Public scrutiny is welcome — Kemraj Parsram — Opinion

Public scrutiny is welcome

October 20, 2026·3 min read

Dear Editor,

I refer to Mr. GHK Lall’s column, “EPA Director, Parsram,” published on October 18, 2026.

Mr Lall is entitled to question the statements and decisions of the Environmental Protection Agency. As its Executive Director, I communicate the Agency’s positions and am accountable for explaining them. The statements he challenges represent the EPA’s position, and I stand by them. Before addressing the substance, one personal clarification is necessary. Mr. Lall describes me as his “good friend”. We are not good friends. If that description expresses a wish on his part, he is entitled to it. Unfortunately, that is not a sentiment I share, not my cup of tea.

Mr. Lall also describes me as a “jester” and a “comedian”, while speculating about my “war pay”. Yet his column offers more theatrical flourish than evidence to support its central allegation of a predetermined outcome. Before assigning me the role of a comedian, he might reflect on his own performance in this column. I am accountable for the regulatory decisions I explain; he should be equally prepared to substantiate the allegations he publishes. Environmental regulation deserves rigorous public scrutiny, particularly where concerns about uranium exploration arise. Those concerns warrant a serious discussion of the evidence, the law and the responsibilities of the institutions involved.

The EPA’s statement that the matter must await the Environmental Assessment Board’s determination explains the regulatory process. It neither predicts the Board’s decision nor assures the developer of approval. My responsibility as Executive Director is to communicate that position clearly, without prejudging the appeals.

The Environmental Protection Act provides a mechanism through which persons who may be affected can challenge the EPA’s decision that an Environmental Impact Assessment is not required.^[1] The EAB has the authority to confirm or set aside that decision. Respecting this process means allowing the Board to consider the appeals without presuming its conclusion.

There is an important distinction between deciding whether an EIA is required and deciding whether a project should receive an environmental permit. An EIA exemption is not, by itself, permission to commence the proposed activities. Even where an exemption is upheld, the EPA must still determine whether to approve or reject the application and, if approved, the conditions necessary to protect human health and the environment.

Mr. Lall asks when the EAB has disagreed with the EPA. The Board’s record is a legitimate subject for scrutiny. However, the proper test of any determination is its reasoning, the evidence considered and its consistency with the law. Agreement does not, by itself, establish political obedience, just as disagreement does not, by itself, establish independence.

The column goes further, suggesting that political pressure and fear have already settled the outcome. Yet it identifies no evidence of instructions to the Board, interference in these appeals or a predetermined decision in this matter. References to unrelated controversies do not establish those allegations. An assertion does not become evidence simply because it is delivered with confidence or repeated through rhetorical questions.

I will not presume to speak for EAB members or announce their conclusions in advance. Equally, I reject the suggestion that explaining their statutory role makes me a comedian or renders the professionals involved mere rubber stamps. Their work should be examined on its merits, and any allegation of improper conduct should be supported by evidence.

Public concerns about uranium deserve substantive answers. Questions about the proposed activities, potential exposure pathways, effects on water and communities, and the adequacy of safeguards are entirely legitimate. They should be examined through the project information, the reasons for the screening decision and the grounds raised by appellants. Personal ridicule contributes nothing to that examination.

The public is entitled to expect the EPA to explain and defend its decisions with evidence. It is also entitled to an appeals process whose outcome has not been pronounced in advance by either the regulator or its critics. The regulatory statements challenged in Mr. Lall’s column are those of the Environmental Protection Agency. As Executive Director, I stand by them and remain accountable for explaining the Agency’s decisions and respecting the statutory review process.

Kemraj Parsram
Executive Director
Environmental
Protection Agency

References

Rules and Procedures for Conducting and Reviewing Environmental Impact Assessments — epaguyana.org ↩

