Petition from Kewunor Advocates on Behalf of Kewunor Community Concerning the Proposed Project on Kewunor Estuary Island in Ada to be carried out by Trasacco Estates Development Company in partnership with Hilton Hotels
To: Acting Director
Environmental Protection Agency
P.O. Box MB 326 Ministries post office
From: Volta Revival Foundation
PO BOX AF012
Dear Madam/Sir,
This petition is made on behalf of the Kewunor community and their interests concerning the proposed project on Kewunor estuary island in Ada. Kewunor Advocates is a special interests group formed by many stakeholders in this project including individuals, NGO’s, and community leaders; the principle stakeholder being: the Volta Revival Foundation, as well as business owners, youths, and leaders from Kewunor community and many others from around the world.
This petition is comprised of three major topical concerns, firstly for the wellbeing and livelihoods of the over 1,000 residents of Kewunor and their proposed resettlement, secondly for effective environmental protection measures concerning the proposed project on Kewunor Estuary Island in Ada, and thirdly for the greater interests and benefit of the Ada, Ghana, and global posterity.
It is our position that without community input in all aspects of the resettlement proposal, that any deal made on behalf of the community will be void of proper authority. The community members will be the ones most negatively affected by this project and so it is of the greatest importance that in the name of protecting their basic human and indigenous rights, that all resettlement policies will be made with the community rather than for the community. Therefore as our first and foremost request we are asking that a copy of the full report of the Environmental and Social Impacts Assessment carried out by Ecosystems and Environmental Solutions Limited (EESL) be given to the Volta Revival Foundation and the Kewunor Advocates so that the community is informed on all plans and considerations going forward.
The following document takes these positions into account and will work tirelessly on behalf of the community to see the best possible arrangements provided for them and their interests.
1. Petition for reasonable living standards based on community input concerning the proposed resettlement plan.
The following petition points are based on community census information as well as the views which community members have shared with Kewunor Advocates over the last years concerning an acceptable resettlement plan, which would position the community so that it will not lose because of the proposed project.
a. Land proposed for Kewunor community’s resettlement: Up to now, Kewunor community has not been made aware of any proposed land for their resettlement. Any land which is to be proposed for their resettlement should follow the basic guidelines of being approved of by Kewunor community in writing, in addition to a full environmental suitability review made by the EPA in order to understand weather the proposed place is truly feasible for the resettlement of the community. According to a 2018 independent land survey conducted by CD Ayam licensed Surveyor 231, the current land size of Kewunor community is 39.73 acres or 16.03 hectares; therefore, any proposed site of resettlement should include a land size of at least equal or greater size to the community’s current land size. Additionally, any land for the proposed resettlement must be free of conflicting ownership, this means that any land bequeathed to Kewunor community should be given to them with the full title documents in the name of Kewunor community itself and no other, family, or institution. All of these provisions will make for a conflict free transition of land rights for the Kewunor community which currently resides on Kewunor Estuary Island.
b. Sea and River Access: Currently, Kewunor community is reliant on access to both the sea (Gulf of Guinea) and the Volta river for the continuance of their livelihood activities which revolve around fishing, fish smoking, and fish mongering. Any proposed resettlement must therefore include access to both the river and the sea in order to maintain the community’s livelihood activities as well as their wellbeing.
c. Harbor: In addition to sea and river access, any proposed resettlement plan must include a harbor where the residents of Kewunor community may park their most valuable possessions, their boats. Any harbor should include space for at least as many boats as are currently owned by Kewunor community residents currently parked at Kewunor Community, and should allow room for expansion of the community’s fishing activities.
d. Market: Based on expanding livelihood opportunities, any proposed resettlement plan should include provisions for a centralized market place where all residents of the Kewunor community as well as surrounding communities may engage in market and trading activities. This will allow for the community to have a central commercial center as well as a place for selling their goods. The market should also include a cold store for the fisherman’s daily catch and a place for fish smoking as well as public toilet facilities.
e. Home Units: Currently, there are 163 households in Kewunor community comprised of many people living at each household. Each compound includes multiple structures and rooms in order to accommodate all members of the household. It is of primary concern that every household as well as every structure in the compound is fully provided for in any resettlement proposal which is to be made. Additionally, every structure must be made with quality modern materials, and including a kitchen, family room, bedrooms (based on the number of household residents), Indoor and outdoor plumbing provisions, covered verandah, doors, roofing, fans in every room, indoor and outdoor lighting and windows. Every household must have its own toilets and shower facilities the number of which should be based on the number of persons living in that household. Every household should be given plenty of land space for a small farm, as well as for future constructions; therefore, all structures should be built in such a way that they may be expanded according to the household needs. Every household should have pure running water, as well as electricity and power outlets.
f. Pure Water: In addition to every household having pure running water, the community as a whole must have clean (tested) water, and the ability to expand their water capabilities and usage. Water should be near and connected to all public spaces including the market place, community center, churches, the school, and businesses.
