USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
USDA Forest Service Office of International Programs Due Diligence Trip Report
Government of Namibia Proposal to the Millennium Challenge Corporation
MCA Namibia Investment Three: Promote Private and Community-based Investment in Tourism
Section III: Social and Environmental Assessment
FINAL REPORT – May 20, 2007 Mission Dates: February 24 – March 10, 2007 and April 7 – 17, 2007
Oliver Pierson Peter Gaulke Susan Charnley USDA Forest Service USDA Forest Service USDA Forest Service International Programs Ecosystem Management PNW Research Station 1099 14th St. NW Coordination 620 SW Main St. Suite 5500W 201 14th Street, SW Suite 400 Washington, DC 20005 Washington, DC 20024 Portland, OR 97205 (202) 501-2632 (202) 205-1521 (503) 808-2051 [email protected] [email protected] [email protected]
1 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
TABLE OF CONTENTS
I. List of Acronyms 3
II. Forward 3
III. Environmental and Social Assessment Due Diligence Questions 4
A. Environmental Legal and Regulatory Structure 4 B. Environmental Screening 8 C. Environmental and Social Impact Assessment 18 D. Health and safety 20 E. Resettlement (project by project) 22 F. Gender and Underrepresented Groups 23
IV. Additional Terms of Reference Reponses 28
IV.1. Consideration on whether MCC should recommend that GON conduct a 28 Strategic (or Sectoral) Environmental Assessment. IV.2. Criteria for Selection of Conservancies to Receive MCC Investment 29 IV.3. Consideration of National Park Management Plans 30 IV.4. Kunene Contractual Park 30 IV.5. Inadequacy of Current Training Programs in MCA Compact Proposal 32 IV.6. Donor and Partner Coordination IV.7. Potential for Conservancies to Contribute to Poverty Alleviation through 33 Tourism Investments IV.8. Environmental and Social Safeguards – Ecotourism Certification 38
Appendix I: Documents Reviewed (Partial List) and Cited 40
Appendix II: Additional Documentation Needed 42
Appendix III: Specific Issues at Future Bwabwata National Park: 43
Appendix IV: MCC Namibia Due Diligence Mission Itineraries 45
Appendix V: Persons Consulted 52
Appendix VI: Partial list of Environmental, Social, Health And Safety Issues & Effects 53 Reviewed During Field Visits
Figure 1: Namibian Environmental Assessment Procedure 54
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I. LIST OF ACRONYMS
BBM Bwabwata, Mudumu and Mamili National Parks CBNRM Community Based Natural Resource Management DEA Directorate of Environmental Affairs (MET) DOI United States Department of Interior ESA Environmental and Social Assessment EIA Environmental Impact Assessment EMB Environmental Management Bill EMP Environmental Management Plan FENATA Federation of Namibian Tourism Associations GON Government of Namibia MCA Millennium Challenge Account MCC Millennium Challenge Corporation MET Ministry of Environment and Tourism NGO Non-governmental organization SDAB Sustainable Development Advisory Board SIA Social Impact Assessment USFS USDA Forest Service
II. FORWARD
At the request of the Millennium Challenge Corporation (MCC), the USDA Forest Service (USFS) provided Environmental and Social Assessment (ESA) and Environmental Impact Assessment (EIA) expertise in evaluating certain elements, known as a “due diligence” process, of the Government of Namibia’s Compact Proposal on tourism. This included an assessment of the legal, regulatory and institutional environment within the Government of Namibia related to ESA issues, including an initial screening for compliance with MCC Environmental Guidelines.
Due diligence was be performed as part of an integrated team using MCC staff, USFS and Department of Interior (DOI) personnel, and consultants concentrating on infrastructure, engineering, tourism, community based natural resource management (CBNRM), wildlife, environment and social assessment issues, and land and property rights.
Specifically for ESA and EIA issues and all proposed tourism programs, projects and activities, MCC provided environment and social assessment due diligence questions which were reviewed to the fullest extent possible during the mission. Where sufficient information was provided, detailed responses to those questions are provided in this report. Responses to the questions highlight where there is insufficient information to answer a given question and/or when it is too early in the design process to provide a response. Where deemed appropriate, suggested conditions to disbursements under the MCC grant are provided.
For all MCC-funded tourism projects reviewed on this mission, ESA issues were reviewed using the MCC Environmental Guidelines and the MCC Gender Policy. This EIA focused report should be considered in context with the report submitted by the USFS CBRNM Consultant who covered additional social and gender due diligence questions.
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III. Environmental and Social Assessment Due Diligence Questions
Note: This report primarily focuses on ESA issues (Section III of the January 9 MCC Namibia Tourism Due Diligence Scope of Work) and should be considered as complementary to the March 22 report submitted by the USFS/DOI team that responded to Section I of the Scope of Work. This report focuses on ESA Due Diligence Question sets A through set F in Appendix A of the Scope of Work.
A. Environmental Legal and Regulatory Structure
A.1. How well do the country’s environmental laws and regulations, as well as capacity for implementation and oversight, satisfy MCC Environmental Guidelines?
General Discussion: EIA Policy: Pre-trip Namibian EIA documentation consisted of the January 1995 “Environmental Assessment Policy for Sustainable Development and Environmental Conservation” available publicly on the internet. This 1995 document is draft and the version currently in use in the Directorate of Environmental Affairs (DEA) within Namibia’s Ministry of Environmental and Tourism (MET). An updated draft 2002 Environmental Management Bill was provided for review by ESA consultants during meetings in Windhoek.
In-country discussions highlighted the development of a legal EIA policy framework that has been under consideration for over 10 years. Current status of this “Environmental Management Bill” is that it has been endorsed by the Minister, is now with the Attorney General, and is expected to be on the agenda for the Namibian Parliament’s next legislative session. However, it is difficult to predict how long it will take before it is signed into law, although there is a desire to have it completed in 2007.
This current 2007 draft Environmental Management Bill (2007 EMB) before the Namibian Parliament will be used in this report to determine whether Namibia’s environmental laws and regulations, as well as proposed staffing will satisfy the MCC Environmental Guidelines (January 20, 2006). It should be noted that the 2007 EMB is a significant departure from the 1995 draft policy and provides significantly greater detail in process, staffing and enforcement than either the 1995, or the draft 2002 EMB.
In addition to the proposed Environmental Management Bill, a 14-page “Screening Questionnaire for Projects” produced by the DEA, was provided by MET Staff and reviewed for inclusion in this report. The status of this document and its use under the proposed 2007 Environmental Management Bill is unclear.
EIA Staffing: Current staffing in the Environmental Assessment section of the DEA consists of three staff - one section head and two support staff. This staff is responsible for all ESA review and documentation that passes through MET, not for production of ESA documents.
Effectively, not unlike many African countries, most EIA documentation in Namibia is completed under contract by a host of non-governmental organizations (NGO) and contractors. It is the responsibility of the DEA to review each document for compliance and sufficiency with the Environmental Management Policy.
The proposed 2007 EMB includes a staffing structure and review framework which, if implemented, would provide greater surety of project adherence to Namibian environmental policies. Proposed staffing includes an Environmental Commissioner, Deputy Environmental Commissioner, and Environmental officers. Of particular note is the establishment of the Sustainable Development Advisory Board (SDAB) consisting of parties both inside and outside the Government of Namibia (GON). The SDAB’s function
4 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment is to advise the Minister on, among other things, the “development of a policy and strategy for the management, protection and use of the environment”, but does not affect individual projects or activities. Staffing of the Directorate of Environmental Affairs is on hold until the bill is signed into law.
Findings: The 2007 EMB endorsed by the MET Minister and pending Namibian Parliament approval meets the overall requirements of the MCC Environmental Guidelines and good international practices. This proposed bill provides for appropriate screening and appropriate environmental and social analysis. There is a close parallel in principles and process between the proposed Namibian Environmental Management Bill and those principles and processes outlined in the MCC Environmental Guidelines. Minor gaps identified between MCC guidelines and the Namibian environmental management policies are discussed below.
Without actual or draft 2007 EMB implementing regulations one must utilize the 1995 draft policy to cross reference specific elements of the MCC Environmental Guidelines with those required by the GON. In doing so, the environmental procedures, content of environmental documents, review procedure, list of activities/projects necessitating EIA review, and requisite level of documents are relatively aligned.
Currently, the MET relies largely on voluntary compliance with environmental management policies, including the development of EIA and Environmental Management Plans (EMP). No legal requirement, other than draft policies, yet exists to require the preparation of an EIA. While voluntary compliance appears to be strong throughout the country, there is no mechanism for compliance validation or enforcement of these policies. It appears that external donors are a stronger force for implementation of comprehensive EIA practices than are the requirements of Namibian environmental policy.
Recommendations: As the Namibian Environmental Management Policies are in draft form and staffing of the DEA is pending approval of the proposed 2007 EMB, it is strongly recommended to include passage of this Environmental Management Bill by the Namibian Parliament and signing by the President as a Condition Precedent to Disbursement for the Tourism Compact. In addition, it is recommended that, at a minimum, DEA staff be appointed to administer provisions contained in the 2007 EMB. These two conditions are essential to move Namibian environmental management policies out of a period of voluntary compliance into a period of oversight, regulation and enforcement. Only through enacting formal legislation will there be a tightening of environmental procedures and policies.
A.2. Do requirements exist in the country for ESIAs, environmental analysis, and environmental management plans, and if so, what are the determining factors?
General Discussion: As stated above, Namibia currently operates under a 1995 Draft Environmental Management Policy, and is poised to enact a new comprehensive Environmental Management Bill. This proposed bill, if enacted, provides a strong policy framework for ESIA review of proposed projects.
Several Environmental Management Plans (EMPs) were reviewed during the in-country mission. EMPs are essentially implementation plans which follow completion of appropriate EIA documentation. Insufficient documentation was available to determine whether issues and environmental concerns developed during the EIA process where brought forward into corresponding EMPs.
A key stage in the Namibian EIA process is project screening at which time a significance determination is made. This determination is based on responses to the 14-page questionnaire provided by the project
5 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment proponent and some undetermined level of review within the DEA. The significance determination, as are the MCC Environmental Guidelines, is based on a list of example projects with the potential to cause significant negative environmental impacts due to their type, location, sensitivity and scale.
Findings: Based on the Environmental Management Plans reviewed during the due diligence mission, adequate coverage of the environmental, social and ethnic concerns are brought to bear during project implementation.
Indications point to a significance determination based on the type of activity and not on predicted project impacts to critical resources. Utilization of a “project schedule” during the screening phase to determine significance downplays the importance or the potential of projects to take into account site-specific impacts to sensitive locations throughout Namibia. Sensitive locations are easily identified within Namibia. Examples identified during field visits include: o Wetlands & flowing water o Ephemeral stream courses and their aquifers o RAMSAR sites or certain IUCN Categories o Proposed World Heritage Sites and World Biodiversity Hot Spots o Mountainous ecosystems o Archeological sites and Monuments o Sites of local endemism o Pan Systems o Sossusvlei Region
Through the development and use of sensitive locations, which aid the determination of significant impacts, reviews can also more effectively understand and account for thresholds of unacceptable impacts. Threshold of unacceptable impacts are, at best, difficult to determine based on a “project schedule” list.
Recommendations: Without careful consideration of sensitive habitats and locations it is difficult to predict the context and intensity of impacts for each action. It is recommended that MCC request the GON incorporate in regulations the importance of site-specific sensitive locations into the environmental screening process for determining significant project impacts as well as the requirements for documentation in the EIA process.
A.3. What is the process and timeline of the ESIA review?
General Discussion: The proposed 2007 EMB establishes an environmental assessment process framework (Part VIII) and provides for the establishment of implementing regulations (Part X, 56). Though the proposed 2007 EMB does not include a process flow chart, based on discussions with MET Staff and the Permanent Secretary, the process is expected to be similar to that displayed in the 1995 Draft Environmental Policy and displayed in Environmental Impact Assessment in Southern Africa (SAIEA, 2003). (See Figure 1)
Timing of an individual project being regulated through an EIA process is based on a number of factors. These include, but are not limited to location, scope and complexity of the proposal, availability of site- specific environmental and social data, availability of contractor support to acquire data and documentation, etc.
Findings:
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Key legislation and process, building on the status of existing policies and processes, appear poised to be enacted by the GON. The 2007 EMB, 14-page Questionnaire, and pending regulations provide a strong environmental management policy and framework for projects and activities proposed in Namibia.
Recommendations: Consider as a Condition Precedent to Disbursement for the Tourism Compact the development of a working draft of implementing regulations for the 2007 EMB which reported is already under development. It is reasonable to expect that final approval of such regulations will take time and careful scrutiny, yet a working draft will enable the GON to administer and enforce the legislation. The 1995 draft policy provides a good point of departure to begin development of these implementing regulations.
A.4. Do existing environmental requirements include social impact assessment?
General Discussion: Without actual or draft 2007 EMB implementing regulations it is difficult to determine actual requirements for social impact assessments (SIA), though there are several indications that lead one to conclude that inclusion of an SIA, as appropriate, will become common environmental practice in the GON.
The proposed 2007 EMB includes several principles which guide the inclusion of social issues in the ESA process. They include:
Part II, 3 (2)(d) equitable access to environmental resources must be promoted and the functional integrity of ecological systems must be taken into account to ensure the sustainability of the systems and to prevent harmful effects;
Part II, 3 (2) (g) Namibia's cultural and natural heritage including, its biological diversity, must be protected and respected for the benefit of present and future generations;
Part II, 3 (2) (b) community involvement in natural resources management and the sharing of benefits arising from the use of the resources, must be promoted and facilitated;
Under the 2007 EMB, the term “environment” is defined to include both the natural and human environment. The later is defined to include cultural, historical, aesthetic, economic and social heritage and values.
A “significant effect” in the proposed bill means having, or likely to have, a consequential qualitative or quantitative impact on the environment, including changes in ecological, aesthetic, cultural, historic, economic and social factors, whether directly or indirectly, individually or collectively;
The 14-page “Screening Questionnaire for Projects” in its current form includes several questions addressing land use, land and property, and wider social considerations. As stated previously, the status of this document and its use under the proposed 2007 EMB is unclear. One could reasonably assume that a screening process using this document, or a questionnaire of similar format would remain in use.
A schedule of listed of projects subject to the proposed 2007 EMB includes “land use planning and development activities” which include rezoning and resettlement schemes. Projects of this nature under the proposed bill would be subject to an EIA review, and by inference, require a SIA.
EIA and EMP examples provided during the mission include social issues and social impact assessment elements.
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Findings: It is difficult to determine actual requirements for social impact assessments (SIA) without final or draft 2007 EMB implementing regulations. Having said this, the draft bill and several draft policies provide indications that inclusion of an SIA, as appropriate, will become common environmental practice.
One sample EIA document for a non-MCC proposed project was made available for review during the Due Diligence mission, the socio-economic assessment for the Kavango Biofuel Project. This report documents a strong socio-economic analysis, including public consultation.
Recommendations: As recommended in Section A.3., consider as a Condition Precedent to Disbursement for the Tourism Compact the development of an implementing regulations working draft for the 2007 EMB, which would include requirements for social impact assessments.
B. Environmental Screening
B.1. Is the Project likely to cause a significant environmental, health, or safety hazard as defined in the MCC Environmental Guidelines?
