argued that the area, which constituted the suburbs of Albina, was not inhabited by the Lower Marowijne Indigenous Peoples when the land was subdivided, or during the years that preceded the start-up of these activities, and indicated that the town of Albina, the capital of the district of Marowijne, had been a nucleus of social, economic and cultural activities in the Lower Marowijne region for centuries. It also indicated that although the Kaliña and Lokono peoples had taken part in these activities, they did not consider Albina to be part of their ancestral territory over which they could claim ownership rights. In this regard, the State indicated that these peoples never protested against the project, because the site on which it was carried out was not part of the land with which they had a special relationship. In addition, the State declared that part of the villages claimed, in which the indigenous peoples live, are shared with members of Maroon tribes.153 During the visit, it added that the area claimed includes around 18 communities in which Maroons reside (supra para. 41). 120. Regarding the nature reserves, the State affirmed that they had been established to advance nature conservation efforts and that they responded to a higher interest that prevailed over the property rights of the Kaliña and Lokono peoples. It also argued that it had never restricted access or use of resources within the reserves to these peoples, and it had encouraged their participation in the management of the reserves. 154 However, the State explained that it opposed the indigenous peoples managing the “nature reserves on their own.” The State also argued that the restitution of the lands that are now part of the reserves would pose a threat to its obligations towards its citizens and could jeopardize the balance of a system that had proved able to keep the peace, owing to the legal, social, economic, ethnic and racial implications that this restitution could signify. Similarly, the State affirmed that it was unable to share the management of the natural resources, because if all indigenous and Maroon peoples claimed control over such resources in their ancestral territories, it would be disastrous for Suriname’s economy.155 121. Regarding the bauxite mining concessions, the State affirmed that the indigenous peoples did not live in or near the mining area and that the distance between this and the nearest indigenous village (Alfonsdorp) was approximately 6.3 km. The State also indicated that, currently, there were no exploration or exploitation activities in the area; however, Suralco intended to reinitiate exploration activities, and an exploration team would be collecting bauxite samples from the area. Similarly, the State argued that the mining activities had had no harmful effects on the community and that, in any case, the alleged victims had been compensated for any possible damage that they might have been caused by the mining concessions, because they had benefited from the possibility of using the road that existed for their logging activities and to transport timber. 153 The State argued that the land claimed by the Kaliña and Lokono peoples is under the jurisdiction of three administrations: Galibi, Albina and Patamacca. Galibi comprises 677 indigenous persons and 5 Maroons; Albina 915 indigenous persons and 3,082 Maroons, and Patamacca, to the south of Marowijne District, comprises 412 Maroons, but has no records of indigenous peoples living in the area (merits file, folio 583). 154 The State argued that the indigenous people may make free use of the resources in the three nature reserves in the Lower Marowijne area, because the restrictions in force for the other Surinamese inhabitants, such as official fishing and hunting licenses, do not apply to them (merits file, folio 587). It also affirmed that the State had given priority to the participation of the members of the Kaliña and Lokono peoples in the management of the reserves in the Lower Marowijne region, respecting and including their traditional knowledge. As an example, the State mentioned the promotion of activities such as tourism in the Galibi Nature Reserve, where members of the Kaliña and Lokono peoples were hired on a full-time basis or seasonally to help monitor the sea turtles. In addition, the State affirmed that it rents boats and lodges from the local community (merits file, folio 588). Cf. Affidavit made by Claudine Sakimin on January 27, 2015 (merits file, folios 479 and 480). 155 The State emphasized that 85% of the economy was dependent on natural resources; thus State control was required because it was a matter of national security (merits file, folio 604). 33

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