Policy Brief The National Environment Policy of Ghana

The government of Ghana deserves to be congratulated for its National Environment Policy, which is expected to inform all relevant stakeholders in their roles of managing the environment to sustain society at large. By the policy, government has announced a new National Environmental Action Plan (NEAP). In this brief we summarize key elements of the policy, comment on where we think it is strong and weak, and make suggestions for how it can better incorporate youth concerns. The National Youth Authority (NYA) is a key institution that must be given clear roles and responsibilities especially given the fact that the nvironment is one of the priority areas captured the National Youth Policy of Ghana. The youth are arguably the major contributors to negative environmental practices such as creating e-waste, littering, and open defecation. It is therefore necessary to regard young people as key stakeholders by engaging them in the decision-making processes so as to ensure effective and efficient sustainability of this policy.

Among our key recommendations are:
1. There must be clear provisions for youth in the legislative framework.

2. There must be specific requirement for active youth participation in all decision-making processes from local to national levels if goals are to be achieved.

3. There must be an unambiguous and strict framework for punitive and incentive measures to encourage acceptable behavioural practices among young people.

According to Section 3.1 of the policy, the new vision for environmental management is based on an integrated and holistic management system for the environment in Ghana. It is aimed at sustainable development now and in the future. The vision for the environmental policy, therefore, is: “To manage the environment to sustain society at large.”The policy seeks to unite Ghanaians in working toward a society where all residents of the country have access to sufficient and wholesome food, clean air and water, decent housing and other necessities of life. This will further enable them to live in a fulfilling spiritual, cultural and physical harmony with their natural surroundings.

Though the policy has clearly stated aims, SYND requires clarification in some of them. In Section 3.3 (Policy Statement) of page 10, the second bulleted aim reads as follows:

• reversing rapid population growth, economic expansion, persisting poverty, poor governance and institutional weaknesses and failures.

Our difficulty is with the basis of “reversing economic expansion”. Is this what is intended? Is this a good decision to make? We will appreciate some responses.

The eighth bulleted aim also reads:
• taking appropriate measures, irrespective of existing levels of environmental pollution and extent of degradation, to control pollution and the importation and use of potentially toxic chemicals.

Indeed, whiles we applaud the need to take appropriate measures of environmental pollution and extent of degradation to control pollution and so forth we want to know why existing levels should not be taken into account (“irrespective of existing levels”). Is it not a prerequisite to measure the existing situation prior to taking corrective measures?

We do caution that though such statements may be the result of sloppy wording, the consequences can be very costly as it can create confusion among key stakeholders who depend on such national policies for direction in their respective programs or projects.

Section 6.1 of Page 28 captures the Institutional Framework and Responsibilities:

The policy states that “…In order to avoid conflict of interests, the policy assigns responsibilities to separate institutions for environmental and natural resource development and management activities. On the other hand, environmental protection, regulation and monitoring are vested in the lead agency, EPA.

Do we therefore assume that institutions for environmental and natural resource development are different from institutions that manage environmental and natural resource activities? If yes, we wish to know the specific institutions tasked with these responsibilities.

Also, if EPA is regarded as the lead agency assigned with a specific mandate (“environmental protection, regulation and monitoring”), then similarly we wish to know the specific tasks of the other agencies, namely the Council for Scientific and Industrial Research (CSIR), the Ghana Atomic Energy Commission and the Town & Country Planning Department. SYND is of the view that EPA should take responsibility for making information available to the public as the lead agency. This is because it is possible for some institution's work to overlap that of others. A clear or specific mandate for each institute we believe can strongly help reduce possible differences if not eschew them completely.

Section 6.2 of Page 28 states the Legislative Framework:

The policy further states that “the legal framework should encourage the participation of all Ghanaians in the management of the country's resources. It should ensure that all aspects of the legal system are in agreement with the supreme law of the country and the prevailing political, socio-cultural and economic policies, and to harmonize these with the principles of sustainable development. The framework should create conditions for formulating, reviewing and updating sectoral regulations for the restoration, protection, management and sustainable use of all resources in the country”.