General Discussion: During the first due diligence mission, numerous sites proposed for inclusion in the tourism compact were visited . All of these sites centered on the North-East Parks area. An element of repetition was including during these field visits – that is, several site specific locations were visited for each proposal. For example, several locations of proposed park entry sites were reviewed. MCC decided that only a sample of sites representing a cross-section of the proposed project investments in northwest Namibia should be visited during the second due diligence mission. Some of these sites were visited; however, several of them were not because the field trip ended earlier than anticipated. For this report, the element of redundancy is used to make determinations on whether individual proposals have a likelihood of causing significant environmental, social, or health effects, safety hazards, or may be identified as sensitive sector projects by the MCC Environmental Guidelines.
Each site visited was reviewed for a variety of environmental, social, health and safety issues and effects. See Appendix VI for a partial list used during the due diligence mission. In addition, projects were reviewed using the MCC Environmental Guidelines list of sensitive sectors and sensitive locations.
Findings: In general terms, projects proposed in the tourism compact posed minimal to low environmental, social, health and safety risks. Individual projects or locations where concerns arose are detailed below. Of greater concern than individual projects is the cumulative effect of these projects and the potential for a gradual movement of rural based economies to more semi-urban economies and lifestyles. Beyond these concerns, the Namibian ESA screening process, EIA development, and the subsequent EMPs are expected to adequately address impacts discussed below..
It is important to note that many project locations within the compact have yet to be identified or are subject to change based on continued refinement by the Namibian Millennium Challenge Account (MCA) Team and results of this due diligence review. Therefore, this review should be considered a pre- feasibility review. As such, the results of this ESA review should be taken in context with the resulting changes to proposed projects. Having said this, the scope of the activities is anticipated to remain
8 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment relatively constant, as are the site-specific locations and cumulative impacts which may warrant future EIA review.
Omega1 & Begoni Block: There are at least 10 villages, 2000 permanent and 6000 transient residents in Bwabwata Park. This population, made up of Kwe San people and other tribal groups, is one of the poorest populations in the country. The proclamation of the national park will likely result in some of the population losing their cattle, or potentially requiring resettlement.
The Begoni block, located in the northwest corner of Bwabwata Park is receiving increased population and development, yet contains important riparian habitat on the east bank of the Kavango River. It is also being considered for the GON “green scheme” proposal which could create significant agricultural operations and corresponding infrastructure facilities, all of which could have significant and substantial environmental (riparian) and social impacts. The west side of the Kavango River has already been severely impacted. This area has been proposed for deproclamation.
The Omega1 enclosure within Bwabwata Park is a former military base that has received a steady increase its population. It includes an airstrip, cell phone tower, and large cattle population with veterinary issues. This area is proposed to be declassified / degazetted, but no official GON decision has been made. The present population is a mix of cultures. Issues are complex regarding this area, particularly fencing and social issues.
Buffalo Military Camp: As it currently exists, this series of old military sites present a high environmental, safety and health hazard. This situation has existed for approximately 18 years. These sites are proposed “borrow sites” for materials to construct park infrastructure. MCC does not have adequate funding or cause to undertake reclamation of these sites.
High Value Game Breeding Camps: Concerns were developed during the mission that game camps could, according to the Social Assessment section of the MCA Proposal, potentially lead to “substantial land take” from conservancies and tribes without prior buy-in, resulting in conflict, resentment and poor management activities. It is unclear whether proposed game camp sites are exclusively in conservancy lands already zoned for wildlife management actions, or if some of the game camp sites overlap with areas currently used for other livelihood activities that are incompatible with game breeding, such as grazing. If “substantial land takes” are necessary, resettlement plans and social impact assessments will be necessary, as the camps could take sizable areas out of traditional grazing practices and create the loss of other traditional uses. If not properly managed game camps can also lead to considerable habitat destruction. Environmental impacts may include habitat degradation and altering habitats through the exclusion of other native wildlife species.
Three of the proposed game breeding camps (also referred to as core management areas) are located at sites outside the boundaries of Etosha National Park to the north and northwest: Sheya-Shuushona, Orupupa, and Narawandu (to the east of Sheya-Shuushona, in an area that may be proposed for a conservancy). We did not visit any of these sites nor engage in any discussion about them with people in the field. Peter Gogan, wildlife biologist on trip 2, did visit Sheya-Shuushona and discuss all three proposed game breeding camp sites with people in the field. He notes in his trip report that the area north of the park in the Sheya-Shuushona Conservancy, where the proposed Sheya-Shuushona game breeding camp site is located, is currently being used for livestock grazing and contains some human settlements consisting of scattered bomas or kraals with huts and water points. If a game breeding camp is established in this area, it will require relocation of these settlements and provision of water at the new sites.
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Recovery of Natural Assets : The MCA Namibia proposal does not mention if any specific management interventions will be necessary by conservancies to maintain the increased wildlife populations envisioned in the “Recovery of Natural Assets” section. It may be that nothing is necessary and these animals can fend for themselves. However, if any management actions are needed, they should be detailed, either on a species or conservancy basis, and an assessment of the selected conservancies’ capacity to perform these actions should be provided.
Bush Access and 4x4 Viewing Tracks: These projects have yet to be clearly articulated or located in the proposal and therefore it is difficult to determine anything more than generalized impacts from their implementation. Bush access and 2-track imprints can last for years on the landscape. An increase in roads and 2-tracks can also increase the potential of lasting impacts from “self drive wandering”, potential wildlife harassment and changes to aesthetics. Impacts from bridge construction should be considered in this set of proposals. These projects have a medium to high environmental risk depending on their terrain and location. Many access routes should be considered (in the same EIA) as connected actions to lodge development and park infrastructure projects.
Fencing Proposals: Fencing of natural areas, parks, or conservancies whether for game camps, managing human-wildlife conflict, or control of cattle movement will undoubtedly have high environmental and social impacts, depending on the scale at which it takes place. These impacts will likely include interruptions of wildlife migratory patterns, interruption of livestock movements, increased vegetation impacts, increased need to develop water sources affecting the local area’s water table, as well as allowing management and upkeep of the fences to become an economic burden. These proposals remain vague at this time and need additional elaboration.
Tourism Information Hubs: One proposed tourism information hub site was visited in northwestern Namibia during trip 2, located on the Uibasen-Twyfelfontein Conservancy. A hub site has also been proposed for the Sesfontein Conservancy, but we did not visit that specific site. It came out in the discussion that took place at Uibasen-Twyfelfontein that one of the main motivating factors behind creation of the tourism information hubs from the conservancy perspective is to help mitigate negative environmental impacts associated with tourism. At least at Uibasen-Twyfelfontein, the tourism hub was viewed as a way of protecting natural resources, besides providing a few local employment opportuntities through craft sales, food and drink sales, etc.
The Uibasen-Twyfelfontein Conservancy is one of the most visited conservancies in northwest Namibia because it contains the Twyfelfontein National Monument. For example, we were told that 70,000 people per month came to visit the Twyfelfontein site during the high season months of August through November in 2005 (this seems very high – could be misinformation). Tourists come to see the San rock engravings and paintings at the Monument, which are estimated to be 2,000 to 6,000 years old, and occur there in one of the highest concentrations anywhere in Africa (over 5,000 figures have been documented). The site has been proposed as one of Namibia’s first UNESCO World Heritage sites. The high number of visitors that come to the conservancy each year to visit the Twyfelfontein National Monument has caused concern over their environmental impacts. Conservancy leaders said that they have virtually no control over the behavior of self-drive tourists who come onto their lands.
Torra Conservancy leaders also complained that they had no control over tour operators who come onto their lands and drive off-road, and #Khoadi //Hoas Conservancy leaders also raised the lack of control over off-road driving by tourists as a problem. The associated issues described by conservancy leaders we met with were: they cannot count how many tourists come onto their lands or keep track of where they go; and, self-drive tourists frequently drive off road across the landscape looking for tourism attractions, camp wherever they please, collect and burn fuelwood, and do not use toilets. These activities were said to have negative environmental impacts including unsustainable consumption of fuelwood
10 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment which is in short supply, environmental damage associated with uncontrolled driving off roads, and camping impacts. According to a newspaper article published in The Namibian while we were there, feces decompose very slowly in the arid environment of northwestern Namibia, meaning they stay around a long time, causing pollution and eyesores.
At Uibasen-Twyfelfontein, conservancy leaders want to locate the tourism information hub near the intersection of the main transportation corridor and the main access route to conservancy lands. Doing so would cause people who drive onto conservancy lands to necessarily pass by the hub. At the hub, they would have an opportunity to use toilets; be given information about where and how to camp with minimal environmental impact; and obtain maps or directions to where the tourism attractions are located so that they do not have to drive off roads in search of them. They believe that providing tourists with educational information at the hub will cause them to behave differently and do less damage to the environment when they are on conservancy lands. The conservancy would also record the number of visitors passing by the hub and where people are going on conservancy lands, giving them a better idea of visitation levels and impacts. In addition, tourists could obtain information about the sights to see on conservancy lands, perhaps becoming aware of sights they didn’t know about previously, causing them to stay longer, with potential added economic benefits.
Criteria for where information hub sites should be located that were mentioned during our visit include: sites where there is high tourist visitation; sites that could be part of a tourism circuit in the northwestern part of the country to facilitate marketing the hubs as a network and directing tourists along a route through different conservancies, the Kunene contractual park and concessions, and into Etosha; and locations close to main transportation corridors.
Managing Boundary Conflict: Wildlife populations on conservancy lands have been increasing through reduced poaching, conservation, and recovery measures in conservancies and adjacent national parks. Measures undertaken under the MCC proposal to recover natural assets are designed to further increase wildlife populations, which will potentially increase predator populations. One result of increased wildlife populations is greater human-wildlife conflicts. In northeastern Namibia these conflicts largely revolve around elephants that damage crops. In northwestern Namibia the conflicts revolve mostly around predators (e.g. lion, cheetah) that attack livestock. In the northwest, elephants also damage fences and water infrastructure. And in both locations, wildlife occasionally harm people.
The conservancies visited in the northwest have taken the initiative to come up with mitigation measures that address human-wildlife conflict. These include allocating a portion of the revenue generated from wildlife to be used for payments to compensate individual livestock owners who lose animals to predators; calling in professional hunters to dispatch problem animals; purchasing diesel for running water pumps at wells; purchasing livestock so that loaner animals can be given to families to help them restart herds; developing a predator monitoring system for early warning of potential attacks; and self- insurance schemes. All of these strategies have strengths and weaknesses.
Proposal 5 of the MCC Namibia Compact asks for assistance with managing boundary conflict through improved fencing and developing alternative wildlife water points. Managing boundary conflict is important because if communities are going to play a lead role in conserving wildlife, they need to have a way of managing associated conflict so that the costs of conservation are not too high, becoming a disincentive. Supporting efforts to manage human-wildlife conflict will have positive effects on human safety, livelihood security, human health, and wildlife conservation.
Unlocking New Lodge Establishment: MCA is requesting support for new lodge development on conservancy lands, and in areas in or adjacent to national parks. The lodges would primarily be developed through community/private partnerships with conservancies as the primary beneficiaries.
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Exact sites and conservancies where the lodges would be developed have not been specified, nor have criteria been established for their selection. According to the MCA proposal they would be established in areas that are prime tourism locations, and it was the strong opinion of MET that they should be established in places that have the greatest potential for success.
To date, tourist lodges have made an important economic contribution in some conservancies. They do this in two main ways: by creating jobs for local community members, and by paying a fee associated with the lease right on conservancy land. The fee is negotiated by the conservancy and private partner; in the lodges we visited, it was 10 to 15 percent of the bed levy.
During Trip 2, three lodges were visited on conservancy lands in northwest Namibia where discussions took place about the lodges, the benefits they have generated for conservancies, and associated issues. What emerged was a rather diverse picture of how the lodges have been established and the conditions under which they operate. This is illustrated by describing them below.
Namibia Country Lodges/Twyfelfontein Lodge: The Namibia Country Lodges/Twyfelfontein Lodge is located in the Uibasen-Twyfelfontein Conservancy, and is roughly a five-hour drive from Windhoek. There is an airstrip near the lodge; one can fly there in roughly 1.5 hours from Windhoek. The lodge opened in 2000 and is the first lodge that Namibia Country Lodges established in joint venture partnership with a conservancy. The experience has been a positive one for them, and they are now in the process of setting up two more joint venture lodges. This is an example of a successful community/private lodge partnership.
According to Willem de Wet, the conservancy gets N$700,000 per year in payments through its lease to Namibia Country Lodges (bed levy payments), and roughly N$100,000 per month(?) in other benefits, ie. wages. The lodge sleeps 140 people per night. Eighty people were employed during lodge construction, and 90 people are currently employed at the lodge – 80 percent of whom are conservancy members, or were referred by members. Apparently 99 percent of all revenue received by the Uibasen-Twyfelfontein conservancy comes from this lodge joint venture agreement. There are no hunting operations in the conservancy because they decided they did not want hunting there; they want to protect wildlife.
The Uibasen-Twyfelfontein Conservancy currently has 73 members. It is a small conservancy, being 286 sq. km. in size, and was registered in 1999. The dominant ethnic group is Damara. The conservancy is spending the money it receives from the lodge mostly on education projects – helping families pay school fees, helping improve facilities at existing schools, and building staff housing. They have also bought some vehicles for the conservancy, and are helping some herders who need food to buy food. Future goals are to build a health clinic and build a bridge across a river that periodically floods and limits visitor access to the lodge and national monument.
Palmwag Lodge: Palmwag Lodge is located in the Palmwag Concession, in the Sesfontein Conservancy. It is run by Wilderness Safaris. The Palmwag concession (one of the largest concessions in Africa, at over 5,000 sq. km.), borders Skeleton Coast National Park and the Sesfontein, Anabeb, and Torra conservancies. Palmwag has been managed for hunting and tourism for the past 30 years. The Palmwag Concession has been a 20-year concession term from the Namibian government, with Wilderness Safaris coming in at the end of the 20 years to take over the concession. The concession term is up this year and a new one is being negotiated, this time with the conservancies rather than GON because under the terms of the proposed Kunene contractual park, conservancies will be the direct beneficiaries of the concessions in northwest Namibia rather than the government.
Since taking over the Palmwag Concession, Wilderness Safaris has paid to lease the concession, and has also taken responsibility for land management in the concession in collaboration with Save the Rhino
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Trust, a NGO that has been working there for about 20 years. Wilderness Safaris invests roughly N$1 million annually in stewardship activities. In order to protect the long-term sustainability of the concession and operations there, they want the new concession lease to be long term (at least 20 years), because that provides more incentive for them to manage the concession for long-term sustainability. Now that the concession will be obtained from the conservancies rather than the government, the length of tenure is uncertain – conservancies appear to favor a ten-year term so that they can renegotiate at the end of 10 years. Currently, the cost of the lease rental is 10% of the revenue generated by lodge accommodations. The first recipient of this money is the Ministry of Environment and Tourism, with the 3 conservancies that border the concession also receiving a share of the profits. Currently, the Palmwag Lodge operates at a loss. However, Wilderness Safaris views it as a place where there will be future investment opportunities, and believes the lodge can be financially successful if there is investment in tourism development in the northwest associated with establishment of the Kunene contractual park. Insecurity of tenure limits their willingness and ability to invest in both sustainable land use and management inside the concession, and in lodge development. They would like to develop a new, high- end luxury camp in the concession that would be high value and low volume, and will do this if they get more secure tenure under the new lease.
