MEMBERS
CONSULTATION: MARCH 2010
STOP PRESS:
After considerable international opposition to this development, on 15th
April 2010, Protea Hotels withdrew their application to build this 144-bed
conference hotel. The Zambezi Society, along with many other concerned individuals
and organisations, made a comprehensive submission to the Environmental Council
of Zambia objecting to the location and design of this development and its
potential impacts on the wilderness values of the Zambezi River and Mana Pools.
We hope that our comments will be taken seriously should the proposal re-emerge
in a different guise. In the meantime, we will be monitoring the situation.
144-BED HOTEL IN ZAMBIA OPPOSITE MANA POOLS
PROTEA
HOTELS DEVELOPMENT PROPOSAL - ZAMBIA
Zambezi Society members need to know about a 144-bed hotel development
proposed by the Protea Hotel Group, Zambia to be situated on the banks of
the Zambezi River, in communal land in the Chiawa Game Management Area some
500m opposite Vundu Point in the Mana Pools National Park and World Heritage
Site.
An advertisement has appeared in the Zambian newspapers asking for public
comments and/or objections to on the Environmental Impact Statement (EIS)
document for this development that has been submitted to the Environment Council
of Zambia (ECZ) for approval.
Submissions should reach the ECZ (see contact details below) NO LATER THAN
14th APRIL 2010
The Zambezi Society was first alerted to this through concerned Zambian tour
operators and conservationists (not through the developers nor the consultant
who completed the EIS).
THE ZAMBEZI SOCIETY WILL MAKE A SUBMISSION BASED ON THIS MEMBERS CONSULTATION
We wish to make an informed submission on behalf of our membership by
the due date and are therefore asking ALL concerned Zambezi Society members
to write to us URGENTLY with your comments on this proposal by the
9th April 2010.
A full copy of the Environmental Impact Statement for this hotel development
can be downloaded from the internet at this link:
http://mailhost.necz.org.zm/news/comments/eis-reports/Lower-Zambezi-Lodge.html
Note that it is a large PDF file - about 8MB and so needs a fast connection
and will take some time to download. Alternatively a copy of the EIS is available
on CD or flashdisk at the Zambezi Society offices at the Mukuvisi Environment
Centre in Harare. If you wish to make a copy, please bring your laptop or
phone us first on 747002 or 747004 or cellphones: 0912 254462 or 0915 688542
to check we have electricity and can make a copy for you onto your own CD
or memory stick.
CAN I MAKE MY OWN SUBMISSION? IF SO - HOW?
If you (or an organization that you represent) would like to submit a public
comment or objection separately (or in addition) to that of The Zambezi Society,
please feel free to do so. (e.g. The Lower Zambezi Tour Operators Association
will be submitting separately on behalf of Mana Pools operators) Here's what
you do:
Step 1: Register your interest IMMEDIATELY by sending a short e-mail
asking to be registered "as an interested and affected party" to
the author of the EIS document, consultant Shadreck Nsongela snsongela@zamtel.zm
copied to Protea Hotels Zambia Director Adam Leithbridge director@arcades.co.zm
Make sure you ask for an acknowledgement by return of e-mail, and keep bugging
them until you get one.
Step 2: Prepare your detailed comments and/or objections to the development
and send before the 14th April 2010 by e-mail to:
1. The Manager, Inspectorate, Environmental Council of Zambia, jsakala@necz.org.zm
and
2. Inspector, Chirundu Border Office, Environmental Council of Zambia, csimwanza@necz.org.zm
Again, insist on an acknowledgement by return of e-mail.
HERE ARE THE FACTS: For those who do not necessarily wish to read
the full EIS document, the pertinent facts are as follows:
- The developers are the Protea Group of Hotels owned and managed by Union
Gold Zambia, Ltd. The group operates under Protea Inns and Hotels Pvt Ltd
- a South African franchise.
- The Board of Protea Hotels Zambia Ltd consists of :
- Stuart Mark O'Donnell, British resident in Zambia & Chairman
Of Union Gold
- Nicholas Frangeskides, Cypriot resident in Zambia & MD of Velos
Enterprises (a large construction company)
- Efi O'Donnell, Cypriot resident in Zambia & Financial Director
of Union Gold
- Peter Frangeskides, Cypriot resident in Zambia & on the board
of Union Gold
- Mauro Guardigli, an Italian resident in Zambia & MD of Protea
Hotels,Zambia
- The development site lies within the Chiawa Game Management Area (equivalent
to Zimbabwe's CAMPFIRE communal land), 10 kms upstream from Zambia's Lower
Zambezi National Park and about 500m across the Zambezi River from the Zimbabwean
shoreline in Mana Pools National Park at a position directly opposite Vundu
Point (between New Ndungu Camp and the Operators Vine Camp.) The site is
known as the former "Donatini" site, and, according to the EIS
"is sandwiched between Baines Tourist Camp to the west and Munyemeshi Self
Catering camp to the east (across the Munyemeshi stream)" - (see map below.)
- The Zambezi River is narrower at this point than further downstream, so
that the Zambian shore is relatively close to Zimbabwe's Mana Pools shoreline
at this point.
- The development is a 72-room (144-bed) facility aimed at the Zambian local
conference market.
- Calculating on 7-month's high occupancy during the dry season months,
May-November, we estimate that this means a potential influx of around 25,000
people into the area per annum, with associated air, boat and vehicle traffic
and visitor pessure on the National Parks and wildlife areas.
- The development is to be known as "Lower Zambezi Lodge", but
it is clearly the size of a hotel - (against Management Plan recommendations
to keep tourism low- volume in order to preserve wilderness qualities).
