Proceedings of 23rd International Business Research Conference
18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8
Community Participation in Environmental Impact
Assessment for Mining Projects in Selected Communities
in Ghana
Emmanuel Yamoah Tenkorang*, Hannah Owusu-Koranteng** and
Richard Hato-Kuevor***
The potential contribution of mining to Ghana‟s economy was acknowledged
and
given
priority
attention
under
the
Economic
Recovery
Programme/Structural Adjustment Programme (ERP/SAP) undertaken
between 1983 and 1990.The accelerated growth in the mining sector under
the ERP/SAP has led to Ghana achieving the status of the second largest
gold producer in Africa after South Africa. This achievement notwithstanding,
mining has had significant impacts on the environment, especially on
biodiversity, air and water quality, pollution levels as well as land degradation
and health. The EIA is now a prerequisite for securing a mining license, but
practical weaknesses with the EIA process which deny the opportunity to
participate fully, especially for affected local communities are also noted.
The objective of the study was to assess communities‟ participation in the
Environmental Impact Assessment (EIA) process undertaken for mining
operations. The study employed a descriptive design in an attempt to describe
the reality of a situation as compared with what the law states. The study area
consists of three large scale mine catchment areas: Birim North; Prestea-Huni
Valley and Ellembelle District. Both purposive and convenience sampling
methods were adopted to select required respondents for the study from two
communities purposively selected in each of the three selected mining areas
and three Focus Group Discussions (FGDs) in each of these communities. In
total, there were 16 interviews and 18 focus group discussions. The study
concludes that even though there were generally several different levels of
meetings, the participation of communities was mostly limited to information
dissemination and to a smaller extent consultation. This study recommends
that the Government of Ghana through the EPA should ensure that the EIA
process is more transparent than it is now. This can be achieved by for
instance, ensuring that technical documents used as a basis for the
organization of community meetings and fora are made available to the
communities for periods adequate to allow for proper studies before the
meetings and fora are organized. In addition, government through any
appropriate agency and in consultation with affected communities should hire
the services of consultants to act for and on behalf of the affected
communities in negotiating appropriate redress for the environmental impact
of mining projects in Ghana.
_________
* Institute for Development Studies, University of Cape Coast, Ghana
** WACAM, Ghana
*** Oxfam America West Africa Regional Office, Ghana
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Proceedings of 23rd International Business Research Conference
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1. Introduction
The potential contribution of mining to Ghana‟s economy was acknowledged and given
priority attention under the Economic Recovery Programme/Structural Adjustment
Programme (ERP/SAP) undertaken between 1983 and 1990. With the aim of increasing
production and productivity of the mining sub-sector, changes were made in mining
sector legislation to attract Foreign Direct Investment (FDI). This effort included
increased fiscal liberation of the mining sector, the strengthening and reorientation of
government support institutions for the mining sector and the privatisation of state
mining assets (Akabzaa and Darimani, 2001).These reforms resulted in the expansion
of the mining sub sector in Ghana.
At the start of 2008, a total of 212 mining companies had been awarded mining leases
and exploration rights (Minerals Commission, 2008 cited in Boon and Ababio, 2009).
Sixteen percent of these mining companies were given mining leases by the Minerals
Commission. As of 2009, Ghana had nine large-scale mining companies producing
gold, diamonds, bauxite and manganese. There were also over two hundred registered
small scale mining groups and 90 mine support service companies. Twenty four percent
of all mining companies in Ghana as at the time were foreign controlled mining
exploration companies, whilst the Ghanaian controlled mining companies, which
constituted 60 percent of all mining activities, were mostly involved in small-scale mining
and spread across the length and breadth of the country.
The accelerated growth in the mining sector under the ERP/SAP has led to Ghana
achieving the status of the second largest gold producer in Africa after South Africa and
a significant producer of bauxite and diamond (Ghana Chamber of Mines, 2009). This
achievement notwithstanding, mining has had significant impacts on the environment,
especially on biodiversity, air and water quality, pollution levels as well as land
degradation and health (Boocock, 2002). To make matters worse, some mining
companies have even been granted mining leases to mine in Forest reserves in Ghana .
Regardless of the location, large areas of land and vegetation are cleared to make room
for surface mining activities, which is the predominant mining process in use in Ghana.
Surface mines use their concession space for activities such as siting of mines, heap
leach facilities, tailings dump and open pits, mine camps, roads, and resettlement for
displaced communities (Akabzaa and Darimani, 2001).
The negative impacts of mining are compounded by the fact that the mining industry
has been a major perpetuator of the continuing marginalisation of indigenous
communities, as this activity has alienated them from their land and livelihood resources
(Aubynn, 1997). As Boocock (2002) argues, mining activities have had dire
consequences on the environment and society and have negatively impacted the social
and economic character of mining communities. Mining companies have also been
accused of shirking their obligations to the communities in which they operate, thereby
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Proceedings of 23rd International Business Research Conference
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increasing the level of local poverty and vulnerability. Notwithstanding the considerable
benefits from mineral resources, a further issue is the “paradox of resource curse”; that
is, though rich in mineral resources, the majority of the people continue to be poor. To
illustrate, a 2008 UN Integrated Regional Information Networks (IRWN) report indicated
that 12.8% of Ghana‟s 22 million people were deemed “extremely poor” by UN
standards, as they live on less than a dollar a day, and struggle to access basic social
services like health, water and education. Concerned about the paradox, human rights
activists, civil society organizations, environmentalists, and government officials in and
outside Ghana have been critical of mining and mineral resource exploitations and the
lack of effort to develop the people and the local environment. Serious criticisms have
been directed at foreign players who have been known to exploit legal loopholes and
abuse both human rights as well as the environment. For example, the current mining
law (most agitations are calling for its review) does not allow farmers enough say in
authorizing their lands for mining activity, making it difficult to crack down on the
rampant exploitation of the environment by mining industries.
There is no doubt that it is the local people who bear the brunt of all the environmental
degradation that accompanies mining operations. The nation as a whole gains
disproportionately from the taxes of all types and dividends accrued from mining
companies. No portion of this financial benefit is specifically allotted for the development
needs of the degraded environment.