Grootberg Lodge: The Grootberg Lodge is located on the #Khoadi //Hoas Conservancy. #Khoadi //Hoas was registered in 1998, is 3,366 sq. km. in size, and has about 2,500 members. Damara are the dominant ethnic group; Herero, Nama, San, and Otjiwambo peoples also reside there. The lodge opened in 2005. It is aimed at the mid-market. There are 24 beds. It employs up to 29 people.
What is unique about this lodge is that it is 100% community owned. It is the first community built and owned lodge in Namibia. A number of advantages to having a 100% community-owned lodge were pointed out by the conservancy manager: it involves communities directly in tourism, communities are empowered and have direct control over decision-making, communities get more economic benefits, they don’t have to work through the suspicion and lack of trust that often exists between them and the private sector, employment opportunities for community members are not limited to junior and mid-level positions, and they contribute to community self-sufficiency. A major problem with community-owned lodges, however, is that conservancies have even more problems than the private sector securing loans from banks. Not only do they not own land to offer as collateral; they don’t have money from other operations to invest, or other lodges as collateral, the way a tourism company might. Grootberg Lodge was built with grants from the European Union and MET. It serves as a model, or test case, for the potential of communities to own their own lodges from the outset.
The lodge is not completely without a private partner, however. A private management company (Ecologistics) was hired to be in charge of lodge management and has a five-year contract to do so. After five years, either the conservancy will take over management, or another contract will be negotiated. The contract stipulates that 15% of the lodge profits go to the conservancy. To date, the Grootberg Lodge has not turned a profit and the conservancy has not earned any money from it; it has been operating at a loss. This is because the lodge is new, it was unable to do marketing in advance of the first tourist season during which it was open, it is difficult for the community to get loans, and there were cost over-runs during construction because they had to use European engineers (required as a condition of the EU grant) whose construction standards were higher than what was necessary locally. The lodge has since done more marketing and business is increasing. We were told that in general it takes 3-5 years to start making a profit; thus having a short term contract isn’t attractive to partners.
The hope is that Grootberg will be one of an eventual chain of mid-market lodges that are community- owned in northwest Namibia. MET currently has plans to fund five new community lodges at roughly N$7 million each that would be part of this network, and marketed together. All would be 100% community-owned from the outset.
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This information led to a long discussion of the value of lodges established through joint venture community/private partnerships (the model MCC supports) in which communities can have an increasing ownership share over time, vs. GON/donor-funded lodges that are 100% conservancy-owned from the outset, in which the conservancy has not invested any equity. Questions were raised about whether the Grootberg model would create an unfair competitive advantage with the model MCC is considering investing in, which could undermine the viability of the former model; about whether the latter model can succeed; and about whether new lodge development following both approaches simultaneously would saturate the market. MCC pursued discussions on this topic during the rest of trip 2.
Specific findings on unlocking new lodge development:
Environmental Impacts: At the Palmwag Lodge we discovered that insufficient funds to invest in lodge development, maintenance, and improvements can have negative environmental consequences. There, Wilderness Safaris stated that it had not been able to afford investment in proper waste, garbage, and sewage disposal mechanisms. In addition, one wonders what the effects of new lodge development on water resources will be – this issue was not addressed during our visit.
Social/Heritage Impacts: A problem at the Twyfelfontein Lodge is that it was built on an inappropriate site. First, it is built amongst rocks that contain San engravings that are clearly important heritage sites. Second, the lodge is located on an important Damara cultural site that was used in the past for initiation rites. Namibia Country Lodges apparently did not realize this until it was too late (permission to build there was granted by the government, not the conservancy) and they are planning to adjust the access route to the lodge. This problem points to the importance of ensuring that a social impact assessment takes place prior to lodge construction.
There are numerous other social aspects of joint venture lodges that will require additional attention to minimize risk of failure of these MCC-supported investments. For example, conservancy members may have little to no experience with working in a structured and time-sensitive environment, and may have difficulty adapting to such environments. Lodge owners may also be unfamiliar with local customs, and may not understand how community events, such as funerals or births, may impede the ability of their employee’s to report to work. An additional consideration is whether conservancies will have adequate support to negotiate a fair deal with the private sector partner, for direct and indirect benefits from the lodge, as well as how to share these benefits amongst their members. One can envision a Code of Conduct guiding entry into joint-venture agreements between conservancies and the private sector that would address these and other issues, including how to resolve conflicts at water points near lodges between wildlife and livestock. The use of such a code of conduct, along with facilitated meetings between the conservancies and the private sector operators to clarify the basis for such partnerships, could reduce the possibility for misunderstandings and conflicts between all parties to these agreements.
Criteria for investment: A clear set of criteria for deciding where to invest in new lodge development has not been established by MCA Namibia. The sentiments expressed by several members of the Namibian contingent that accompanied trip 2 was that it’s best for MCC to support building lodges in places that have the highest potential for success, as opposed to places that are struggling the most to become financially viable and perhaps have a greater need, because if you can demonstrate some success stories, you can learn from them and use them as models that can attract investments elsewhere. Targeted investments to ensure that the model does work successfully are important, because then there are examples to draw on and learn from. Characteristics of conservancies and locations that have a greater likelihood of success are: they are located in a place that has major tourist attractions; they are located in a place that is accessible by a major transportation corridor in Namibia; they are located along a tourism circuit that contains a number of attractions, including a national park; and the capacity and skills exist or
14 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment can be developed to support them. More work is needed to identify criteria for site selection for lodge development.
Recommendations: As outlined in Section A.2. of this report, incorporate in regulations the importance of site-specific sensitive locations into the environmental screening process for determining significant project impacts.
Omega1 & Begoni Block: It is the opinion of the authors of this report that no MCC investment in this area should be dispersed until the GON formally decides on a process for addressing the area’s concerns. The recommended option of MCC should be to reclaim the entire area, including Bwabwata Mutliple Use Area, Begoni Block, Omega 1 Block and the Buffalo Area as a National Park. This includes removing the “green scheme” proposal from the Begoni Block. Subsequent to reclaiming the area, the GON should assess all management options available, and through an inclusive consultation process develop options for future management which protects resources (water quality, wildlife habitat, etc.), indigenous cultures (Kwe San and others) and promotes continued implementation of the Kavango-Zambezi Transfrontier Area concepts. A strong EIA and social impact assessment is mandatory for any activities proposed in these areas of the Bwabwata Park. See Appendix II for more complete treatment of this subject.
Buffalo Military Camp: It is recommended that MCC funding should not be utilized to reclaim these military posts beyond the reuse of construction materials.
High Value Game Breeding Camps: Game breeding camps typically cover an area of 100 to 200 sq. km. and are enclosed by a game-proof fence. This is a large area, implying potentially significant impacts on livestock herders. Each proposed game breeding camp should require a full and comprehensive EIA, including a detailed social assessment.
In addition, it is essential that conservancy/private partnerships are highly participative at the local level, are closely monitored to ensure equitable income distribution, and that proper management practices are employed.
Fencing Proposals: It is recommended that MCC ask MCA Namibia to reassess the entire fencing strategy as proposed and present a more detailed proposal. Strong consideration of the net environmental, social and economic benefits should be undertaken. This assessment should be conducted for each individual fence proposed, or if part of larger connected action such as game parks, assessed as a whole in an EIA.
Tourism Information Hubs: If the Uibasen-Twyfelfontein information hub site we visited is indicative, the tourism information hubs should have positive environmental effects for conservancy lands as a whole. They should also have positive safety impacts because they would presumably help keep tourists from getting lost and inadvertently driving to dangerous places, and help conservancies track how many people are on their lands and where. They could also serve as emergency help centers. These benefits are in addition to those associated with providing additional income-earning opportunities for a small number of people who would be employed there, or run small businesses there; providing an information service to tourists; and helping direct tourists to conservancy lodges and campsites, promoting use there. They would provide a valuable service in a number of ways and are a good idea in our opinion.
Site-specific social and environmental impacts associated with where a hub site is established should be assessed prior to construction, following existing country practices and regulations for ESIA. A plan for how to maintain basic health and cleanliness standards at the hubs – ie. at restrooms and any cafes – should be included.
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The MCA Namibia document containing responses to tourism sector due diligence questions notes that Twyfelfontein is a high priority site for a tourism information hub. Uibasen-Twyfelfontein meets all of the above-mentioned criteria for where a hub should be established. Because the Monument site draws a high number of visitors, and access to two other tourist attractions (Organ Pipes and Burnt Mountain) also occurs through this Conservancy, a tourism information hub would be appropriate here. It should be noted, however, that the Twyfelfontein National Monument has an excellent visitor center not far from the proposed site, so services should be complementary, and small business establishment at the hub might experience some competition from the visitor center.
Managing Boundary Conflict: There is already a collaborative process in place that is being piloted in the northwest in conservancies adjacent to Etosha National Park (e.g. Ehirovipuka) in which conservancies, MET, and other stakeholders work together to develop Human-Wildlife Conflict management plans that are appropriate to the specific circumstances of each conservancy. The plans lay out strategies and activities designed to manage conflict. Disbursement of funds to individual conservancies through MET to support managing boundary conflict should be predicated on the existence of a Human-Wildlife Conflict management plan and be linked to the strategies and activities outlined in the plan, as appropriate. Because these plans are collaboratively developed between conservancies, MET, and other stakeholders, they presumably reflect best thinking about how to address conflict in specific places, taking into account any potential negative impacts associated with activities such as construction of fences and alternative wildlife water points. MET is drafting a new human-wildlife conflict management policy, which we have not seen. The policy should be consulted to learn more about how investments in this area can be made most appropriately.
Unlocking New Lodge Development: MCC investment in joint-venture lodges, that are essentially partnerships between private tour operators and conservancies, offer an exciting opportunity for conservancies to benefit directly from tourism on or adjacent to their lands (in national parks). Conservancies with existing joint-venture lodges, such as the Mayuni and Uibasen-Twyfelfontein Conservancies, have received substantial direct benefits from these partnerships, as well as indirect benefits in the form of employment for conservancy members and increased demand for goods and services provided by conservancy members. Additionally, the idea put forth in the MCA proposal to utilize MCC investment to provide conservancies with equity funds that will help offset construction and lead to conservancy share-holding in the operations should be supported. If approved this component of the MCC investment should be accorded adequate flexibility to make decisions about amounts of investment capitalization and equity on a site by site basis, and perhaps to even allow conservancies an opportunity to purchase shares in existing lodges on or adjacent to their lands. Finally, judging by the Environmental Management Plan for Xamsa Camp on the Nyae Nyae Conservancy, the environmental aspects of lodge construction are being carefully studied and appropriate plans are being developed to ensure that new lodges will be compatible with their environments. Environmental and social impact assessment should be conducted to ensure that lodges are established in ecologically and socially appropriate places.
To accompany the MCC investment in joint-venture lodges, MCA Namibia should commission the elaboration of a “Joint Venture Code of Conduct” as well as designate actors to work with all parties to disseminate this code of conduct.
It should be noted that widespread incorporation and use of the Federation of Namibian Tourism Associations (FENATA) Good Practices Handbook could substantially reduce the environmental footprint of lodges and ancillary structures. Standardization of this Handbook in the tourism industry should be encouraged.
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The fact that GON is pursuing and supporting the Grootberg model of grant funding to support 100% community lodge ownership from the outset clearly raised a red flag. We defer to the economists to address this issue.
B.2. Is the Project in a sensitive sector? (Suggestive list is included in the MCC Environmental Guidelines)
Refer to Section B.1. of this report.
B.3. Will any of the Project activities be located in or near any environmentally, socially, or culturally sensitive areas? (Suggestive list included in the MCC Environmental Guidelines.)
General Discussion: As highlighted in Section A.2. of this report, a list of example projects is used in the MCC Environmental Guidelines or the 1995 draft Namibia EMB to determine whether project activities are located in or near any environmentally, socially, or culturally sensitive areas. The 1995 draft clearly states that this list “should be used to guide” the decision on whether a project requires EIA documentation. Using a sample list of projects avoids the need to review and make a determination for each project based on its potential to cause significant negative environmental impacts due to its type, scope, location, sensitivity and scale.
Findings: Without clarity in the MCC Environmental Guidelines or in the implementing regulations for the proposed Namibian 2007 EMB that the screening process should include a review of site-specific indicators of environmental, social or culturally sensitive impacts, it will be difficult to ensure that proposed projects will have adequate ESA review and documentation. Equitable benefit distribution within conservancies remains a high social issue given the potential for increased tourism activities.
Recommendations: Refer to Section A.2. of this report.
B.4. What is the environmental screening category determination, in accordance with MCC Environment Guidelines (provide screening category justification)?
General Discussion: Without actual or draft 2007 EMB implementing regulations the response to this question must rely on the 1995 draft policy. The proposed 2007 EMB itself does not articulate screening category determinations or identify a level of EIA review required for individual projects types. The 1995 draft policy includes such determinations and its process is detailed schematically in the Environmental Assessment Procedure flow chart (Figure 1).
Having noted this, the 1995 draft Namibian policy does not utilize the same environmental classification scheme as detailed in the MCC Environmental Guidelines. The 1995 draft policy references a “go / no go” determination made regarding the need for documentation in an EIA. Said differently, the MET can decide that an EMP can be drawn up without a full EIA when a project is not expected to result in significant negative environmental impacts.
The 14-page “Screening Questionnaire for Projects” produced by the DEA which is completed by the project proponent, includes a strong element of the “honor system”. The detail provided in this document
17 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment could range from simple yes/no responses to more detailed explanations. This wide variation in responses may leave an incomplete picture of projected impacts from which the DEA has to determine the degree of effects.
Findings: Key legislation, building on the status of an existing environmental management framework, appears to be ready for enactment. The 2007 EMB, 14-page Questionnaire, and pending regulations provide a strong environmental management policy and framework for projects and activities proposed in Namibia. Having said this, the draft bill and draft policies provide indications that the category determinations will be in alignment with those of the MCC Environmental Guidelines.
It is fair to say that most environmental and social impacts directly result from the site selection phase. For this reason, the environmental screening process is critical. Operating under the assumption that all proposed projects will undergo an environmental screening process similar to that described the 14-page Questionnaire and outlined in 1995 draft policy, it is reasonable to predict that each project proposed in the tourism compact will have an adequate determination on its required level of documentation sufficient to disclose and assess significant environmental, social, health and safety impacts.
Recommendations: Consider recommending to the DEA that the proposed 2007 EMP implementing regulations include a more detailed environmental classification scheme which will remove inconsistencies with and more closely parallel those articulated in the MCC Environmental Guidelines. As an alternative MCC may want to consider that each proposed project complete an MCC approved screening questionnaire to determine whether a more detailed EIA review is warranted than what would be required under Namibian Policy. MCC could easily develop such a questionnaire based on due diligence reviews.
C. Environmental and Social Impact Assessment
C.1. What kind of environmental review will be required for the activities based upon country requirements?
Findings: In general terms, proposed projects of the tourism compact posed minimal to low environmental, social, health and safety impacts. As such, it is expected that this set of projects are unlikely to have adverse environmental and social impacts and will likely be “categorically excluded” from documentation and review in a full EIA. Individual projects or locations where concerns arose are detailed in Section B.1., Findings, of this report. Beyond these concerns, and not withstanding issues outlined in Section B.4., the Namibian ESA screening process, EIA development, and the subsequent EMPs are expected to adequately address environmental review concerns and any potential impacts.
