Clare Mateke writes...

SUBMISSION TO THE ENVIRONMENTAL COUNCIL OF ZAMBIA ON THE ENVIONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED “MOSI-OA-TUNYA HOTEL AND COUNTRY CLUB ESTATE PROJECT” IN LIVINGSTONE, ZAMBIA

As a Zambian citizen and resident of Livingstone for 26 years, I am gravely concerned about the proposed golf resort development by Legacy Holdings Limited in Mosi-o-tunya National Park.
I have read the Environmental Impact Assessment Report and have the following concerns:

• Lack of Consultation: The Mosi-o-tunya National Park has a large number of Heritage sites and falls under Livingstone District. Therefore, any large scale development such as this one, should not be allowed to go ahead, and even the leasing out of the land, should not have been allowed without prior consultation with all the relevant authorities, including the National Heritage Conservation Commission and the Livingstone City Council. The area has also at several times in the past been under joint management with Victoria Falls authorities in Zimbabwe. To the best of my knowledge, none of these authorities were consulted by ZAWA before leasing out the land and laying the foundation stone. Furthermore, the land was not even advertised by tender according to law. According to the “Project on the Development of the Mosi-o-tunya National Park as a model of Sustainable Economic use and Biodiversity Conservation in a Management Intensive Environment - 2005 to 2009 (ZAWA), “The Park … must demonstrate effective management of its multi-purpose roles, including an array of joint management activities with other institutions.” This joint management is not being implemented by ZAWA concerning such leases and developments.
• World Heritage Site: The Victoria falls and its surrounds, both in Zimbabwe and Zambia, is a World Heritage Site under UNESCO, and is therefore protected by international convention. The purpose of declaring it a World Heritage Site is because the Victoria Falls is a natural world wonder and should therefore be protected for the entire world to see. In order to protect the Victoria Falls, there is need to protect the area around the Falls and the river which flows into it. There is also need to protect the gorges below the Falls, as they are a unique geological feature and any disturbance to them may affect the Falls. A workshop held in 2002 with UNESCO and authorities from both sides of the border concerning the Site clearly recommended that there should be NO FURTHER DEVELOPMENT in the World Heritage Site. Going ahead with the proposed development would be abrogating international and regional conventions for the protection of the site. A recent meeting (6 November 2006) held with UNESCO and Zambian government authorities in Livingstone made it clear that UNESCO is not happy with the way the Falls is being managed and that if any further development is allowed to go ahead, they would be risking having the World Heritage status withdrawn, and UNESCO would be prepared to mount a vigorous international campaign to discourage tourists from coming to the area. Furthermore, Zambian government authorities have not consulted Zimbabwean authorities concerning the proposed development, which would negatively affect them as it would risk them also losing the world heritage status.
• National Park: The area concerned is designated as National Park, with the main objective being to conserve the environment, particularly around the Victoria Falls, and the Zambezi River. ZAWA’s Mosi-oa-Tunya Draft General Management Plan of 1999 states: “A national park, by definition must possess nationally significant natural or cultural resources and retain a high degree of integrity as a true, accurate, and relatively unspoiled example of a resource.” It further states that priorities for the management of the park include: “Protecting and conserving the Zambezi River and its riverine vegetation. Any development … which threatens the integrity of the riverine ecosystem should be opposed in the strongest terms.” If this development is allowed to go ahead, ZAWA will be going against its mandate to preserve the natural resources in protected areas, as the EIA report clearly states that there will be significant and irreversible damage to the natural vegetation, aesthetic value and biodiversity of the area if the project goes ahead. According to the “Project on the Development of the Mosi-o-tunya National Park as a model of Sustainable Economic use and Biodiversity Conservation in a Management Intensive Environment - 2005 to 2009 (ZAWA), the area around the Victoria Falls is ecologically and culturally sensitive. It is therefore crucially important that every effort is made to protect is, rather than to destroy it with such a development.
• Wilderness Value: The EIA document goes on to state that the park provides the “much needed wildlife experience for tourists visiting Livingstone and the Victoria falls”. The proposed development would totally destroy the “wildlife experience” which most of the visitors come to experience. The 220 hectares of wilderness will be turned into a series of large houses (villas) all crammed together, interspaced with exotic golf lawns and a few trees. It will totally lose its wilderness value which foreign tourist come to experience.
