone to great lengths to create enabling conditions for the profitability of large scale, predominantly foreign investment. The price of gold has climbed steadily for more than decade. Our impoverished and unemployed youth can see the millions being made from gold by these investors. Is it any surprise that they defy the law, risk their lives, pollute our water bodies to seek a share this wealth for a living?  

Security swoops do not address root issues

The NCOM disapproves of and is concerned about the destruction of water bodies and other ecological damage being caused by galamsey. The Coalition also fully supports the policy of reserving the small scale mining sector for Ghanaians and supports efforts to root out the growing influx of Chinese and other non-Ghanaians in the sub-sector. We condemn the possession and use of firearms by some illegal small scale gold miners against state security operatives. We however believe that the growing militarization of policing responses to galamsey is fuelling the violent responses of some galamsey operators. We are firm in our view that security swoops will not solve the galamsey problem because it is first and foremost a livelihood issue. It is the responsibility of all Ghanaians to demand that violent policing, whether represented by the seeming “shoot to kill” policy in respect of alleged armed robbers or the violation of the rights of galamsey operators do not become established as normal practice. We also condemn the abuse of power by chiefs and other elements of the elite in purporting to allocate land to galamsey operators as well as the complicity of public officials who protect and benefit from galamsey activities.

Figures for the size of all small scale mining sector, legal and illegal, are hard to confirm, with official estimates ranging between 500,000 and 1 million persons. It is almost certain that the majority of these estimates are galamsey operators. The number of those directly or indirectly dependent on the sub sector is several times these estimates. The official statistics for gold production does not distinguish between legal ASM and galamsey gold, the proportion of which has been rising year by year, reaching  a quarter of gold production in 2010 and rising to an estimated one third in 2012. These figures underline the economic and social significance of galamsey and the need for policy responses which recognise this fact.

Small scale miners suffer discrimination

Since the passage of the Small Scale Gold Mining Law in 1989 a number of policy measures and projects have been undertaken by public institutions to support the development of the small scale mining sector. Numerous studies have identified the challenges facing the sub sector. However the truth remains that in the official conception the small scale gold mining sector remains a distant poor cousin to the large scale sector. The bulk of public institutional resources and creative energy is very much focused on the needs of the large scale foreign owned gold mining sector. This in our view is due to the underlying prioritization of fiscal revenue from mining over everything else.

In the general clamour around and condemnation of galamsey many forget that there is an established legal small scale mining sector. Their experiences and frustrations sharply illustrate our earlier point about the distant poor cousin status of small scale gold mining relative to the foreign dominated large scale mining. Also the difficulties they face by and large are very similar to those faced by Ghanaian entrepreneurs, small and large, engaged in production in other sectors of the economy especially agriculture and manufacturing.

In a speech in 2010 the Minister of Lands and Natural Resources proudly announced, without any apparent embarrassment, that the Government was “establishing a revolving fund of about GH¢700,000.00 for organized small-scale mining groupings (e.g. co-operative and associations) to benefit from”.  GHC700,000!! for the development of the mining sub-sector where hundreds of thousands of Ghanaians are located If anything indicts the relative neglect of ASM this is it. GHC700,000 is not even a drop in the ocean when compared to the privileges enjoyed each year by foreign mining companies, especially those with stability agreements.

Developmental Policy framework needed for all mining

A developmental starting point for mining policy will lead at the very least to placing the contribution of small scale gold mining on par with whatever large scale mining is contributing. Such equal recognition will have a number of consequences for public policy and practice. At the very least policy focus, the creation and functioning of public institutions, supporting measures for the development and sustenance of small scale mining will be on par with what is currently devoted to large scale mining. Most importantly it should lead to ASM policy being “embedded into a broad rural development strategy” as called for by the Action Plan of the Africa Mining Vision. Such a broad rural development strategy will offer opportunities to a much larger number of Ghanaians to operate as legal small scale gold miners and create other livelihood opportunities that will help reduce the incidence of illegal mining.

The national stakeholder consultation carried out on ASM under the government’s Natural Resources and Environmental Governance (NREG) project highlighted the many issues that need urgent attention. We believe that the kind of attention that our public institutions need to pay to the challenges arising from the small scale gold mining sub-sector, especially those connected with galamsey problem, cannot be solved if our public institutions, particularly the responsible Ministries and the Minerals Commision continue to see the large scale sector as their main focus. The galamsey problem urgently requires these institutions to treat the small scale gold sector as their main priority for a period, devoting the bulk of their institutional time to its problems.  Needless to say a change of mind set will be required away from what is so patent in all the promotional literature put out by the Minerals Commission and other agencies which focus heavily on the wonderful conditions foreign investors can enjoy and very little about how they are responding to the challenges facing Ghanaians in the mining sector.

Immediate Demands of the NCOM

1.       Moratorium on large scale gold mining projects

To kick start this new orientation the NCOM demands that an immediate moratorium be placed on the granting of new reconnaissance and exploration licenses and mining leases for large scale gold mining. Such a step will have a number of benefits.

The more land which goes to large scale mining the less there would be for potential utilization by small scale operators. Precisely because the approach so far has been imbalanced in favour of large scale operators the gold bearing land potentially available for Ghanaian small scale operators has continued to decrease. This issue touches on the wider issue of situating mining, large and small scale, within a national land use and environmental management policy.

Attention can be devoted to dealing with the tensions and conflicts between galamsey and large scale mining companies. This is one of the main problems in the mining sector not only because of numbers of but also size of concessions to large scale firms. In a very thoughtful speech during last year’s National Mining Forum, Mr. P.V. Obeng Chairman of the National Development Planning Commission noted the conflicts between galamsey and larger scale mining companies “can benefit from an appropriate re-structuring of relations between large and medium scale mining operators and now their illegal informal sector operators, galamseys, by default. The nucleus and out-grower models practiced in agricultural production could be adopted and properly regulated in the interest of peaceful and safe co-existence of the two arms of industry”. This approach has been accepted in principle but movement on it is not proceeding with the urgency that is required.

2.       Limits on Size of Large Scale gold projects

As part of the ongoing mining policy reform process the government should place an upper limit on the size of concessions given to any one large scale company.

3.       Government support for ASM organisations

The government should support the efforts at self organisation and unity by small scale miners. The quality of such organisation is important for not only the miners themselves but will make them a better partner to government in the policy making process.

Accra 21st April 2013

For more information contact Alhassan Atta-Quayson at the NCOM Secretariat


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