WILDLIFE AND ENVIRONMENTAL CONSERVATION SOCIETY OF ZAMBIA (WECSZ) , Livingstone

The Manager Inspectorate
Environmental Council of Zambia
P. O. Box 35131, Lusaka
E-mail: pzulu@necz.org.zm
Tel: 01 254094/254130
Fax: 01 254164

WILDLIFE AND ENVIRONMENTAL CONSERVATION SOCIETY OF ZAMBIA (WECSZ) , Livingstone
P.0 Box 60498

ECZ Submission for the EIA for the LEGACY HOLDINGS ZAMBIA LIMITED proposed “Mosi-Oa-Tunya Hotel and Country Club Estate Project” in Livingstone, Zambia

“Our national parks are as good, only as good, as the intensity with which we treasure them”
John G Mitchel, National Geographic, August 2006.

1) Introduction
2) International Agreements, Conventions and Jurisdiction
3) Golf Course in a National Park
4) Eco Tourism
5) Environmental Impacts
5.1) Birdlife
5.2) Habitat destruction and wildlife
5.3) KAZA TFC
6) Methodology and Baseline Information
7) The Impact on Present Infrastructure
8) Conclusion


1) Introduction
The Wildlife and Environmental Society of Zambia, WECSZ has raised major concerns over the impacts of the Legacy Holdings Zambia LTD proposed Hotel and Golf Estate Project. . This submission outlines the WECSZ objections and the basis for those objections. WECSZ is in agreement with the Legacy EIA statement that the project site will have all its natural vegetation removed and that the result will be “irreversible ecological damage”

The Legacy EIA is actually a project document detailing what is to be done but it does not detail the strategic environmental impacts of such a development to the region as a whole. Many of the facts used in the EIA document are out of date, irrelevant to the site and to the region and are not factual (agricultural statistics, rainfall stastics, employment figures and birdlife). For a multi million dollar investment in an internationally sensitive and crucial conservation area, The EIA for Legacy is seriously lacking in serious data and assessment.

The claim in the EIA that “ 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” is incomprehensible. No amount of mitigation will change the fact that the 220 ha area will be irreversibly changed, the natural environment destroyed and the damage to the park as a whole, and to regional conservation development, devastating. The proposed development would cut the Mosi – oa – Tunya Park and the World Heritage site into two separate parts which has serious implications for the planned improved bio-diversity of the park by the SEED PROJECT including the projected increase in length of stay at Livingstone and the sustainability of Tourism in Livingstone. The danger of the Victoria falls being delisted from its World Heritage Status has major implications for the tourism industry and Zambias standing in the International arena.





The essence of the EIA should be to ask, and then answer, the following question:
Are the economic benefits of the proposed project justifiable against
• completely destroying a World Heritage Site, National Park and protected area, a wildlife corridor, wildlife breeding and feeding grounds
• loss of biodiversity
• permanent alteration of indigenous vegetation
• destruction of Stone Age/Iron Age archaeological sites
• loss of public access to two rivers?
• massive damage to present Transfrontier Conservation Initiatives
• the delisting of Victoria Falls World Heritage Site status
• the massive loss to the economy from tourists who decide not to visit a country which is prepared to sacrifice its heritage for short term gain

WECSZ submits that the irreversible damage to the natural environment at the site of the proposed development far outweighs any potential economic benefits to the local area.
Below is a point-by-point examination of selected issues that arise from the EIA. Each point begins with an issue, in bold, followed by a critique of that issue.

2) International Agreements, Conventions and Jurisdiction
On Friday 10th November 2006 the Times of Zambia reported that the Government has ratified 25 global environmental conventions which play an important role in influencing polices and laws in the sector. Mr. Mutembo, the Copperbelt Deputy Permanent Secretary announced the government “had embarked on a series of initiatives aimed at attaining sustainable socio economic development through sound environmental protection and natural resources management”. How does the proposed development support these ratifications?

