Zambezi Society response to proposed tourism development at Nkupe Camp, Mana Pools
THE ZAMBEZI SOCIETY would like to thank its friends and supporters for their overwhelming response to our Public Consultation Survey on the proposed tourism development at Nkupe Camp in Mana Pools National Park.
As a result of the feedback received (85 replies to date), we have submitted the following official response to the consultants conducting the preliminary Environment Impact Assement (EIA) exercise, to the Zimbabwe Parks and Wildlife Management Authority (ZPWMA) and to African Bush Camps, the proposed developers:-
STAKEHOLDER CONSULTATION FOR AN EIA FOR NKUPE CAMP, MANA POOLS NATIONAL PARK
ZAMBEZI SOCIETY RESPONSE
The Zambezi Society welcomes the opportunity to provide inputs into the EIA process for this proposed tourism development at Nkupe Campsite in Mana Pools. However we find that the information provided by the developer and the EIA consutancy is inadequate and insufficiently detailed for us to provide other than preliminary and general comments on this proposal.
We have nonetheless consulted with our constituency and have received to date 74 general responses which we include in the attached document in support of our comments below.
GENERAL COMMENTS The Zambezi Society understands the need for sustainable tourism development and job creation in Mana Pools. However, we believe that this should only take place if:-
- It does not impact adversely upon the globally-important wilderness and wildlife values which resulted in the Mana/Sapi/Chewore designation as a UNESCO World Heritage Site and a Core Area of the Middle Zambezi Biosphere Reserve
- Does not have detrimental effects on the ecology of the narrow strip of “ alluvial terrace” environment along the Zambezi River
- Falls within the guidelines recommended by the Mana Pools Management Plan developed by the Zimbabwe Parks & Wildlife Authority in consultation with all stakeholders. (We recognise, however, the need to urgently review components of the existing Plan, and believe that any new tourism developments should only be taking place within the Mana Pools in the light of a renewed and updated Management Plan.)
- Does not deprive ordinary Zimbabweans of access to and enjoyment of prime areas within the Mana Pools National Park and World Heritage Site. (The Parks and Wildlife Act (Part IV Section 21) specifically states that “The purposes for which national parks are or may be constituted under this Act shall be— (a) to preserve and protect the natural landscape and scenery therein; and (b) to preserve and protect wild life and plants and the natural ecological stability of wild life and plant communities therein; for the enjoyment, education and inspiration of the public.)
In the 2006 Management Plan for Mana Pools, currently used by ZimParks when reporting to UNESCO regarding the status of the World Heritage Site), a list of Guiding Principles were elaborated for the Mana Pools National Park Tourism Programme. They are listed below:-
· 1. Wilderness qualities will be maintained · 2. Tourism away from the river will be encouraged · 3. Camping and low impacted tented camps will be promoted · 4. Unescorted walking will continue to be permitted · 5. Citizen and educational access will be promoted · 6. ZPWMA accommodation will be competitive · 7. Linkages with appropriate communal areas will be encouraged · 8. Exclusive use areas will be discouraged
These Principles were laid down with the long-term future of the Park in mind, in order to protect the globally-recognised integrity of the Park’s ecology and its wilderness values, as well as to ensure rights of access for the public, in particular, future generations of Zimbabwean citizens.
However, in 2017, citizen access to the riverside wilderness areas of Mana Pools National Park has been gradually “squeezed out ” in favour of short-term gains offered by the leasing of exclusive tour operator sites (with a predominantly regional and international clientele) along the Zambezi River frontage, some with considerable exclusion zones around them. Sites previously available to the public, but now exclusively occupied by tour operators include: Vundu Camp ; Vine Camp; Old Ndungu 1 & 2; Trichelia Camp; Goliath Camp and Croton Camp.
Now Nkupe Camp is proposed as a tour operator-exclusive semi-permanent site, and we believe that BBC Camp and an area on the Chitembe River in the Nyamatusi Wilderness Area are also slated for operator development.
REASONS FOR OBJECTION
The Zambezi Society believes that the site in question is not suitable for the proposed tourism development for the reasons outlined below, and that an alternative site should be chosen.
1) The site proposed is adjacent to the Zambezi River and its position directly contradicts the recommendations of the Mana Management Plan which advises “low impact accommodation facilities away from the river” in order to reduce tourism pressure on the very fragile ecosystem of the Mana alluvial terrace area.