There is a general belief in Ghana that poverty and lack of sustainable development in
the mining communities and the country in general has been caused by the behaviour
and operations of the mining companies. However, these companies have countered
this claim by arguing that in a developing country like Ghana, poverty is generally
pervasive, even in communities where there is no mineralization. The mining companies
do not perceive their presence and operations in local communities to contribute to
poverty and vulnerability. The Ghana Chamber of Mines (GCM), an association of all
corporate miners in Ghana, contends that the social investments its members make in
the mining communities are their contribution towards improving the well-being of the
people and facilitating community development. The GCM also notes that most nonurban and non-mining companies do not benefit from these private sector contributions.
Importantly, the GCM argues that mining companies should never be seen as surrogate
governments; rather the efforts of the companies should be seen only as
complementary to what government has to provide.
Given the divergence of opinion regarding who is responsible for the current state of
affairs, it thus becomes imperative to include all the stakeholders in the mining license
“decision-making” and choice of technology for the mining project. All efforts to involve
all stakeholders, issues of level of participation of each stakeholder, the conditions of
participation and the media for interaction if appropriately considered and selected will
foster transparency and government accountability and responsiveness. This is also
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Proceedings of 23rd International Business Research Conference
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reflected in the Rio declaration, principle 10 which states: “Environmental issues are
best handled with the participation of all concerned citizens at the relevant level”
(WCED, 1992).
To achieve mutual benefits, the impacts of the mining life cycle require the participation
of both the mining companies and host communities in meaningful dialogue. The
information communities need in order to participate in mining activity decision-making
includes basic knowledge of the five stages in the mining life cycle: mineral exploration;
deposit evaluation; mine planning; construction and operation; and mine closure
reclamation.
However, the reform in the mining sub-sector was done with little attention paid to
reforming existing environmental laws to manage the environmental consequences. In
1989, the Environmental Protection Council began to apply the Environmental Impact
Assessment (EIA) as an environmental management tool for industrial operations. The
Mining and Environmental Guidelines, published in 1994 with the objective of assisting
the mining industry to operate environmentally responsibly, was given a legal mandate
in December 1994 when the EPC was transformed into the Environmental Protection
Agency (EPA) by an Act of Parliament (EPA Act, 1994 (Act 490) to empower it to
enforce environmental laws in Ghana. With the passage of Act 490, it became
mandatory for all new mining projects to prepare EIA, while existing mines were
required to prepare and submit Environmental Management Plans (EMP).
Legislative Instrument 1652 (LI 1652), Environmental Assessment Regulations, 1999
was passed to operationalise the implementation of EIA in industries that have either
perceived or known impacts on the environment.
The EIA process involves
identification and quantification of environmental impacts. It also involves categorisation
of impacts including direct, indirect and cumulative impacts.
2. Problem Statement
The EIA is now a prerequisite for securing a mining license, but Akabzaa and Darimani
(2001) note practical weaknesses with the EIA process which deny the opportunity to
participate fully, especially for affected local communities.
A major principle of the EIA process is that the proponent is required to give notice and
advertise the proposal in the national press to enable the public to express its interest or
concerns or to comment on the project. While at first glance this appears reasonable,
the approach requires some scrutiny. Article 12 (k) enjoins the EPA to require, as part of
the Terms of Reference (TOR) for the submission of an EIA, that the proponent consults
with members of the public likely to be affected by the operations of the undertaking.
However, the actual procedure for the consultation is not clear or outlined. This
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Proceedings of 23rd International Business Research Conference
18 - 20 November, 2013, Marriott Hotel, Melbourne, Australia, ISBN: 978-1-922069-36-8
therefore gives the proponent the discretion to decide the kind of community
participation that will be used in the process.
After a draft EIA report has been submitted by a proponent, the EPA is supposed to
publish it in at least one national and one community newspaper in the locality of the
proposed mining activity. The Agency is also supposed to make copies of the report
available to the local community for review and comment, with the public having 21
days, from the first day of publication, to provide any such comments. This approach to
public consultation is, however, problematic. For instance, the media of advertisement,
primarily the national press or the premises of District Assemblies, are not very
functionally accessible to these communities. Also EIA reports are presented in
technical language, which is beyond the comprehension of the average community
members preventing them from being able to raise concerns. Given these observations
the question arises as to how the EIA in practice address the issue of community
participation.
The objective of the study was to assess communities‟ participation in the
Environmental Impact Assessment (EIA) process undertaken for mining operations. The
study was done to answer the following research questions:
i. What has been the practice of participation by communities in the EIA process?
ii. What problems inhibit improved community participation in the EIA process?
iii. How can community participation in the EIA process be enhanced to ensure
environmental sustainability?
3. Environmental Impact Assessment
Ghana, like any other country and especially developing ones, has had to exploit its
resources to achieve development. However, the kind of large scale resource
exploitation embarked upon by mineral rich countries has ignored environmental
consequences (Mabogunje, (1980), cited in Ofori, (1991). However, after the United
Nations Conference on the Human Environment (UNCHE) of 1972, efforts at
acknowledging the relationship between development and environment were given a
boost with accounting for the environmental consequence of development effort forming
a major component. While the Stockholm conference was important, subsequent
environmental conferences, especially the Rio Conference of 1992 gave practical
meaning to environment-development relationship. The protection of the human
environment for the well-being of peoples and economic development was made a duty
of all Governments. Developing countries were entreated to direct their efforts to
development that bears in mind the need to safeguard and improve the environment
and to improve the human environment for present and future generations
(http://www.unep.org/Documents.Multilingual/Default.asp?documentid=97&articleid=150
3-).
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Proceedings of 23rd International Business Research Conference
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The Environmental Protection Council (EPC) of Ghana was formed in 1973 based on
recommendations of the UNCHE to advise the government on environmental issues. In
1981, the EPC submitted a memorandum to the Parliamentary Committee formed to
draft a National Investment Code for Ghana on the need to include in the Code,
provisions requiring investors to state the likely environmental effects of their investment
(Ofori, 1991). In 1985, the 1981 investment code was abolished and replaced by
Provisional National Defence Council Law 116 (PNDCL 116 of 1985). This law made
the statement of the likely environmental consequence of investments a condition for
the approval of any project. This law placed no specific responsibility on the EPC, but
based on its own initiative, it coordinated activities with the GIC and the Ministry of
Industries, Science and Technology to form a sub-committee of the Environmental
Impact Assessment Committee (EIAC) of the EPC to draft EIA legislation for Ghana
(Ofori, 1991).