We wish to ask what has been formulated with respect to the sectoral regulations. Have they ever been reviewed & updated? We will appreciate some responses. SYND contends that the youth are not actively involved in the management of the country's resources. We therefore desire to know, what has been the contribution of young people in the formulation of this legal framework? We also want to know what provisions have been made for youth to be able to participate going forward. Knowledge, experiences and/or expertise should be drawn from youth groups or associations that are actively working in the environment sector. The legislation must make provision for the inclusion of young people in decision-making from the community level to the national level. Their time, energy, resources and abilities need to be well harmonized and channeled towards sustaining environmental programs or initiatives in achieving common goals and objectives.

The last paragraph under the legislative instrument states that, “finally, the environmental policy provides a broad framework for both punitive and incentive measures”.

SYND thinks this should be clearly defined to guide the behavior or attitude of young people towards the environment. For instance, young people actively involved in protecting the environment should be recognized and celebrated in at least the government-owned media and also provided with full or partial educational scholarship to encourage others. However, young people whose actions are found to be detrimental to the environment can be 'named and shamed.'

Section 6.3 of page 29: National Environmental Action Plan (NEAP)

In order to ensure that the national policy is successfully translated into action, the Environmental Protection Agency (EPA), in consultation with Ministry of Environment, Science and Technology (MEST) and the National Development Planning Commission (NDPC) and other relevant institutions, will develop a new National Environmental Action Plan detailing strategies and action plans, and setting targets and time frames for the Medium Term (i.e. Ten years).

The NEAP will focus on and prioritize goals and objectives which require action by government and other MDAs within the next ten years. Criteria for prioritization will include:

- those actions which will ensure healthy working and living environments

- actions to protect the environment for present and future generations

- activities to assist in achieving growth to meet basic human needs

- programmes to achieve integrated and holistic environmental management

The NEAP process must be participatory, drawing on the experience of the previous NEAP.

We wish to know who the “other relevant institutions” are in developing the new NEAP. While SYND is very pleased with the introduction of NEAP, we are not told how different it is from the previous one. (Effort by SYND to obtain the last NEAP has proven futile). It will be good to know if any assessment was done of the last NEAP. What are the key inputs or amendments in the new NEAP that addresses specific failures of the last NEAP? Again, we are not told when exactly the new document will be available. We are therefore hoping that the appropriate institutions provide a timetable for production and release of the plan on an expedited basis.

SYND wants to know the current status of Ghana's performance in achieving targets set for the Medium Term. What are the successes and failures? How does government intend to achieve the aims of the policy in spite of the challenges faced? More importantly which Medium Term are we referring to? Is it in reference to the Ghana Shared Growth and Development Agenda (GSGDA), 2010 – 2013? We sincerely seek for clarification.

Section 6.4 of page 29: Financing Arrangements

A major factor required to ensure success of policy implementation is the timely availability of adequate funding required for programme and project implementation. Due to the cross- sectoral nature of the environment, financing arrangements for the sector have implications for all stakeholders.

SYND agrees with the fact that environmental issues are cross-sectoral. Therefore, there is the need to liaise with all relevant institutions both in government, private sector, donor agencies as well as civil society organizations to achieve a common cause. Financial constraints may be a challenge but that should not inhibit or reduce efforts from being made. Indeed, while more timely availability of adequate funding is imperative, it is also important for the sector ministry to report on detailed progress made so far including all financial commitments made. This will prove a clear case of transparency and accountability.

Section 6.5 of 30: Monitoring, Evaluation and Policy Review

Individual programme and project monitoring is the responsibility of the appropriate decentralized institutions. However, monitoring of the overall impacts of the implementation of this Policy on the country's resources should be consistent with the institutional arrangements specified above i.e. the MEST through the Cross-Sectoral Planning Group carries the overall responsibility for monitoring, evaluation and review of this Policy. However, specific aspects of monitoring can be delegated to other institutions, e.g. EPA.