Based on the strong working relationship between private contractors and NGOs with the GON capacity to complete the ESA process for projects proposed through MCC funding is expected to be high. Namibia has a strong presence of well qualified ESA consultants, including members of the Southern Africa Institute for Environmental Assessment. The ability to complete quality ESA documentation is not expected to be a hindrance.
C.2. What kind of environmental review will be required for the activities based upon MCC requirements?
Findings:
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There is a close parallel in the environmental screening and review process between the MCC Environmental Guidelines and those detailed in the 1995 draft policy, and those expect to arise from the proposed 2007 EMP (see Section B.4., Findings.). As discussed, MCC Environmental Guidelines utilize a more detailed environmental classification scheme than the 1995 draft Namibian policy. This more detailed classification scheme is not anticipated to result in hidden or unaccounted for significant environmental or social impacts not found under Namibian policy.
Recommendations: Refer to Section B.4, Recommendations, of this report.
C.3. What environmental analysis has been conducted on the Project(s) to date, including any existing or related Environmental and Social Impact Assessments (ESIAs)?
Findings: In northeastern Namibia, an extensive “Draft Infrastructure Assessment & Initial Proposals” report was completed for the Bwabwata, Mudumu and Mamili Parks proposals by Caprivi Parks Consultants Infrastructure Team (Ed Humphrey). This 44-page report and supporting materials, though not considered or intended to be an EIA document, does include useful descriptions of proposed projects, activities and connected actions. It does not contain environmental impact discussions.
In northwestern Namibia, a regional conservation assessment is currently underway in the Kunene region by Round River Conservation Studies (a non-governmental organization based in Salt Lake City, Utah) and Save the Rhino Trust. Although not originally designed for this purpose, the assessment will help support development of the Kunene contractual park and its management, and land use planning activities in the area. It includes a social assessment component. See http://www.roundriver.org/kunene/html for more information on the assessment, which should eventually be available in draft form through MET.
Several EMPs were reviewed during the mission (See documents list, Appendix X). These EMPs contain practical measures that must be implemented to ensure that potentially negative impacts upon the environment (ecological and social) are minimized or completely avoided. No EIA documents corresponding to these EMPs where discovered or available during this due diligence review. Generally this is due to the MET determination that the EMP could be developed without a full EIA because the projects were not expected to result in significant negative environmental impacts.
Other than these documents, no actual EIA documents were identified or available for review for the projects identified in the proposed tourism compact.
Recommendations: Should MCC desire to track and monitor compliance with MCC Environmental Guidelines, EIA environmental screening, and documentation for individual projects in the tourism compact, consider including a requirement to have MCA-Namibia submit the relevant documents, when completed, for each approved project. Utilize these documents to ensure appropriate environmental policy is adhered to.
C.4. If there has been environmental and social impact analysis undertaken, what is the quality?
Findings: As referenced in Section C.3., no environmental and social impact analyses were identified for the projects identified in the proposed Namibian Tourism Compact. Some of these projects are included as elements of regional tourism development plans or pre-feasibility studies, such as the KAZA pre- feasibility study. The Tourism Sector Due Diligence team has requested copies of these documents to
19 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment review their coherency with proposed MCC investments as well as the extent to which they include environmental and social impact analysis.
C.5. If there hasn’t, what is the process to accomplish the environmental analysis that will be required by the country and by MCC?
See responses to Section A of this report.
C.6. For existing ESIAs, what public consultation has occurred in the ESIA process and where and when will the ESIAs and component parts, to include Resettlement Action Plans, where relevant, be publicly disclosed?
General Discussion: The 1995 draft environmental policy declares that the environmental assessment policy, as far as practicable, will “strive for a high degree of public participation and involvement by all sectors of the Namibian community in the EA [EIA] process.” Additionally, it also requires, during proposal development, at the earliest stage possible the process it “notify neighbours and other interested and affected parties” of the proposal.
The proposed 2007 EMP has policy statements similar to those articulated in the 1995 draft policy as highlighted below
o Part I (2)(b) ensuring that there are opportunities for timeous participation of interested and affected parties throughout the assessment process;
o Part II (3)(2)(b) community involvement in natural resources management and the sharing of benefits arising from the use of the resources, must be promoted and facilitated;
o Part II (3)(2)(c) the participation of all interested and affected parties must be promoted and decisions must take into account the interest, needs and values of interested and affected parties;
Findings: No actual EIA or ESA documents were identified for projects detailed in the proposed Namibian Tourism Compact. As such, review of written public consultation results was not practical. Numerous conversations with MET staff, local conservancy management and members, ESA consultants, and NGO personnel highlighted an emphasis placed on Namibian environmental policies and practices regarding public consultation. It appears that the importance and value of public participation is widely accepted.
One sample EIA document for a non-MCC proposed project was made available for review during the Due Diligence mission, the socio-economic assessment for the Kavango Biofuel Project. This report documents public consultation and highlights issues developed during consultation.
Without implementing regulations the emphasis on public consultation in Namibian environmental policy is unclear and can only draw upon examples of past practice. A thorough review of Conservancy laws and policies may provide a more detailed perspective on some requirements for public consultation.
D. Health and safety
D.1. What Project-related safety issues exist to include potential impacts on occupational and public health and safety, including disease transmission and worker safety?
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General Discussion: Employment related health and safety issues were identified during the review of project proposals. A key health related risk is the transmission and spread of HIV/AIDS from a workforce aggregation supporting tourism lodges and facilities, and increased tourist traffic. The transmission and spread of HIV/AIDS could also be of particular concern if workers from outside the region or country are brought in to populate tourism and park infrastructure construction crews.
Child labor issues were not identified during the due diligence mission. Impacts to vulnerable indigenous groups may include changes to traditional religious and cultural practices. This is of particular concern for the San People.
D.2. Is the Project located in an area subject to natural disaster risk?
Findings: Several proposed lodge and camping sites reviewed during the mission are located adjacent to floodplains and wetlands. The possibility for flooding does exist. Probability of such occurrences is uncertain and would need further study.
Northwestern Namibia is extremely dry and at risk for drought, which – according to articles in The Namibian newspaper – is predicted to become more likely over the next 20 years with the onset of global climate change. The conservancies visited in the northwest receive about 100-150 mm of rain annually. This could have implications for water supply at prospective lodges, though water was not raised as an issue during our trip. The aridity of the climate in the northwest points to the importance of finding ways for communities to diversify their household economic strategies so as to be more resilient to the potential impacts of drought. In this regard, investing in tourism development is an important economic diversification strategy for a region largely dependent upon livestock herding. Drought affects wildlife movements, however, which in turn affect the viability of some wildlife-based development options, such as trophy hunting, shoot and sell, and tourism based on wildlife viewing. In the Torra Conservancy for example, conservancy leaders reported that wildlife move to the neighboring conservancy when drought occurs, affecting their trophy hunting program. Cooperative wildlife management and planning activities, and benefit distribution opportunities, between conservancies could help address this problem. Currently, five conservancies in the Kunene area of the northwest have formed a regional conservancy forum to address such issues as cross-boundary wildlife management.
D.3 Has the project incorporated design features for handicap access?
General Discussion: The “Draft Infrastructure Assessment & Initial Proposals” report completed for the Bwabwata, Mudumu and Mamili Parks proposals by Caprivi Parks Consultants Infrastructure Team mentions disability access only briefly. This is the only document encountered during the due diligence mission which discusses accessibility.
Findings: No disability or accessibility references in the 1995 draft policy or proposed 2007 EMP were identified. MCC requirements regarding reasonable accommodations are unclear.
There are private Safari operators (www.endeavour-safaris.com) which offer handicapped travel resources in Namibia for the disabled, deaf, blind, low vision, and mobility impaired traveler. These operators appear to provide niche marketing and the level of support for their operations by the GON is unknown at this time.
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Recommendations: Request any reasonable accommodations or disability access policies from the GON, and assess these documents against MCC requirements, if any. It is possible that some accessibly standards may be incorporated into design standards for MET structures.
E. Resettlement (project by project)
E.1. Does this project require any physical or economic resettlement, including temporary relocation or loss of access due to construction activities, for example?
Findings: There do not appear to be any proposed activities in the MCA Namibia Tourism Proposal that could lead to physical resettlement, with the exception of the proposed “High Value Game Breeding Camps” (see section B.1). Another possible exception is if current thinking for the proclamation of Bwabwata National Park changed to require resettlement of populations within the park, but based on policy and precedent in Namibia, this situation seems highly unlikely. We were told that the creation of Kunene Contractual Park explicitly does not entail any physical resettlement. A premise of the contractual park concept is that the stakeholders involved in developing the contract agree to its terms and conditions, through consultation with their constituents, and can escape from the contract at any time. Thus, if this park did entail resettlement it would in theory be agreed upon and negotiated by stakeholders.
The MCA Namibia tourism proposal has one proposed investment area that may lead to economic resettlement issues. According to the Social Assessment section of the Proposal, the proposed “High Value Game Breeding Camps” could lead to “substantial land take” from conservancy residents. This land take could in turn result in conflict, resentment and poor management. It is unclear whether these proposed game camp sites will be established exclusively in conservancy lands already zoned for wildlife management actions, thereby eliminating the potential for economic resettlement, or if some of the game camp sites overlap with areas currently used for other livelihood activities that are incompatible with game breeding, such as grazing. If “substantial land takes” are necessary, resettlement plans and social impact assessments will also be necessary as accompanying measures, as the camps could take sizable areas out of traditional grazing practices and create the loss of other traditional uses. However, until additional information is received from MET / MCA Namibia regarding the exact sites for these game camps, and their relation to conservancy zoning plans, it is impossible to provide a definitive answer.
The construction of fences and/or new waterpoints could also potentially lead to economic resettlement issues, particularly if grazing / farming areas are lost due to fence construction or prevented due to the presence of new wildlife waterpoints. However, the MCA Namibia proposal does not provide adequate detail about the proposed investment sites to determine what possible impacts these investments will have, if any, on existing livelihood strategies. The MCC Tourism Due Diligence Report pertaining to Section I of the Scope of Work provides multiple questions for clarification regarding the site selection and impacts of these fences and waterpoints. Once the Namibian side responds to these questions, additional analysis will be necessary to ascertain whether the proposed new fences / waterpoints will create any resettlement issues. Additionally, if the MCC livestock investment will lead to the relocation of the veterinary cordon fence to the north of Etosha Park, there may be important economic resettlement issues, particularly if the new fence is along the border with Angola and thereby limiting river access.
Finally, there are some specific economic resettlement issues that could originate from the proclamation of the Future Bwabwata National Park. See Appendix II for more information.
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Other proposal topics, such as the hubs, the service centers, the 4x4 tracks, the recovery of natural resource assets, etc. do not appear to have any possible physical or economic resettlement implications. The remaining resettlement due diligence questions, listed below, will be answered upon receipt of additional information from MCA Namibia / MET.
Recommendations: Seek additional clarification / information from MCA Namibia regarding site selection for game camps and fence / waterpoint constructions, to ascertain if any of these new facilities could create economic resettlement issues. If game camps conflict with current grazing areas, a more thorough analysis will be necessary to provide answers to the questions below and to ensure that any adverse impacts of the camps are mitigated and that conservancy residents are compensated for any losses.
Remaining Resettlement ESA Due Diligence Questions to be answered, if necessary, upon receipt of additional information from MCA Namibia / MET regarding potential impacts of Game Camps, Fences and Waterpoints
E.2. What are the country’s related regulations and safeguard process(s), and how do they compare to the World Bank’s involuntary resettlement policy or other similar internationally-accepted norm? E.3. What is the scale of resettlement: Number of people or households affected, and how many require actual physical relocation versus compensation for partial loss of land? E.4. How has the consultation on relocation been managed? E.5. How are processes for resettlement and/or compensation for public taking of land for public good conducted? E.6. How is valuation for compensation determined? Will it be paid in cash? How will it be delivered? Has a gender-disaggregated approach been considered in the disbursement of funds? If compensation is equivalent property, what is the status and process for obtaining land for the new property and formally recording rights to it? E.7. What is the policy towards people who are illegally on the land (i.e. do not have the title or other valid right of occupancy or use)? E.8. Are there Resettlement Action Plans or equivalent? E.9. Who in the government has overall responsibility for management of resettlement / relocation issues and managing the relocation and resettlement process?
F. Gender and Underrepresented Groups
F.1. What are the expected impacts on women and other underrepresented groups and what mitigation measures are considered?
General Discussion: The proposed MCC investment will provide opportunities for community conservancies and community trusts / associations to benefit from tourism investments and activities. The conservancies are grassroots organizations that are formed by interested community members and are governed by the provisions of the 1996 conservancy legislation for communal areas. Conservancies are open to all and are comprised of members of ethnic groups for the areas involved in each conservancy. Some conservancies, such as the Nyae Nyae Conservancy, are comprised of entirely one ethnic group speaking one home language, which in this case is San People speaking Ju/’hoansi. Other conservancies contain multiple ethnic groups speaking multiple languages, such as the !Khob !Naub conservancy with four home languages represented amongst its members. In general, the conservancies are excellent models for democratizing governance of natural resources, with elected officials sitting on committees, annual general meetings where decisions are taken, transparent financial management, management plans and existing constitutions. Given the large areas and difficulty in communicating with remote villages, as well as limited history or experience in collective management of common resources, the conservancy model provides an excellent example of fair and democratic decision-making and representation. See section 14.7 for a more detailed discussion of this model.
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Findings: Women and underrepresented groups fare reasonably well in conservancies. Although conservancy membership data are not readily available, membership in the conservancies visited in northwestern Namibia was reportedly about 50:50, male:female. As of January 2006, women comprised 37 percent of all conservancy management committee members, and according to USAID Namibia indicators, more than half of the conservancies have management committees with 25 percent or higher female members (WWF et al. 2006). Underrepresented groups, such as San and Himba peoples, are active members in some conservancies (e.g. Nyae Nyae and Orupembe, respectively), which provide them with revenue generating opportunities previously unavailable. No data are readily available regarding conservancy or management committee membership by ethnic group. By forming a conservancy, women and under- represented groups have a legal claim to managing their wildlife and participating in tourism actions, and have a strong voice that is supported by multiple NGOs working to represent their interests at the national level (NACSO, NNF, NACOBTA, etc.). Finally, as the conservancies are a relatively new concept, the youth in the ethnic groups involved in running conservancies play a strong role in both membership and management committees, at least in the conservancies we interacted with in NE Namibia. In the conservancies we visited in NW Namibia, one had to be at least 18 years of age to become a member.
The MET has also strongly supported the conservancy model, and is seeking opportunities to provide the conservancies with tourism benefits from joint venture lodges, game camps, etc. Numerous tourism operators, such as Lianshulu Lodge and Nyae Nyae Fly Camps support the conservancy model by entering into these joint venture agreements which are the most important source of revenue to date for the conservancies involved.
The conservancies have been supported to ensure not only full participation of members in decision- making, but also in natural resource management, financial management and benefiting from tourism revenues. Conservancies have received specific training regarding how to use wildlife resources, who to contractually engage as investors and partners, and how to use conservancy-generated benefits. In theory, each conservancy has developed an “Equitable Benefits Management Plan” that describes how conservancies will use tourism revenues, and is approved by all members. By supporting the conservancy model, the MCC investment will both build on and benefit from a strong foundation that has strived to provide full opportunities for participation to women and underrepresented groups.