• The EIA lists some of the conventions and agreements to which Zambia is a signatory, such as the Convention on Biodiversity, The Ramsar project, IUCN, UNESCO, etc.
• The Victoria Falls and its surrounds - both in Zimbabwe and Zambia - is a World Heritage Site and is therefore protected by international convention. UNESCO declared a 30km radius of Zimbabwean and Zambian territory around the Victoria Falls a World Heritage Site in 1989. At a July meeting of UNESCO's World Heritage Committee in Lithuania's capital, Vilnius, the committee cited concerns that "the integrity of the property [Mosi-O-Tunya National Park] remained threatened by uncontrolled urban development, pollution and unplanned tourism development." In her presentation to the meeting at the Fairmount Hotel, Livingstone on the 6th November, UNESCO commissioner, Mulenga Kapwepwe, said the Victoria Falls, which had put Zambia on the tourism world map, risked losing its world heritage status because of the laxity to consider the protocols seriously.
• The World Conservation Union (IUCN) management plan for the area (The Strategic Environmental Assessment of Developments around Victoria Falls, June 1996) states categorically that no developments should be allowed within the boundaries of the site, and that the wilderness value and the biodiversity of the area are prime resources, which have to be maintained.
• Since then Zambia has ratified a number of international treaties, including :
Convention Concerning the Protection of the World Cultural and Natural Heritage, and the
African Convention on the Conservation of Nature and Natural Resources. The proposed Legacy site is also a designated Important Bird Area (IBA) as declared by Birdlife International and it forms part of the Transfrontier Conservation Area (TFC).

The Post, Thursday November 16th quotes The Minister for Tourism Environment and Natural Resources, Mr Kabinga Pande, “It must be remembered that laws are in place to safeguard the interests of citizens. I have further directed the Environmental Council of Zambia to ensure that existing law on environmental protection is enforced and complied with fully.”

The proposed Legacy site falls under the joint jurisdiction of ZAWA, the NHCC and the City Council:
1) The Livingstone Development Plan, which was approved by Council in 2006, includes the Vision of the Council to guide future development:

• “Livingstone, as the main tourism destination in Zambia, must strive to become the preferred tourism destination in Southern Africa, through provision of a quality tourism experience, by resolutely protecting the World Heritage Site and its surrounds, and actively promoting this unique environment, thereby improving the economic situation and quality of life of the residents.”
• “The mission of the Livingstone City Council is to provide minimum level of services that are affordable and to ensure that the costs of such services are recovered in order to protect the environment of this World Heritage Site and promote sustainable development.”

2) This is further endorsed by ZAWA’s Mosi oa Tunya General Management Plan (GMP) of May 1999, which inter alia 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;

• Section 3 (Planning Guidelines) states clearly:
“Management emphasis in national parks will be to minimize all undesirable human impacts on wildlife populations”;

• Section 3.5.1 (Natural Resources) states that the priorities for the management of the national park will include: Protecting and conserving the Zambezi River and its riverine vegetation. Any development – local, national, international – which threatens the integrity of the riverine ecosystem should be opposed in the strongest terms.

• Figure 7 in the GMP illustrates the distribution of management zones within the national park.
A narrow riverside path route is provided between the Maramba River and the present Sun Hotel site for pedestrian access. The rest of that sector is designated for general tourism activity where permanent structures cannot be erected without full justification. Permitted activities in the Tourism Zone include only: game drives; escorted walks; and picnics.

The narrow, riverside development zone north of the Maramba River will be restricted to existing developments and to jetties, information centres, car parks, toilets and picnic sites. In this area “…no new leases will be considered…These limitations are imposed to keep development to a minimum and safeguard the corridor used by wildlife in this narrow and restricted part of the park.”

The road that runs from the cultural centre along the Maramba River to the confluence is a public road and any change in its status requires that it be de-gazetted by an act of Parliament. Zambian Law on land tenure vests all national parks and gazetted sites in the hands of the state, and any lease of such land is subject to normal tender procedures. As former Minister, Sonny Mulenga said the land had not been advertised or subjected to any tender procedures. "We are setting a very bad precedence for the future generation – land which is gazetted, as a World Heritage Site should never be given out for a song. No records have been given on who evaluated that land, and the amount in question is a mockery."

