Mr Lamin Dibba, the honourable minister of Environment, I am writing to you not as a former classmate or a friend but as a concern Gambian environmental advocate. I would like to take this opportunity to pray for your sound health, may Almighty Allah increase you in wisdom, patient and make your daily task easy for you. Amen. I am concern about your ministry’s decision to allow three fishmeal factories within a 14-kilometre radius to dump tons of highly proteinaceous and Arsenic laden fishmeal waste into the ocean. This dangerous practice will undoubtedly have a devastating short and long-term effect on our fragile ecosystems, especially the marine ecosystem and it is in contravention of the National Environmental Management Act_1994 (NEMA Act_1994). According to NEMA Act_1994, section 38 subsection (1); no person shall discharge dangerous material, or substance, oil or mixture containing oil into any water or any segment of the environment except per the regulation prescribed by the council.
Subsection (2); a person who discharge any dangerous materials or substance, oil or mixture containing oil in any water or other segments contrary to subsection (1) commits an offence.
Please allow me to remind a quote directly from the recently concluded Faraba Banta Commission of inquiry report; talking to people and especially following the commission’s field visit to Sanyang and Gunjur and talking to various stakeholders, it appears that the incident that occurs in Faraba Banta could happen in other parts of the country if the concerns about the environment and land ownership and land use are not addressed within affected communities. Please take this from me, majority of the people along the Kombo South are fed uf with all these environmental violations being perpetrated by these fishmeal factories and sand miners. How ironic, barely a week after Faraba Banta commission of inquiry’s report was made public, Nassem Fishmeal factory in Sanyang was allowed to start operation and dump their highly proteinaceous and arsenic-laden waste into the sea against the will of majority of the community, and this follows a similar trend in Gunjur’s; Golden Lead and Kartong’s JXYG fishmeal factories. In just 14-kilometre radius, three fishmeal factories will be dumping tons of highly proteinaceous and Arsenic laden waste into the sea. The deleterious effect this decision will have on our marine ecosystems and tourism industry cannot be quantified.
The exponential rate of our industrial development means more and more dangerous chemicals are being pumped into our environment, sometimes indiscriminately. As people, we have to be on our guide at all times. We have to make sure we observe and practice good environmental practices to save ourselves from ecological catastrophe through our actions. It is against this backdrop that entire Kombo South are crying day and night to make sure fishmeal companies operating along the Kombo Coastlines observe good environmental practice to safeguard health and safety of the people, animals and plants living around these locations. It is heartbreaking to see our citizens in positions of authority conniving with unscrupulous investors to get away with complete violations of our national environmental laws.
Between February and June 2017; we have all seen the gory pictures of “The Bolong Fenyo” Wildlife Reserve, in Gunjur as a result of the indiscriminate dumping of fishmeal waste into the lagoon by the Golden Lead [GL] fishmeal factory. At the height of this environmental carnage, we took water samples from the lake and sent them to Germany for biochemical analysis, when the results were communicated back to us, it was an absolute disaster. We immediately alerted National Environmental Agency (NEA) about these biochemical results. Acting on our test results, NEA launched an investigation into the activities of Golden Lead (GL) fishmeal factory. They found enough environmental violations to warrant revocation of GL’s operational license. GL was subsequently sued to courts for the damages to the local environment. Only for Dr Isatou Touray, the then minister of trade to intervene and stopped the case from proceeding at the courts and vetoed for GL to continue operation without remedying any of their environmental violations. The final straw for local environmentalist on the ground, in August 2017, local environmental groups against GL at the high courts for ecological damages and sought an injunction for them to stop operation until they rectify all the environmental violations they were engaged in, frustrating enough our case is being dragged at the courts since.
Honourable minister, resumption of operation by JXYM and Nassem fishmeal factories in Kartong and Sanyang respectively are terrible for our environment and food security. Before the emergences of these fishmeal factories, Kombo South is undoubtedly the fastest growing area in eco-Tourism. Your ministry decision to allow these factories to dump their dangerous sludge waste into the sea is going to have a grave deleterious effect on the tourism sector around the Kombo coast, and this will eventually harm youth employment opportunities in the area.