2) The Mana and Chiruwe rivers form a natural corridor for wildlife between the interior and the Zambezi River front. This has already been disturbed by the introduction of the seasonal “temporary extended” site for John’s Camp (Robin Pope Safaris) at the Croton Camp site. An all-year-round “semi-permanent” development in this area would effectively further impact upon the free movement of wildlife to the river at this point. (See map below)
3) A 24-bed safari camp with 12 tents built on raised wooden decks occupying a prime area ofriverine environment with associated staff facilities and outbuildings (kitchen, storeroom, workshop and staff accommodation of prefabricated structures set on raised wooden decks) cannot be described as “low impact” as advocated in the Management Plan
4) The site chosen is an existing low-impact public Exclusive campsite (see map). Development of a 24-bed camp in this site would therefore reduce the camping opportunities available to visitors seeking a low-impact tourism experience (often Zimbabweans) and necessitate the replacement of this site with an alternative along the river, adding to the riverine tourism pressure specifically advocated against in the Management Plan.
5) The site overlooks Mana Mouth a popular spot for visitor recreation, fishing, game viewing, walking and sundowners (see map above and image below)
This area is a focal point for bird-watching, with the presence of a nesting colony of bee-eaters in the Mana riverbank and a number of rare species (e.g. the long-toed Lapwing and the Rufousbellied Heron) resident on the marshy floodplain immediately below the Nkupe camp site. The presence of a 24-bed safari camp with associated “back-end” staff facilities, noise etc so close to this area is not conducive either to the wellbeing of these bird species, the peaceful enjoyment of the Mana Mouth visitors and wildlife or birding enthusiasts or the privacy of safari camp guests. The impacts in all cases would be unsuitable and create a conflict of visitor uses. It would be a gross infringement of the rights of visitors to Mana Pools if public access to Mana Mouth were to be prevented by en exclusion zone around the camp. The Mana Pools Management Plan makes specific reference to avoiding such exclusivity.
6) Road access to this site from Nyamepi Camp is currently via small “bushtracks” which become impassable and rutted during the rainy season because of the nature of the soils in Mana Pools. These would be insufficient to cope with the traffic required to facilitate construction of a “semi-permanent” safari camp at Nkupe, which lies between the Mana and Chiruwe river systems. So some fairly major road reconstruction and possibly bridge-building would have to take place because of the site’s location. This would hugely impact on the Mana Pools alluvial terrace environment and destroy the wilderness quality of the existing “low key” bushtrack system.
7) Since roads into the proposed lodge would only be useable for the dry months of the year, the safari camp is proposing that clients and staff will access the camp by boat from Mana and Chirundu during the rainy season and that a temporary floating jetty will be required on the Zambezi River to moor the boats. Currently only motorboats with small engines are allowed on the Zambezi River in Mana Pools during the rainy season, with very good reason - to reduce impacts on the river ecology and on wilderness values. Long-distance ferrying of passengers along the river from Chirundu would require larger boat motors and use of the Zambezi River main channel. This would increase noise levels and create further disturbance of wilderness values on both sides of the river and create increased wave action which would impact on riverbanks and sandbanks, potentially disturbing nesting birds etc. The main channel of the Zambezi River is currently flowing at a considerable distance from the proposed location of the camp. The construction and use of a jetty (even if it is “temporary” and “seasonal”) will entail road access across the sensitive floodplain wetland in order for the jetty to be safely reached. This is a gross violation of the wetland value of a RAMSAR site and will undoubtedly be a huge disturbance for wildlife and birdlife on the floodplain, as well as an eyesore for other visitors in the Nyamepi/Mana Mouth area. (With regard to general tour operator boat access to Mana Pools from Chirundu, see below our recommendation for a shared jetty facility at the western periphery of the Park, which would serve to minimise impacts and disturbance).
8) The proposed site lies within the Lower Zambezi-Mana Pools Trans-Frontier Conservation Area and is directly opposite the Zambian Lower Zambezi National Park where lodge development has deliberately been kept to a minimum (most tourism developments on the Zambian side of the Zambezi River are in the Chiawa Game Management Area). With its current use as a public exclusive campsite, this site has the advantage of creating minimal visual impact from the Zambian side or the river. The proposed lodge development, however, has the potential to create considerably increased visual and noise impacts which may be unacceptable to the Zambian authorities and stakeholders. (Have they been consulted in this regard as part of any EIA process?)