However, there are some challenges that must be addressed to ensure that MCC investments in tourism activities involving conservancies continue to benefit women and underrepresented groups, and do not lead to unequal treatment, financial trouble, or other negative impacts. These issues are described in detail below, and range from degree of involvement of minority indigenous groups in conservancies to how to ensure proper capacity is built and maintained for conservancies to have a fair share in tourism ventures. At this early stage of the MCC Compact development, these issues are being raised so that additional information and clarification can be provided, and/or the proposed activities can be modified to address the concerns highlighted here.
Conservancy Membership: Under the conservancy legislation, no one can be excluded from conservancy membership on the basis of ethnicity or gender. However, given the history in Namibia of direct and indirect discrimination towards certain ethnic groups, such as the San People, the MCC should take additional steps to ensure that the conservancies it is supporting have provided ample opportunities for all residents of the area to participate and benefit from conservancy activities, should they so desire. Additionally, as new conservancies are developed, it will be important to ensure that underrepresented groups are being supported to develop conservancies or participate in fledgling conservancies, should they so desire.
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MET is currently making efforts to support tourism-related developments around Etosha National Park that would explicitly benefit the Hei//om San, who historically inhabited the area of Etosha. In the northeast of Etosha, some 250 San families live in a state of abject poverty. MET is developing an airport in the area (near Oshivelo) to facilitate tourism, and a joint venture lodge, that together would provide an estimated 120 jobs. In the southeast, MET is considering giving the San a concession where another joint venture lodge could be developed. MET is also trying to purchase some farms that border Etosha to the south, where the Heikom San could live and establish a conservancy.
Recommendation: Conservancies slated to receive MCC support with large numbers of underrepresented indigenous peoples in the conservancy boundaries should be studied to ascertain whether these peoples have the skills and abilities to join conservancies and play leadership roles in them, are adequately represented in conservancy membership, and if the distribution of benefits is indeed equitable to all members. Also, some analysis should be performed to understand reasons why residents of a conservancy area have chosen NOT to join a conservancy, assuming such populations exist. If these reasons are linked to ethnic or gender tensions / prejudices, than the MCC investment should be reevaluated. Finally, special care should be given to provide support (on demand) to underrepresented groups interested in forming new conservancies. For example, MCC may wish to target support to MET efforts that explicitly aim to develop tourism-related benefits for under-represented and indigenous peoples, such as the projects being developed to benefit the Hei//om San described above.
Training Issues: Component Four of the MCA Namibia Proposal, “Empowerment and Capacity Building,” does not adequately address the support needed by conservancies for participation in the proposed tourism investment activities. As discussed during the due diligence mission, additional capacity building support is needed to help conservancies develop skills for tourism enterprise management, entry into joint ventures, and equitable distribution of benefits. As currently written, the “Empowerment and Capacity Building” component is too focused on developing entrepreneurial skills for new small to medium enterprises. Additional detail is provided below on two examples where support and capacity building for conservancies will be necessary. This issue is of particular interest given the earlier than anticipated termination of the USAID-funded LIFE program. • Conservancy Management Capacity for Tourism Hubs: Conservancies will require support to manage the hubs, at least initially. Procedures will need to be developed to ensure minimum cleanliness and maintenance standards are implemented, especially in café and restroom areas. Clear guidelines for hiring and sanctioning employees, paying bills and maintenance costs, requisitioning new supplies, etc. will need to be established as well. What is unclear in the MCA Namibia Proposal is who will support the establishment of the hubs? The first due diligence mission led us to see that business management capacity of the conservancies varies, and it is inaccurate to think that every conservancy could easily assume the management burdens of running a hub. MCC should ask for clarification regarding how hubs will be supported to develop suitable management capacity. • Public Private Partnerships for Game Camp Management: It is clear that given the technical nature of raising high-value game, such as tsessebe and disease-free buffalo, conservancies selected for game camps will require support from licensed experts in game breeding. The conservancies will also need support from a third-party to negotiate the terms of these partnerships to ensure equitable stakes in the investment are secured for both sides, proportional to investment and level of effort in running these enterprises. MCA Namibia should either describe how this support will be provided to the conservancies, or provide a template for negotiating such partnerships based on existing experience. Training Recommendation: MCC should ask MCA Namibia to rewrite Component Four to include additional capacity building for conservancies to successfully participate in tourism enterprises, with attention given to how this training will be sustained post compact implementation.
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Land Tenure for Hubs: Hubs will ostensibly be built on lands granted by land boards to conservancies, and conservancies will receive some sort of leasehold / town planning permit to protect their rights. Additionally, the ownership of the hubs should logically be in the conservancies’ names.. A secondary issue to address is who is eligible to run a curio shop or café within the hubs? Must one be a conservancy member, or is any entrepreneur welcome? If it is an outside entrepreneur, will he/she have to employ / train conservancy members? Recommendation: MCC should request clarification of these two points from MCA Namibia so that tenure / ownership issues related to the hubs are clearly understood before investment begins.
Game Camps and Conservancy Benefits: Investing in game camps obviously creates an important and valuable asset that, if properly managed, could provide substantial benefits to the camp operators. However, experience from the management of similar camps in Namibia suggests that from the inception of such a camp to the point when benefits are first derived can take over five years. Additionally, while game breeding camps provide multiple options for conservancies to reap benefits, such as tourism, trophy hunting, and live sales, some of these uses are not compatible, and each use requires individual management actions and varying periods of preparation before benefits start to flow. Recommendation: MCC should seek clarification from MCA Namibia regarding what the principal uses of these five proposed game camps are, how these uses will provide benefits to communities, and how much time it is estimated will be needed to enable these camps to begin providing the anticipated benefits.
Bwabwata National Park: There are considerable issues surrounding the proclamation of the Bwabwata National Park that could have a negative impact on the Kwe San people, a local tribal group. See Appendix II for more information and our recommendations on this subject.
HIV/AIDS mitigation and prevention: According to the United Nations Programme on HIV/AIDS, adult HIV infection levels in Namibia are somewhere between 20 and 24 percent. Women bear a disproportionate share of this burden: they are more likely than men to suffer from HIV infection, and they are the prime caregivers to others who are infected. While there is no explicit mention of HIV/AIDS related issues in the January 20, 2006 version of MCC’s Environmental and Social Guidelines, increased risk of HIV/AIDS is generally associated with increases in tourism activities, and therefore this cross- cutting environmental and social issue needs to be considered. The Namibian Government has taken steps to increase awareness of the dangers and transmission vectors of HIV/AIDS, which were very visible during our field trips in the forms of informational posters, widely available free condoms, and “World Aids Day” T-Shirts. In addition to educating its own people, the MET and its private sector partners grouped at the future Tourism House should make these materials available to tourists. Some conservancies have chosen to invest a portion of their revenues in health services and AIDS-related programs. Thus, MCC tourism investments that lead to increased revenues for conservancies can increase the availability of funds for conservancies to invest in AIDS education, prevention, and treatment, should they so choose – thereby helping to mitigate against the potential increased risk of HIV/AIDS associated with tourism development. Recommendations: Conservancies have the power to develop their own benefit distribution plans and to determine how to invest revenues generated from wildlife utilization and tourism, based on community priorities. Outreach and education to make conservancy members well aware of the health risks associated with tourism development, and things they can do to reduce these risks, would be worthwhile and would help conservancies decide whether and how to invest in health services and AIDS education, prevention, and treatment. HIV/AIDS outreach measures should be continued with conservancies, MET staff, and foreign and domestic tourists. HIV/AIDS prevention materials should be available at hubs, park management facilities and the Tourism House. MCC should monitor national HIV prevalence data to ensure that the MCC investments are not accompanied by any significant increase in new HIV cases.
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F.2. Is there in place or is there a need for a specific participation plan to include women and other underrepresented groups (ethnic minorities, indigenous peoples, youth, etc) in project implementation?
Findings: Based on our understanding of the conservancy legislation and model, and participation of women and underrepresented groups in conservancies, there are adequate safeguards and plans in place, such as the Equitable Benefits Distribution Plans, to ensure that women and underrepresented groups are benefiting in a fair and transparent way from conservancy involvement in tourism and wildlife management activities. Therefore, there is not a need for a specific participation plan at this time to include women and other underrepresented groups in project implementation. Rather, there is a need to monitor the involvement of women, minority and indigenous peoples, and youth in conservancy activities, to determine if their participation remains strong.
Also, as mentioned above, there should be some analysis done to determine why certain segments of the population are choosing NOT to join conservancies, if such cases exist. If conservancies exist where substantial elements of the population are not part of the conservancy, be it certain groups or just sheer numbers of people, some consideration will need to be given about what actions need to be taken, if any, to ensure that the conservancy benefits “trickle down” to conservancy non-members. This would be particularly relevant if there are compelling social or cultural reasons that are discouraging certain segments of the population from joining the conservancies. It is possible that women, minorities, and indigenous peoples do not participate fully in conservancies for reasons relating to education and skills development. If this is the case, there may be a need for a specific training plan targeting women and other under-represented groups who would like to become more involved in conservancies, but lack the necessary training and skills.
F.3. How has the Project design factored in the concerns of women and other underrepresented groups (ethnic minorities, indigenous peoples, youth, etc.)?
See description of the Conservancy Model under Sections F.1. and IV.7.
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IV. Additional Terms of Reference Reponses
IV.1. Consideration on whether MCC should recommend that GON conduct a Strategic (or Sectoral) Environmental Assessment to inform selection criteria for tourism investments.
General Discussion: The MCC Environmental Guidelines define environmental social impacts to “include significant induced, indirect and cumulative impacts, and reasonably foreseeable effects that may be associated with or ancillary to the project.” Direct (induced) and indirect impacts are easily identified and assessed in project driven EIA documents. Cumulative impacts and reasonably foreseeable effects, though often more difficult to grasp conceptually, can also be accomplish at the project level.
When governmental organizations propose policies or programs which have far reaching impacts, both positive and negative, the assessment of potential cumulative impacts and reasonably foreseeable effects has historically been minimized, ignored, or are accomplished when the timing of such an assessment can have minimal value to critical policy and planning decisions.
The GON, through funding of the proposed MCC Tourism Compact, is poised to make a series of seemingly small, sequential and iterative decisions related to tourism, natural park and game management infrastructure. Tourism is depicted as a dynamic and fast-growing sector in Namibia potentially having rapid growth over the next 5 – 10 years, particularly in the Caprivi region. Much of this growth is predicted to be private sector driven. The effects on the social and biophysical environment, including contribution to economic growth and poverty alleviation, are noteworthy. Yet the GON is on the verge of making these decisions with a level of information that is strong at the project level, but relatively lacking at the programmatic level in both qualitative and quantitative data and analysis.
Though impacts are voiced as currently being widely dispersed across the vast Namibian landscape, without a thorough programmatic review of all project proposals, there is little possibility of an early warning of cumulative and potential large-scale environmental and social impacts of implementing the compact in its entirety, or of including the impacts of the compact together with other GON and donor driven projects in the tourism sector.
Strategic environmental assessments: (a) provide broader environmental vision; (b) ensure early consideration of environmental issues; (c) anticipates environmental impacts; (d) facilitates environmentally-oriented chain of actions; (e) provides for the incorporation of adaptive management strategies; and (f) contributes to integrated policy-making and planning. Simply said, strategic environmental assessments address the environmental implications of decisions made above the project level.
Findings: It is proven that, through tiering and incorporation, strong strategic level impact assessments can reduce the time and effort necessary to consider cumulative impacts in each subsequent individual project EIA. In addition, with many projects having minimal to low environmental impacts, it is likely that a substantial number of projects will receive waivers from full documentation and analysis in an EIA. As such, a full and comprehensive assessment of the cumulative impacts of these projects and activities will not take place without a strategic environmental assessment.
The due diligence review identified numerous “strategic-esque” plans and assessments. Many of these have adjacency and overlap. These plans and assessments include many useful components for a strategic environmental assessment, including location specific data, land use zoning, work plans, and monitoring plans. A sample of these plans and assessments are identified below. o Bwabwata, Mudumu and Mamili Parks (BMM) Socio-Ecological Study (92-93)
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o Caprivi and Kavango Parks Vision (1998) o Namibian National Tourism Plan (2002 – 2006) o BMM Draft Infrastructure Assessment and Initial Proposals (2007) o Vision 2030 o Kavango-Zambezi Transfrontier Conservation Area Pre-feasibility Study as well as neighboring countries land use and tourism master plans o Selected regional tourism master plans (e,g, northwest & southern regions) o 36 of 50 Conservancies have some level of management plans
Recommendations: It is expected that based on the number of plans and assessments currently completed, that the much of the initial data required for completing a strategic environmental assessment will be readily available. For the reasons articulated above, it is strongly recommended that MCC require the MET to complete regional level strategic environmental assessments to assess what is now a relatively uncontrolled tourism and planning movement. Namibian funding for a strategic assessment will likely be lacking and MCC should consider funding these assessments in regions where MCC funded projects are proposed.
At a minimum, the GON should determine how this patchwork of management plans should be synchronized to facilitate the wise use of its resources.
IV.2. Criteria for Selection of Conservancies to Receive MCC Investment
Findings: Based on field reviews during the due diligence mission, positive benefits to conservancies and their members in the form of job creation, income generation, natural resource management as a direct and indirect result of tourism enterprises are noticeably high. The link between tourism investment within conservancies and poverty alleviation is direct. The MCA proposal includes numerous projects identified which will bring investment into select conservancies. These include joint venture lodges, game camps, trophy hunting, tourism hubs and associated local enterprises, and wildlife reintroduction.
Unfortunately, the MCA Namibia Tourism Proposal does not address in adequate detail the selection criteria for choosing which conservancies will benefit from these investments. Objective selection criteria are of the utmost importance to ensure social and ethnic justice. Selection criteria should focus broadly on natural resource, social, economic, and management considerations. Selection of project locations which receive MCC investment can also be aided by development of a strategic impact assessment.
Recommendations: MCA Namibia, in concert with MET and other partners (NGOs), must develop a set of clear, objective and transparent criteria for selection of which sites and locations, and ultimately which conservancies, will receive MCC investments. The status of trusts and associations should also be considered in these criteria. There are many factors by which the MCA Namibia could judge the eligibility of a conservancy for MCC investment, such as:
• Number of Members • Geographic Representation • Male / Female Ratio • Wildlife Populations • Financial Performance • Financial Self-Sufficiency • Experience with Tourists • Business Experience • Completed Management Plan • Protection of Indigenous Peoples • Proximity to Parks
These and other characteristics of the conservancies must be studied to develop clear criteria for selection of conservancies to benefit from MCC investments. The selection process will help ensure that the investments are viable and funds are properly managed, but will also ensure that selected conservancies
29 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment can adequately represent their needs and objectives in a business partnership so that benefits are distributed equitably. Finally, if the conservancies being considered for investment happen to have large populations or certain segments of the population that are underrepresented in the conservancy membership, the MCC should study how the conservancy investment will impact (or fail to impact) these groups, and what action should be taken to remedy that situation, if any.