GHK Lall’s “EPA Director, Parsram” piece is purposeless - Guyana Times

guyanatimesgy.com · 2026-10-19

GHK Lall’s “EPA Director, Parsram” piece is purposeless - Guyana Times # GHK Lall’s “EPA Director, Parsram” piece is purposeless October 19, 2026 #### Dear Editor, I am writing to offer a candid analytical evaluation of GHK Lall’s recent column in Kaieteur News, titled “EPA Director, Parsram.” When evaluating any opinion piece, it is critical to distinguish between essential arguments and mere rhetorical style. An analysis of this 650-word column reveals that approximately 75% of the text consists of stylistic filler, sarcasm, and theatrical commentary rather than core factual information—making it a definitive waste of time, space, and effort. Put simply, it is all ‘talk and no evidence.’ It is fair to say that Mr. Lall’s writing leans heavily into the lexiphanic, resulting in a highly logomaniacal output. From both a logical and journalistic perspective, the article is completely void of empirical or verifiable evidence to support its severe accusations. Rather than offering investigative reporting, the piece firmly belongs to the genre of speculative political commentary. The tommyrot, as expected, is quite high-sounding, but intellectually empty, as it fundamentally lacks evidence for several key reasons: First, Lall is relying on his ‘Unverified Assertions and Speculation.’ He wistfully alleges corrupt “arrangements with political gatekeepers” and claims that the Environmental Assessment Board (EAB) and the Environmental Protection Agency (EPA) function merely as a “rubber stamp.” Mind you, the gravity of these claims poses great danger. Yet he cites no specific documents, transactions, dates, recorded instances, or witnesses to prove such backroom deals exist. Secondly, he boringly makes use of cliched Rhetorical Questions Instead of dealing in Facts.’ I note that rather than proving the EAB is compromised, Lall relies on loaded questions, asking, “When has the EAB gone against Guyana’s Environmental Protection Agency?” In basic logic, a loaded question cannot substitute for empirical evidence. One must ask: wherein lies his academia? Finally, GHK insinuates ‘Guilt by Association’ as he references a past event involving a judge as a “warning” to other officials. He uses this past situation to insinuate how current officials will behave, rather than offering actual proof of contemporary wrongdoing regarding the uranium project. Ultimately, instead of an evidence-based report, the column is a rhetorical argument built entirely on a systemic assumption. Because the author assumes the state apparatus is inherently captured by foreign and political interests, every action taken by the EPA Director is viewed through a single lens of sarcasm, cynicism, and hyperbole (such as “invading hordes”). This is an infantile at work. Consequently, the article fails to provide a factual foundation to legally or logically substantiate its claims. Rather than reflecting genuine public cynicism or constructive political dissent, it serves as little more than a self-indulgent exercise for the author. ... Harg

Source

Public scrutiny is welcome in Guyana Times, October 20, 2026

Rules and Procedures for Conducting and Reviewing Environmental Impact Assessments