9) The Parks Authority cites The Mana Pools Management Plan in its reporting to UNESCO on the state of this World Heritage Site. However, this particular tourism development proposal situated at a prime riverine site was not presented during the long process of negotiations and compromise that resulted in the Management Plan.
10) It appears that the Parks Authority has issued an offer letter to the tour operator BEFORE stakeholder consultation on the suitability of this site for such a development. We assume that as a Public Authority, ZimParks has followed due process in terms of required procedures for allocation of this site for tourism development. A breach of such due process could result in local and international outrage, given the global recognition of Mana Pools as a World Heritage Site, and would be an embarrassment to Zimbabwe and the region.
11) African Bush Camps already has an inland concession at Kanga Pan. It is now being offered a riverside year-round “semi-permanent” site in addition to its existing concession. Previously the company was operating its riverside operation, Zambezi Expeditions, as a mobile tented safari camp. So the question arises: why has the company been offered an all-year-round semi-permanent site instead of the seasonal temporary extended (TEC) option which has been allocated to other Mana Pools operators this year?
12) A previous application for a 24-bed tourism development at the Nkupe Camp site was proposed in 2011. The Zambezi Society made similar objections as above in a preliminary EIA process for this application. The project did not progress. We question why the same site is now being put forward again for a similar tourism development, given the objections previously raised.
13) While The Zambezi Society recognises that the ZWPMA is trying to maximise its revenue by encouraging tourism opportunities in popular areas like Mana Pools, and that the exclusive site leases paid by tourism operators are an important source of income for the Authority, we believe that the issuing of new tourism leases should not be undertaken until the Authority has found solutions to the current inefficiencies of the central booking system for public campsites like Nkupe. The system frequently shows the public Nkupe campsite to be fully booked, but in reality there is no-one using the site. Such site-booking inefficiencies are losing the Authority valuable income from the general public. (See recommendations below).
RECOMMENDATIONS In the opinion of The Zambezi Society, the proposal as it stands is in clear violation of the Parks Authority’s mandate to conserve ecological integrity while allowing access and enjoyment of this prime tourism site by multiple and diverse groups of visitors .
The Zimbabwe Parks Authority needs to recognise the importance of its commitment to the long-term conservation of wilderness and wildlife values in prime National Park areas like Mana Pools, for the enjoyment, education and inspiration of the public. Mana Pools is also globally valued as a World Heritage Site, a Core Area of the Middle Zambezi Biosphere Reserve, an Important Bird Area, a RAMSAR wetland site, and a Trans-Frontier Conservation Area. The potential long-term impacts of leasing “exclusive-use” sections of such a globally-significant area for tourism development should not be ignored in favour of short-term income generating solutions for the Parks Management Authority.
We therefore recommend that:-
1) Any prior approval for this development at the public Nkupe Campsite as outlined in the proposal be revoked and any development plans/activities carried out so far be halted.
2) This tourism development be down-sized to a 12-bed seasonal “temporary extended” (TEC) camp and allocated either an existing tour operators campsite (e.g. Old Ndungu 1) like the other operators (as per the recommendations of the Mana Pools Management Plan), or an alternative site at a location further removed from the more popular public-use areas of the Park (see Recommendation 3 below)
3) In urgent negotiation with stakeholders, components of the Mana Pools Management Plan be revised to make provision for the inclusion of carefully-chosen tourism development sites along the Zambezi River within the Nyamatusi Wilderness Area. This would help to reduce the current tourism development pressure in the narrow riverside zone along the Mana Pools “floodplain”.
4) The issue of boat access into Mana Pools via Chirundu (for tour operators) should be addressed with the construction of a shared jetty facility at an agreed site at the western periphery of the Park, to reduce impacts on the Park ecology and on its wilderness value for visitors.
5) An urgent overhaul of the current Parks central booking system in order to improve efficiency and thereby maximise on tourism revenues from the public. Mana Pools could be used as a pilot for this.
6) All due processes have been followed by the Authority in allocation of this (and any past or future) tourism lease agreements.
The Zambezi Society looks forward to more detailed engagement as an important stakeholder in the ongoing EIA process for this development, in a reduced form and at an alternative location, which will be more appropriate to long-term conservation and sustainable tourism in the Mana Pools National Park and World Heritage Site."
You can find the Zambezi Society's CONSULTATION SURVEY ON THE PROPOSED DEVELOPMENT AT NKUPE CAMP as News Items on our website at www.zamsoc.org