10th February, 2004.

10th February, 2004.

The Minister of Lands, Housing and the Environment,
Youyi Building (3rd Floor),
Freetown
Sierra Leone

Dear Sir,

Re: Koidu Kimberlite Project

The Campaign for Just Mining, a coalition of civil society organizations countrywide, which the Network Movement for Justice and Development (NMJD) is spearheading wishes to express its concerns over the Koidu Kimberlite Project which has started the exploitation of the Koidu Kimberlite pipe in the Kono District since May 2002.

Since the start of operations of the Koidu Holdings Limited last year, there has been a great deal of talking and wrangling between the local inhabitants of Koidu and the Koidu Holdings Limited. This has aroused the attention and interest of not only the directly affected masses, but also civil society and rights-based organisations all over the country, including NGOs as well. It is in this light that the Campaign for Just Mining which since 2000 has been engaged in advocacy work around mining, environmental and human rights issues deems it necessary at this point to raise some pertinent issues relating to the operations of the Koidu Holdings

Limited and the welfare of the people in the operational areas. Amongst them are the following:

• That the Environmental Impact Assessment (EIA) Report and related documents were released very late here in Sierra Leone. It was sent to the World Bank and Group-MIGA in October last year, but only released in Sierra Leone in the last week of January this year. Why could not this document have been released here in Sierra Leone at the same time it was released to the World Bank? Who is a major stakeholder here – World Bank or Sierra Leone? Is this right?

• That the EIA document has not been made available in public places such as the Government Bookshop, the Sierra Leone Library Board, the Department of Geology at Fourah Bay College, line government ministries and departments as well provincial offices where the ordinary man and woman could easily access the report. Contrary to widely publicized venues, the EIA document is only confined to the offices of Koidu Holdings Limited and their consultants i.e. CEMMATS. This is in contravention of the World Bank policy of public disclosure and national legislations.

• That contrary to the provisions of the Environment Protection Act 2000, only three weeks were allotted to the general populace to read, digest and input to the report instead of six weeks as stipulated by law. This, in addition to the non-availability of the report in public places, also places considerable constraints on the people to have their views adequately reflected in the final document; Or was it a well designed ploy to deny them of their rights?

• That the participation of the local inhabitants in the preparation and validation of the document was totally ignored despite the tremendous impact it will have on their lives.

• That the number of people directly affected by the operations of the Koidu Holdings Limited is 4,536 with 284 households, who should be accorded priority access to the EIA in their local language and consultations facilitated to ensure their input and active participation.
  

With regards to the above, the Campaign for Just Mining considers the following recommendations as the way forward.

1. That, the EIA report should be made available to the affected communities in Kono and that the document should also be deposited to all public places like libraries, bookshops, colleges, government departments and ministries, among others for the public to easily access it.
2. That the time allotted for the reading of the document by the general public should be extended from three weeks to six weeks for a better understanding of the issues raised in the report so as to enable people to meaningfully make their own inputs.
3. That Koidu Holdings Limited should ensure meaningful participation of the affected communities in the planning and implementation processes of all projects and programmes that affect the communities through regular consultations and participatory monitoring.
4. That the blasting which has so far caused untold suffering for the affected communities should be suspended henceforth until relocation arrangements for the affected populations are satisfactorily completed.
5. That the affected households should be resettled as efficiently and satisfactorily as possible with minimum disruption to their existing livelihoods, and in a manner that does not lead to impoverishment. In order to achieve the above, the people should be:
   . Informed about their options and rights pertaining to resettlement.
   . Consulted on the overall resettlement package, offered choices and provided technically and economically possible resettlement alternatives; and
   . Provided prompt and adequate compensation/full replacement costs for loss of assets attributed directly to the project.
   
6. That public consultations should be conducted regularly with all stakeholders including the affected communities, government, donor institutions like the World Bank, rights-based organizations and corporate bodies engaged in the extractive industry.
   
7. That consideration for mining licenses be done only after the above issues are properly dealt with.
   

It is the fervent hope of the Campaign for Just Mining that these recommendations will be taken in good faith and implemented immediately. Whilst looking forward to your earliest response to the concerns raised above, we would want to thank you for your understanding and cooperation in previous matters of this nature.

Yours sincerely,

Abu A. Brima

National Coordinator, NMJD.

Copy:

Minister of Mineral Resources
Minister of Trade and Industry
Minister of Labour and Industrial Relations
Minister of Internal Affairs
Minister of Local Government and Rural Development
Attorney-General and Minister of Justice
Parliamentary Committee on Mines and Mineral Resources
Parliamentary Committee on Labour
Director Mines
Director of Geological Survey
Country Director, World Bank
Department for International Development
Peace Diamond Alliance
Council of Chiefs
Senior District Office, Kono District
Chief Police Officer, Koidu
UNAMSIL Human Rights Section
Civil Society Movement – Sierra Leone
Chamber of Commerce
Inter-Religious Council
Geological Department, Fourah Bay College-University of Sierra Leone
Sierra Leone Bar Association
Sierra Leone Teachers Union
Sierra Leone Association of Journalists
Inspector of Schools, Kono District
Resident Minister, Eastern Region