It is noteworthy that the practise of EIA then was for the proponent of the project to
submit a statement on the environmental impact without clear provisions regarding the
involvement of the people affected by the project. The National Environmental Action
Plan (NEAP) was inaugurated in 1989 with a note that the EIA was to be as
comprehensive as possible. This NEAP was to be coordinated by the EPC whilst the
EIA requirement was still a responsibility of the GIC.
Environmental Impact Assessment became integral to the consent process for major
development projects financed by most International Finance Institutions (IFIs) like the
World Bank and International Finance Corporation. Most applicants were also required
to submit an Environmental Statement in support of applications for funds. The World
Bank, for instance, effective 1st March, 1999, required the undertaking of an
Environmental Assessment to be provided and reviewed for all projects to be funded by
the Bank to ensure that they were environmentally sound and sustainable to improve
decision making (World Bank, 1999).
4. Participation
The definition of “participation” is a matter that has attracted a considerable
disagreement among development scholars and practitioners (Cohen and Uphoff,
1980). The World Bank (1991) defines participation as mainly a process whereby those
with legitimate interest in a project influence decisions which affect them. This definition
of participation does not distinguish between collective and individual influence on
decision-making. Others view participation as an instrument to enhance the efficiency of
projects or as the co-production of services. Some would regard participation as an end
in itself while others see it as a means to achieve other goals (Cohen and Uphoff,
1977). These diverse perspectives truly reflect differences in the objectives for which
participation might be advocated by different groups.
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Paul (1987) defines community participation as an active process by which beneficiary
or client groups influence the direction and execution of a development project with a
view to enhancing their well-being in terms of income, personal growth, self-reliance or
other values they cherish. This definition reflects the broad nature of the process of
community participation and the fact that interpretation is linked to an agency‟s
development perspective. Community participation can be said to occur only when
people act in concert to advise, decide or act on issues, which can best be solved
through some joint action.
The nature of the project and the characteristics of beneficiaries will determine, to a
large extent, how actively and competently the practices of participation can be
achieved. Further, it is useful to distinguish between various levels of intensity in
community participation, though different levels of community participation may co-exist
in the same project (Paul, 1987; Cohen and Uphoff, 1980; Oakley, 1991; Nelson and
Wright, 1995). Paul (1987) identified four ascending levels of participation as
information sharing, consultation, decision-making and initiating action. According to
Paul, all four levels may coexist in a project. The first two categories present ways to
exercise influence, which he terms low participation; the latter two offer ways to exercise
control, which he sees as high participation.
Pretty and Vodouche (1997) created seven categories describing participation, from
least to most participatory.
1. Passive participation describes the type of participation where locals are told
what is going to happen and involved primarily through being informed of the
process.
2. Information sharing describes the type of participation where locals answer
questions to pre-formulated questionnaires or research questions and do not
influence the formulation or interpretation of the questions.
3. Consultation describes the type of participation where project beneficiaries meet
with external agents who define both problems and solutions in light of the
responses, but are under no obligation to take on people‟s views or share in
decision-making.
4. Provision of material incentives involves project beneficiaries providing
resources, such as labour/land in return for other material incentives. They do not
have a stake in continuing activities once the incentives end.
5. Functional participation occurs when locals form groups usually initiated by and
dependent on external facilitators to participate in project implementation. The
groups may become self-dependent and are usually formed after major decisions
have been made, rather than during the early stages of the project.
6. Interactive participation describes the type of participation where locals
participate in joint analysis leading to the formulation of project plans and the
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formation of new local institutions or strengthening existing ones. The groups
take control over local decisions and in maintaining structures or practices.
7. Self-mobilization describes the type of participation where locals participate by
taking initiative independent of external institutions and develop contacts with
external institutions for resources and technical advice, but retain control over
how resources are used (Pretty and Vodouche, 1997).
Shaeffer (1994) also divides levels of participation into two parts: passive involvement
and active participation. Passive involvement includes the mere use of a service; the
contribution or extraction of money, materials and labour; attendance which implies
passive acceptance of decisions made by others; and consultation on a particular issue.
Active participation can be demonstrated in the delivery of a service, often as a partner
with other actors; as implementers of delegated powers; and in real decision making at
every stage including identification of problems, the study of feasibility, planning,
implementation and evaluation.
The global recognition of the need to assess the extent of community participation in
development projects and programmes is encouraged as there is still a gap between
participation rhetoric in politics and participation as practiced at the operational level
(Oakley, 1991; Rudqvist and Woodford-Berger, 1996). There is a growing realisation
that if participation, in one form or another, is an objective of poverty reduction or
environmental protection programmes, its intensity must be assessed (Oakley, 1991;
Bhatnagara and Williams, 1992; Clayton, Oakley and Pratt, 1997 and DFID, 1995). In
undertaking a project, three main areas of participation need to be assessed.
1. The extent and quality of participation. It is important to evaluate the extent and
quality of participation and where it falls on the continuum of participation (Oakley
and Marsden, 1984; Uphoff, 1989).
2. The costs and benefits of participation to the different stakeholders. There is the
need to evaluate the costs and benefits of participation to the different
stakeholders (Oakley, 1988) as donor agencies mostly take into consideration
the cost of promoting participation in development.
3. Performance and sustainability involving the development of quantitative and
qualitative techniques for assessing the costs, benefits, and long-term effects of
projects (Rudqvist, 1992).
5. Indicators of Community Participation
Several indicators for measuring the extent of participation have been proposed. The
identification of the critical traits of the process and use as broad indicators have been
suggested: the vital signs of participation serving as a framework for evaluating
participation; proposal of the use of the “where”, “what” and “how” of participation to be
the basis for assessing participation; and finally the development of a broad continuum
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of participation from wider to narrow and the two ends of the continuum seen as two
extreme indicators have been suggested (Hamilton, 1978; Lassen, 1980; Charlick; 1984
and Rifklin and Oakley, 1996) .
Other development authors and agencies have devised measures that can be used in
developing indicators of the extent and quality of participation. Oakley (1991) and
Department For International Development (DFID) (1995) outlined some quantifiable
indicators of participation which assess the economic benefits of the project and who is
participating in the project benefit. With regards to the qualitative indicators, Narayan
(1995) notes that the emerging sense of collective will, involvement in discussion and
decision, development of beneficiary capacity and understanding of policies and
programmes are very useful indicators. The mechanisms to be used in order to promote
participation such as the translation of project documents into local languages to inform
people; sensitization workshops for stakeholders to elicit opinion and joint-project
committees in which beneficiaries are represented are all important issues to be
addressed in any evaluation.