g. Electricity: In addition to every household having electricity and power outlets, the community as a whole must have electricity, and the ability to expand their electricity usage and capabilities. Electricity outlets and especially lighting is a matter of safety in a community and should therefore be provided in all public spaces including: lighting along all community roads; inside and outside lighting and power outlets provided to the market place, community center, churches, the school, and businesses.
h. Road Access to the Community: Accessibility to the community is a matter of great importance and safety, therefore, any resettlement proposal must include a paved road to and through the community, with major road arteries leading to all major public spaces including the community center, the market, the school, the churches, and all major businesses.
i. Businesses: Kewunor community relies heavily on its business to maintain and develop their community, because of that any resettlement proposal must include full, adequate, and equal provisions so that all businesses are able to commence business directly upon their resettlement. There are two major categories of established businesses on the island, the first is Eco beach resorts which includes Maranatha, and Midas; the second is bars and restaurants which includes many enterprises. All businesses must be rebuilt on the agreed upon resettlement area, including: all rooms, storage rooms, toilets, showers, shelving, seating, fans, lights and power outlets, kitchens, and pure water.
j. School: Currently in Kewunor community there is a primary school which provides education to 500 students Kindergarten through Junior High School (KG1 – Form 3). Therefore, any resettlement proposal for Kewunor community must include another school and the school must include: classrooms for every class built with quality materials and suitable for 40 students and providing desks, chairs, white boards, teachers desk, and books and materials for the students. Additional structures on the school property must include: a full kitchen, a main office, a teachers conference room, a sports field for football and volleyball, a changing room, a sports storage rooms, a office storage and filing room (with filing cabinets), a cafeteria with tables and chairs, a library stocked with all necessary books for the school including students and teachers books for every teacher and student in the school as well as enough book shelves, toilets suitable for over 500 students and staff members, and a playground. In order for the educational needs of the community to be well attended to considering their socioeconomic situation, there should also be an educational fund which allows for those struggling students to pay their exams fees, and their entrance fees into senior high school.
k. Additionally, some students come to the school from overbank because their communities do not have a school, therefore these students education should be considered in the resettlement plan as well, in that scholarships should be made available for them to attend school somewhere else which may be further from their home communities.
l. Churches: There are currently five churches in Kewunor community including: Great covenant, Pentecost, Zoe temple, Global Evangelical, and Apostolic. Each of these churches must be considered in any resettlement proposal and should be replaced in any resettled community with the following provisions: a large assembly hall, Sunday school room, a clergy room, a storage room, and toilet facilities, pews for the entire congregation, an alter, and a stage. The hall should be large enough for church growth.
m. Shrines: There are currently 15 established shrines in the Kewunor community. Any resettlement proposal should take these religious sites seriously, and should work with the community members to locate 15 spots in the new resettlement community which are agreed upon by community elders and priests, and with the help of the community, should move these shrines to those agreed upon locations in the new resettlement area. This exercise should be done with the utmost care, and in respect of cultural and religious sensitivities.
n. Community Center: Kewunor community has one community center. Any resettlement proposal must include this important community gathering spot with the following provisions: a great hall for congregating, chairs to fill the great hall, a stage for performances (either indoor or outdoor but it must be covered), large toilet facilities, a meeting and office room for chiefs and elders, a verandah, and a storage room.
o. Health Clinic: Although Kewunor community is not currently having a health clinic, the community is within 5 kilometers to the nearest health clinic. Therefore, any resettlement proposal must take into consideration the health needs of the community, and if the community is to be situated farther than 5 kilometers from the nearest health clinic then the proposal should include provisions for the construction of a health clinic. If the proposal seeks to build the community a health clinic then the clinic must include lighting and power outlets, running water, road access, parking, pharmacy, laboratory and all other necessary aspects for the installation of an effective health clinic.
2. Petition for effective environmental protection measures concerning the proposed project on Kewunor Estuary Island
The following petition points are based on biological understandings about how best to care for this earth we all call home. The Kewunor Island Estuary is a place of great importance for many species of life, not just for humans, but for sea turtles, whales, unique biology only found at the estuary, and hundreds of species of fish and sea life. In an effort to preserve and protect this ecological paradise, the following considerations must be made in any valid resettlement proposal.
