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A Livingstone Problem
by Gill Staden
We hear that
government is to decentralise some of its operations to the
Councils. This is a great move. Local knowledge and local
expertise can be used to solve local problems. It is a shame,
though, that, here in Livingstone, local knowledge and local
expertise is not being listened to, to solve a local problem. Our
local problem is the development of part of our small National Park
by Legacy Holdings Zambia. The development, which we can only
imagine, will turn 220 ha of a very sensitive wildlife area of the
Park into a golf estate, two hotels and over 400 houses, is being
totally opposed by local residents. But central government does not
seem to be taking any notice.
 An
Enviromental Impact document has recently been submitted to the
Environmental Council of Zambia. The EIA is a 360-page document on
how Legacy Holdings can mitigate the effects the development. How
does one mitigate destruction? And destruction it has to be. The
Maramba River and its confluence with the Zambezi River is an
Important Bird Area, regularly monitored by the Ornithological
Society of Zambia. The Wildlife Society has researched the flora
and found plants which are marginal to the region. National
Heritage Conservation has several cultural sites within the area.
The EIA document states that existing vegetation and trees will be
removed – loss of flora and fauna. No doubt bulldozers will be used
to remove the vegetation … and dig up all the cultural sites in the
process. The Environmental Impact Assessment document is available
on
www.necz.org.zm.
Local Livingstone
residents have regularly stated that they are not against the
development – they are against the site of the development. Legacy
Holdings Zambia seems to be stating that the socio-economic impacts
outweigh the environmental concerns. If this is so, why cannot
Legacy find an alternative site; provide the jobs and leave the Park
alone. An alternative site is available outside the Park.
To re-iterate the
reasons why Livingstone residents are against the development:
·
The
Mosi-Oa-Tunya Park is within the World Heritage Site which surrounds
the Victoria Falls. A World Heritage Site is subject to strict
guidelines as laid down by UNESCO and agreed to, and signed by, the
Zambian Government. No approval has been given by UNESCO for the
development. Without this approval we may lose the World Heritage
status.
·
The
development will remove an important elephant feeding ground and
force the elephants out of the Park and into the farming blocks,
thus increasing conflict between people and animals.
·
The
development will, effectively, cut the Park in two
thus stopping the free movement of animals within the Park. Free
movement of the wildlife in the Park is crucial, as the land inside
the old Zoological Park has been overgrazed and the animals need to
move out of that area for food. The SEED Project is fencing the
whole of the Park in order to allow more movement of animals. So
the Legacy development and the wishes of the government in the SEED
project seem to be in conflict.
·
The
Livingstone community relies on tourism for jobs and its local
economy. However, there has to be a balance between development and
the environment. A drive to the Falls from Livingstone, now, is
often punctuated by stops to watch elephant cross the road – a great
tourist attraction. If the project goes ahead the tourist will
drive to the Falls and see only concrete blocks; no more elephant.
·
A
road runs along the Maramba River to the Zambezi River – it is an
old extension of Riverside Drive. This road is used by local
residents and tourists as a hiking or biking trail and is an
important earner for some small businesses. It is also a gazetted
road and cannot be removed without Parliamentary approval.
·
Local Livingstone businesses have, in the past, applied for part of
this land and have been told that it is a non-development zone. We
cannot understand why the land has changed from a non-development
zone to one of a major development. We are not aware of any
consultative process, although ZAWA has recently held a workshop in
Livingstone to produce a management plan for the Park. The plan
which ZAWA produced showed the Legacy Development; the plan which
participants produced showed no development.
These are only a
few of the concerns of Livingstone residents; more are available on
www.victoriafallsheritage.blogspot.com.
Environmental
groups from all over the world have taken up the matter. Africa
Geographic had an article in last month’s issue. National
Geographic and the BBC are also researching the story. The fact
that Zambia has agreed to protect the World Heritage Site for the
whole of mankind is the issue at hand. It is not only the Zambian
government that has to approve the development; it also has to be
approved by UNESCO, the body that was set up to monitor the World
Heritage Site on behalf of the World.
However, the
process of ratifying the approval for the development is being
driven from Lusaka. Livingstone residents did have a chance to air
their concerns at a Scoping Meeting held in Livingstone during
September. The meeting was a dominated by local professionals,
residents, press, wildlife experts, cultural experts and legal
experts saying ‘no’ to the development on that site. And everyone
wondered how central government could make such a decision without
local input prior to its approval. Maybe central government should
take a leaf out of its own book and decentralise all the departments
that can have such a major impact on a local population; or, at the
very least, allow local consultation prior to decision-making. And,
in this case, world approval has also to be sought.
