SITUATION ANALYSIS OF THE SMALL-SCALE GOLD ... - WWF

Institutional: It provides guidance to government departments, administrators,
decision groups, monitoring and regulatory agencies for the application and
interpretation of laws and regulations affecting both national and international
investors in the sector.
An integrated stand-alone gold mining policy document can play a critical role in the
process of regulatory reform. The following question can now be posed: How should the
policy-making process take place?
Article 90 makes it clear that the President is responsible for initiating and managing this
process. This does not imply that the President must be involved on a day-to-day basis in
order to dispense mining policy. The President could appoint a mining policy
development commission that reports to him and develops an integrated national mining
policy under his guidance and supervision. It is not clear why this was not done before
the legislative drafting process got underway. The overall regulatory process vacillates
between policy development and legislative amendment. At the commencement of a
reform process, however, policy development is logically prior to legislation drafting. It
is difficult to understand how the many complex and politically loaded issues were
translated into provisions of the draft mining code. Without the guidance of an approved
policy directive, or a more comprehensive and integrated policy document, it would be
difficult to choose the best alternatives in a wide range of legislative options.
As the previous chapters indicate, there is a huge gap between the current mining code
and the realities in the gold fields. And there still is a large gap between the provisions of
the draft mining code and the realties in the field. These gaps have to be closed. The most
effective and efficient way to close this gap is to develop a mining policy that enjoys
broad support from all key players in the mining community. This policy directive can
then be used to develop the provisions of the new mining code.
5.3 Unresolved basic policy issues
There are a number of basic issues that have to be resolved before the process of
legislative drafting and institutional development can get underway. The most basic of
the issues is the position of the government on the place and role of SSM in the economic
development of Suriname.
Does it want to discourage the activities in this sub-sector, as indicated in the
explanatory memorandum of the current mining code? Does the government
believe that the days of SSM are numbered and that the challenges associated
with the sub-sector will phase out automatically as small-scale deposits are
exhausted? Does the NH believe that the regulatory, economic, social and
environmental problems associated with SSGM will disappear as alluvial
resources become exhausted?
Or does the NH want to recognize the SSGM sector as an important source of
employment and economic activity, and will it invest in programs and activities
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