CONTINUING ‘DEVELOPMENT’ THREATS TO THE VICTORIA FALLS WORLD HERITAGE SITE

I.P.A. Manning

Given that developers are in the process of establishing yet another tourism project in the Zambian portion of the Victoria Falls World Heritage Site (VF-WHS), with possible far-reaching impacts elsewhere, it is time to take stock.

This latest development, one already approved by the Zambian Wildlife Authority and the Forestry Department, but not yet the Environmental Council of Zambia (ECZ), the National Heritage Commission, or UNESCO - who oversee the VF-WHS, is to import captive-bred lion from neighbouring Zimbabwe, to rear them in the Dambwa Forest on the outskirts of Livingstone, walk them with tourists in the adjoining Mosi oa Tunya National Park - while allowing the lion to hunt prey species there, then when the lion are older and a threat to tourists, to release them into the Zambian bush. All that is now required is for the ECZ to approve the EIA carried out by the developers and for the decision not to be overturned by the Minister of Tourism, Environment and Natural Resources. This project reminds me of another controversial project in the Mosi oa Tunya, one still ongoing.

In January 2007, ECZ rejected an appeal by Legacy Holdings to construct two hotels, an 18-hole golf course and 450 villas in the Mosi oa Tunya in Livingstone, and requested that it review its master plan by building just the two hotels (later ECZ approved phase one of the construction of two hotels, one of which would be a five star hotel with 280 rooms and 40 suites).
 The reason ECZ restricted the proposed development was because it was to be implemented in a National Park and because it considered that the 220 ha of development would have a major negative impact on the National Park and on the VF-WHS. Legacy later made application to ECZ for approval of the revised plan for the second phase, wishing to complete phase one by 2010 in time for the World Soccer Cup. The last I heard was that Minister Kaingu of the Ministry of Tourism, Environment & Natural Resources was in discussion with Legacy over future plans, but to date I am not aware of any conclusion, nor has any new EIA been considered. In addition, the statement made to me by the Chairman of the Zambia Wildlife Authority Board that he had placed a moratorium on all new developments in the Mosi oa Tunya – and presumably the Dambwa Forest, should have put paid to all new projects until such time as the Victoria Falls Development Plan - compiled by UNESCO and IUCN, was reassessed.

The Environmental issues apart, my concern is with the disregard for due process. In the case of Legacy, the acting Director-General of ZAWA at the time, Gershom Chilakusha, acted illegally (pun intended) in awarding Legacy 220 ha on a 75 year lease – Legacy’s foundation stone being laid before the EIA was approved. In the lion project’s case, ZAWA issued the lion project (ALERT) an import permit for 19 lion before the EIA was approved, and the Forestry Department entered into an agreement with them over the use of the Dambwa Forest, both agreements requiring an EIA as is required in accordance with
the Environmental Protection and Pollution Control Act (Cap 204 of the
Laws of Zambia), Regulation 3 (1) of the Environmental Impact
Assessment (EIA) Regulations, Statutory Instrument No. 28 of 1997.

But there is more that is awry. The recent Zambia Auditor-General's report on parastatals for 2005, reports as follows:
“ Irregular Issue of Title Deeds in Mosi-O-Tunya National Parks. 


29. According to the provisions of the Act, ZAWA allocates sites in National Parks and 
Wildlife /Bird sanctuaries to successful bidders. The successful bidders are awarded 
a Tourism Concession Agreement (TCA). The TCA is a commercial agreement that 
regulates the conduct of the operators. It confers the rights and obligations of the 
concessionaire and grantor (ZAWA). An Environmental Impact Assessment (EIA) 
is prepared and approved by Environmental Council of Zambia (ECZ) before the 
operator would proceed with the development of operations. 

However, it was observed that two operators namely Waterfront lodge and 
Maramba River lodge had been issued with title deeds in the Mosi-O-Tunya 
National Park. The title deeds for Waterfront have since been cancelled and a 
Tourism Concession Agreement was signed on 8th February 2005 for a period of 
twenty five (25) years. As of August 2006, the title deed for Maramba River lodge 
had not been cancelled and the Authority was not receiving any money from the 
lodge, as there was no agreement though the lodge operated in the National Park. 

Furthermore, there was no evidence of an Environmental Impact Assessment 
having been done for the above-mentioned lodges by the ECZ.”

So, given the lack of due process and accountability, what are UNESCO doing about their area of responsibility? And why do public-funded NGOs such as the African Wildlife Foundation – the latter active in the Zambezi and Livingstone area, continue to remain silent? And is the World Bank, supposedly funding the re-habilitation of Mosi and Livingstone’s environs bringing to bear some conditionality. Ordinary Zambians need to be aware that, apart from the admirable ECZ with their thumb in the dyke and some resolute members of the Livingstone branch of the Wildlife, Environment and Conservation Society of Zambia, the mice are taking over the shop.