Lower Zambezi National Park Plunder Environmental Sop

The Director General
Zambia Environmental Management Agency
Lusaka

Dear Sir,

re THE PROPOSED KANGALUWI MINING PROJECT IN LOWER ZAMBEZI NATIONAL PARK – OUR HERITAGE

I was recently informed that Mwembeshi Resources have submitted an Environmental Impact Statement (EIS) – presumably prepared by by their consultants, GeoQuest, in respect of the proposed mining of copper and gold by way of two open-pit mines and two below-surface mines in the the Lower Zambezi National Park, having already been issued a large Scale Mining License, and presumably, having submitted and had approved the mandatory Environmental Brief from the Dept. of Mine Safety, the Zambia Wildlife Authority (ZAWA) and the Zambia Environmental Management Agency (ZEMA). My previous requests to ZEMA, the Ministry of Mines (P.S. Mr Beene) and the PS of the Ministry of Tourism under the MMD Government, for a copy of the EB, failed. In addition I note that your website carries no details of this project, nor any invitation to comment on it. I would like to draw your attention to the following :

In mid-October 2011, UNESCO issued Decision:35 COM 7B.8: The World Heritage Committee:

Having examined Document WHC-11/35.COM/7B. And, Recalling Decision 34 COM 7B.7, adopted at its 34th session (Brasilia, 2010), Welcomes the decision of the State Party of Zambia not to approve the proposed mining operations in Chiawa Game Management Area and Lower Zambezi National Park nor the original proposal for a tourist and conference facility in the Chiawa Game Management Area across the river from the property, which could have impacted the property’s Outstanding Universal Value; Notes that mining exploration is on-going in other parts of the Lower Zambezi Catchment, and considers that mining exploration and exploitation in the catchment could adversely affect the property if not strictly regulated; Encourages the State Party of Zambia to consider nominating the adjacent Lower Zambezi National Park in order to eventually constitute a joint trans-boundary inscription on the World Heritage List, in line with the World Heritage Committee’s recommendation at the time of inscription; Requests the State Party of Zambia to: Ensure that any redesigned tourist and conference facility in the Chiawa Game Management Area across the river from the property be subject to a new Environmental Impact Assessment which should include an assessment of the impact on the Outstanding Universal Value of the property, in accordance with Article 6 of the Convention; Submit to the World Heritage Centre, by 1 February 2013, a report on progress in implementing the mission recommendations concerning mineral exploration and mining and tourism development and on the status of the mining activities and tourism developments which could affect the property.

In addition to the Park being under consideration as a World Heritage Site, it is a category II protected area – as are all national parks, managed mainly for ecosystem protection and recreation, defined by the IUCN World Commission on Protected Areas as a ’Natural area of land and/or sea, designated to (a) protect the ecological integrity of one or more ecosystems for present and future generations, (b) exclude exploitation or occupation inimical to the purposes of designation of the area and (c) provide a foundation for spiritual, scientific, educational, recreational and visitor opportunities, all of which must be environmentally and culturally compatible.’ Any mining or large scale hotel development is therefore exploitation and occupation inimical to the purposes of designation of the area. This is recognised in the proposed amendment to the Wildlife Act of 1998, which would prohibit mining in the LZ National Park and in the adjoining Chiawa Community Partnership Park.

And I should bring to your attention the fact that on 18 October 2008, Chieftainess Chiawa (Chiawa/Kafue) Chiefs Chipepo, Simamba, Sinadambwe – all of Siavonga district, and Chiefs Mupuka and Mbunema of Luangwa met and issued an historic statement against mining for 17 chiefdoms of the whole Zambezi system. The Zambia Wildlife Authority is already on record as saying no mining would be allowed in national parks ( on 5 November 2008 the DG of ZAWA, Lewis Saiwana, wrote to Andy Fleming of Zambezi Resources stating that “National Parks and Game Management Areas should not be subjected to mining activities…”) .

In addition the Government, under its own PF Manifesto, avows the Christian stewardship of nature, they are therefore solemnly bound to protect the integrity of the national parks of Zambia, powers which the Minister responsible has within his remit.

I suggest it is therefore beyond ZEMA’s legal power and authority (ultra vires) to invite or make any decision on mining in a national or partnership park.

Yours, etc.,
Ian Manning

Lionscam in Livingstone continues…by I.P.A. Manning

Zambia from aloft

 With the news that the lionscam organization in Livingstone, ALERT,  is about to seek the Zambian Government’s permission to release a pride of Heinz-variety lion into the Zambian wilds, we need to go over some of the ground…

In June 2006, the Livingstone branch of the Wildlife and Environmental Conservation Society of Zambia (WECSZ) wrote as follows: (http://lionscam.blogspot.com/2006/07/walking-with-lions-and-captive.html)

African Encounters, with Safari par Excellence, are planning to set up a captive lion breeding/tourist attraction in the Mosi-o-Tunya National Park, near Livingstone, and the nearby Dambwa Forest Reserve. The offspring of these lions will then be relocated to the wild to replenish depleted lion populations.  On the African Encounter Website it states that “captive bred lions can and have been rehabilitated to the wild. In South Africa this is confirmed by senior ecologists and conservationists”. Lionesses and cubs will be imported from an existing operation in Victoria Falls, Zimbabwe and a breeding male lion from Tanzania to start the project. Cubs will be removed from the mother for hand-raising and habituated to humans for wildlife walks and when too big/dangerous at 12 – 16 months, will be transferred to enclosure(s) in the Dambwa Forest Reserve for wild-release training and “semi-captive” breeding. Second generation animals from Dambwa will then be released into areas where the lion population has decreased e.g. the Kafue National Park, and presumably into GMAs, where the real shortage of lions exists.