a. Sea Turtles: As the EPA knows well, sea turtles are a class A endangered species across the world. Sea turtles are unique in their migration patterns because when a sea turtle is born it goes into the sea, and when a sea turtle is ready to lay its eggs, it can only go to the beach where is was born to lay it eggs. It is often the case is this rapidly developing world that when sea turtles return to their birth place, they find the place lit up with bright lights and playing loud music whilst many tourists enjoying their shores; their birthplace replaced by a resort. Because sea turtles are afraid and averted by light, noise, and human activity, when they find these conditions on the beach, they will not come to lay their eggs, and in fact may never lay their eggs. Therefore, we see a correlation between large beach resorts and the decrease in sea turtles around the world. Even now as we write this petition, enumerable damage has been done to the sea turtle population of Ada because of construction of the proposed development project. This year more dead sea turtles have been found on Ada’s shores than living ones, and the estuary has been a prime location for sea turtle nesting due to the limited lights, noise and human activity, up to now. It is alarming that even during the inception of this project that it is threatening Ada’s turtle population because the structures which had begun being constructed are in a very close proximity to the sea, and the work on the ocean side, as well as the inadequate space for nesting has effectively scared away countless hundreds of turtles. In light of these considerations, we know that what is best for the turtles is that no construction projects should be made on the beach side of the sand barrier, in order to allow for a continued cycle of turtle births, and to allow for the continued existence of sea turtles who are a class A endangered species.
b. Sand Barrier: The Ada sand barrier completed in 2012 by president Atta Mills administration and was paid for using tax payers cedis. As of today that same sand barrier which was created in order to keep the ocean from rising and sinking under its shores the entire Ada coastal area, is currently being used by Trasacco in the construction of their private estates on the beach side at the edge of the estuary. This construction method is geographically unsound and socially irresponsible, and must stop regardless of weather or not this project is fully undertaken. The sand which has already been used must be replaced, as it is Ada’s first defense against the sea and must be protected if this lovely place is to be preserved.
c. Rock Sea Defense: As a result of much sand being used from both the sand barrier and the floor of the estuary, the edge of the estuary is very low, and the rock sea defense which acts as a wave breaker is being weakened at is base as rocks are being sucked out from under the defense and pulled into the ocean. This defense is also very important in terms of keeping Ada safe and must therefore be rebuilt and strengthened in order for this project to be safe from deterioration by the sea and coastal erosion, which would eventually cause their concrete structures to crumble.
d. Structural Feasibility: In light of the above factors the last environmental concern which must be considered in any development project at the Kewunor Island Estuary is the structural feasibility of building on sand. Of course, many development projects have succeeded in building on sand, but in order for such constructions to be long term, durable and safe, the foundation must be rebuilt with stone, and even then the structure may be prone to crumbling depending on the level of erosion at that area. The two structures built by Trasacco in 2013 located on the river side of the estuary already exhibit large and substantial cracks to their foundations, this is particularly troubling since the currently proposed project has planned for a two story hotel building on the island, when in only 6 years the single story structures they have already built are cracking at the base and the roofing frame has rusted to the point that they had to tear it down. Therefore, any more structures which are to be put up in the future should take note of these deteriorations, and improve the foundations especially considering the amount of lives which could be at risk if they didn’t.
3. Petition for the greater interests and benefit of the Ada, Ghana, and global posterity
The following petition section focuses on the impacts of a private development which restricts access to the estuary will have on the generations to come. Because we are not just on this earth for today but our children will live on after us, we must consider the impacts of such a privatization very seriously in light of the local, national, and global posterity. If any project is to be a real public asset to generations to come as is stated on Executive instrument 47 (1974) whereby the government of Ghana acquired the estuary in the name of tourism and the public interest ; then the following provisions should be made in order to protect that public interest.
a. Estuary Access: The Kewunor island estuary in Ada is renown for its beauty and serenity as the hidden paradise of Ghana. It has become famous not because of its fancy pools, jet skis, or private chalets; but rather for its simplicity, the fact that anyone can come; be it locals or internationals: any classroom or group in Ghana can visit this national treasure for the day, and any tourist can afford to stay there. There is no restriction that those enjoying the estuary must buy something, there is no restriction on who can fish in the river or the sea at the estuary, and there is also very little crime. These are all very good characteristics of a location, and have drawn in thousands to Ada’s shores while helping to develop Kewunor community. The fact that the estuary is public allows for all to come and enjoy rather than just those who can afford to buy a 15 cedi Club. Therefore, any developments made at the estuary should not close off the estuary to the public, because the public is the reason for Ghana to have acquired the location in the first place and because that is the exact reason that the Kewunor Island Estuary in Ada is so loved.
b. Marine Life and Marine Biology: Due to the great diversity of sea life, another consideration about the estuary is that it is an ideal place for biological research, and privatizing the area could mean losing out on the great academic work of future generations.
The above petition sections and points outline the Kewunor Advocates position and rationale for best practice in the case of any future resettlement exercise for Kewunor community, and any further construction, or business establishment on Kewunor Estuary Island in Ada concerning the proposed project to be carried out by Trasacco Estates Development Company in partnership with Hilton Hotels. Again we ask that a copy of the full report of the Environmental and Social Impacts Assessment carried out by Ecosystems and Environmental Solutions Limited (EESL) be given to the Volta Revival Foundation and the Kewunor Advocates so that transparency and justice will be the foundations of any project going forward. On behalf of Kewunor community, the estuary environment, and posterity we implore that you tune your ears to our voice, we are the voice of Ada.
Sincerely
The Kewunor Advocates, Volta Revival Foundation