The concession was expanded from 2 ha. to 220 ha. for a reported period of 75 years without going to tender and is therefore procedurally incorrect and subject to cancellation by the Commission for Investigations
ii) The boundaries of the Park would have to be changed by statute to make the concession possible.
iii) The proposed development places ZAWA in default of its statutory mandate as laid down in the Wildlife Act of 1998: section 5(1) (a) and (c)
iv) The concession reduces the area of the National Park, contrary to Section 12 of the Act.

3) Golf Course in a National Park
The Legacy EIA justification for building and destroying a natural, protected area within a National Park is by reference to golf courses in other National Parks, namely Kruger, Pilansberg, Sabi River, Mt Kenya, Aberdares, and Mweya in Uganda.
What is not considered or pointed out is that these other National Parks are far larger than Mosi-Oa-Tunya National Park (MOTNP). The golf courses in these parks do not take up the entire neck of a Park as Legacy would do in MOT NP. The other golf courses do not completely block a wildlife corridor, whereas the Legacy Development would effectively cut the MOT NP into two distinct halves. In Zimbabwe, the Falls are surrounded by the 2 340 ha Victoria Falls National Park and the 57 000 ha Zambezi National Park. The golf course at Elephant Hills on the Zimbabwean side does not, therefore, impact on the free movement of wildlife as there is adequate space for animals to move around the developed area. This is not the case in the much smaller MOTNP where the Legacy Development would take up 3% of the entire park, and block the crucial wildlife corridor of the park.
4) Eco Tourism
The EIA states that “It is the intention of the developers to follow the "eco-tourism" guidelines produced by the Livingstone Tourism Association”. Ideally, true ecotourism should satisfy several criteria, such as
• conservation (and justification for conservation) of biological diversity and cultural diversity, through ecosystems protection
• promotion of sustainable use of biodiversity, by providing jobs to local populations
• sharing of socio-economic benefits with local communities and indigenous people by having their informed consent and participation in the management of ecotourism enterprises.
• increase of environmental & cultural knowledge
• minimisation of tourism's own environmental impact
• affordability and lack of waste in the form of luxury
So, why is ZAWA allowing Legacy to turn a huge area of our National Park into luminous green carpet of landscaped fairway? Is ZAWA under a deluded notion that, because golf courses are green in colour, they are somehow 'green' in the environmentally friendly sense, too? The truth is, golf courses take up too much space, too much water and disrupt the balance of wildlife. Why has ZAWA allowed this when they are tasked with the protection of our natural environment?
5) Environmental Impacts
• The Legacy EIA states that the development would remove all natural vegetation from the site and that it would cause ‘irreversible ecological destruction’ and cause “disruption to Elephant/Animal Corridors”, despite this it insists that the socio-economic considerations outweigh environmental impacts.
• Despite being offered alternative sites on the river Legacy has stated that if refused, Legacy will pull out of Zambia. Why has Legacy Holdings refused to consider an alternative site, despite this being required by Law under the Environmental Protection and Pollution Control Act (EPPCA). How can Legacy Holdings Zambia embrace irreversible environmental damage and the loss of World Heritage Status without considering an alternative site?
• The EIA report states “The main 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”. The resorts are being built on that specifically identified narrow part of the national park where elephants cross the river and move through to the gorges - an area of major conservation importance for water birds and other wildlife, and also the only part of the river near the Victoria Falls accessible to the people of Livingstone. So how do you mitigate the effects of permanent environmental damage, the blocking of a wildlife corridor, fencing hippo out of their grazing grounds, the pollutants from chemicals and pesticides and fertilizers, the loss of biodiversity and the closure of access of locals to the river? The mitigating measures put forward by the EIA, i.e. by planting exotic grass, an elephant corridor of 200 meters, allowing a few tame impala to run around, sparing some trees for weavers to nest in, or planting Acacia nigrescens, which take years to mature, are paltry and trivial. Having seen the plans for proposed project, which include a swimming pool built on the Zambezi riverbank, (despite recommendations for building 50 meters from the river), it is obvious that the recommendations in the EIA and mitigating factors would also be ignored.