It is generally assumed that participation of rural people in the different stages of a
project cycle will either be beneficial or a cost in the long run depending on how the
beneficiaries are involved in the project.
6. Participation in EIA in Ghana
In a review of EIA reports produced in Ghana, Sampong (2004), (cited in ECA (2005),
ranked the Environmental Impact Statements (EIA) as satisfactory perhaps because the
country had considerable experience with the process, dating back to Act 490 of 1990.
However, most of the Environmental Impact Statements (EISs) were graded very low
due to the weaknesses in and lack of necessary skills, information and data on several
factors. One of these factors was public participation, even though it was acknowledged
that some progress appeared to have been made since 2001.
Akabzaa and Darimani (2001) noted various challenges with the public participation in
the EIA process is Ghana. These include:
(i)
(ii)
(iii)
the sources of information, which are the national press or the premises
of District Assemblies, are inaccessible for these communities.
The technical language of the EIA, which is impossible for the people in a
community to read and understand.
the confidentiality clause for Environmental Audit Reports, which allows
the mines and EPA to treat the Environmental Audit Reports as
confidential documents and therefore unavailable to the public.
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(iv)
(v)
(vi)
(vii)
(viii)
The proviso in the guidelines on mining, which a company‟s obligation to
accept recommendations made by an audit report, thus reducing the EIA
to a mere submission of a report.
the fact that, the proponent or their consultant conducts the study and
therefore establishes the desirable content of the report after consultation
with selected individuals
the fact that public hearings are nothing more than public relations forums
where companies largely dwell on the expected positive economic
benefits of the project to both the state and the local population while
downplaying the negative impacts of the project.
the lack of follow up in Ghana where hearings have raised serious
objections to an EIA.
the failure of EIAs to adequately deal with the social impact of mining
projects. The social issues dealt with are usually issues of payments of
compensation and royalties.
7. Methodology
The study employed a descriptive design in an attempt to describe the reality of a
situation as compared with what the law states. The study area consists of three large
scale mines and their catchment areas, Newmont Gold Ghana Limited in the Birim
North District of the Eastern Region; the Goldfields Ghana Gold limited‟s mine in
Prestea-Huni Valley District and Adamus Resources Limited‟s new mine in Ellembelle
District, both in the Western Region of Ghana.
Both purposive and convenience sampling methods were adopted to select required
respondents for the study. Two categories of respondents were sampled. The first
category was made up of respondents from communities affected by the activities of the
selected mining companies. These included some selected chiefs, queen mothers,
community leaders and youth. The communities and key informants within them were
selected purposively and then youth members were selected conveniently to become
respondents.
The second category of respondents consisted officials of the mining companies,
regulators of mining and district planning authorities within whose jurisdiction these
mining activities resided. Purposive sampling methods were used to sample key
informants from various institutions for the study. Table 1 presents a distribution of
respondents and their locations.
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Table 1: Distribution of respondents and their locations
Respondent
Locations
Data
collection Number
tool
EPA
-Accra
Interviews
1
-Koforidua
1
-Takoradi
1
-Tarkwa
1
MINCOM
-Accra
Interviews
1
-Takoradi
1
-Oda
1
-Newmont Gold GL -Accra
Interview
1
1
Chiefs
-Damang
Interview
1
-New Kyekyewere
1
-Teleko-Bokazo
1
-Koduakrom
1
Queen mother
Salman
Interview
1
District
Planning -Birim North
Interviews
1
Officers
-Ellembelle
1
-Tarkwa
Total
Source: Fieldwork, 2010
16
Two communities were purposively selected in each of the catchment areas of the three
selected mining companies and three Focus Group Discussions (FGDs) conducted for
adults, youth males and youth females in each of these communities. Table 2 gives a
distribution of the FGDs done.
Table 2: Distribution of FGDs organised
District
Community
Number of FGDs
Prestea-Huni Valley
Huni Valley
3
Kyekyewere
3
Ellembelle
Salman
Teleko-Bokazo
3
3
Birim North
Hwakwae
Yayaso
3
3
Total
Source: Fieldwork, 2010
18
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8. Participation in Environmental Impact Assessment
The involvement of key stakeholders at all levels of activities is desire-able for a
sustainable implementation of any project or programme. This study investigated the
involvement of various stakeholders.
Most respondents felt that everybody that needed to be involved took part in the various
stages of the permit acquisition process. A minority of the respondents said they
sometimes saw people around, doing one activity or the other and sometimes taking
part in meetings, but they were not clear who the people were and what titles they held.
The study identified three main stakeholders in this process; these include: the mining
companies and consultants working on their behalf; government regulation agencies
and communities themselves (who were sometimes represented by NGOs/CBOs). The
main regulating institution respondents identified was the Environmental Protection
Agency (EPA). Other entities of government identified were the Minerals Commission,
Forestry Commission, Water Resources Commission, Ministry of Local Government
and Factories Inspectorate and Commission on Human Rights and Administrative
Justice.
Organisation of public engagements
Most of the public engagements were organised in public meeting places. Public
announcements were made on FM stations or pasted on information vans; letters were
also sent through elders who had attended earlier meetings; or sometimes the
traditional gong-gong was beaten and the information about the organisation of the
meeting was disseminated. These meetings were usually organised in order to avoid
market or farm days so that more people could attend. When meetings were held
between the youth and the company or between chiefs and the company they were held
on the premises of the company. Most members of the communities who were not part
of these meetings were suspicious that the community members attending the meetings
were influenced by the company, which gave them treats and or gifts so that they
granted concessions to the company to the detriment of the whole community.
In some instances the meetings were held between community leaders like the chief,
Assembly man or Member of Parliament and the mining companies or their agents
mostly in the presence of the District Chief Executive or a member of the District
Assembly. The leaders then organized the communities to inform them of the meeting
deliberations. The respondents were almost unanimous on the fact that it was the
mining companies that organised these public consultations, which were generally
chaired by chiefs, Assembly men or other community leaders.
However, in Teleko-Bokazo one respondent noted that the EPA had organised public
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forums there. In Yayaso, the male youth noted that they had heard of some public fora
organised by the EPA and in one instance, the Forestry Commission had organised
one. This may possibly be because the mining pit would affect the Ajenjua Forest
Reserve, a concern which had generated public discussions led by NGOs, focusing on
the negative environmental impacts. Since the reserve is managed by the Forestry
Commission, they then might have had to organise a public forum to gather community
opinions.