IV.3. Consideration of National Park Management Plans
Findings: Meetings with MET staff in Windhoek and during field reviews included discussions on National Park Management Plans. Few Namibian national parks have complete or comprehensive management plans. Nor has MET instituted a policy and template for developing such plans. Management plans are imperative to guide implementation of management activities and ensure that individual park natural resource attributes and objectives are attained. It is important to note that simplified management plans are practical to complete in a relatively short timeframe.
Recommendations: Consider a Condition Precedent to Disbursal mandating MET to develop a template (format), policy, and timetable for development of national park management plans within the first 1-3 years of the compact. Priority should be given to those parks which are to receive MCC investments. All park management plans should include road management plans to guide road use, development and maintenance.
IV.4. Kunene Contractual Park
Findings: In the Kunene area of northwestern Namibia, GON is looking for support from MCC for tourism-related developments in the proposed Kunene contractual park, including lodges and tourism information hubs. The proposed Kunene contractual park is located between Etosha and Skeleton Coast national parks and would connect the two parks, include the three concessions that exist in the region, and six conservancies. The area has high conservation value because it contains a population of over 100 free-living black rhinoceros, large populations of desert elephant, floristically rich and unique vegetation characterized by savanna elements that have invaded the desert, a high rate of endemism, ecosystem connectivity between the Skeleton Coast and Etosha, and high biodiversity value. Tourism potential in this region is high because of the biological and landscape features found here, and its location between Etosha and Skeleton Coast National Parks. Other activities such as agriculture and mining have low economic potential, largely because valuable minerals do not occur here and rainfall is low (0 at the coast up to 300 mm/year as one moves east).
A concession is a lease of right to conduct tourism exclusively in an area. There are 3 concessions in the Kunene contractual park area: Palmwag, Anabeb, and Etendeka, which together total 650,500 ha. The concessions are located on communal lands but came under government control at Independence. The terms of the current concessions expire in 2007, so discussion is now underway about what the new terms will be. Under the contractual park arrangement, the Ministry will award concession rights to conservancies who can then enter into subsidiary agreements with private partners if they desire to run tourism and management activities in the concessions.
This is the most ambitious contractual park proposed for Namibia. A contractual park is different from a national park because it is based on a contract between the Ministry of Environment and Tourism and local community representatives, with communities setting some of the conditions for park establishment. The contract outlines the roles and responsibilities of different parties, and management principles. A technical committee having multiple stakeholders is working out how to address community concerns about park establishment. The committee has identified issues, and ways to address them. Key principles guiding the development of the contractual park are: 1) conservancies should be the primary beneficiaries
30 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment of the concessions in the park; 2) park management should take place through a comanagement/joint management approach between the government and the conservancies; 3) the park should not undermine traditional leadership authorities; 4) the contract should specify the relationship between the park, conservancies, and communities regarding park management; and 5) the contract can be terminated by either party if behavioral obligations and park objectives are not met. So far, some conditions of park establishment that have been identified are: there will be no fences, boundaries will be established in a negotiated way that accommodates human needs, there will be compensation for livestock lost to predators, no one will be resettled, emergency grazing opportunities in the park will be allowed, there should be maximum benefit sharing with conservancies from joint park management, and there will be training and skills development. A draft contract for the park has been developed and presented to stakeholders and their constituents for consultation to determine if it is acceptable, and all parties can agree on it. This is the current stage they are at in the process.
Leaders from the Anabeb and Sesfontein conservancies offered their views to us on the contractual park. At first the communities were opposed to the idea; they feared the model would be like that of Etosha, which prohibits grazing and most human settlement. They have been conserving wildlife on their lands for a long time (conservancies were pioneered in this region), and were worried that they would be penalized for it because the government would decide that their lands, rich in wildlife, should be taken over and designated a national park – undermining the incentive to conserve wildlife. However they understand now that a contractual park model is different, and will accommodate their needs; they have had to build trust. They support the park as long as conservancies can remain key players, people are not resettled or prohibited from livestock herding, there is no fence constructed, and jobs are created that they can obtain. They also see the benefit of obtaining control over the concessions and having the ability to lease them out to the private sector; they want to be partners in tourism development. In addition, they see park status as giving them more ability to control incursions by outsiders who have been moving into the area from more northern areas in search of grazing and conservancy benefits, which has been a problem for them in Sesfontein.
#Khoadi //Hoas conservancy leaders also offered their view of the contractual park. They said that tourism is high on their agenda, and believe that creating a park will help maximize the benefits to conservancies that border on the concession areas. This is because under the contractual park, concession rights will be given to conservancies rather than the government, who can then negotiate leases and derive the benefits. They also believe that the park will generate employment opportunities for conservancy members, provide opportunities for them to become shareholders in enterprises developed there, help them obtain capacity building skills by being involved in park comanagement, benefit from lodges that are built in the park, and help to control self-drive tourism. It will also enhance conservation and monitoring of wildlife in the area, which ultimately benefits communities. Because they have been part of the process of designing the contractual park and are involved in developing how exactly they will benefit, they feel like they have a voice at the table and that it is a good thing.
Constraints on tourism development in the Kunene contractual park area to date include a lack of infrastructure development. It is difficult to move between Etosha and Skeleton Coast because the roads are few and generally in bad condition, there is limited air (fly in) capacity, and bed capacity is low (about 200 beds). Other constraints on tourism development, from the perspective of Wilderness Safaris, is the limited term of the concessions, and the difficulty in getting loans to invest in tourism development there (the land is state land).
Western Etosha National Park currently has no tourism development, e.g. lodges, which is why there are many economic opportunities that conservancies bordering Etosha could capture to help them benefit from the contractual park and associated developments. Conservancies could also get contracts for park maintenance activities, like maintaining the Etosha fence along park/conservancy boundaries.
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Recommendations: The Kunene contractual park represents an innovatice and participatory model for national park establishment in Africa that explicitly engages, and aims to benefit, communities. The Park and associated tourism development should be supported.
IV.5. Inadequacy of Current Training Programs in MCA Compact Proposal
Findings for Component Three: The incentive based training program (p. 156) called for in Component Three of the MCA Namibia Proposal needs to be clarified. It is unclear whether MCC funds would be used to cover training costs, or to provide incentives for tour operators to train their staff, and what the difference between these two options is.
Recommendation for Component Three: MCA Namibia should provide substantial clarification about exactly how MCC funds will be used to remove barriers for tourism development and provide incentives for tourism operators to train their staff.
Findings for Component Four: In the opinion of these authors, the “Training and Mentorship Programs” as currently conceived in Component Four of the MCA Namibia Proposal do not provide training opportunities for conservancy members to learn how to safely enter into tourism enterprises. Specific skills sets will be needed to manage hub operations, negotiate joint-venture lodge deals, participate in maintenance of game breeding camps, plan the investment of MCC-funded equity into joint-venture lodges, manage revenues from tourism enterprises, etc. With the reduction and subsequent termination of USAID funds to the WWF LIFE program, the principal source of funding to the NGOs that have provided such support to the conservancies will be drying up as demand for these services will inevitably increase. Given that the community management of these tourism enterprises is one of the key linkages between tourism and poverty alleviation, the lack of capacity building support for conservancy members is a serious oversight in the current version of the MCA Namibia Proposal.
While it is true that sustaining funding for training programs targeting community members is a challenge, the MCA Namibia team must think creatively about how to obtain long-term funding for this type of training once the MCC compact is finished. Possibilities include obtaining matching funds from the Ministry of Education, charging a fee for training services, developing a “green tax” for tourists to cover such costs, or some combination of these options. MCC funds should be viewed as an opportunity to jump-start these training programs and develop standardized training content which can be provided to conservancy and community associations well into the future.
Recommendation for Component Four: MCC should request that MCA Namibia re-write this section of the proposal to prioritize capacity building for conservancies on tourism enterprise management skills.
IV.6. Donor and Partner Coordination
Findings: If ultimately approved, the MCC’s investment in tourism will need to be integrated not only into the MET’s annual activities, but also into numerous natural resource management and tourism activities in different parts of the country funded or implemented by numerous donors, such as KFW, World Bank, DANIDA, GEF, FAO, etc. When donors collaborate and share information, they avoid replication and overlap of proposed activities. Additionally, when policy reform is desired, a united group of donors have a much stronger voice to encourage the host-country government to support reform, as seen in the Congo Basin, Liberia, Madagascar, etc. In the event that donor funded activities in the tourism sector or other sectors have the potential to have an adverse environmental impact, donor collaboration will be critically important to devise strategies to mitigate this impact or seek alternative options. Finally,
32 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment if other large activities, such as the GRN’s “Green Scheme” are implemented close to sensitive areas with the potential for an adverse environmental impact, such as proposed large-scale irrigated agriculture projects near the Kavango River in the Caprivi Region, donor coordination will be critical to attempt to influence the Government to take an approach that balances needs for development with maintenance of environmental services and biodiversity habitat.
Recommendations: Donors supporting tourism / NRM projects in Namibia should share information about their activities and collectively assess whether the potential exists for cumulative impacts of these activities to have adverse environmental impacts. Additionally, if these donors are supporting activities in other sectors that may impact the tourism / NRM actions (mining, agriculture, etc), there may be an additional need to evaluate the cumulative impacts of these multi-sectoral activities for the possibility of adverse environmental impact at a landscape scale. It may be useful for MCC / MCA Namibia team members to initiate some sort of periodic tourism / NRM donor meetings, or participate in such scheduled meetings if they already exist to improve donor coordination.
IV.7. Potential for Conservancies to Contribute to Poverty Alleviation through Tourism Investments
General Discussion: A key question that arises in community-based natural resource management is whether or not it results in poverty alleviation through community development, with equitable distribution of social and economic benefits to community members. In some cases, CBNRM initiatives have reinforced rather than ameliorated local inequalities and power hierarchies, reduced rather than increased access to resources by community members, extended rather than transferred state control over the management of local natural resources, and done little to alleviate poverty. Key conditions that are correlated with positive CBNRM outcomes are: (1) the meaningful transfer of authority – not just responsibility – for resource management decisionsmaking from states to communities; (2) the presence of democratic processes for deciding how natural resource-related benefits should be distributed; (3) downward accountabililty for decision-making (those in decision-making positions must be primarily accountable to community members rather than the state); (4) the presence of democratic processes for making rules and decisions about how land and resources are managed; and (5) opportunities to capture benefits that are structured in socially and culturally-appropriate ways, and are thereby accessible to the target populations.
Moreover, if CBNRM is to prevent and alleviate poverty among community members through natural resource-based development, it must be ecologically sustainable. Conditions that are correlated with ecologically-sustainable CBNRM are: (1) well-defined property rights and secure tenure over natural resources, and (2) the presence of effective local-level insitutions for resource management that have rules regulating resource access and use; sanctions for rule breaking; and enforcement mechanisms, with community members playing a meaningful role in developing these rules, or considering them legitimate.
In order to critically assess whether the proposed MCC investments in tourism will contribute to the goals of poverty alleviation and economic development, it is useful to examine the forms that CBNRM takes in conservancies, and whether it is structured in a way that is likely to equitably distribute the benefits of tourism investments to conservancy and community members. Poverty has many dimensions, and tourism development as a way to alleviate poverty can potentially address many of these dimensions. Poverty alleviation includes: enhancing material benefits like jobs and income, and ensuring that they are equitably distributed; improving natural resource access; increasing household livelihood security and reducing vulnerability; facilitating empowerment and decreasing exploitation; promoting skill and capacity building through education and training; and increasing access to health services to address nutrition, human health, and life expectancy.
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Findings:
Material benefits: The material benefits of tourism include jobs and income for conservancy members. Conservancies receive income from activities like joint venture lodges, trophy hunting, shoot and sell programs, and selling live wildlife to farms. Studies show that the conservancy program has generated positive financial returns for communities (Barnes et al. 2002). In 2006 the value of quantifiable cash, employment, and in- kind livelihood benefits received by conservancies and related CBNRM activities in Namibia was estimated at N$25,700,000 (WWF et al. 2006), with tourism in particular being an important source of conservancy income (Barnes et al. 2002). Investing in tourism development will make it more so.
Who receives these benefits? In some conservancies, only members are entitled to benefits; in other conservancies, all residents can receive benefits, irrespective of membership. Rules vary from conservancy to conservancy regarding who qualifies to become a member of a conservancy. Membership criteria are laid out in the conservancy constitution. Criteria described for the conservancies visited in northwestern Namibia generally included age (e.g. one must be at least 18), residence (e.g. you must have lived inside the conservancy for a minimum period of time, say two years), and conduct (e.g., you comply with the rules of the conservancy). Residents can choose to join the conservancy or not, and by law can do so regardless of ethnicity or gender. In the conservancies visited in the northwest, membership was free, meaning people belonging to all income groups could join. In 2006 there were 44 conservancies having a total of 211,120 members (WWF et al. 2006). In 2007 this number had grown to 51 conservancies.
A small percentage of conservancy residents benefit from jobs generated by CBNRM activities. In 2006 there were 742 full-time and 5,153 part-time jobs in conservancies created through CBNRM activities such as tourism lodges, campsites, hunting operations, and enterprises like craft production. A large percentage of conservancy residents can potentially benefit from other social and economic benefits like meat distribution, direct payments, or community development projects funded by conservancy revenues.
Who gets the jobs? One of the reasons lodge development is viewed as beneficial is because it creates local jobs in conservancies, meaning people don’t have to leave home and engage in urban migration in order to find a job. In the conservancies visited in the northwest, lodges run by public/private partnerships stipulated in their contracts that a certain percentage of lodges jobs had to go to conservancy members. What is the nature of a lodge job? Based on the lodges we visited, it appears that lodge staff typically reside at the lodge property rather than commute daily from their homes. The work schedule is variable, but for example, at Grootberg Lodge people stay for 3 months working, then have 8 days off, then return to work. We were told that a schedule like this makes it easier for single women to work at lodges than for married women, and that such a schedule makes it difficult for people with children, especially women (typically the main caregivers) who must find someone else to tend their children, and who only see them during their time off. For men to work lodge jobs, they must find a way to balance them with other responsibilities at home, such as livestock herding. Some jobs may be more appealing to women or men. For example, men typically prefer jobs such as driver, guide, and guard. Women typically do housekeeping jobs such as laundry, kitchen and restaurant work, and room cleaning. In short, the people who are able to benefit from lodge and other tourism-related jobs are those who are able to take advantage of them by balancing household responsibilities, and having the needed skills. Cultural considerations also play a role, with jobs that are more culturally-appropriate being easier and more appealing for people to take advantage of, without
34 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment requiring them to trade off their sense of identity. For example, hunting or tourism guide jobs may be more appealing and appropriate to San men, who are typically skilled hunters and trackers having detailed knowledge of local landscapes and natural history, than jobs working in lodges cleaning rooms or cooking.
Before a conservancy can be legally created it must have a benefit distribution plan. Benefit distribution plans are developed in a participatory way, and are a mechanism for capturing and addressing peoples’ priorities and interests in how they would like to see conservancy revenues invested so that a large number can benefit.
