Mr Ayisi (middle) making a point during the national dialogue
Mr Ayisi (middle) making a point during the national dialogue

Gold-rich forest reserves - To mine or not to mine?

“Must we be truthful to ourselves by allowing mining responsibly in forest reserves and restoring it? Or we behave like the ostrich by saying that it is a reserve; we are not going to mine it; sign all forms of protocols to preserve it, and yet day in and day out, people go there at midnight to mine illegally?”


This was the key question the Chief Executive Officer (CEO) of the Minerals Commission, Martin Ayisi, posed when he made a case on why he thought it was prudent to allow responsible mining activities in Ghana’s forest reserves.

Hundreds of stakeholders, including experts, academics and policymakers, had gathered at a national dialogue organised by the Graphic Communications Group Limited (GCGL) in Accra to brainstorm how to ensure sustainable management of the country’s natural resources.

Mr Ayisi stressed that he would rather prefer that forest reserves were mined than sit idle for people to mine illegally.  

“We say we are not going to mine in the forest reserves, but we are not able to police it; people go in there to mine illegally; and before you realise, huge levels of devastation emerge,” he said.

This position by Mr Ayisi is at variance with the conservationist principle of environmentalists, who believe that protected areas must not be tampered with.

Illegal miners continue to wreak havoc to the Fure River Forest Reserve at the Asankragua Forest Region

Protected areas

According to the International Union for Conservation of Nature (IUCN), a protected area is “an area of land or sea, specially dedicated to the protection and maintenance of biological diversity and natural and associated cultural resources and managed through legal or other effective means”. 

Protected areas are important because they play a critical role in biodiversity conservation, protection of watersheds, soils and coastlines, as well as safeguarding cultural assets.

In terms of the fight against the global climate crisis, protected areas help in carbon sequestering — the process of capturing and storing atmospheric carbon dioxide. 

This process helps to reduce the amount of carbon dioxide in the atmosphere and ultimately helps to reduce climate change. 

In Ghana, the Environmental (Mining in Forest Reserves) Regulation, 2022 Legislative Instrument (L.I 2462) prohibits mining in restricted or protected areas, including forest reserves.
Section 3(1) of L.I 2462 states: “A person shall not issue a licence or permit to any person to undertake mining activity, including exploration activity in the following areas — a globally significant biodiversity area; a protected provenance area; an institutional research plot; a hill sanctuary; a high conservation value area; a seed orchard; swamp sanctuary; plantation sites and cultural sites.

Section 3(2) adds “Despite paragraph (a) of sub-regulation 1, the President may, subject to Article 268 of the Constitution, give approval, in writing, to a mining company to undertake mining activity in globally significant biodiversity area in the national interest.”

An earthmoving machine causing destruction to portions of the Oda River Forest Reserve in the Bekwai Forest District in the Ashanti Region


Currently, the government has declared forest reserves no-mining zones as part of a raft of measures to curb illegal mining activities. 

Consequently, there is a halt to the issuance of reconnaissance, prospecting and/or exploration licences in forest reserves, unless under exceptional circumstances. 

Even more, river-bodies, most of which take their sources from forest reserves, have been declared as red zones for mining.

While presenting a report on the state of the country’s forest reserves to Parliament in February, this year, the Minister of Lands and Natural Resources, Samuel Abu Jinapor, disclosed that six forest entry permits had been issued for mining in forest reserves.

Tano Nimire Forest Reserve at Enchi in the Western Region has not been spared by illegal miners.

Giving the status of those licences, the minister said CIMAF Ghana Limited, which was granted in 2018, expired in 2021 and was no longer in force, while that of Chirano Gold Mines Limited was renewed in 2019 after the existing permit granted in 2004 expired the same year. 


He added that Kingsperp Mining Ltd, Koantwi Mining Company Ltd, Onex International Co. Ltd and Trans-Atlantic Logistics Ltd were all granted licences in 2020.

Mr Jinapor had also indicated that out of the six licences, only Chirano Gold Mines and Koantwi Mining were in mining operations, while the others were still working on some permits and/or authorisations required to commence their operations.

It is within this context that one finds the call for mining in forest reserves by the Mineral Commission CEO, who is the head of the state institution responsible for regulating mining activities in the country, interesting. 

Don’t touch it

However, the Deputy National Director of A Rocha Ghana, an environmental civil society organisation (CSO), Daryl Bosu, has said any attempt to open up forest reserves for mining activities would amount to ecological suicide.


“The thought that because we have gold everywhere, so we should go into our forest reserves and dig anyhow is suicidal because it has lasting effects on humanity,” he stressed.

The environmentalist stressed that mining in forest reserves would mean displacing forest ecosystems, biodiversity and worsening the climate crisis.

A former CEO of the Minerals Commission, Benjamin Aryee, said there was currently no thorough environmental and social impact analysis to give any compelling justification to mine in forest reserves.

“If we decide to mine in any forest reserve for merely economic reasons, we will lose the forest cover and possibly, a degraded landscape; and that is not what we want,” the Advisor to the Minister of Lands and Natural Resources on Mines stressed. 


He added that the only reason why some countries allowed mining in forest reserves was because they could restore the environment.

“I have been to Australia where they have the super pit. It is one of the biggest pits resulting from mining. They had to assess whether they wanted it or not, even before they started mining. So, before anything starts, we must decide that we want to live with the outcome,” Mr Aryee said.

“They decided that they will leave that huge pit and fill it with water so that it becomes some form of buffer supply of water for the communities around; it will be used for water sports, fish farming and other things,” he said.

The former Minerals Commission CEO observed that until Ghana had a well-thought-through plan for an efficient mining method and post-mining activities, there should be no mining in forest reserves.

A conservationist at Echo-conscious Citizens, an environmental group, Kwaku Attah, observed that the current situation where the government had been overwhelmed by the activities of illegal miners was enough justification that no attempt must be made to open up forest reserves for mining. 

“If we cannot effectively monitor mining activities now, how can we gamble with our forest reserves in the name of mining responsibly? Our forest reserves must be left alone,” he stressed.


A State of the Nation’s Forest report presented by the Forestry Commission on May 2, this year, revealed that 392,714.81 hectares of the country’s 288 forest reserves had been significantly 
“impacted” by illegal mining activities, out of which 4,726.26 hectares in 34 of the reserves had been confirmed as destroyed.

With this in mind, the country must be extra cautious to open the floodgates for mining in forest reserves. 

The focus should be on enforcing the mining laws, especially mining in forest reserves, and this must be colour-blind. 


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