• River Frontage: The area which has been leased to Legacy Holdings includes 3 kilometres of Zambezi River frontage and about 1 kilometre of Maramba River frontage (both sides). Out of the 20 kilometre length of the park, this is a considerable portion of river frontage being sold to one private investor. Not only is this a selfish act, denying any other tour operator or local individual to use this long stretch of river, it will also have a significant impact on the biological diversity in the area. The richest diversity of vegetation is found in the riverine woodland along the riverbanks of both the Zambezi and Maramba Rivers. This provides a large number of ecological niches, thus leading to a high diversity of birds and other animals along the river frontage. This national park was laid out along the river in such a way as to deliberately conserve the river frontage and all its diversity. The river also provides links with neighbouring countries. The ZAWA “Project on the Development of the Mosi-o-tunya National Park as a model of Sustainable Economic use and Biodiversity Conservation in a Management Intensive Environment - 2005 to 2009” states: “By maintaining natural habitats along the northern bank of the Zambezi River the Park contributes to preserving this biological diversity, especially if managed as the cornerstone of the economic sector based on biodiversity conservation that serves to open up the linkages between the large parks and community conserved areas in Zimbabwe, Botswana, Namibia, Angola and Zambia.” But if this development is allowed to go ahead it will destroy much of this biological diversity as well as the international links to other conserved areas. It will also deny local people, scientists and tour operators from making use of these large stretches of this scenic river frontage, with its diverse array of plant and animal species, as they are currently doing.
• Bottleneck: The area allocated for the development is situated in a critical faunal bottleneck, which provides the only formally protected natural fauna link between the northern and southern portions of the park and of the region. The development will stretch from one side of the park to the other. It will therefore literally cut the park into two, as movement of animals will no longer be possible between the two halves of the park. Already there are problems of movement due to internal fences and small developments along the river. This will severely worsen the situation and prevent all further movement of large animals, since the development will have surrounding and internal fencing as well as rows and rows of large houses with no gaps between them to allow for any animal movement. Even without the houses, the golf course development would destroy the natural vegetation which the animals currently feed on and take refuge in, so they would still be very unlikely to cross the area, which will probably be fenced anyway to protect it from elephants.
• Elephant Corridor and Crossing Point: The National Park protects part of a traditional elephant migration route between the Hwange and Chobe areas in the south, where elephants are currently abundant (80-120,000 individuals), and the Kafue area in Zambia in the north, where numbers have been depleted (some 4,000 elephants). Elephants regularly cross the Zambezi River from Zimbabwe. They frequent the area between Sun Hotels and the Maramba River, their passage being hindered by increasing tourist activity and related developments. I have seen clear evidence of this in form of droppings and footprints throughout the area, every time I have visited it, and have often met herds of elephants there. The area in question is the last remaining intact area of good vegetation where elephant are free from human pressure. It is crucial that this area remains undeveloped and conserved as a route for animals within the Park and those crossing the river to travel to the gorges and the Mukuni area. The IUCN Strategic Environmental Assessment Report of the Victoria Falls Area (1996) states “there should be access to the riverbank and animal crossing points”. The elephants currently do not cause any significant damage to trees in this area, because there is enough food for them, particularly grass, shrubs and palm bushes. If the development was to go ahead, all the natural undergrowth vegetation which the elephants currently feed on would be removed and they would be left with nothing but tall trees. So even if there were no buildings and no chilli or other fences, the elephants would likely start uprooting the few remaining trees in order to get at the leaves and also out of anger due to the disturbance of their feeding grounds - as they do in the fenced area of the park when much of the ground cover has been lost due to poor management of the animals, resulting in low regeneration of grass and shrubs. The proposed mitigation measure the allow a narrow stretch of natural vegetation along the Maramba River for the elephants and other wildlife is in no way adequate, as elephants are large animals, often moving in large herds and requiring large feeding grounds. It would be ridiculous to expect them to be satisfied with a 200 m corridor through the concrete jungle of villas, hotels, conference centres and golf greens, with hundreds of vehicles and thousands of people moving about all over the place.
• Hippo and other Wildlife: The area is also a critically important hippo grazing area, and the Maramba River confluence is important for crocodile viewing and water birds. I have personally observed hippo paths emerging from the river all the way along the riverbank, almost throughout the three kilometre stretch of river, as well as along the Maramba River, and have often seen hippos in the water in this area. I have also observed monitor lizards, which live along the riverbanks, Monkeys, Baboons, Grysbok (small antelope), Night Ape and Cane Rat, a large rodent which feeds on reeds. Also occurring or likely to occur in the area are waterbuck, bushbuck, common duiker, genets, scrub hares, various types of mongoose, numerous rodents, as well as birds, insects and reptiles. Crocodiles are abundant in the Maramba River and Zambezi, especially around the confluence, as the nutrients from the Maramba River combine with those from the Zambezi at this point, producing an abundance of fish and aquatic insects for other animals to feed on. No less than 5 crocodiles may normally be seen