- The design consists of a fully air-conditioned one-storey main reception
building, 6 rectangular two-storey accommodation "blocks" (see
drawings at the top of this e-mail), a swimming pool, parking lot for 40
vehicles, walkways and a boat mooring/launching area.
- The development is being strongly promoted by Protea Hotels to the local
Chiawa community as offering job opportunities, support & development to
the community, training and career development, business opportunities,
improved social well-being of the area, promotion of local culture to the
outside world, enhanced protection of the environment and additional tax
revenues for the Zambian government.
- The developers propose to bring electricity into the area by extending
an existing power line downstream for 30 km. The EIA document mentions the
"positive multiplier effects" of this on the community and on
other Zambian tour operations and lodges in the area which currently operate
without mains electricity.
- Tour Operators on the Zimbabwean side of the river have already complained
to their counterparts across the river in Zambia about existing light pollution
at night and excessive boat and aircraft noise pollution during the day
affecting wilderness quality in Mana Pools.
- Two "stakeholder consultation" meetings for this Protea proposal
have already taken place, in April and July 2009. Neither of these was attended
by any representative from Zimbabwe. The majority of the invitees were from
the local Chiawa community.
- According to the EIA document, announcements of these meetings "were
e-mailed" to relevant authorities in Zimbabwe, but there was no response.
In its follow ups with UNESCO Zimbabwe, Zimbabwe's Parks & Wildlife Authority
and with the Mana Pools Tour Operators Association, The Zambezi Society
has been assured that no one received any such e-mail announcement.
- The EIA document makes no reference to existing, recent (though as yet
unsigned) Management Plans for Lower Zambezi National Park and environs
and Mana Pools National Park - both completed by consultant, Dr Ian Games,
for the relevant wildlife authorities. Both these documents acknowledge
the importance of safeguarding the priceless wilderness values of the Zambezi
River in this area (upon which tourism is based) and advocate restricting
tourism numbers and keeping tourism developments at low density in order
to minimise impacts.
- The EIA document makes no mention of potential impacts of this development
on the other side of the river, and appears to neglect any need for consultation
with Zimbabwe on this matter. This ignores several initiatives being discussed
at government levels between the two countries to create a trans-frontier
tourism and conservation area incorporating both sides of the Zambezi River
here.
- In total, there are only four references to Zimbabwe and Mana Pools in
the 164-page document, and only one reference to the existence of a World
Heritage Site across the river in Mana Pools:
- Para 3.5.3: Site Alternatives - in justifying choice of site,
the document states: "the site is close to the Lower Zambezi National
Park (about 10 kms), Mana Pools National Park of Zimbabwe (about 500m
across the Zambezi River) and the proposed Partnership Park (sharing
the boundary) making it possible to tap on any of the tourist attractions
offered by the said wildlife sanctuaries." (So Zambian conference-goers
staying in a non-wilderness area are set to "tap" Zimbabwe's
pristine wilderness area through the Partnership Park arrangement, without
benefit to Zimbabwe!)
- Para 4.1.2. Site location There is reference to the facility
being bordered "in the south by the Zambezi River and Zimbabwe’s
Mana Pools National Park (across the Zambezi River)" - no mention
of a World Heritage Site
- Para 5.3.3. Settlements and buildings. The existence of tourist
facilities on the Zimbabwean side are mentioned briefly as "Mana
Pools Lodge to the south-west and Vuundu Camp in the south-eastern direction".
No mention of Mana Pools' tented safari camps, overnight canoe camps
(Vine Camp) or the popular self-catering public exclusive campsites
at Ndungu and New Ndungu at all.
- Para 5.5 Tourism and Recreation This paragraph mentions the
Chiawa Game Management Area as being "in close proximity with Mana
Pools, a World Heritage Site on the Zimbabwean (sic)" This is the
ONLY reference to the existence of the World Heritage Site in Mana Pools
in the entire document.
- Para 2.3.5. Convention on the Protection of World Cultural
and Natural Heritage - Although this paragraph deals with World Heritage
Sites, it simply states: "Selected heritage properties are entered
in the World Heritage List on the basis of guidelines set by the World
Heritage Committee. In Zambia so far, only the Victoria Falls, one of
the seven wonders of the world, which is shared with Zimbabwe, has so
far been listed" There is NO mention of Zimbabwe's Mana Pools World
Heritage Site within 500m of this proposal development!
- Zambian tourism operators and conservationists have suggested alternative
(and less wilderness-sensitive) sites for the development, or a reduction
of its size to 28 beds, which is more in keeping with the traditional "safari
lodge" ethos of the area.
- There is potential for this development to set a precedent for larger
developments on both sides of the river in the future
- A similar controversial development by Legacy Holdings on the Zambian
side of the Zambezi River at Victoria Falls was halted several years ago
after public outrage and the intervention of UNESCO, the international organisation
responsible for designation of World Heritage Sites. Zimbabwean objectors
are in discussion with UNESCO in the hopes of a similar intervention here.
The Zambezi Society calls on all its members to respond urgently to this
consultation so that we have time to compile our full report and comment and
submit it to the Environmental Council of Zambia in time for the deadline
of 14th April 2010.
STOP PRESS: SIGN UP NOW TO THE NEW FACEBOOK GROUP: Save
Mana Pools
In addition, we also ask members to pass on this information to any influential
contacts in government, NGOs, business or in the media in Zambia, Zimbabwe
or South Africa who are in a position to challenge the developers about this
proposal - both in terms of its impacts on a World Heritage Site and one of
the region's finest wilderness areas, and in terms of its neglect of Zimbabwe
as a major stakeholder in the area.
Protea Hotels South Africa should be a major target for objections.
PLEASE RESPOND QUICKLY. WE DO NOT HAVE MUCH TIME TO MAKE OUR SUBMISSION.
14TH APRIL IS THE DEADLINE.
Top