Barriers
The major barrier to effective public participation in the EIA was related with the
reconciliation of the technical nature of the mining processes and the low capacity of
affected communities to understand. Even though the EPA makes available to the
concession district a copy of the Environmental Impact Statement, the capacity of the
general public to understand the content was seen as usually so low that in essence the
process of public participation was not as effective. This is because the people the EIA
sought to protect could not appreciate it.
It was also noted that because of the technicalities of mining, sometimes the
Environmental Impact Assessment did not achieve its desired effect. The reason is that
the public for whose benefit it was done could not comprehend it. Additionally, mostly
the Environmental Protection Agency had no offices in the districts to explain the
technicalities to interested community people.
Another barrier mentioned was that not all the affected people got the chance to
participate in the EIA because of the way the public fora were organised. Specifically
the communities were represented by selected people and also the public fora were not
held in all the communities affected by the project, but in selected ones.
The arduous nature of public participation processes lead to prolonging the time used to
take decisions on mining. This was one of the barriers to effective participation in the
EIA noted by respondents.
The personal interest of people at various levels of the permitting process was also
noted to be a barrier to effectiveness as these people might inhibit both the flow of
information and the imposition of sanctions, thus flouting the EIA law. The law in itself
was seen as good, but the personnel implementing it might sometimes either bend the
rules, stifle information flow or could not implement them without fear or favour. The fact
that mining in the Ajenjua forest reserve was permitted, was seen as a specific example
of ineffectiveness of the EPA in implementing the law without fear or favour. The EPA
was encouraged to set up more well manned and stocked district offices for proper
monitoring especially in mining areas.
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9. Meetings and their organisation
Leader of meeting
The leadership of most meetings is very important for steering the meetings to a
successful end and in determining which discussions would be recorded for further
attention. The community respondents noted that most of the time, either the company‟s
or the EPA‟s officials chaired the meetings. Sometimes, they were chaired by the
Corporate Affairs Manager or the Community Affairs Manager or any other
representative of the company or agency. Respondents believed that this was a
problem because only issues that favoured the company were mostly discussed at the
meetings.
At other times, during public meetings between the company and the community, either
the chief or the Assembly man or any other opinion leader in the community was
elected to chair the meeting. At these meetings, issues affecting the communities were
given more space for discussions as the leadership was from the community. The
leadership of the meetings generally handled their responsibilities well. This is because
even though the people had no idea of EIA, they were able to convince them to come to
agreements at the end of these deliberations.
However, respondents were divided on the neutrality of the leadership. Most
respondents believed that they influenced the decisions made at the meetings. The
respondents explained that people were convinced to accept resettlement packages
proposed by the company even though they were not satisfied with them.
Some of the comments captured at FGDs in some of the communities regarding the
leadership of meeting influencing negatively, issues agreed on at the meetings are
presented for illustration:
One participant in the female youth FGD in Hwakwae noted;
“What happens is we do not know whether our views are presented to the big
bosses or not. This is because after the various engagements they do not come
back to tell us whether our concerns would be met or not. So we can‟t tell
whether they influence it or not, but once we do not hear from them, we can
conclude that they do not like our decisions”.
A young male in the FGD in Teleko-Bokazo also noted;
“None of the decisions have seen the light of day. With this in mind, we can say
that they definitely influence negatively decisions taken. The fact of the matter is
we have not been able to take major decisions because what the company says
is always different from what we also say”.
A female respondent in Yayaso also said;
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“It was Newmont that facilitated the meeting, so of course they would negatively
influence the decisions. The decision to implement what is decided on largely
rests on the mining company. The reason we say they negatively influence the
decisions is that none of the decisions taken have been implemented. If nothing
has happened with the decisions, then everybody can conclude that the
decisions are swept under the carpet”.
A male respondent in Salman said;
“Since they are best serving the interest of the mining companies, relevant
issues bothering the community are carefully eliminated”.
The quotations from the various areas show that the situation where people did not trust
that decisions made at meetings cannot be a random occurrence and that, the
respondents who felt the leadership of meetings negatively influenced decisions were
passionate about this allegation.
Presence of influential people at public meetings
The attendance at public meetings by influential people, like managers, directors, etc
who took decisions on what the company did and other regulatory agencies helped the
meetings to draw workable plans of action that were more likely to reflect consensual
position. The presence of these people at these meetings was determined from the
respondents.
Most community respondents thought influential people attended the meetings but they
did not know for sure. The community members were not sure of the roles these people
played.
Another group of respondents were categorical that the influential people were usually
not present at the public fora organised. A member of the adult focus group discussion
in Hwakwae substantiated this position thus:
“For our part, all the opinion leaders are present. At such forums, we do not know
who is supposed to be present from either government or the company. We
know the top brass of the company are also to be present. The question is we do
not know whether the right person is represented. This is because sometimes, at
such meetings when you ask them a question, those from the company who are
present will say that, they will have to refer the question to their bosses for an
answer. We think it will be appropriate that those people in the company who will
be in the best position to answer our questions are present”.
In these situations, it became impossible to achieve consensus as the decision makers
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were not present and issues coming out of the meetings would have to be relayed to
decision makers who would then take the final decisions. This is also one of the reasons
why the community respondents complained that these public fora were public relations
gimmicks.
Issues discussed at meetings
Respondents mostly said that issues of resettlement of both households and livelihoods
and compensations for farms and farmlands lost were discussed at the meetings. These
discussions centred on who had to be resettled, whether the resettlement should be in
terms of new apartments being built for the affected people or whether they had to be
given monetary compensation. Those who opted to be given new apartments then went
into negotiations on what kind of building, the number of rooms etc. While those who
had to be paid compensation packages also then went into those negotiations.
In Salman, for instance, respondents said that the mining company informed the
community that households who lived in mud houses were going to have their houses
paid for but those living in cement block buildings were going to be resettled on the new
resettlement site.
In the Teleko-Bokazo and Yayaso areas, the discussions centred more on the mining
project, the impacts and their mitigation measures. „Discussions were around the
project, its advantages and less on the impacts‟, a resident of Teleko-Bokazo said.
Youth in Yayaso also said that the company talked more about the advantages of the
mining and less about its disadvantages.
Another issue discussed at the meetings were how sources of drinking water for
instance were going to be affected by the mining activities. The perceived developments
the mining was going to bring to the areas were also discussed at the public fora like
improvement in infrastructure and job creation.