basking on the rocks at the confluence at any one time. As an undeveloped area with minimal road access, the area is a crucial breeding and feeding ground for a number of species. With such developments along two river banks, the hippo will no longer be able to come out to feed and other wildlife will be chased away. The EIA report proposes erecting a fence 10 metres from the Rivers to protect the resort from hippos. This will deny the hippos access to their feeding grounds, as they feed on grass far inland from the river. They have already been denied feeding grounds in areas of the Sun hotel complex and the developments upriver. The riverbanks along the fenced area of the park are steep and difficult for most animals to climb. The proposed development area is currently one place which allows easy access from the river for aquatic animals to come out and feed or breed and for land animals to access water to drink. The EIA report also proposes erecting a chilli fence along the Maramba River to control movement of elephants. How will this and the hippo fence affect movement of other animals? Or is the development only going to keep tame impala that will never be allowed out of the area?
• Important Bird Area: The Mosi-o-tunya National Park and gorge area has been designated an Important Bird Area (IBA) by Birdlife International. The IBA programme protects a global network of sites critical for the long-term survival of bird species and their habitats. About 420 bird species are known to occur in the Victoria Falls area. More than 70 are water birds, dependent on the river. In a ten year study by the Livingstone Museum 53 species of water birds have been recorded in the proposed development area alone, and in a recent study by the Wildlife and Environmental Conservation Society of Zambia (WECSZ), 49 species of woodland birds were identified in two hours on the north bank of the Maramba River. If the development goes ahead, this diversity in bird species will reduce drastically, as much of the habitat will be destroyed. Some important birds in the Victoria Falls area include the Taita Falcon, which breeds in the gorges, Rock Pratincoles, which breed in large numbers on the rocks in the Zambezi River, African Skimmer, White-backed Night Heron, Western Banded Snake Eagle, African Finfoot and Brown-necked parrot. The area is also part of an important flyway for migratory birds between southern and central Africa and beyond to Eurasia. Threats to the biodiversity of the area include the general level of disturbance and the effects of the ever-expanding tourist industry.
• Vegetation: The IUCN report states that no mature trees or riparian vegetation should be cut down. In a recent brief study by the WECSZ, a total of 54 woody plant species were recorded on the north bank of the Maramba River alone. Of special interest is Tree Wistaria (Bolusanthus speciosus), a marginal species for Zambia but an endemic genus of the Zambezian region. This species alone is enough to recommend the site for preservation.
• Access by Local People: This stretch of river, particularly between the Maramba River and the Falls, has always been a favourite spot for social outings by the local residents, because of the scenic river frontage and the wildness of the area. It is also used for scientific research, including a long-term study of water birds. Furthermore, it is used for bird-viewing walks by local and foreign bird-enthusiasts and is used for giving scenic tours to tourists by some local tour operators. Almost all the rest of the river frontage has already been taken up by private tourism investors and is no longer accessible by local people. It is crucial that this area of river frontage is kept open for Zambians.
• Golf Courses and Villas in National Parks: There is concern about how such a large area of land was given out in a very small national park. In the EIA report cases have been sited of golf courses that exist in national parks in other parts of the world. However, none of the other parks mentioned are as small as this one. In all these cases, the golf courses take up a minute fraction of the national park. I don’t think any of them take up as much as 3% of the total land area of the park. As far as I know, none of them stretch from one side of the park to the other, take up 5 km of river frontage, are in World Heritage Sites or are adjacent to natural world wonders. Furthermore, national parks in Zambia, by definition, do not allow residential houses within them. But this development includes 450 2- and 3-bedroom residential houses. These are not lodges or hotels, but houses where families will be living for three or more months, doing their laundry, driving vehicles, having recreational activities, having visitors, etc. Would this normally be allowed in any national park in Zambia? As for golf courses, their mere creation involves removal of natural vegetation, planting of exotic grass, and fertilisation and other chemical treatments. The development will also involve a large labour force and machinery, which will be constantly moving about the area to maintain the condition of the grass. None of these activities are normally permitted within the rules of national parks in Zambia. Why is this an exception? Are we changing the definition of national parks, and do we expect to see all these activities spreading to other national parks?
• Positive versus Negative Impacts:
From the Executive summary of the EIA report the following major negative environmental impacts are expected from the development:
• Disruption to elephant/animal corridors
• Disfigurement to the landscape
• River siltation
• Oil and gasoline spills
• Littering domestic refuse and sewerage waste
• Increased dust
• Air pollution from increased traffic
• Increased noise pollution
• Irreversible environmental destruction
• Changed human settlement patterns