A survey of 1,192 households from 7 conservancies in the Caprivi and Kunene regions conducted in 2002 examined whether conservancies significantly increase household welfare, are pro-poor, and whether conservancy members benefit more than nonmembers (Bandyopadhyay et al. 2004). The study has several interesting findings: • About 34% of the households were conservancy members, but membership did not necessarily confer more welfare benefits to members than nonmembers; • About 25% of conservancy households were aware of conservancy constitutions, plans, and activities; • Conservancies have an overall beneficial effect on household welfare, and these effects were pro- poor in Caprivi and poverty neutral in Kunene (e.g., poor households benefited disproportionately more from conservancies than rich households in Caprivi, but not in Kunene); • More educated and asset-rich households do not gain more from conservancies than their less- educated and poorer counterparts; thus, benefits are not being captured exclusively by the elite; • Male-headed households do not gain more benefits from conservancies than female-headed households; • There are significant community-level benefits from conservancy creation.
One risk associated with conservancies is the potential for corruption. A 2005 investigation found that most problems associated with missing money in conservancies stemmed from poor accounting systems rather than theft or fraud (NACSO 2006). Conservancy legislation has a provision that conservancy rights over wildlife can be withdrawn if there is evidence of mismanagement of funds.
Overall, evidence indicates that tourism investments in Namibia’s conservancies can have a positive and significant effect on increasing material benefits for conservancy residents, and equitably distributing these benefits. There are some issues that could be addressed however in order to improve this outcome, that were raised during trip 2: (1) how to control conservancy residence, membership, and benefit sharing; and (2) how to benefit from tourism in conservancies by self-drive tourists and tourism operators who do not stay at lodges or conservancy campsites.
Regarding issue 1, the Uibasen-Twyfelfontein Conservancy is an example of a conservancy that has benefited from high levels of tourism to the Twyfelfontein National Monument, resulting in high visitation to the Twyfelfontein Lodge, and associated revenue generation for the conservancy. We were told by conservancy leaders that this success has drawn newcomers to the area who want to reap the benefits of conservancy success. The conservancy does not have an effective way to control residency, membership, and benefit sharing, meaning that at some point the benefits become so widely distributed as to be relatively insignificant for individuals. This problem could be amplified by government resettlement programs.
Regarding issue 2, conservancies have control over wildlife management, but do not appear to be able to control access to conservancy lands or tourism activities on their lands by tour operators
35 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment or self-drive tourists, because they do not own their land. The Namibian Constitution says that people can go anywhere. Conservancies get revenue from lodges and campsites, but many tourists do not stay at these, and instead, camp wherever they choose on conservancy lands. The inability to control tour operators was raised as a problem at Uibasen-Twyfelfontein, Torra, and #Khoadi //Hoas. Some tour operators are willing to pay to bring clients onto conservancy land and camp, but some aren’t, and if the rules are inconsistent, it puts those who are willing to pay at a competitive disadvantage.
Empowerment: One of the most important benefits of conservancies is that they empower local communities to manage and benefit from wildlife. Devolution of authority over wildlife management is not complete (conservancies recommend quotas for wildlife utilization to MET, who must approve them, and conservancies work with MET to determine what form that utilization should take), but is substantial.
The conservancy committee is the executive body of the conservancy. Members are elected or appointed to a term specified in the conservancy constitution (e.g. one to five years), and under conservancy legislation, must be representative of the community it serves. Data are not readily available regarding the ethnic composition of conservancy committees. In 2006, women comprised 37% of committee members. Conservancy members meet periodically to discuss relevant issues. Participation in conservancy activities may be limited, however, by practical considerations such as widely-dispersed settlement patterns, particularly in the arid northwest. Conservancies develop their own constitutions.
In a study of two conservancies in the Kunene region, Schiffer (2004) found that some power has shifted to the local level as a result of the transfer of wildlife management authority from the state to communities, but in general, local communities have not necessarily been empowered. There was a gap between conservancy staff and committees, and the rest of the local population, in terms of empowerment. There was also a lack of clarity around the roles of traditional authorities and conservancy authorities, which in some cases created conflict, with the former potentially serving as either a catalyst or a roadblock to the latter. It is unclear how the governing bodies created by conservancy legislation interface with traditional authorities in conservancies.
Skills/Capacity Building: The creation of conservancies has been a process that has led to many opportunities for skills development and capacity building in rural communities. The acts of organizing to form a conservancy, developing a constitution, taking charge of wildlife management, managing conservancy funds, building new enterprises, entering joint venture agreements, monitoring various aspects of the conservancy using the event book system, and working in the tourism sector have required people to develop new or refine existing skills in order to make conservancies successful. For example, the proposed investments in joint venture lodges provide an excellent opportunity for community members to build their capacity to eventually own and manage their own tourism lodges and operations, providing the private partners are committed to power sharing, training, and creating a working relationship that supports them in doing so. It is evident that as conservancies build their capacity, they take on other roles in communities besides wildlife management: they function as businesses, service providers, community development organizations, and land management organizations. Thus, the skills and capacity that conservancies develop in the course of carrying out their functions transfer to other areas of community life, and support broader natural resource management and development activities.
It appears that considerable investment has been made in capacity building to support Namibia’s CBNRM program. For example, during the period April – September 2006, 12,099 person days of CBNRM-
36 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment related training, planning, and coordination/networking occurred, in which 3,842 people participated – 33% of whom were women, and 48% of whom were community members (WWF et al. 2006).
One issue that emerged during trip 2 was that people who are trained to work in lodges by lodge operators often leave in search of better tourism jobs elsewhere. This raises the question of whether conservancy lodges provide quality jobs, including good pay and opportunities for advancement.
Outreach may need to be conducted to women, indigenous peoples, and under-represented groups in conservancies to assess whether they are interested in training that would prepare them for tourism-related jobs, and targeting them for training opportunities. Relationships between conservancy and private partners in joint ventures may need to be monitored to ensure that they support the transfer of skills and capacity building for community members. It could be helpful to identify and develop strategies for encouraging trained people to continue working in their conservancies, so that they can be retained.
Human Health: We are not aware of any studies that have assessed the effects of conservancies on human health, nutrition, and life expectancy. Some conservancies have chosen to invest a portion of their revenues in developing health services and AIDS education and prevention programs. Others have used revenues to purchase vehicles, and sometimes assist community residents who need transport to health clinics or hospitals. Thus, investing in tourism development and increasing revenues to conservancies, can increase the money available to invest in health-related services if communities make this a priority.
Ecological Sustainability: Conservancies have exclusive (though incomplete) rights to manage wildlife within geographically defined areas; conservancy boundaries must be delineated before a conservancy can be legally established. Conservancy lands are state lands however; they are not community-owned. Therefore, communities do not necessarily have the authority to manage natural resources other than wildlife. Several have, however, developed land use plans that identify zones within conservancies that are managed for different uses, e.g. tourism, livestock grazing, and settlement. In conservancies, property rights are well-defined and tenure over wildlife appears to be secure.
Other land and resource tenure issues emerged however. There are issues around settlement inside conservancies, with several of the conservancies visited reporting problems relating to their inability to control settlement, natural resource use (apart from wildlife), membership numbers, and visitation on conservancy lands. There were also issues related to Namibia’s resettlement program that we could not explore in detail during our visits. The ability to control natural resource access is important for ensuring sustainable use. On the positive side, conservancies appear have sanctions for rule breaking, and game guards or environmental shepherds that enforce those rules, with back-up support from the state.
Monitoring data indicate that wildlife populations in conservancies have been increasing (NACSO 2006); wildlife are coming to be viewed as an asset to be protected because of the benefits they can generate for conservancy residents, rather than as a liability. The event book system used in many conservancies is an effective tool for adaptive management (Stuart-Hill et al. 2005).
Recommendations: Investing in tourism development through the conservancy model will contribute to many dimensions of poverty alleviation, community development, and sustainable natural resource management, and should be supported. These outcomes could be enhanced by working to address some of the issues raised in the above sections.
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IV.8. Environmental and Social Safeguards – Ecotourism Certification
One way to encourage environmentally and socially responsible tourism development in Namibia would be to consider developing an ecotourism certification scheme there. The Good Practices Handbook developed by “Eco Awards Namibia” takes an important first step towards the development of a series of standards for ecotourism products in Namibia, that could, with some additional effort, evolve into the basis for an ecotourism certification program. Tourism certification is a procedure that audits and gives written assurance that a facility, product, process, service, or management system meets specific standards (Honey 2002). The certified entity receives a logo or seal indicating that it meets or exceeds the baseline criteria or standards set by the certification program. Ecotourism certification schemes have emerged in countries around the world, with Kenya and South Africa providing examples from Africa. The community-based approach to tourism development in Namibia is an excellent example of ecotourism: travel to natural areas that contributes to environmental conservation and improves the welfare of local people, and could therefore stand to gain from marketing its products as certified through an independent system.
There are several potential benefits associated with ecotourism certification. First, ecotourism certification is a tool for helping tourism benefit local people and ensuring that it takes place in an ecologically and culturally-sensitive way. It does this by setting environmental and social standards of conduct that must be met (that can include health and safety standards), and creating an independent (preferably third party) monitoring system to ensure those standards are maintained over time. It also provides a pathway for tourism operators to gradually improve their behavior. Most ecotourism certification systems offer a rating that ranges from one to four stars for example. This system creates direction and incentive for operators to improve their performance over time.
Second, it is a marketing tool. The number of tourists who care about engaging in responsible travel is growing as people become more educated about the possibility, and increase their environmental and cultural awareness. A high percentage of the tourists to Namibia come from Europe and South Africa. South Africa has already begun to promote ecotourism certification through Fair Trade in Tourism, South Africa (http://www.fairtourismsa.org.za/), reflecting a growing awareness of these values in that country. And Europeans in particular have a relatively high level of awareness about and interest in certification, reflected in such programs as EcoClub, PAN Parks, Blue Flag, and Nature’s Best.
Third, ecotourism certification can attract donor funding. It can be attractive to NGOs, philanthropists, and development assistance organizations to help support development efforts that are being carried out in environmentally and socially responsible ways. Certification helps ensure that this occurs. While it is important for Namibia’s conservancies to strive to be financially independent, donor funding has been important in helping them build the capacity to do so.
Fourth, certification protects against “greenwashing” – false claims and advertising on the part of competitors who claim to run green tourism operations, that can undercut good operators. It provides a mechanism for verifying truth in advertising, protecting both consumers and legitimate community ecotourism efforts.
There are two key drawbacks of ecotourism certification. The first is that it may cost an entity money to undergo the certification process, which can be prohibitive for small and medium-size businesses. However, innovative schemes are being developed to address this problem. In some countries, like Costa Rica for example (http://www.turismo-sostenible.co.cr/EN/home.shtml), certification costs are underwritten by the government, so that there is no additional fee to a lodge or operator for assessment. Another possibility is for the government to lower the cost of licensing to certified tourism operators, thereby helping to offset the cost of certification, and creating an incentive for certification. Businesses
38 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment can also reduce their operating costs by adopting more ecologically-sustainable practices that meet certification standards.
A second drawback of certification is that in many countries, certification standards have been developed and imposed by outsiders – e.g., international NGOs. Namibia is well-positioned to organize an effort in which conservancies work together to develop their own certification standards – both environmental and sociocultural – based on criteria that are appropriate to the scale and places they operate at, and the values that are important to them. Including indigenous peoples, women, and other under-represented groups in the process of developing certification standards is an important way of ensuring that their interests are reflected in these standards.
MCC/MCA Namibia may wish to consider allocating funds to support the development of an ecotourism certification system in Namibia. Linking investments in lodge development, for example, to a set of internally-developed certification standards, would help ensure that MCC tourism investments are supporting environmentally- and socially-responsible development; would provide incentive for tourism development in Namibia to follow the direction it already appears to be headed in, based on the conservancy model; and could help in marketing tourism in Namibia. Many examples and resources currently exist to learn from. See Honey (2002) for more background on this topic.
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Appendix I: Documents Reviewed and Cited
Documents Reviewed (Partial List)
Screening Questionnaire for Projects, Annex III – MET Screening Guidelines, Directorate of Environmental Affairs, Ministry of Environment and Tourism, Environmental Impact Assessment in Southern Africa, Southern Africa Institute for Environmental Assessment, 2003 Namibia’s Environmental Assessment Policy for Sustainable Development and Environmental Conservation, Directorate of Environmental Affairs, Ministry of Environment and Tourism, January 1995 Environmental Guidelines, Millennium Challenge Corporation, January 20, 2006 Environmental Management Bill, Ministry of Environment and Tourism, 2002 Draft Environmental Assessment and Management Act, 2007, (aka Environmental Management Bill), Ministry of Environment and Tourism, 2007 Proposed Bill Bwabwata, Mudumu and Mamili Parks Project, Draft Infrastructure Assessment & Initial Proposals, Caprivi Parks Consultants Infrastructure Team, 2007 Nyae Nyae Fly Camps, Environmental Management Plan for Noma Post Camp, Final Draft, Southern African Institute for Environmental Assessment, February 2005 Nyae Nyae Fly Camps, Environmental Management Plan for Xamsa Post Camp, Final Draft, Southern African Institute for Environmental Assessment, February 2005 Kavango Biofuel Project, Environmental Impact Assessment: Specialist Component Report on Socio- Economic Impacts, RAISON, March 2007 Gender Policy, Chapter 14, Millenium Challenge Corporation, December 2006 Namibia's Communal Conservancies, a review of progress and challenges in 2005, MET & Partners The impact of travel and tourism on jobs and the economy, Travel & Tourism Council NAMIBIA: BWABWATA MUDUMU and MAMILI PARKS PROJECT: Project Phase 1 Operational Plan 1st July 2006 to 30th June 2009 Total Value of Benefits Generated for all conservancies through 2005, WWF LIFE Program Responses to Tourism Sector Due Diligence Questions, MCA Namibia Scope of Work USDA (USFS) and Department of Interior (January 9, 2007), MCC New Compensation Policy 20th / 20.08.02 / 006, Namibia Cabinet Decision BEE Overview, FENATA Tourism Industry Transformation Charter: A User's Guide, FENATA Transformation Charter Report for the Tourism Industry, FENATA Tourism Awareness Campaign DRAFT, FENATA Qualifications: Hospitality and Tourism Levels 1 & 2, FENATA Supporting Details for the FENATA Mentorship Program contained in the MCA Proposal, FENATA Annex 3 2005 Environmental Analysis Update, USAID Namibia Namibia National CBNRM Programme, NACSO Good Practices Handbook, Eco Awards Namibia
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Documents Cited
Bandyopadhyay, S., Shyamsundar, P., Wang, L., and M.N. Humavindu, 2004. Do Households Gain from Community-based Natural Resource Management? An Evaluation of Community Conservancies in Namibia. World Bank Policy Research Working Paper 3337. http://www.dea.met.gov.na/met/publications/research/RDP68.pdf
Barnes, J.I., Macgregor, J. and Weaver, L.C., 2002. Economic Efficiency and Incentives for Change within Namibia’s Community Wildlife Use Initiatives. World Development 30(4):667-681.
Honey, M., 2002. Ecotourism and Certification: Setting Standards in Practice. Washington, DC: Island Press.
NACSO (Namibian Association of CBNRM Support Organisations), 2006. Namibia’s Communal Conservancies: A Review of Progress and Challenges in 2005. NACSO, Windhoek.
Schiffer, E., 2004. How Does Community-based Natural Resource Management in Namibia Change the Distribution of Power and Influence? Preliminary Findings. Directorate of Environmental Affairs, Ministry of Environment and Tourism Discussion Paper 67. Windhoek. http://www.dea.met.gov.na/met/publications/research/RDP67.pdf
Stuart-Hill, G., Diggle, R., Munali, B., Tagg, J., and D. Ward, 2005. The Event Book System: A Community-based Natural Resource Monitoring System from Namibia. Biodiversity and Conservation 14:2611-2631.