Other respondents, for example, women in Huni Valley said that the company talked
about many more other issues they did not understand, which were technical in nature
and also conditions that had to do with the permit the company had acquired.
At these gatherings, the company informed the members on the issues and people
were allowed to ask questions and answers were given. Some of the respondents were
not pleased with the answers sometimes given, as they did not see them as meaningful
answers.
The female youth respondents in Yayaso summed up their views of the public
consultations thus:
„The various public fora were just cosmetic shows to the authorities that they
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were following due process. It was a talk shop where after, nothing happens. We
were not properly consulted and adequately involved in the process. They
promised us many goodies but they were all lip service. Even though we have
not been compensated, the company has started destroying our farm which is
our only source of livelihood which we think is against the laid down rules. This
may lead to unhealthy clashes‟.
Understanding of the issues discussed
Two main topics emerged regarding how well the respondents understood the issues
discussed at the meetings. The first had to do with the issues of compensations and
resettlement of the people, which the local community respondents generally
understood. But when it came to the conditions of resettlement or amount of
compensation, the respondents did not comprehend why they had to be given packages
they thought were inadequate for the losses they were incurring.
The second arena of the discussion had to do with the mining project itself and the
technical as well as the scientific information given. The local community respondents
did not understand the information because it was too technical and also because
efforts to interpret for the local people was inadequate. Given their inability to
understand, respondents paid little attention to this aspect of the meetings. A male
youth respondent from Hwakwae had this to say about the issue of communication
between the local people and the mining company:
„I remember when the issue of moratorium came, I asked some farmers whether
they understand it and they said no but have heard it before at their various
meetings with the company. When I explained it to them they were shocked and
angry that the company did not explain it well to them. So there are times people,
especially farmers face such difficulty. Sometimes we understand, sometimes we
don‟t understand. When the moratorium issue came, some understood it as “stop
work”. When we asked them they told us it is not true but after it was declared we
realized that what we knew about the moratorium meaning “stop work” was true
because they are preventing us from farming.‟
Respondents said that though people were not prevented from speaking at the fora,
majority of people had no opportunity to ask a question because the organisers of the
meetings limited the number of people allowed to speak and this number was generally
less than the number of attendees. Some female adult respondents in Huni Valley and
Kyekewere felt that the women in particular, were not given enough chance to speak, as
in most instances, only the leaders of the community delegations were allowed to
speak. These leaders were predominantly males.
In order for communication to proceed and result in desired outcomes, public
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discussions should close when all groups have an understanding of the issues for
discussion and are aware of the salient points of the discussion.
The
meeting
participants normally asked for clarifications on the points that were not clear and most
said the presenters normally explained the same points again. These explanations
generally did not result in better understanding by the people.
Sometimes, like in a case of Darmang, the company hired consultants to organise
further meetings to explain issues in the local languages to the people. The companies
were alleged to claim this was the normal protocol. Some respondents contended that
the company normally came to the communities after they had taken decisions and the
objections and calls for further clarifications did not result in much change in the original
plans of the companies, leaving the local people with no possibility of influencing
decision making. For instance in Teleko-Bokazo, the community told the company that
they did not understand so the company representatives stated they had to reorganise
and return to offer better explanation: but the company never went back.
Sometimes, like in the case of Salman, the meeting ended abruptly or the meeting was
adjourned for over a year and then processes of consensus building were engaged in to
get to an agreement. This also occurred in Huni Valley.
10. Influence of participation on understanding of technical issues
Clarity of terms
In the meetings and public forums, the respondents noted that the experts from the
regulators or the companies tried to thoroughly explain the various terms, technologies
and science to help the community understand. Most of the community relations officers
of the mining companies spoke the local languages and they tried to translate these
discussions for the community. Even when other experts could not speak the local
language, translators were recruited to do the translations.
There were, however, difficulties posed by this situation as there were limits to how well
one could explain scientific or technological jargons and concepts to people who often
times were illiterate.
Knowledge used
The kind of knowledge used to arrive at decisions for project implementation often
determines what outcomes the project achieves. Both intuitive local knowledge and
anecdotal evidence were considered by the Minerals Commission in arriving at these
decisions. For instance, in the Abirem area the community people indicated that the
Ajenua Bepo forest had some sacred spots. Those spots, according to the District
Assembly, were going to be preserved in the mining project.
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The mining company had this to say about the sources of information used to arrive at
decisions:
“We listen to every piece of information because in the end it helps us prepare
better for the project. So for a particular community we may be told that a river
gets dried up when their goddess is angry for some reason. Ours would be to
observe those times and so find out the reasons if we intend to use the river and
we may find out that there is a perfectly good reason why this happens maybe
because it is seasonal. We then prepare using the knowledge that for a particular
period the river may not be useful to us. We do not take into consideration
everything that is said by the people but we do our best to respect the culture
and belief of the people in order to ensure a smooth working experience with
them”.
In gathering this information, the companies and regulators used different sources and
methods. The methods used were very much dependent on the kind of community that
was affected and whose participation was sought. The regulators noted that they tried to
be as down to earth as possible in order to elicit the correct information from the
community. In doing so the project, its prospects, effects and impact could be clearly
explained to the community to ensure their understanding of the project, which was
needed for them to make an informed decision.
One of the mining companies said they did not go into the communities just to elicit
information, but also to inform them about their intentions and its likely impacts through
durbars; films and even field trips to other mines so that the community saw first hand,
what they were about. So for example Newmont took a community to Obotan Gold
mines, which was closed but had been reclaimed so the people understood that their
land after mining was not going to be left with big gaping holes which were death traps.
The company collected information by constituting different groups including farmers,
market women and even children. For example, they set aside a particular time for taxi
drivers by contacting, where available, their respective unions since the project was
likely to occasion fleet increase. Even before they went to the EPA, they had solicited
the views of the groupings within the community to find out the best practices to be
followed. They sometimes spent a whole day with each of these groupings to be able to
do thorough work.
The company also noted however that because they did a lot of underground studies
and visits they got to have a pretty good idea of every possible issue that arose as a
result of their project and these were things they took steps to deal with even before
they were asked to do an EIA. During their consultations with the various groupings
within a community they also took the trouble to provide for dispute settlement
processes using the representatives of the people so that by the time they were done
consulting them they already had solved a lot of the problems that might have been
occasioned by the intended project.