5.1) Birdlife
The riverine vegetation is a crucial breeding and feeding ground for many species of waterbirds, and woodland species prefer the shrubs, scrub, grasses and trees of the drier mopane areas. At the Lower Maramba to Zambezi Confluence, at the proposed site for Legacy, on the 14th June 2006, R Stjernstedt, S. P. Norman and M. Kalaluka , carried out a brief study of the birds in the area , covering a distance of 1.3 km. This is a walk frequently used by bird-watchers and naturalists in Livingstone, because it is a stretch of undisturbed riverine vegetation on the banks of the Zambezi River, looking directly across to a nesting colony of Egrets and Cormorants. This is also a site, almost the only point left to the general public, to see such Zambezi specialities as Rock Pratincoles, White backed Night Heron, Osprey, and Finfoot.

The survey reported 49 species of bird. Notable among birds special to this habitat were
Purple Heron African Goshawk
Gymnogene Red billed Wood Hoopoe
Orange breasted and Grey headed Bush Shrikes African Golden Oriole
Yellow-bellied Greenbul Brown headed Kingfisher
Trumpeter Hornbill Lesser Honeyguide
Collared Palm Thrush Eastern Bearded Scrub Robin
Yellow breasted Apalis Spectacled Weaver.

A longer study, conducted over a ten-year period by the Livingstone Museum Department of Natural History has identified 53 species of waterbirds in the area. Renowned ornithologist and local resident, Robert Stjernstedt, reports that 420 bird species are known to occur in the Victoria Falls Area. The survival of these birds depends on the biodiversity of the area.

For this reason, the area within and around the proposed site for Legacy Holdings’ development of a golf course and resort was declared an IBA (Important Bird Area) declared by Birdlife International. The aim of Birdlife International’s Important Bird Area Programme is to identify and protect a global network of sites that are critical for the long-term survival of all bird species and their habitats. Birds are prone to endemism (found in a restricted distribution area) and are an excellent indication of biodiversity in general. If an area holds rare or endemic birds or a particularly diverse range of birds, it is likely to hold a comparable array of other organisms. When water levels drop, rocky islands and sand bars are exposed along the river above the falls. Rock Pratincoles breed in large numbers on the rocks, and sandbars attract species such as White-fronted Sand Plover and African Skimmer. The riparian forest is home to species such as White-backed Night Heron, Western Banded Snake Eagle, African Finfoot and Brown-necked Parrot. A number of interesting species has been recorded on the boundary of the National Park at the Livingstone Sewerage Ponds including several rare waders and a variety of crakes. Slaty Egret has occurred on a few occasions. The general area also holds large numbers of indigobirds, amongst which can be found odd individuals imitating Brown Firefinch” From Important Birds of Zambia, Peter Leonard. Published by ZOS 2005

Threats to the biodiversity of the area identified by Birdlife International are the general level of disturbance and the effects of the ever-expanding tourist industry, which include light aircraft and helicopters, tourist activities and the immediate disturbance caused by new roads and infrastructure.

5.2) Habitat destruction
The expected Civil Works and construction phase of the Mosi oa tunya Hotel and Country Club as laid out in the EIA would be expected to last twenty-four months.

“This phase would involve the following activities, which would adversely affect the environment:
i) Clearance of the existing natural vegetation and trees;
ii) Removal of the top-soil around the foundation area;
iii) Construction of access road and internal roads within the project area;
iv) Installation of surface water drains;
v) Construction of buildings.
The activities would be undertaken using front-end loaders, graders, wheelbarrows, shovels and picks. The soil removed from the foundation area would be stockpiled in designated areas for future re-planting”.
The IUCN report states that “no mature trees or riparian vegetation should be cut down”. The natural vegetation provides crucial habitats for a wide variety of species of wildlife: large mammals (elephant, hippo, waterbuck, bushbuck and occasionally buffalo), smaller mammals (baboons, vervet monkeys, cane rats, genets, scrub hares, civet, duiker, mongoose, night apes, etc.) as well as birds, insects and reptiles.

