Dear Volta River Authority (VRA) and Shenzhen Energy Group,

With reference to your publication in the Daily Graphic newspaper dated January 8, 2015, page 27, titled ‘Scoping Notice’, the Ghana Youth Environmental Movement (GYEM) wishes to bring to your attention our concerns about the 2x350MW Supercritical Coal Fired-Power Plant as follows:

1. We first of all acknowledge that the 120 page Scoping Report only sets out and validate the extent of the Environmental and Social Impact Assessment (ESIA) of the project and ascertain the significance of the impact of potential key areas. It is not an ESIA in itself and hence not the absolute document for the justification of the project. However, for the environmental movement in Ghana, it serves as a very important document on the path of rejecting coal power in Ghana and recommend other alternatives to coal;

2. Within the few weeks of circulating the Scoping Report to different organizations, civil society platforms, environmental coalitions and indeed the media, we came to a shocking conclusion that a greater section of the public and the media were not adequately aware and informed about the project. We therefore call for a number of coordinated public hearings and press conferences to further discuss it and most importantly involve individuals, organizations and institutions that responded to the Scoping Notice you served with phone calls, emails and in writing to you;

3. Our major concerns about the project are the environmental pollution and health impacts of the activities leading to construction and operation of the coal fired power plant. Although the ESIA will make a frantic effort to quantify the extent of the related environmental impacts, we are well aware of the devastating health and environmental impacts of coal fired power plants across everywhere on this globe. Coal is a foreign pollutant in this part of the globe and indeed the Scoping Report duly acknowledged that there is limited knowledge of coal power use in this part of the world. But we are very much aware of the high level of fly ash, particulate matter (PM10), smog and other thermal pollution related impacts associated with the operation of coal power plants and hence making judgments based on the experiences of their use and impacts elsewhere is very important;

4. We are very much aware of the tons of waste-- about 5 million tonnes of ash waste (per annum) that would be generated from the plant, the air pollution of poisonous and hazardous gases that are injurious to heath, the discharges into water bodies that threatens aquatic life forms (including turtle breeding grounds close to the project site) and the destruction of the natural environment. While it is important for the ESIA to clearly communicate this for a progressive public debate, we are adequately informed by evidence of coal fired power plants elsewhere that the negative impacts are relentlessly devastating to human life and the environment as well as the irreversible nature of these impacts not only on the environment but also on human life;

5. The Scoping Report indicated that children in Ekumfi Aboano are 55.9% of the entire population of 1,900 people. Children are very vulnerable especially to air-borne pollutants such as PM10 and smog. We are deeply concerned by the undeniable facts available that point to their health been compromised by the coal fired power plant. Ghana being a member of WHO, UN and other global conventions has a national mandate to protect the health of children and the vulnerable in society including those in Ekumfi Aboano.

6. While we wait for the ESIA to respond fully and appropriately to each impact that would be outlined in that document, we hereby reject the idea of bringing coal power to Ghana on grounds of devastating health and environmental impacts of coal fired-power plants.

7. In the interim, we are gathering and collecting signatures of individuals and civil society organizations who also reject coal power in Ghana as a petition to Government to abandon plans of coal.

8. Respectfully submitted.

Cc: Volta River Authority (VRA)
Shenzhen Energy Ghana
Environmental Protection Agency (EPA)
Ministry of Environment, Science & Technology (MEST)