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Understanding of technical issues by communities
One important aspect of participation of local people in the project cycle is the transfer
of knowledge from the experts to the local people. Enquiries into whether the type of
meeting participation translated into a better appreciation of technical issues by the local
community respondents show that majority of respondents did not experience
improvement in their level of appreciation of technical issues. However, some other
respondents had an improvement in technical appreciation. A chief interviewed in
Teleko-Bokazo intimated that he had become aware of how dams were going to be built
to contain cyanide waste.
Respondents who said there was no change in their technical capacity due to their
involvement with the projects were asked to suggest ways to make sure this happened
in future projects. The most frequent response was that the mining companies should
ensure that translations of the technical issues were communicated to them before the
meetings were conducted so that they could understand and make either productive
contributions or criticisms. This suggestion has already been made part of the permitting
process, but the translation into local languages were not addressed in the law.
Section 15(1)(d) of LI 1652 states:
Where an applicant has been asked to submit an environmental impact statement it
shall be the responsibility of the applicant to (a) advertise in at least one national newspaper and a newspaper, of any
circulating in the locality where the proposed undertaking is to be situated;
and make available for inspection by the general public in the
locality of the proposed undertaking, copies of the scoping report.
If this provision is enforced and adhered to, then it would be possible for community
people who are literate to read these reports before the public fora and therefore make
meaningful contributions.
Male youth in Hwakwae summarised thus:
„Newmont should employ people to explain the technical words to us anytime we
meet. When they say something and you do not understand and you ask for
clarification they will tell you that they will have to refer it to their big boss, but
nothing happens in such instance. We will also plead with government to impress
on them to make all their work easy for us to understand so that later we will not
be fools in the future‟.
One other suggestion for improving the technical capacity of the community was that
they should be taken to view the site. The last suggestion made was that the
communities should be supported to engage the services of a consultant or consultants
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to attend meetings and fora so that they could help to explain trends in discussions and
to negotiate properly on their behalf. These consultants should be recognised and
allowed to sit in meetings and discussions as part of the EIA and all conditions for
permitting that border on the community livelihood.
11. Role in meetings
The roles played by different stakeholders are as discussed in this sub section. The
chiefs usually played the role of representatives of their communities in most of the
meetings they attended. The District Assemblies were not aware of any specific
provision in the EIA law that mandated them to play a specific role in the process.
However, they usually attended these meetings as interested stakeholders. Sometimes,
the Metropolitan, Municipal or District Chief Executives were chosen to chair the
functions. The Assemblies usually answered any questions related to how the
Assembly would ensure security in the area.
The Assembly was also consulted for data on the area and also to facilitate the
assessment process by informing the general populace about the mining operation and
the organisation of various processes of the operations. Once the EPA and Minerals
Commission had permitted the mining, the Assembly issued or refused to issue permits
for their physical installations like buildings and claim property rates on them. The
Assemblies were to ensure that no installation of the companies violated any physical
development plans of the District.
The community respondents believed that their role in these meetings was just to listen
to the information given by the company officials and to ask questions when they did not
understand anything. Thus, the community really did not play any role in the meetings.
This situation does not bode well for enhanced participation of them in the EIA. The
communities just engaged in this process as passive participants (Pretty and Vodouche,
1997).
12. Perception and practice of public participation
This section reports on how the concept of public participation was understood by the
regulating agencies and the mining company. The agencies of interest were the
Metropolitan, Municipal and District Assemblies (MMDAs), Minerals Commission, EPA
and the mining company. This analysis was done with a view to establish the
knowledge basis informing how participation was operationalised on the field regarding
the permitting process of mining and the mining process itself. The second part of the
section then looks at issues related with the actual practice of participation in the EIA
stage from the perspectives of the governmental and business entities.
Perception of public participation
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The perceptions of public participation held by the various regulatory and business
entities sampled for the study are discussed in this sub section.
One respondent from the EPA saw participation as an action that allows a person
affected by a project to be involved from the beginning to the end. The concept of public
participation denotes the process of eliciting the views, concerns and interests of the
public so that any final decision that was taken on an issue or project reflected the
opinion of the public. Another EPA respondent perceived participation as a level above
consultation, where affected people were told the details of the project at each level.
Another perception of participation from the EPA was informing communities about the
project and as far as the process of decision making was concerned, while another EPA
respondent perceived that public consultation and public participation meant the same
thing.
With the Metropolitan, Municipal and District Assembly (MMDA) planners, public
participation was seen as the involvement of the citizenry in the process and procedures
about company activities in which people have the chance to raise their concerns or in
which the general public becomes involved in decision making processes that affect
them either negatively and positively.
The Minerals Commission respondents saw public participation as a matter of
identifying who will be involved or affected and allowing them to have a say in a
particular project; the processes involved, when it would start and their concerns
addressed before the start of the project.
The mining company respondent believed public participation to essentially be the
involvement of the public in decision making. This might take the form of getting to know
their views, concerns, etc., in relation to the intended project and soliciting their
assistance to ensure that the project was wholesome.
The practice of public participation by regulators and business
The practices of participation by various regulators were explained from both the
institutional and public respondents.
The Metropolitan, Municipal and District
Assemblies (MMDA) planners reported that a public forum was held where the
interested parties could interact, questions were asked and answers given. Another
planner saw the public participation practice as a public hearing where all stakeholders
were invited and questions asked for answers to be given. The last reported practice as
seen by another MMDA planner was a situation where representatives of affected
communities were presented with community score cards to do an assessment of the
project.
The Minerals Commission saw the practice of public participation as depending on the
type of the project and its impact on communities or the environment; a public hearing
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might be done as part of public participation. Essentially however, public participation
could also be done at all stages and at all levels of a projects‟ lifespan. What happened
usually was that before, during or after the review, i.e. after an Environmental Impact
Statement was submitted by the proponent to the EPA, it was reviewed by a committee
to determine if the document reflected the thinking of the community. Before a public
hearing, the EPA went around the community to inform them about the need for it; this
is called a recognisance visit. After the approval of the Environmental Permit if there
was the need for a review of the terms, for example a change in work plan or operations
which would have environmental consequences, then a public hearing was organised
and the public involved.