Some
Questions and Comments the Legacy Holdings EIA of their tourism
concession area in Mosi oa Tunya National Park
EIA :
Executive Summary
This Environment
Impact Statement Report on the proposed Mosi-Oa-Tunya Hotel and
Country Club Estate Project has been prepared to comply with the
requirements of the Environmental Council of Zambia (ECZ). Baseline
data was collected through field appraisal, discussion with relevant
agencies and institutions in the concerned areas and consultation
with local communities and individuals in the project area.
Comment:
This seem to be narrow in scope and does not incorporate a strategic
environmental impact assessment which requires consultation with all
stakeholders , not just local ones : UNESCO, Zimbabwe, KAZA and so
on.
EIA : Executive Summary cont.
The
Mosi-Oa-Tunya Hotel and Country Club Estate will be an
environmentally sensitive tourism development along the banks of the
Zambezi River as well as the Maramba River. (Then they state the
impacts):
• Clearance of the existing natural vegetation and trees;
• Irreversible environmental destruction from construction
activities such as deforestation, borrow pit digging and camping
site for construction workers
• Disruption to Elephant/animal corridors
Comment: So, it is agreed that 220 hectares of a 66 sq.
km National Park and World Heritage Site will be completely altered
from a natural state to a totally man made environment, not only
cutting off elephant movements, but other animal life as well; and
the river/land interface will be completely overrun with
infrastructure (450 houses) and the requirements for considerable
boating and other use of the river
EIA :
Executive Summary cont.
A summary of the public consultation meetings and the
discussions with the government agencies indicates that the
socio-economic benefits of the project to the communities in the
project area of influence outweigh the “no-development” scenario.
The project is therefore being recommended for implementation
assuming the incorporation of the recommended mitigating measures
and implementation of the Impact Mitigation Plan and Environmental
Monitoring Plan.
Comment: The results of the stakeholder meeting in
Livingstone do not seem to support this statement. Even were they to
do so, to conclude that socio-economic considerations are paramount
when considering "irreversible" perturbations in a World Heritage
Site and National Park, which happens to be one of the seven wonders
of this world, will cause amazement and concern for all those who
cherish the Victoria Falls and who strive to bring sustainable
development to Zambia.
EIA : Chapter
1 1.1
It is from this background that ZAWA identified a portion of
the Mosi-Oa-Tunya National Park, which is also a northern part of
the World Heritage site, and tendered it for development. The
proposed site has been earmarked for tourism development as
reflected in the Mosi-Oa-Tunya Management Plan.
Comment: Was the full 220 ha, having been expanded from
the Tourism Investment Ltd 2 ha. apportionment, ever part of the
Management Plan?
EIA : Chapter
1 cont.
Legacy Holdings Zambia Limited is a joint venture between a
local tourism company called Tourism Investments Zambia Ltd and the
Legacy Group of South Africa. The local shareholders are Zambians.
Comment: Legacy Holdings got permission from ZAWA and
its Board to expand from the Tourism Investments Ltd concession of 2
ha to an area a hundredfold larger. Did they tender for it?
EIA : 1.2
Over a period of ten years they have successfully completed
the development of seventeen world-class properties
Comment: Legacy Resorts & Hotels has made many
investments, but it seems no all have been success. Of Tourism
Investments Ltd we are told nothing, so presumably the venture is
totally dependent on Legacy Resorts as the financing and management
partners. Presumably what Tourism Investments had to 'deliver', was
the 220 ha. of the Park, symbolized by the laying of a foundation
stone there.
EIA : 1.2
The overall objective of this EIA is to examine impacts on
ecological units and ecological processes of the project area
including impacts on physical, biological, socio-economic and
cultural environment and to provide mitigation measures for
identified impacts for the construction of the proposed
Mosi-Oa-Tunya Hotel and Country Club Estate in Mosi-Oa-Tunya
National Park in Livingstone
Comment: Given that Legacy Holdings state that the area will
have all its natural vegetation removed and that ‘irreversible
environmental destruction will occur’ the EIA is intellectually,
morally and scientifically absurd.
EIA : 1.6
The scope of the study is outlined in the Scoping Report and
Terms of Reference (August 2006) as reviewed, commented upon and
approved by Environmental Council of Zambia in the letter dated
September 4th, 2006. The output from the EIA process is this
Environmental Impact Statement (EIS) comprising of an Environmental
Management and Monitoring Plan (EMP).
