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

classification of sub-sectors in the draft code results in several lost opportunities that
could protect the interests of the State, miners, third parties, and protect the environment.
Allocation of concessions. Educational levels, literacy, cultural and language barriers are
all significant barriers to regulatory reform in the gold mining sector. Thousands of
interior and migrant miners are not literate in Dutch, or do not speak the language, and
are thus unable to apply for a concession. Moreover, almost the entire greenstone belt has
been given out to large-scale, medium-scale enterprises and speculators, thus the chances
of finding a free mine site is very small. Under the current circumstances most gold
mining will remain illegal.
As suggested in the next chapter, zoning of the mining regions can contribute
significantly to a much better regulation of the sector and sub-sectors. It is suggested,
therefore, that the mining areas should be formally partitioned into mining regions and
zones, much like the administrative zoning of Suriname into districts and resorts, or into
electoral districts and resorts. Once mining regions and the constituent zones have been
established by law, it will be much easier to develop an effective regulatory system. For
example, if each mining region has a mine inspector, concession allocation and
equipment registration could be issued in the mining regions by the responsible inspector.
In a very short time almost the entire SSGM sector could be formalized in this manner.
But in order to do so, an entirely new concession regime is needed, which at least
distinguishes small-scale concessions from medium-scale and LSM, and which specifies
which concession could be issued in the field and which must be secured in Paramaribo.
Part III – Environment, Health and Safety. The dual classification system retained in
the draft law creates a situation whereby LSM must adhere to the very stringent norms
and standards of the World Bank, as outlined in the “Pollution Prevention and Abatement
Handbook,” while SSM must “strictly abide by the environmental rules given by the
Minister.” Environmental regulation is a very sensitive and politically loaded subject. It is
not appropriate to subject the Minister to the political risks associated with executive
regulation of the many serious environmental problems in a sub-sector that is out of
control.
69