The mining company initially held consultations with various groupings within the
community and informed them of the project. Issues about the project that the company
shared with the community includes the activities of the project; impacts of the project
on the communities; impacts of the project on the accessibility to natural resources by
the community etc. The groups normally consisted of people perceived to be directly
influenced by the operations of the mines, namely farmers groups, youth groups and
trades groups like hunters. These consultations occurred before the application of a
mining permit. Participant views and concerns were collated to be presented at public
hearings to further sensitise the community and assure them of the company‟s
intentions. During the public hearings the company also ensured that as many people
and groups as possible had the opportunity to express themselves and that the
company would respond in clear and simple language that most people could
understand.
Drivers of the public participation process
The Minerals Commision (MINCOM) saw the major drivers of the public participation
process as non-state actors; NGO‟s like WACAM, Coalition on Mining etc. and
particularly WACAM, which participated in most of the public hearings and even went to
the communities to teach them about the project and to mentor them on how to ask
relevant questions.
The mining company also noted the importance of NGOs in this domain. NGOs took the
lead and drew attention to many activities that might have been taken for granted. For
example NGO‟s were reported to have highlighted the fact that usually in these
assessments, the universities were usually interested in studies, but there should have
been baseline studies that could reveal the impact of the project over a longer period
instead of just ending at the periphery. There was no interface between the community,
the mining company and the relevant agencies in this regard so in the long run the
community was still at a loss.
Benefits
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Public participation allowed for the communities to express their concerns, highlight
omissions of vital information and to correct of errors made in the EIA process. The
participation of the public usually brought out very salient factors like areas held by the
communities as sacred, which needed to be considered by the project proponents.
One of the benefits of participation as perceived by the mining company was that it was
an on-going educational process which also created a sense of belonging in the
community promoting the willingness of the communities to support and cooperate with
decisions.
The issue for discussion here is that it appeared to all the regulators and company that
participation would only benefit the communities. What then happened was that these
agencies saw themselves as doing communities a favour by engaging them in the
rudimentary participation of information dissemination. The first point that must be made
is that the law on EIA in Ghana requires participation to be part of the process. A benefit
derived from this is that by engaging the public, the companies avoid being sanctioned.
When seen this way, agencies‟ attitudes towards the participation of communities in the
EIA could definitely be perceived by the community people more positively.
13. Effectiveness of the public participation process
The MINCOM respondents assessed the process as very effective because EPA went
to every community on the property and the people were invited to express their views.
The company felt public participation in EIA was generally effective but could definitely
be better. A typical example was the fact that the Environmental Assessment
Regulations, LI 1652 in its various processes like scoping and posting of notices,
contains elements of public participation. Surprisingly these comments, the company
noted, were mostly taken seriously by project proponents because it was to their
advantage to understand the perspectives of the people who were impacted by their
activities. For the mining company, the EIA process was one of the best in Africa; so
good that, it was added, only a few lapses like operational lapses regarding the
issuance of notices and monitoring of information flow needed to be addressed to make
it a near perfect one.
The company further noted that, even though there were many players like the EPA,
Minerals Commission etc and all the relevant institutions were fairly represented in most
of the environmental impact procedures, more often than not the EPA predominated.
For the mining company, EPA was concerned with the more ambient side of things but
there were other impacts of a project that other institutions were better qualified to deal
with. For example, for mine design pits and the project level design they believed the
Inspectorate Division of the Minerals commission was better suited to deal with it. They
therefore believed that institutions that were better at doing specific things should be
allowed to regulate those specific sub sectors. However, they were optimistic that
Ghana had a legal framework for the EIA that was considered to be good. Since the
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mining sector was very organic, the continued growth and learning would finally result in
a good system where all these concerns and challenges would be adequately
addressed.
14. Suggestions for improvement of participation
With regards to respondents suggesting ways of improving participation of affected
people in the EIA process, the District Assemblies thought that the coverage of
participation should be widened to allow for diversity of views that could be achieved by
expanding the number of representative stakeholders beyond communities to be
affected to families to be affected. Also, if the operation will affect eight communities,
public hearings and any other meetings should be organised in all eight and not
communities chosen because of population or size. The Minerals Commission
suggested that even before these community hearings, someone from the community or
someone who understood the language of the community should be recruited to break
things down to the communities before the need for a public hearing even arises. “They
should not be consulted only as a cosmetic measure”, one respondent remarked.
Another suggestion from the Minerals Commission as well as the mining company was
that much more education was necessary to ensure that the community felt a part of the
EIA process. In some instances, communities have existed for centuries and their
survival often has depended on the resources they extracted from the lands and forests.
They naturally owned the lands and forests and have inherited this ownership from their
ancestors. The permit process, which sometimes took less than a year to complete, was
too short a time to allow the communities to fully accept that their access rights to these
resources might have to be curtailed to make way for the mines. It was therefore
suggested that government should expand access to schools in all areas so that the
people already had an understanding of the issues at hand before an outsider came in
to convince them to allow mining.
15. Conclusion
The study concludes that even though there were generally several different levels of
meetings, the participation of communities was mostly limited to information
dissemination and to a smaller extent consultation. These constituted the least three of
the seven levels of participation defined by Pretty and Vodouche, (1997). Given the
nature of the meetings, final decisions on the projects were usually done with minimal
influence of the perspectives and situations of the local communities. Processes where
communities are involved in the process of mining right from the decision to prospect
through the mining phase would ensure proper more active participation.
The major problem inhibiting community participation in the EIA was a combination of
illiteracy in most mining areas coupled with the non-transparent manner in which most
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of the documents and information that informed decision making processes were
created. When public fora shared technical documents, they were not made available to
the communities for studies beforehand. They were translated for representatives of
communities to ask questions on behalf of their people. This process did not allow for
more participation of the communities and resulted generally in a situation where public
fora were organized to satisfy the EIA permitting conditions but not to actually bring the
communities on board so that decisions would benefit both the proponent and the
communities.
This study recommends that the Government of Ghana through the EPA should ensure
that the EIA process is more transparent than it is now. This can be achieved by for
instance, ensuring that technical documents used as a basis for the organization of
community meetings and fora are made available to the communities for periods
adequate to allow for proper studies before the meetings and fora are organized. It was
suggested that at least 90 days should be given for this purpose. In addition,
government through any appropriate agency and in consultation with affected
communities should hire the services of consultants to act for and on behalf of the
affected communities in negotiating appropriate redress for the environmental impact of
mining projects in Ghana.
References
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study of the Tarkwa mining region, SAPRI, Accra.
Aubynn, A. K., (1997). Land-based resource alienation and local responses under
structural adjustment: Reflections from Western Ghana. Institute
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