In a study by WECSZ, 54 species of woody plants were recorded on the right bank of the river. It was found to be heavily infested in places with exotic Lantana, Melia and gums (Eucalyptus); apart from these the indigenous vegetation appears intact, with Kigelia africana, Combretum, Acacia, Diospyros, Terminalia, and Bauhina specimens of good size, being undisturbed by human encroachment. Of special interest is tree wistaria, Bolusanthus speciosus, a marginal species for Zambia but an endemic monobasic genus of the Zambezian phytochorological region. This species by itself is enough to recommend the site for preservation, as it is of frequent occurrence here and the trees are of good form and height, thus offering Zambians a unique opportunity to see this beautiful tree within their own country.

The IUCN management plan states “there should be access to the riverbank and animal crossing points”. The Legacy development ignores this stricture. The importance of elephants in overall conservation is as a keystone species, i.e. they encourage biodiversity through dispersal of seeds through dung, through their large ranges and by opening up overgrown, dense thickets giving other plant species a chance to grow. Elephants frequent the area between Sun Hotels and the Maramba river, their passage hindered by increasing tourist activity and the developments built to support tourism. The area in question is the last remaining intact area of good vegetation outside of the Park where elephants are free from human pressure. It is crucial that this area remains undeveloped and conserved as a route for animals from the Park and for those crossing the river to travel to the gorge and the Mukuni area. MOT is already damaged by overgrazing and deforestation. The competition for feeding is very high, and so the elephant destruction to trees within the park area is devastating. Over 100 elephants have been seen to use the Legacy area, in various-sized herds, primarily for feeding on fruiting trees , grasses and shrubs. There is very little evidence of trees having been pushed over in the Legacy site area, probably because of the lack of competition from other game. This alleviates much pressure from the fenced Zoological Park. If the Legacy Development went ahead, the increase in destruction to the fenced Zoological Park would be disastrous and could permanently alter the vegetation and carrying capacity of the Mosi-Oa-Tunya National Park. There is also likely to be an increase in elephnant /human conflict upriver past the Sinde if the elephant access to the gorges is blocked off.

5.3) KAZA TFC
One of the “major negative environmental impacts of the Legacy Holdings Development have been identified in the EIA as : Disruption to Elephant/Animal Corridors”.
At the World Summit on Sustainable Development, one of the key resolutions was to foster Transfrontier Conservation Area. ZAWA has signed an agreement with the Kavango Zambezi Transfrontier Conservation Area (KAZA TFC) to establish a Transfrontier Conservation Area (TFCA) with the Peace Parks Foundation (PPF) in agreement with the Africa Wildlife Foundation (AWF). The underlying philosophy of TFCA’s is that cooperation in the management of natural resources that occur along international boundaries will spur increased collaboration between neighbouring states, which will benefit conservation through the wise use of these shared resources by
• Enhancing biodiversity conservation across borders
• Socio-economic development based on sustainable management of natural resources
• Enhancement of cooperation between states, government agencies and communities across political borders.

In practical terms the combining of protected areas across borders allows for improved management and increased ranges for migratory animals such as elephant. It also allows for the marketing of a larger and more diverse tourism destination.

At a meeting held in Angola in April 2003, the Ministers responsible for tourism in Angola, Botswana, Namibia, Zambia and Zimbabwe, agreed to establish a major transfrontier conservation and tourism development area in the Kavango and Upper Zambezi River basins.The proposed Kavango Zambezi TFCA falls within the Okavango-Upper Zambezi TFCA Zone, where the international borders of five countries converge. It includes a major part of the Upper Zambezi basin, the Okavango Basin and Delta. The most significant feature of the Kavango Zambezi TFCA is the large drainage system running though it (the Zambezi, Kavango/Okavango, Kwando and Chobe rivers). The core area is a series of wetlands (Okavango, Chobe/Zambezi) and saline lakes (the Makgadikgadi Pans). The other major feature is the presence of significant populations of the African Elephant. The area is estimated to have nearly 200 000 elephant which is around 30% of the world’s estimated population. Elephants are recognised as the flagship of conservation. The TFCA is designed to conserve landscape-scale ecological function, and elephants being such important herbivores need large landscapes to move around naturally and cannot be conserved inside traditional game reserves and national parks, which are too small and do not necessarily cover international boundaries.

