Environmental Non-Governmental Organization A Rocha Ghana has dismissed claims that repealing the Environmental Protection (Mining in Forest Reserves) Regulations, 2022 (L.I. 2462) could lead to unregulated mining in forest reserves.

The organization described these concerns, raised by the Environmental Protection Agency’s (EPA) Director of Mining, Mr. Michael Sandow Ali, as unfounded and misleading.

Mr. Sandow Ali recently warned that repealing L.I. 2462 without a stronger replacement law could create a regulatory vacuum, potentially enabling widespread and unregulated mining activities in Ghana's forest reserves.

He argued that retaining the law was critical to ensuring oversight of mining operations within forest areas.

However, A Rocha Ghana, in a statement signed by its National Director, Dr. Seth Appiah-Kubi, disagreed.

The NGO asserted that risks to Ghana's forests exist irrespective of L.I. 2462 but claimed the regulation had exacerbated those risks by facilitating large-scale mining activities.

Key Concerns Raised by A Rocha

Increased Forest Access for Mining
A Rocha Ghana stated that L.I. 2462 has opened forest reserves to large-scale mining, which indirectly fueled a surge in illegal mining activities.

Unlike the 2018 Environmental Guidelines that limited mining to 2% of production forest reserves, L.I. 2462 removed such restrictions, enabling expansive mining operations with minimal oversight.

Biodiversity Threats
The statement noted that L.I. 2462 has allowed mining leases in critical biodiversity areas, such as Globally Significant Biodiversity Areas (GSBAs), previously off-limits. This undermines Ghana’s commitments under the Convention on Biological Diversity and other national policies aimed at preserving ecological integrity.

Inadequate Provisions for Responsible Mining
A Rocha criticized the regulation’s biodiversity offsetting provisions, which allow companies to establish plantations instead of restoring natural forests. The NGO argued that this approach fails to compensate for biodiversity loss or address community concerns.

Expansion of Mining Licenses
A Rocha noted that L.I. 2462 has significantly expanded mining access in reserves like Nkrabia and Boin Tano, threatening ecosystems and livelihoods.

Recommendations for Sustainable Forest Management

A Rocha Ghana called for the repeal of L.I. 2462, describing it as "retrogressive" and harmful to sustainable forest management. The organization proposed:

A complete ban on mining in forest reserves through new legislation. Strengthened oversight and enforcement mechanisms to minimize environmental impacts and combat illegal mining. Restoration of forest areas and prioritization of biodiversity conservation through participatory planning. Alignment with Ghana’s Forestry Development Master Plan (2020–2035) and commitments under global biodiversity frameworks. Conclusion

A Rocha Ghana emphasized that repealing L.I. 2462 is a necessary step to protect the country’s forests, biodiversity, and communities for future generations. The NGO urged the Attorney-General and the Ministry of Environment, Science, Technology, and Innovation to expedite the process of repealing the regulation and introducing a more progressive framework for sustainable forest management.