Comment: ECZ stated that they had been handed a draft
EIA, but that a scoping report was supposed to have been done. It
seems that Legacy only began the scoping exercise (woefully
incomplete) after this.
EIA : 1.7
Tourism Investments Zambia Ltd and the Legacy group tendered
and got this portion of land in response to the favourable policies
in the tourism sector in the country.
Comment: They only won the 2 ha area on tender, the 220
ha. being given out at the behest of the ZAWA Board. ZAWA should now
provide for scrutiny, as should the National Heritage and
Conservation Commission, of the legal instruments used to excise 220
ha from a National Park for 75 years, there being no difference from
a leasehold tenure having been awarded. Thus, effectively, precedent
is set for all national parks and forest areas in Zambia to be
alienated on long lease should 'socio-economic' interests require
it.
EIA : 1.8
Alternative Options For The Project Development
Option A: Doing Nothing
Option B: Develop Mosi-Oa-Tunya Hotel and Country Club Estate
Comment: No mention is made of alternative sites and
their availability. Why not? This tends to negate all Legacy’s
socio-economic justifications put forward for a development in
Livingstone. If they were good for Mosi, why not an alternative site
outside of the Park. Legacy are being disingenuous, one cannot do an
EIA on something which is totally destroyed i.e. 220 ha of a World
Heritage Site and a National Park. No amount of ameliorative
flannel, even 360 pages of it, will persuade otherwise.
EIA : 1.8.3
A summary of the public consultation meetings and the
discussions with the government agencies indicates that the
socio-economic benefits of the project to the communities in the
project area of influence outweigh the “no-development” scenario.
The project is therefore being recommended for implementation
assuming the incorporation of the recommended mitigating measures
and implementation of the Impact Mitigation Plan and Environmental
Monitoring Plan.
Comment: This is an extraordinary assertion of
developmental arrogance having no regard for conservation or
international standards of environmental care. No amount of
mitigation can alter the fact that the 220 ha area will be
irrevocably changed, and that the damage to the park as a whole, and
to regional conservation development, devastating.
EIA : 1.10.3
Scoping
The scoping exercise included consultative meetings and discussions
with relevant government institutions at national, provincial and
district level, local communities, Headmen, representatives from
NGOs and community based organisations and residents from
communities along the project area. Letters stating the objectives
of the project and requesting local participation and consultation
in the process were also distributed. Responses from the
consultations and discussions provided the relevant background
information and helped identify major environmental concerns of the
communities along the road for the detailed EIA process.
Comment: A bit of hyperbole. ECZ sent Legacy back to do
the scoping properly. From a perusal of the list of those
interviewed, it seems this aspect is incomplete; in fact is has
barely begun.
EIA : 1.10.7
EIA Team
R. MUSHINGE Civil Engineer and Team Leader
J. CHISHIBA Ecology/Environmental Management Specialist
N. KIMANI Environmental/Economics Specialist
L. TUMBAMA Socio-economist/Cultural Environment Consultant
A. SIMUNKANZYE Water and Sanitation Engineer
Comment: Is the team leader the same person who is a
Director and shareholder of Legacy Holdings? If it is, then clearly
the EIA will be biased in favour of a development from which he and
his fellow shareholders and directors would benefit. Is the team
leader also a relative or perhaps brother of the ZAWA official who
issued the tourism lease? ECZ has admitted that they do not follow
the EIA professional certification process as required in SADC
countries; guidelines set by the Southern African Institute of
Strategic Environmental Assessment. Thus the EIA is totally
compromised by not having been conducted by an independent EIA team
duly registered and certified within SADC
EIA : 2.8
Applicable International Conventions
Comment: It appears that this development flouts all the
Conventions to which Zambia is signatory. It also flies in the face
of agreements made (and the resulting recommendations) by the
Commission for Africa, a commission to which Zambia was a full
participant and which led directly to its debt write-off. In
addition, this development and its obvious strong support under
current legislation, the Citizens' Economic Empowerment Act of 2006
(not mentioned in the EIA), is probably causing considerable
discomfort among donor agencies, investors and NGOs already
investing in the National Park. Some of these investors applied for
the same site but were turned down, for very good reason.
In conclusion, as Legacy itself admits, the development will cause
"Irreversible environmental destruction", what makes them insist on
doing this to Mosi oa Tunya National Park when alternative sites are
available?
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November
2006