The Kaza TFCA boasts renowned natural features such as the Okavango Delta (the largest Ramsar Site in the World), the Victoria Falls, and the Kafue wetlands as well as considerable tracts of riverine and floodplain habitats along the Okavango and Zambezi Rivers and their tributaries, namely the Kwando, Chobe and Quito Rivers. The TFCA covers many areas formally gazetted as national parks, game reserves, forests or wildlife management areas as follows:

Namibia
• The Mamili, Mudumo and Bwabwata National Parks
• State Forests

Zambia
• National Parks: Liuwa Plains, Kafue Park, Mosi oa Tunya and Sioma Ngwezi National Parks
• Game Management Areas: West Zambezi, Mulobezi, Sichifulo, Bilili, Namwala, Mumbwa, Lunga-Luswishi, Busanga and Kasonso
• State forests

Botswana
• National Parks: The Chobe, Makgadikgadi, Nxai Pan National Parks and Moremi Game Reserve
• Wildlife Management Areas: Okavango, Kwando, Nunga, Ngamiland, Boteti and Nata State Lands
• State forests: Kazuma and Chobe
Zimbabwe
• National Parks: Hwange, Kazuma Pan, Zambezi and Victoria Falls National Parks (and the Matetsi Safari Area)
• State forests: Kazuma, Panda Masuie and Fuller forests
Angola
• National Parks: Luiana and Mavinga Game Reserves
• State hunting areas: Longa-Mavinga, Luengue and Mucusso Coutadas

KAZA TFC is currently working with ZAWA and WECSZ in creating the links between the protected areas in Zambia and those in the neighbouring countries. The Open Areas that occur between the Game Management Areas and the Zambezi River will create the links between the Kafue Park and the protected areas in the neighbouring countries, with the vision of creating wildlife corridors and linkages to re-establish the old elephant migratory routes between the Zambezi River and parks such as the Kafue Park and the Sioma Ngwezi Park.

Current studies for the KAZA TFC include seeking land features between conservation areas (parks/forests) that meet the habitat needs of elephants, mapping the landscapes that effectively allow fragmented elephant populations to interact, and evaluating the suitability of these wildlife habitats with the emphasis on the habitat requirements of elephants. Recent satellite data received from Elephants without Borders, an NGO working to track elephant movements to establish elephant corridors using satellite imagery have shown that elephants use the entire area of the proposed Legacy Holdings site, not just a corridor along the Maramba river. The Legacy proposed “elephant corridor” along the Maramba River is simply not viable: elephants do not walk in straight lines and the area is not a walkway but a feeding ground. Preserving a corridor will not preserve the functioning of the crossing point as the entire area needs to be preserved. As has been shown in Botswana, elephant corridors need to be not less than two kilometers wide to be sustainable.

6) Methodology and Baseline Information

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.

The foundation stone was laid prior to any consultation with local stakeholders, including the Livingstone City Council. The recommendations and concerns put forward at the Scoping Meeting held by Legacy at the Fairmount Hotel have been noted but ignored. The ECZ public meeting held at Maramba River Lodge was more of a political rally with cadres bussed in to disrupt environmental concerns, than an assessment of environmental impacts. Threats and racism were used to intimidate the public. ECZ was not on the panel, questions were directed to the Legacy Board of Directors. ZAWA was not present to discuss environmental concerns. NHCC was not present. Few of 300 or so participants had heard of the EIA document, fewer had even read it. Was this an public hearing for Environmental Impact Assessment?
7) The Impact on Livingstone Infrastructure
The increase in traffic and burden on already disintegrating road networks, water and sanitation and electricity in Livingstone would be enormous. Legacy expects a maximum of 3330 guests, 1850 permanent employees and 1250 visitors on a daily basis. The conference center provides for 1000 delegates. There would also be a craft production site which would require more people transported to and fro, as well as fresh produce, i.e. fish and vegetables and other guest supplies produced on site. The traffic increase and congestion, not to mention road accidents and increased pressure on our roads, would be devastating. An estimated increase of 60 more vehicles a day would be used in the construction phase and would be active at peak hours and, once operational, an additional 200 vehicles a day, of which 50 would be bulk supply vehicles. The repercussions for the already-congested road network in Livingstone are alarming.
8) Conclusion
The EIA states 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”.
WECSZ is very aware of the need for employment in Livingstone. We have high unemployment and poverty which requires urgent addressing. The Livingstone community desperately needs more income, more development and improvement to its infrastructure. We do not have a proper or adequate refuse disposal system, we do not have sufficient water, our roads are in a shocking state of disrepair and our economy is limited to seasonal tourism . So Livingstone residents are certainly not against development. They need and want development.
However, we have to embrace responsible tourism for long term sustainability. By destroying the World Heritage Site and a National Park, the negative effects of this development will outweigh the positive impacts of jobs.