epaguyana.org

The Environmental Protection Act, No. 11 of 1996, establishes the requirement for Environmental Impact Assessment (EIA). Part IV of the Act requires all developers of any project listed in the fourth schedule or other project that may significantly affect the environment to apply to the EPA for an Environmental Permit. The application form, which must be accompanied by the prescribed fee, must include a description of the project as well as information regarding the location, size and duration of the project, and potential environmental effects. The EPA and the relevant sector agencies will review the application and assess whether or not the project should be exempted from the EIA process. Once a decision has been made, the EPA will publish a notice to the public, at the developer’s expense, in at least one daily newspaper informing them of the EPA’s position, thereby allowing public review of the decision. Appeals against the EPA’s decision may be made to the Environmental Assessment Board (EAB) within thirty (30) days of the publication of the notice (see Figure 2). ... ##### 1.4 The Role of the EAB The Environmental Assessment Board (EAB) is a body which provides an independent contribution to the development and finalisation of the EIA and makes recommendations which uphold the principles of the EP Act in the context of the interests of the developer, the public and the regulatory agencies. In order to carry out its functions in EIA development, the EAB is involved in the development of the EIA from the point of EIA scoping to establishing conditions for the issuance of an Environmental Permit. This is illustrated in Figure 3. 1.5 Functions of the Environmental Assessment Board The functions of the Environmental Assessment Board are:- 1. To conduct hearings into all appeals submitted to the EAB against a decision of the EPA to exempt a project from the requirement for an EIA. 2. To conduct hearings into EIAs as may be necessary. 3. To recommend to the EPA whether an EIA should be accepted, amended or rejected. 4. To recommend to the EPA whether an environmental permit should be issued. 5. To recommend to the EPA what terms and conditions, if any, should be included in the environmental permit. 6. To ensure a participatory and consultative approach to EIA development by being present to hear the contributions of the public and regulatory agencies in the scoping exercises which are facilitated by the EPA to develop the scope of work and Terms of Reference for the EIA. ... EAB’s Review of EIA All hearings by the EAB are open to the public. The EAB is required to meet in within seven (7) days following the sixty (60) days EIA review period to deliberate on the EIA and render a decision. Such decisions are to be categorised as: 1. Acceptance of the EIA submitted 2. Acceptance of the EIA with minor changes 3. Non-acceptance as submitted with substantially revised resubmission The EAB shall meet and render a decision within thirty (30) days of a resubmitted EIA. 1.6 The Role of the Environmental Appeals Tribunal The EAT is a superior court of record and will have in addition to the jurisdiction and powers conferred by the EP Act, all the powers inherent in such a court. The Tribunal will have the power to enforce its own orders and judgements and the same power to punish contempts as the High Court of Justice. The EAT have the jurisdiction to hear and determine appeals against: - the refusal of an Environmental Permit under Part IV, section 13 of the EP Act; - the requirement of an Environmental Permit; - the cancellation or suspension of an Environmental Permit. ... 3 Figure 2 Preparatory Stages in Obtaining an Environmental Permit – EIA not required Application for Environmental Permit is submitted to the EPA along with a summary of the proposed project, including information on: a) site, design, size and duration of the project b) possible effects on the environment c) a non-technical explanation of the project EPA, in collaboration with the sector agencies, reviews application and project summary. Duration: 14 days Note: A checklist to review applications would be useful The EPA notifies the developer of the findings of the review and publishes in a daily newspaper whether or not the project will significantly affect the environment. If the latter, please refer to Figure 2 (EIA required) EIA not required The public has thirty (30) days to lodge an appeal with the EAB against the EPA decision. If an appeal is made the EAB is required to meet within 7 days after the 30 days period to decide if a hearing is required. The EAB will either confirm or reject the EPA’s decision within 14 days of any hearing. Duration: 60 days Note: The fact that anyone can lodge an appeal against the issuance of an exception for an EIA (Sect. 11(2), EP Act) indicates that EAB provides an independent oversight into applications for Environmental Permit. ... Under Section 28 of the EP Act 1996, any person who is not satisfied with a decision of the EAB may appeal against that decision to the EAT. It is important that the decision itself is set out so that the EAT is able to deal efficiently with the appeal and unnecessary duplication of the work can be avoided. These rules are therefore formulated to ensure that:-(1) - the procedure of the EAB complies with: - the requirements of the Environmental Protection Act. - the common law requirements of natural justice. - the common law requirements for fairness. (2) if a decision of the EAB is challenged on substantive grounds, the EAT is able to hear the appeal without having to duplicate work by the EAB. ... ##### 3.3 Procedures for Appeals ##### 1. Appeals under Section 11(3)(a). 1.1 Any person who may be affected by a decision of the EPA to exempt a project from the requirement for an EIA may lodge an appeal with the EAB within thirty (30) days of the date of publication of the EPA’s decision. 1.2The appeal must be in writing and must set out the reasons why the person appealing believes that an EIA is necessary. A copy of the appeal must be sent to the EPA and the developer. 1.3The EAB shall fix a date for hearing the appeal and shall give not less than 14 days notice in writing to the developer, the appellant and the EPA of the date fixed for the hearing. 1.4The EAB is required to meet at the end of the fourteen (14) days period of notification for a public hearing. 1.5The EAB shall also publish a notice in at least one daily national Newspaper giving members of the public not less than fourteen (14) days notice of the date of the appeal. 1.6The EAB shall meet no later than seven (7) days after the end of the thirty (30) days period to determine if hearing(s) into the appeal(s) is required. 1.7 The EAB shall render a decision within seven (7) days of a public hearing. ##### 2. Hearings 2.1 At the hearing of the appeal, the person appealing may make oral representations or a written submission to the EAB stating - (i) the reasons why the decision of the EPA is wrong; (ii) the risk of damage to the person appealing or to his property or that of any other person; (iii) the risk of damage to the environment; (vi) that the project may significantly affect the environment. 2.2 The EPA shall have a right to reply and to explain the grounds on which its decision is based, but no new evidence or facts shall be relied on to justify the decision of the EPA. 2.3 The EAB may ask the developer for clarification of the project. ##### 3. Matters to be raised. 3.1 The person appealing against the decision of the EPA shall not be required to show that the project will significantly affect the environment, but only that upon the evidence submitted to the EPA, the project may significantly affect the environment. 3.2 Members of the public may be permitted to make submissions to the EAB showing why they may be affected adversely by the project or why there may be significant effects on the environment. ##### 4. Decision. 4.1 The EAB shall within fourteen (14) days of the close of the hearings publish its decision either confirming the decision of the EPA or setting aside the decision of the EPA. 4.2 The EAB shall set out the reasons for its decision. 4.3 The decision of the EAB shall be a public document and shall be available to members of the public. 3.4 The EAB will charge a fee for copies of its decision but the fee will not be more than the reasonable cost of photocopying.