Ruth Henson's EIA submission...

Submission To ECZ on the Environmental Impact Assessment
for the Legacy Development in the Mosi oa Tunya Park

From Ruth Henson A Livingstone Farmer
P.O.Box 60641 rhenson@zamnet.zm

The EIA is generally a very poorly done document. It contradicts itself and in many places copies inaccurate information from other sources without checking.

The public hearing was turned into a political event and very few people who attended knew what the EIA was.
This meant that people with genuine concerns and comments were shouted down or intimidated into not even trying to say anything. Openly racist remarks were made.

Specifically from the EIA:
Executive Summary: This in effect says that the loss of the environment is justified by the jobs created. This is not reasonable as the same number of jobs could be created outside the park.
Page xi The specified building line I think is 50m from the river front. The plans totally ignore this.
Tourism figures are inaccurate as they ignore all the small operators. Small operators contribute proportionately more to the economy as they buy more local products.
Page xii i and ii Clearance of trees and removal of top soil are clearly incompatible with the stated aim of maintaining the ecology.
Page xiii “irreversible environmental destruction” This is what we are against as we believe that the reason the park was created was to preserve our precious environment.
Page xv Following the recommendations of this report will not maintain the ecology of the area if the given plans are followed. Its ecological and archaeological value will be almost entirely lost.
Page 4 The detailed objectives of the EIA can only be achieved by relocating the project out of the park.
Page7 It is a serious failing of the EIA that only two options are considered
A: doing nothing and B: Going ahead with the development
The other options should have been considered
C: Build the same project outside the park or
D: Build a small hotel on the originally tendered 2Ha plot
Page 9 This claims that the scoping exercise consulted widely. This is blatantly untrue. The public was kept in the dark as far as possible and was nearly prevented from attending a meeting. The phrase “Residents from communities along the project area” is misleading. Livingstone residents were never consulted and we believe that the area is part of our environment and that we should have been consulted from the beginning.
Page 13 ZAWA is supposed to control, manage and conserve wildlife ecosystems and biodiversity. Obviously this does not include building golf courses. ZAWA has decided to sacrifice our Livingstone park for the sake of the money. No Livingstone residents were consulted on whether we agree. We mostly cannot afford to go to Kafue or Luangwa and we want to keep our park as a conservation area. Otherwise our children and grandchildren will not be able to see the wildlife and vegetation in its natural state.
ZAWA is legally required to consult the community in order to enter into such agreements. This was never done.
Page 26 4.1.1 If the project goes ahead this road will be woefully inadequate.
Page 44 5.1.5 Rainfall This section has obviously been copied without being read. It is nonsense to say that the average annual rainfall is 600mm and 780mm from November to March and 700mm in October and April.
Page 54 Isn’t it a bit ridiculous for ZAWA to talk about restocking the park when they have just taken animals out of the park to reduce overstocking and others have died of hunger due to mismanagement.
Page 61 The agriculture statistics are at least ten years out of date and were probably wrong then.
Page 66 Water. While the SWSC is theoretically able to supply the water for this project in practice they are unable to supply enough water for Livingstone residents who are concerned that the situation will get worse if the project goes ahead.
Page 85 7.9 Negative aspects should include difficulties getting visas and immigration hassles.
Advertisement forum. Does this mean that we will have big bill boards all over the golf course?
Page 89 7.11.4 Note that other parks have given 0.015% of their land for a golf course. Legacy has been given 3% of our park.
Page 99 8.6 The elephant corridor is much, much too small to be viable. The loss of the feeding area for the elephants will lead to vastly increased crop raiding in both Mukuni area and along the Sinde plots.
Page 101 8.7.2 The figures for laundry are clearly wrong.
Page 116 9.10.1 Use of one to one interviews and discussions with key informants and stakeholders was obviously inadequate as the shoddy state of the EIA shows.
Page 117 9.10.4 part 1 Local Small scale farmers usually do not benefit from such developments. Even medium scale commercial farmers usually are not benefiting.
Page 118 The employment statistics are a bit strange. If 28.5 % are male and 35.2% are female are the others unemployed computers?
Page 141 9. This passage says that Legacy is planning to pay the same wages as the other tourism operations. This directly contradicts propaganda being put out by Legacy to people around Livingstone.
Page 145 Waste management: Livingstone has no solid waste management program and the current dump site is terribly inadequate.
Page 189 Vegetation and flora
If all areas of high conservation value are marked and access restricted the development will stop because the whole area is of high conservation value.
Page 190 Community Consultation so far has been appallingly bad. This does not augur well for the future.
Page 191 (last paragraph) “appropriate legislation for sustainable tourism development” is being totally ignored by both Legacy and ZAWA.
Page 207 If employment stats are correct another 9000 people will have to move to Livingstone. Where are they going to live? No mention of this impact on Land use and surrounding environment.
Page 235 The Livingstone local communities have not been consulted on their views on tourism development and when we put our views they are ignored.
Page 237 13.1.1 Growth of the tourism industry must be sustainable or it will kill itself. The development in the suggested location will make tourism less sustainable because it takes away our wilderness value.

General Concerns
1. The lack of consultation is worrying. Livingstone people have the right to determine the future of the Livingstone environment.
2. Most people in Livingstone want the Livingstone National Park to be kept as a park. ZAWA may want to sacrifice it but we don’t.
3. Local people need to have free access to the river. The plot given to Legacy is the last place that we can access the river without paying a lot.
4. Elephant use this area for feeding a lot. If they are denied access they will spend more time eating crops in Chief Mukuni’s area.
5. Hippos graze in this area and if they are fenced out where will they eat?
6. Bird life. The area is an important bird watching area.
7. It is easy to make promises now but we all know how investors behave after they have got what they want.
8. It is clear from the actual plans that some of the statements in the EIA are going to be totally ignored such as the recommended building line (50 m from the river) and the width of the elephant corridor (EIA 216m, plan 160m)