Tourists are attracted to Zambia primarily for its vast and relatively intact wilderness areas. Most lodges are eco-friendly, small-scale structures with minimum impact on the environment; but the potential damage to the tourism industry, by over-development and the complete commercialisation of the Victoria Falls area could have serious repercussions for Livingstone. Tourists come to Livingstone, and for that matter, Zambia, primarily for a wilderness experience. They do not come to Livingstone to find something like Florida or the coast of Majorca. The construction of Legacy resorts on a World Heritage Site, permanently altering the aesthetic beauty of a natural environment and blocking a wildlife corridor, is likely to alienate those attracted to “the real Africa”.
The main attractions for visitors (and hence the thousands of visitors every year) is the Victoria Falls, the Mosi-Oa-Tunya National Park and the wildlife in our area. IUCN stresses that one of the principal attractions of the area is its perceived “wilderness” value and “the juxtaposition of natural wild area with modern visitor amenities. If this wilderness is lost due to over-development, then the visitors will not come and the economy and social structures will suffer.” IUCN Victoria Falls – Skeleton Management Plan Part Quite simply, if the Park is destroyed through over-development, many of the visitors will stay away. And, as a World Heritage Site it is incumbent on us to protect it for all mankind.
As George Schaller says in an interview with John. G Mitchell in National Geographic, October 2006, “It’s essential that each country keep part of its natural heritage untouched, as a record for the future, a baseline to measure change, so people can see the splendor of their past, before the land was degraded. And if we ever want to rehabilate habitat, we need to see how things used to be. These parks and reserves, these untouched places are also genetic resevoirs, where plants and animals that don’t exist elsewhere still survive. They can be invaluable to the human species as a source of food or medicine. If we destroy the parks, they’re gone forever, and we may be losing something invaluable to us”.
“There are certain natural treasures in each country that should be treated as treasures, and it’s up to conservation organizations to fight on behalf of the special places. Too many of these organizations have lost sight of their purpose. Their purpose is not to alleviate poverty or help sustainable development. Their purpose is to save natural treasures”
Tourism is one of the world's largest and fastest growing industries as more people are exploring other countries, destinations and cultures. “Ecologically sensitive areas, those where natural resources are critically endangered by physical changes and which contain a great diversity and interdependence of living habitats”, are experiencing an increase in visitation. Sensitive areas hold the main assets on which the tourism industry depends, so conservation is a must. Any changes in the component of an ecosystem will have unpredictable effects on the entire system”. These sites may be national parks, world heritage sites, wilderness area or cultural sites. As UNESCO’S Gina Doubleday says, “Tourism is great; there’s more discovery and more awareness about the sites, but it does mean we have to work hard to protect them”. Selling off a park, or degazetting it, serves short term appetites while compromising long term ideals. “Parks exist in the dimension of economics as well as geography, biology, symbolism as well as politics and time.”
We also cannot afford to lose our World Heritage Status. We have much pride in boasting such an internationally recognised status. The Victoria Falls is one of the Seven Natural Wonders of the World (CNN). This deserves all the protection it can get. The response to the proposed Legacy development in our national park has been met with unbridled passion, respect and love for our wildlife and our natural and historical heritage. The publicity that this project has received, both locally and internationally, and the response from all walks of the community have shown that, the value of our wildlife and our environment and its protection outweigh the economic effects of this development.

Ali Shenton. Chairman of the Livingstone Branch of WECSZ.