Nick Katanekwa writes...

LIVINGSTONE TOURISM ASSOCIATION (LTA) COMMENTS ON THE

ENVIRONMENTAL IMPACT ASSESSMENT STATEMENT FOR THE PROPOSED LEGACY

HOTELS/ VILLAS/GOLF COURSE DEVELOPMENT IN MOSI-OA-TUNYA

WORLD HERITAGE SITE / NATIONAL PARK


After a thorough study and debate of the impact statement, the LTA wishes to make the following comments.

VISITOR NUMBERS

Projected Tourism growth by Legacy shows an increase to 150,000 of own generated Tourists in a year 3 of their operations. This will mean over 418,000 Tourists for all accommodation facilities thus taking Livingstone into the super growth scenario according to the IUCN report of 2002-Management of the Victoria Falls Area; Which Way Forward for Zambia and Zimbabwe?

The impact of such an increase in visitor numbers does not seem to be adequately addressed by the statement. Though the economic benefits arising from such an increase are certainly projected to be of major significance an increasing proportion of major economic costs which relate to provision of necessary social facilities and maintenance negate this. The social impacts are likely to be of major significance. These relate to factors such as the adequacy of urban facilities, utilities, poverty and equity issues. Although these can be addressed by appropriate investment commitment by Government and Livingstone City Council such investment has its high economic costs which need to be planned for.

On the environment side such an increase will entail major adverse impact like real loss of resource - loss of habitat, deforestation, loss of biodiversity and destruction of national monument archaeological sites that form part of the story which makes the falls area a cradle of the origins of mankind in the world. These will result in the loss of Wilderness Value with projected (IUCN June 1996) loss of revenue of US$ 62.6 M for lost return tourist revenue and US$ 43.6M for lost new tourist revenue annually. The statement has not addressed these major adverse impacts which will actually threaten profitability of the Legacy Hotels as well let alone the entire Tourism Industry at Livingstone if not addressed. Wilderness value is what attracts most tourists to the falls. If it is lost most say they will not come back or recommend the falls to others.



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The LTA is also aware that at a major UNESCO sponsored stake holders bi – national workshop of all relevant institutions, affected and interested parties in Zimbabwe and Zambia in 2002 the following was agreed:

AGREED POLICIES

(a) Riverbanks and Riparian areas

• No further construction within the World Heritage Site.
• Resist further proposals for Hotels and Lodges on riverbanks in the World Heritage site.
• Enforce minimum distance of 500m between tourist development on the riverbank and 50m away from the river bank

(b) Islands on the river.

• These shall be regarded as specially protected areas – no development should be allowed on them except for tourism viewing.

(c) Mosi –oa -Tunya National park and Zambezi National Park in Zimbabwe

• Stop any further fence erection.
• Artificial waterholes should not be permitted except for eco logical reasons.
• No lodge and Hotel development.

The proposed Legacy development goes against these nationally regionally and internationally agreed policies. The statement does not even mention them.

It is quite clear that Zambia/Zimbabwe risk the World Heritage status the Falls currently enjoys being removed with severe consequences to visitor numbers. What mitigation measures can the proposed development give to such imminent danger if the project goes ahead as planned. UNESCO and IUCN have already expressed their concern.

LOCATION

If the proposed development was to go ahead as planned then the Mosi – oa – Tunya Park and the World Heritage site are to be divided into two unlinked parts -
the Northern part is to be cut off from the Southern part .This means the planned improved bio-diversity of the park by the SEED PROJECT is dead and hence the projected increase in length of stay at Livingstone will not be realised. This has severe implications for the sustainability of Tourism at Livingstone.




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Furthermore when Sun International was being proposed they were not allowed by ZAWA and NHCC to plan a golf course in the World Heritage site due to limited space and also because the historical Livingstone Golf course was to be improved and serve the purpose. The Golf course is being improved why then the need for a Golf course now and in such a small area and when more land is actually required to improve biodiversity.

We note also that the second Hotel, Golf course and 400 Villas are all planned for development (2009 -2010) in a small riparian area which cannot carry such massive development without creating a distasteful Disneyland situation in that sensitive environment. This will also effectively cut off the people of Livingstone from the river which can cause hatred of tourism by citizens thereby posing a danger to the industry.

The buffer zone of 200m proposed for an elephant corridor is also too small and may cause a desert like situation in the area. The overall effect of this development is that there shall not be any more viable Wildlife Tourism Operations in the park and that Zambia will then lose this type of tourism to Chobe, Kasane in Botswana. Finally this EIA statement is also based entirely on library research, no actual site studies took place. What is the relevance of such a statement in that a case? All these issues have not been and or adequately addressed by the statement and yet are key.

LTA PROPOSALS

Our proposals as LTA therefore are:
(a) That Legacy should only develop one Hotel - the Mosi- oa-Tunya - on the land which was advertised and for which they won a tender. This Hotel in fact is the major employer of the proposed development yet one with less impact. The other piece of land which were not advertised and tendered for are the most critical in terms of wilderness value of the Victoria Falls area and should be left alone. No amount of mitigation will minimize the irreparable damage such development shall cause to biodiversity and tourism in the site. Legacy can be allocated more land elsewhere in the falls as an alternative.

(b) That environmental impact Assessment studies should only be allowed where issues of land ownership are resolved unlike the case is with Legacy, where land relating to other authorities has been included in an agreement with only one institution. Where is the legality of the study in such a case?

(c) Since the Environmental Council was part of the stakeholder institutions that agreed on the above stated policies and is aware of the current policies in the Mosi –oa- Tunya National Park Management Plan, it needs to bear these in mind in considering the statement since those policies were based on specific professional studies than this statement.





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(d) That the 30km radius on the falls suggested by the IUCN study of 2002 be the basis for such type of envitable tourism development to protect the wilderness value of the 7th wonder of the world and thereby ensure the sustainability of the industry at Livingstone.


(e) That Transparency in land alienation in the falls area be the guiding principle for a vibrant corruption free tourism industry at Livingstone which will benefit all.

Nick Katanekwa
Livingstone Tourism Association Chairman