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Validity Of Environmental Impact Statement Questioned

New Zambia lodge plans bring about protests from Zambezi Society

Wolfgang H. Thome, eTN  Apr 01, 2010

Protea Hotels of South Africa have come under sustained criticism by the Zambezi Society in Zimbabwe, and according to several emails received by this correspondent, also other wildlife conservation NGOs and wider sections of the safari private sector in Zimbabwe and Zambia over their plans to build a large lodge opposite the Zambezi river in Zambia. As this controversial issue plays out, I am reproducing some material availed from sources in Southern Africa to allow readers to make up their own mind and, in fact, participate in the debate by sending in their pro or con comments to the email addresses supplied.

The Zambezi Society is a non-profit, non-governmental, membership organization working to promote the conservation and environmentally sound management of the Zambezi River and its basin for the benefit of wilderness, wildlife and people.

Zambezi Society members need to know about a 144-bed hotel development proposed by the Protea Hotel Group to be situated on the banks of the Zambezi River, on communal land in the Chiawa Game Management Area some 500 m 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 APRIL 14, 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).

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 end of March 2010 if possible.

A full copy of the Environmental Impact Statement for this hotel development can be downloaded from the internet at this link:

Note that it is a large PDF file – about 8 MB 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 if we have electricity and can make a copy for you onto your own CD or memory stick.


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 email asking to be registered “as an interested and affected party” to the author of the EIS document, consultant Shadreck Nsongela , copied to Protea Hotels Zambia director Adam Leithbridge, . Make sure you ask for an acknowledgement by return of email and keep bugging them until you get one.

Step 2: Prepare your detailed comments and/or objections to the development and send before the April 14, 2010 by email to:

1. The Manager, Inspectorate, Environmental Council of Zambia, and
2. Inspector, Chirundu Border Office, Environmental Council of Zambia,

Again, insist on an acknowledgement by return of email.


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 500 m 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)."

• 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-story main reception building, 6 rectangular two-story accommodation “blocks," 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 andvelopment to the community, training and career development, business opportunities, improved social well-being of the area, promotion of local culture to the outside world, and 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 emailed” to relevant authorities in Zimbabwe, but there was no response. In its follow-ups with UNESCO Zimbabwe, Zimbabwe’s Parks & Wildlife Authorit,y and with the Mana Pools Tour Operators Association, the Zambezi Society has been assured that no one received any such email 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 minimize 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 southwest and Vuundu Camp in the southeastern 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 organization 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 April 14, 2010. Please respond by AT THE LATEST March 31, 2010 if possible.

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 forward this email to anyone who might be interested in helping us to Keep the Zambezi Wild!

Conserving the wildlife and wildernesses of Africa's finest river
Harare Office: Mukuvisi Woodlands, Msasa, Harare, Zimbabwe
Tel: + 263 (0)4 747002-5
Mobile: +263 (0)912 254462

New Zambia lodge plans bring about protests from Zambezi Society
Canoeing at Mana Pools / Image via

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