The following are the major negative social impacts expected:
• Increase in sexually transmitted diseases
• Pressure on limited social facilities

The major positive impacts are:
• Creation of employment opportunities
• Increased trade opportunities
• Improvement to livelihoods
• Increased revenue to local authorities and institutions
It is clear to me from this information, that the negative impacts, both social and environmental, far outweigh the positive impacts. And yet the conclusion of the document, surprisingly says the opposite.

• Proposed Mitigation Measures: Although various mitigation measures are proposed to address the potential negative impacts, I am convinced that most of these measures would not be adequate.
For example:
• To control the loss of vegetation, loss of habitat and displacement of birds and animals, it is recommended that less vegetated areas are used. This does not make sense, since the whole area to be developed is quite well vegetated and the current plan is to build (hotels, houses, golf greens, roads, etc), on almost every available bit of land. It would not be possible to only use “less vegetated areas”.
• Disturbance to birds and small animals and loss of habitat - it is recommended to confine construction to the project area and keep noise within working hours. How will this avoid disturbance to the birds and small animals currently within the 220 hectares of the project area, and how are the animals to cope with the high noise levels within “working hours”?
• Reduced access to the river by local people - the mitigation proposed is to construct a public marina. This will allow people owning boats very limited access to a short stretch of river. It will not deal with the issue of church groups coming for fellowship and prayer activities, family groups coming for quiet, scenic picnics along the river bank, school groups coming to learn more about the natural environment, bird enthusiasts coming to watch birds in their natural environment, etc.
• Elephant-people conflict - use chilli fences. This will not provide feeding grounds for the elephant, hippo, antelope and other animals that currently use the area. Therefore these animals are likely to become dangerous, as they will have no access to their former feeding and breeding grounds. It will also disturb the natural movement of elephants across the river, and may lead to them causing more problems in farm and village areas.
• Denied access to traditional sites - leave a way along the river for the Leya people. This was proposed in the Sun Hotel EIA and they promised to do so. They never fulfilled the promise.
• Impact on landscape and aesthetics - the report only mentions the impact during construction. It does not mention the fact that 2 five-star hotels, an 18-hole golf course and 450 large villas will permanently disfigure the natural landscape and aesthetic beauty that currently exists.
• Impacts of quarries and borrow pits - the solution given is to avoid extraction near water sources or heritage sites or national parks or human settlement. Where will it be done then? This definitely excludes doing it on or anywhere near the site, or anywhere near Livingstone or Mukuni Village.
• Loss of vegetation due to construction of camps - limit clearing to the site. How will this limit the loss of vegetation on site?

• Development: I am not against development in general, and I realise the importance of expanding the tourism industry to provide more employment opportunities, but I am opposed to such a development in an ecologically, socially and culturally sensitive and important area so close to the Falls and the Zambezi River Bank, which has been declared by government as a national park for the preservation of nature and by UNESCO as a world heritage site for the preservation of a heritage resource which is famous world-wide.

• Alternative options: My proposal is that the investors find another site for the project outside these protected areas. There is already a piece of land available upriver, away from the Falls and outside the National Park and World Heritage Site. The hills to the northwest of the proposed site, on the way to Mukuni Village, would also offer spectacular views of the Falls, without destroying the scenic beauty of the river. These areas are not in faunal bottlenecks, so would not affect the movement of animals nearly as much. Being away from major rivers, the area on the hill would run far less risk of pollution of rivers and water sources. The vegetation in these areas is sparser and therefore the damage would be less. Furthermore, these areas are away from the main road between Livingstone and the Victoria Falls and the border with Zimbabwe, and would therefore result in less traffic congestion.

Conclusion:
In conclusion, it is crucially important to protect this important piece of wilderness and world heritage around the Victoria Falls. If we cannot stop this kind of decision-making, we may soon lose the Victoria Falls itself!



Clare Mateke
Keeper of Mammalogy, Livingstone Museum
Secretary, Livingstone Branch, Wildlife and Environmental Conservation Society of Zambia
Livingstone Resident for 26 years