Honourable minister, you will agree with me that what is happening along the Kombo South Coast is not right and failure of your ministry to make sure these fishmeal factories respect our environmental laws and observe all safety precautions is endangering the lives and livelihood of the entire citizenry. Fish caught in ocean waters in Kombo will eventually find its way on the dinner’s tables along the length and breadth of the Gambia and beyond our borders. During your appearance at Kerr Fatou TV on the 17th of May 2018, you mentioned that your ministry tested wastewater from GL plant at Pasteur Institute in Dakar and was confirmed safe enough to be dumped into the ocean.
Curiously enough, this test result was never made public, and even the recently concluded Faraba Banta Commission of inquiry report mentioned nothing about this critical report if it existed at all. The people of kombo south are not the least comfortable with this situation, as the minister of environment, I challenge you to make this report from Pasteur institute public to allay the fears of the Kombo South residents, the general public has the rights to have access to this report for scrutiny. According to our two independent test results, the fishmeal waste coming from GL is loaded with proteinaceous material and highly carcinogenic metalloid; Arsenic. Report # 39461706 of Reef Analytics shows that phosphate levels in the sample of seawater collected from the Bolong Fenyo Wildlife Reserve on 22 May 2017 are starkly higher than maximum levels necessary for the protection of marine aquatic life: Orthophosphate (PO43−) is a dissolved reactive form of phosphate.
At any rate, it is important to point out that an orthophosphate concentration of 9000 µg/L, is 200 times a value deemed necessary to prevent eutrophication in estuarine waters, and 600 times an amount deemed necessary to avoid eutrophication in other coastal waters. Similarly, the concentration of nitrate in the sample of seawater collected from the Bolong Fenyo Wild Reserve on 22 May 2017 is quite high.
What was even more worrying being the level of heavy metal such as Arsenic and Arsenate, these two metalloids are powerful environmental carcinogens. Arsenic is a natural metalloid chemical that may be present in groundwater. Ingestion only poses health problems if a dangerous amount of arsenic enters the body. Then, it can lead to cancer, liver disease, coma, and death. Finding dangerous amounts of arsenic in the natural environment is rare. Finding hazardous amounts of arsenic in the natural environment is extraordinary.
Their levels never exceed more than 23 micrograms/litre (ug/L), worryingly in our test results we obtained from Germany; Arsenate, the soluble form of Arsenic was 55ug/L, an aberration of 138% above average. This dangerous level of very potent carcinogen being pumped at an industrial scale into fish landing site in Kartong, Gunjur and Sanyang on daily bases is too dangerous to continue; it has to stop immediately. For a state minister to stand in front of a national audience and declare these fishmeal waste safe without tangible shreds of evidence is very worrying for the locals. Until you can prove our results otherwise, I think it is wrong for you to declare these dangerous waste safe. We the concerned citizen of Kombo south are calling on you to immediately reverse your decision to allow these fishmeal factories to continue dumping their waste into the local seas and an alternative way of disposing off their waste.
Besides environmental damages, our food security is under serious threat from these fishmeal factories, the majority of Gambians lives on less than two dollars a day, small pelagics fish these fishmeal factories relies on, provide the locals with their cheapest and surest source of protein, which means the locals are in direct completion with fishmeal factories for this essential natural resources, thus putting lots of pressure on the locals on making ends meet. GL daily output stands at 500 tons of small pelagic fish, exporting 32,000 kg [32 tons] of fishmeal powder on monthly bases.
If we consider the output other two fishmeal factories that are operating along the Kombo Coast, that is a combine total of 1500 tons of small pelagics being processed on a daily basis, 450,000 kg [450 tons] of fishmeal powder exiting Gambia’s ports on monthly bases. How can we sustain this as a nation? As a nation recovering from twenty years of brutal dictatorship, this is one problem too many. I am calling on you like the environment minister to engage other stakeholders who are responsible for issuing an operational license to these factories to introduce stringent measures to safeguard of natural resources from overexploitation.
Riyadh, Kingdom of Saudi Arabia