We wish to know the appropriate decentralized institutions. Does it include EPA? What are their specific roles and responsibilities? Are they supposed to feed into the Cross-Sectoral Planning Group? SYND proposes that monitoring and evaluation mechanisms should be clearly defined for proper assessment. Targets must be provided for each project and programme based on the current trends or situation. The policy also does not provide a timeline for reviewing it, which SYND thinks is inappropriate. How do we know if the policy direction is feasible or if it deserves some corrective actions?

Summary
Overall, SYND is concerned with the fact that active youth involvement in the whole process is not clearly spelt out. All current global development plans acknowledges the need to engage or mainstream youth and gender into the processes not only to ensure balance but more importantly deepen sustainability efforts. While we do acknowledge that education is a vital strategy to adopt (page 17 of the policy), the type and quality of education will, however, determine its efficiency.

Indeed, The heads of State and Government and high level representatives, having met at Rio de Janeiro, Brazil (Rio+), from 20-22 June 2012 in their declaration did affirm in Article 50 that “We stress the importance of the active participation of young people in decision making processes as the issues we are addressing have a deep impact on present and future generations, as the contribution of children and youth is vital to the achievement of sustainable development. We also recognize the need to promote intergenerational dialogue and solidarity by recognizing their views.”

Article 31 also states that “We emphasize that sustainable development must be inclusive and people-centered, benefiting and involving all people, including youth and children”

More over, during the 33rd Session of the UN Framework Convention on Climate Change (UNFCCC) in Cancun from 30th November – 4th December 2010, Parties (including Ghana) agreed in Article 6 (2e) of the Convention that “To foster the participation of women, youth, indigenous peoples, civil society groups and relevant stakeholders in decision-making on climate change at the national level and their attendance at intergovernmental meetings, including sessions of the Conference of the Parties, the Conference of the Parties serving as the meeting of the Parties to the Kyoto Protocol and the subsidiary bodies”

For these reasons, government must be seen to be upholding such global conventions with respect to ensuring sustainable development. SYND urges that:

 Youth must be involved in the entire process of decision-making from the community to national level. This will not only bring the youth to the fore of problems bedeviling the nation but will also ensure sustainability of the programs, activities and/or processes employed.

 Youth must be trained and appointed as Environmental Ambassadors working to educate their peers to ensuring clean environment.

 Youth must be given opportunity in government-owned media (TV, Radio, Print etc) to add their voice to the advocacy and campaign efforts.

 Awards scheme must be instituted for hardworking youth helping to ensure environmental sustainability.

It must be noted that until young people are mainstreamed by all key or relevant stakeholders involved, achieving the policy objectives satisfactorily may not to be feasible. A lot of impact can be achieved if the energies, time, and potential of young people are actively channeled towards the management of society to sustain society.

About SYND:
Strategic Youth Network for Development (SYND) is a registered youth-led NGO in Ghana which focuses primarily on deepening good environmental governance. Our operational work involves tracking and contributing environment-related policies as well as formulation and implementation of programs, projects and activities from community to national level.

Our vision is to help achieve environmental sustainability through the development and active participation of young people in managing the environment through policy formulation, programs planning and implementation of projects and activities to sustain society.

Our thematic focus of work are Climate Change, Biological Diversity (Biodiversity), Land Degradation & Water and Sanitation.

Contact Lead:
Chibeze Ezekiel
Executive Member (Coordinator)
Strategic Youth Network for Development (SYND)
Facebook: www.facebook.com/StrategicYouthNetworkforDevelopment

Website: www.strategicyouthnetwork.org
E-mail: [email protected]
* Youth Master Trainer on Climate Change
* Environment Governance Practitioner
Cell. #: (233) 244 967931