 Four years later, on 11 May 2011, Steve McCormick of the lionscam organization, ALERT, (steve@safpar.com) let it be known that – under the direction of his boss, David Youldon (awc@africanencounter.org) – their lion rehabilitation and release into the wild program known as ALERT would soon be needing to release a pride of lions into an appropriate area such as the Kafue National Park in Zambia; and that they  would approach the Zambia Wildlife Authority to support, facilitate and endorse a release.

So, clearly the cubs have grown up and  now present a danger to the hugging tourists, and soon to the villagers.

On May 29, 2011, alerted by Dr. Paul White, I wrote to the Permanent Secretary of the Ministry of Tourism, Environment and Natural Resources, and sent a note to Margrit Harris of NIKELA (www.NIKELA.org):

“I would encourage you and your supporters to write to the following government offices: Permanent Secretary Ministry of Tourism, Environment and Natural Resources (psmtenr@mtenr.gov.zm) and the Zambia Environmental Management Agency (ecz@necz.org.zm), and object to any proposal to Government by the organization, ALERT, to release a pride of lion (reared in captivity and used for tourism in the Livingstone area near Victoria Falls) into the wilds of Zambia, which would threaten the genetics of wild populations, threaten villagers unused to semi-tame and hungry lion, threaten tourists on foot safaris, and threaten current transfrontier conservation initiatives with adjoining countries.”

 

It is worthwhile here revisiting what Dr. Paula A. White, Director, Zambia Lion Project (Center for Tropical Research, University of California, Los Angeles, USA); Dr. Craig Packer, Professor, (Department of Ecology, Evolution, and Behavior, University of Minnesota, USA); and Dr. Luke Hunter, Director, Great Cats Program (Wildlife Conservation Society, New York, USA) had to say  in 2006:

(http://lionscam.blogspot.com/2006/08/fundis-comment-on-proposed-walking.html)

Members of the international scientific community voice their serious concerns and strong opposition to the “Walking with Lions” tourist attraction currently being proposed by African Encounters and Safari par Excellence in Zambia. “Walking with Lions” is a purely commercial enterprise. The purported conservation value of a captive breeding and release program for lions has not been demonstrated. Indeed, many aspects of the proposed program appear ill conceived.

For example, hand rearing of lion cubs will ensure that these animals are imprinted to humans, and that they will thereafter lack natural avoidance behaviors. Teaching hand reared cubs to hunt as sub-adults will not decrease their dependence on humans, nor will it alter their imprinted behaviors. Indeed, semi-tame lions may be as dangerous as wild lions. Recently (August, 2006) in South Africa, three 2½ year-old lions escaped from a game farm and killed two workers. The lions were obtained as cubs and raised by hand. In Tanzania, wild lions kill nearly one hundred people each year, the majority of them villagers. Alteration of lion behavior through captive breeding, hand rearing, and release of semi-tame animals or their habituated offspring is both dangerous and irresponsible when considering the safety and welfare of humans and their livestock in Zambia.

“Walking with Lions” will require a constant supply of cubs. The possibility that this program would result in overbreeding of lions and subsequent development of a canned hunting industry in Zambia, or trade in surplus lions to canned hunting interests in other countries cannot be ignored. Fair hunting practices of wild lions are paramount to Zambia’s commercial hunting industry. For Zambia to associate itself in any way – either real or perceived – with canned hunting of lions could have far-reaching negative impacts on this industry. Currently, Zambia is moving towards ensuring the long-term protection and survival of its lion populations by supporting field research that examines distribution and abundance of lions countrywide, and a genetic assessment of lion subpopulations. It is also actively seeking to establish sustainable quotas through development and implementation of an age-based trophy selection program.

The claim that releasing captive bred lions into national parks and wild areas will serve any conservation purpose by augmenting lion numbers is wholly unsubstantiated. Further, it fails to take into account the genetic structure of lion subpopulations in Zambia. Far from proving advantageous, the released animals may, in fact, introduce deleterious genes or diseases into Zambia’s established wild lion populations, or otherwise alter the local adaptations of the naturally occurring genetic stocks.

Given reasonable protection from excessive mortality and sufficient food resources (e.g., game species), wild lions have the capacity to naturally repopulate a depleted area. In addition to conserving local genetic adaptations, the advantages of natural recovery versus introductions include greater stability to pride structure and movements, and greater predictability as to distance and direction of dispersers. Moreover, a naturally recovering predator population will exist at a density that is appropriate for both game populations and available habitat, thereby reducing the risk of conflict with humans and livestock.

It is emphasized here that “Walking with Lions” has no conservation value. If African Encounters and Safari par Excellence’s desire to assist with conservation of African lions is sincere, they will devote themselves to supporting established programs and organizations that are working towards the restoration and protection of Zambia’s wild lands and animals, and seek to educate their clientele in a similarly responsible fashion.

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