WWF (World Wildlife Fund, Inc.), Namibia Nature Foundation, Cooperative League of USA, and International Resources, 2006. Integrated Community Based Natural Resource Management (CBNRM) for Economic Impact, Local Governance and Environmental Sustainability. Living in a Finite Environment Plus Semi-Annual Report for April 30-September 30, 2006.
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Appendix II: Additional Documentation Needed
• Government of Namibia’s policies on accessibility and disability requirements • DRAFT implementing regulations for MCC Namibia Environmental Management Bill • Copy of 1998 Cabinet Decision for future Bwabwata National Park • Any EIA enforcement policies / procedures currently in practice under the 1995 EIA policy • Most recent version of draft concession policy • Most recent version of draft Environmental Management Bill • Most recent version of draft Parks and Wildlife Ordinance • Law creating the Conservancies • Example of 1-2 Regional Tourism Plans for Caprivi Region • Conservancy Management Plans • Conservancy Equitable Benefits Distribution Plans • KAZA Pre-Feasibility Study • MET Human-Wildlife Conflict Policy • Socio-Economic analysis for future Bwabwata NP • Guidance for design standards for MET buildings (if this exists) • Game Reintroduction Plans • Species Management Plans • White Paper on Tourism Policy • Operations and Maintenance Plan related to MCC investments in national parks • Any reports from the March 13-4 meeting on the future of the Bwabwata National Park
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Appendix III: Specific Issues at Future Bwabwata National Park:
There are many complex issues surrounding the creation of the future Bwabwata National Park. The MET and its partners were to have met March 13-4 to discuss and resolve some of these issues, which include potentially de-proclaiming certain areas of the parks, dealing with livestock in the park, the Kyarama San people with a history of poor treatment at the hands of the government and their lack of traditional authority, and the traditional Chief's claim to the area. While it is impossible to adequately summarize the issues in this document, key points to note are:
• There are some misconceptions about what the 1998 Cabinet Decision actually states with regard to proclamation/de-proclamation of the Omega and Begoni blocks of the future Bwabwata NP. While a copy of this decision has been requested for clarification, our team was told that the 1998 Cabinet Decision does NOT specifically state that the Omega and Begoni blocks of the future Bwabwata NP are to be de-proclaimed. • In the absence of recognized traditional authority for the local San tribes, de-proclaiming the Omega and Bagani blocks would place the San under the authority of the traditional Chief, as well as lead to significant migration for agriculture and cattle grazing • For the San People to be truly empowered, their request for traditional authority must not only be honored, but needs to be bestowed the authority to make land management decisions • The Bagani block contains important riparian areas on the east bank of the Kavango river • If the Omega Block is kept within the park and livestock is removed, wildlife fencing will be necessary to protect subsistence agricultural plots belonging to local residents • The Government of Namibia’s green scheme has plans to increase industrial agriculture activities in the floodplains of the Kavango River, which could have substantial environmental impacts on the Kavango River ecosystem, the Okavango Delta, and downstream communities dependent on the river for their livelihood strategies • The MET will need considerable technical and financial support to successfully manage the Bwabwata National Park as a multiple-use area • There is only a limited amount of cattle (approximately 500 head) in the future Bwabwata NP, and very few if any of the cattle are owned by residents of the Omega areas. It is the teams view that the long terms interests of the area would be best served by removing the cattle and compensating the owners, thus eliminating the need for internal fencing. • The lack of adequate recognition of the status of these lands as a national park has led to illegal activity in the area, such as unregulated construction sites (furniture factory adjacent to San Community Campground at Popa Falls) and storage of Angolan timber from dubious sources prior to transport to South Africa • The signing of the KAZA MOU creates the potential for substantial tourism development in the Caprivi Strip, as well as increased visitation • The Ministry of Lands and Resettlement, with support from KfW, is supporting various small-scale commercial livestock development and small-holder agriculture projects without assessment of land capabilities or potential to market commodities produced
It seems critical that the current Government of Namibia officially declare the proclamation of Bwabwata National Park to establish the legitimacy of the MET as the custodian of the lands in these areas. In our opinion, the best option given the current situation is for the Bwabwata NP to be declared containing the entire area (Mahango Game Park, Bagani Block, Buffalo Core Area, Kwando Core Area, Omega Block and Caprivi Game Park), with a multiple-use management option selected. This approach allows the MET to keep all management options on the table, protects the rights of the San People in the area, conserves important wildlife habitat along the Kavango River both north and south of the main road, and eliminates
43 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment any need to re-settle people or deal with massive in-migration. This approach also gives the MET the flexibility to de-proclaim certain areas in the future, should that become the best option.
Issues to be addressed by Team Two or by MCC in follow-up discussions:
MCC investment in this area provides an opportunity to put some conditions on how the above issues will be resolved. MCC may want to suggest the outcome defined above as being the quickest route to achieving MCC investment in tourism infrastructure in the area. Alternatively, MCC could make successful resolution of these issues along the lines of what is suggested above a condition precedent to disbursal. Finally, MCC should ensure that its other investment areas, such as livestock and roads, are compatible with this vision.
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Appendix IV: MCC Namibia Due Diligence Mission Itinerary
February 24, 2007 – March 10, 2007 Peter Gaulke & Oliver Pierson
Saturday, February 24, 2007 • 1720 – Leave Washington-Dulles
Sunday, February 25, 2007 • 1545 – Arrive Johannesburg, South Africa
Monday, February 26, 2007 • 0745 – Depart Johannesburg, South Africa • 1100 – Arrive Windhoek, Namibia • 1200 – MCC Orientation Meeting Polytechnic Hotel and Tourism School, which included the following presentations: o Welcome and Introductions – Dr. Malan Lindeque, MET Permanent Secretary o The Significance and Trend of Indigenous Biodiversity Production to The Namibia Economy – Dr. Chris Brown, Namibia Nature Foundation o Overview of Namibia Tourism Sector: Tourism Satellite Accounts – Shereen Thude and Sophia Sweigers, Namibia Tourism Board o Economics and Potential of The Namibia National Park System – Dr. Jon Barnes, MET Economist o Overview of The Namibia CBNRM Programme – Tsukhoe Garoes (MET CBNRM Unit) and Maxi Louis, NACSO Secretariat o Overview of The Namibia MCA Tourism Sector Proposal – Colgar Sikopo, MET Deputy Director of Parks and Wildlife o Launch of The 2005 Namibia State of Conservancy Report – Honourable Willem Konjore, MET Minister at Namibia Polytechnic Hotel and Tourism School
Tuesday, February 27, 2007
08h00 Group Meeting with the Helmut Angula, Director General, National Planning Commission (NPC), at the NPC Boardroom
10h00 Meeting with FENATA (Most of Team Present) • Jacqueline W. Asheeke, CEO, FENATA • Larry H. Laursen • Jennifer Lalley, The Nature Conservancy-Namibia Program • Mannfred Goldbeck, Managing Director, Gondwana Desert Collection • Allan Kirby, Director, Wild Dog and Crazy Kudu Safaris • Willem Dewet • Almut Kronsbein, CEO, Namibian Professional Hunting Association • Lloyd ?
13h00 Parks Division, MET (Oliver and Michelle present) • Ben Beytell, Director, Directorate of Parks and Wildlife Management, MET
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• Ulrich Boois, Deputy Director, Parks and Wildlife Management, MET • Midori Paxton, Project Coordinator, SPAN Project
15h00 USAID Namibia (Oliver and Michelle present) • Patricia Skyer, CBNRM Advisor, USAID Namibia, [email protected] • Sanath K. Reddy, General Development Officer, USAID Namibia, [email protected]
15h00 Meeting with Mr. Chris Weaver, Chief of Party, LIFE Plus Project, World Wildlife Fund (WWF) , and Mr. Andee Davidson, Tourism and Business Specialist, LIFE Plus Project, WWF, at WWF Offices.
Wednesday, February 28, 2007 • 0800 – Meeting with Ernst Simon, Managing Director, Urban Dynamics, and Collin Christian, Collin Christian & Associates, at Urban Dynamics Office • 1115 – Depart for Eros Airport • 1230 – Plane departs for Caprivi / Lianshulu Lodge • 1600 – Plane arrives in Caprivi / Transfer to Lianshulu Bush Lodge • 2000 – Presentation on Tourism in Caprivi by Lianshulu Lodge Manager, Mr. Ralph Maier
Thursday, March 1, 2007 • 0815 - Presentation on Bwabwata, Mamili, Mudumu Park Project, Ed Humphrey, Project Manager, Caprivi Parks Consultants, at Lianshulu Lodge • 1115 - Conservancy Developments, Progress, and Support in Caprivi, Richard Diggle, Integrated Rural Development & Nature Conservation (IRDNC), at Lianshulu Lodge • 1200 - Proposed Tourism Development Options and Park Infrastructure Support for Mamili National Park, Ministry of Environment and Tourism (MET) Staff and Ed Humphrey • 1700 - Return to Lianshulu Lodge
Friday, March 2, 2007 • 0800 – MCC Due Diligence Team Meeting at Lianshulu Lodge • 1400 – Proposed Tourism Development Options and Park Infrastructure Support for Mudumu National Park, including Makatwa Park Office and Ngenda Ranger Station – MET staff and Ed Humphrey • 1900 – Arrive at Namashusha Lodge
Saturday, March 3, 2007 • 0900 – Meeting in Choi with Chief Mayuni, Mafwe Tribe, for historical overview of conservation and conservancies in Caprivi • 1115 – Meeting with Kwandu / Mayuni / Mashi Conservancies, Mayuni Conservancy Office, Kongola, Presentation on Conservancies and Mudumu North Complex • 1300 – Visit and Lunch, Bum Hill Campsite, Operated by Kwandu Conservancy, Discussion on campsite operations • 1400 – Visit Susuwe Ranger Station and Bum Hill Campsite, Presentation on Bwabwata East Park Development Plans, MET Staff and Ed Humphrey
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• 1630 – Visit Proposed Entrance Gate (east) to Bwabwata East Park, including other development sites, potential concession sites, potential roads in Susuwe area, MET Staff and Ed Humphrey • 1800 – Visit to Nambwa Campsite, MET Staff and Ed Humphrey • 1900 – Return to Namashusha Lodge
Sunday, March 4, 2007 • 1000 – Meeting with Kyramashan Association, Chetto, East Half of Bwabwata Park, Multiple Use Area • 1300 – Site Visit to Omega 1 Area, Bwabwata Park, MET Staff and Ed Humphrey • 1400 – Site Visit to Proposed Anti Poaching Unit, Bwabwata Park, MET Staff and Ed Humphrey • 1630 – Arrive at Ndhovu Lodge • 1800 – MCC Due Diligence Team Meeting at Ndhovu Safari Lodge
Monday, March 5, 2007 • 0900 – Site Visit to East Ridgeline / Park Boundary, Bwabwata Park, MET Staff and Ed Humphrey • 0930 – Site Visit to Buffalo Military Bases locations, MET Staff and Ed Humphrey • 0945 – Site Visit to MET Buffalo Game Park Office, MET Staff and Ed Humphrey • 1030 – Site Visit to old Sewage Ponds and Location of Proposed Tourism Lodge, Buffalo Camp, MET Staff and Ed Humphrey • 1130 – Site Visit to Nova de Marsh, Small Anti Poaching Unit, Buffalo Camp, MET Staff and Ed Humphrey • 1300 – Lunch at Popa Falls, Ngoaghoasha Campsite • 1430 – Site Visit to Entrance of Mahango Game Park, MET Staff and Ed Humphrey • 1500 – Site Visit and Tour of Mahango Game Park • 1700 – Return to Ndhovu Safari Lodge
Tuesday, March 6, 2007 • 1200 – Site Visit of Proposed Natural Resource Service Center, North Gate, Khaudom Park, MET Staff and Chris Weaver • 1300 – Lunch at Khaudom Camp • 1430 – Site Visit to Khaudom Water Point and Staff Quarters, Khaudom Park, MET Staff and Chris Weaver • 1500 – Site Visit to Doringstraat, Elephant Water Point, Khaudom Park, MET Staff and Chris Weaver • 1900 – Arrive and Overnight at Sigerretti Camp, Khaudom Park
Wednesday, March 7, 2007 • 0900 – Site Visit of Proposed Natural Resource Service Center, South Gate, Khaudom Park, MET Staff and Chris Weaver • 1000 – Site Visit to Nhoma Post #2, Elephant Water Point and Proposed Joint Venture Lodge Site for Nyae Nyae Conservancy, Khaudom Park, MET Staff and Chris Weaver
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• 1030 – Site Visit to Nhoma Post #1, Elephant Water Point, Khaudom Park, MET Staff and Chris Weaver • 1300 – Site Visit and Lunch at Proposed Joint Venture Lodge site for Nyae Nyae Conservancy, Xamsa • 1430 – Meeting with and Presentation by Nyae Nyae Conservancy, Tsumkwe, including Chairperson, Conservancy Manager and several board members • 1800 – Arrive and Overnight at Buffalo Camp
Thursday, March 8, 2007 • 0800 – Brief Tour and Site Visit of Buffalo Camp • 0900 – Depart for Windhoek • 1700 – Arrive Windhoek, Kalahari Sands Hotel
Friday, March 9, 2007
08h00: FENATA to discuss Tourism House (Oliver and Luverne present) • Jacqueline W. Asheeke, CEO, FENATA • Almut Kronsbein, CEO, Namibian Professional Hunting Association • Allan Kirby, Director, Wild Dog and Crazy Kudu Safaris
12h00: Parks Division, MET (Oliver present) • Ben Beytell, Director, Directorate of Parks and Wildlife Management, MET • Ulrich Boois, Deputy Director, Parks and Wildlife Management, MET
14h00 Team Debriefing at MET
16h00 Indigenous People’s Issues (Oliver and Ginny present) • Brian Jones, MET Consultant for Social Assessment Issues
48 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
Trip 2 Due Diligence Mission Itinerary: April 7, 2007 – April 17, 2007 Susan Charnley
Saturday, April 7, 2007 • 0740 Depart Portland, Oregon • 1530 Arrive Washington, Dulles • 1720 Depart Washington, Dulles
Dave Harpman (DOI economist) and Peter Gogan (DOI game biologist) were on the same flight, we had introductory conversations and I traveled on with them to Windhoek.
Sunday, April 8, 2007 • 1445 Arrive Johannesburg, South Africa
Monday, April 9, 2007 • 1055 Depart Johannesburg, South Africa • 1155 Arrive Windhoek, Namibia
This was a holiday (day after Easter) so no offices were open in Windhoek. Spent the day getting acquainted with Peter and Dave, exploring Windhoek, and reviewing project materials.
• 2100 Met with Tom Campbell, Virginia Seitz, and Theresa Osborne of MCC, Washington, DC, who arrived in Windhoek that evening. Had an orientation meeting with them at the Kalahari Sands Hotel
Tuesday, April 10, 2007 • 0830 Depart Windhoek by air for Twyfelfontein with the other 5 members of U.S. team plus Malan Lindeque (MET), Kandi Iihuhua (MET), Chris Weaver (WWF), Eline van der Linden (MCA) and Jeremia Kavaa (MCA) • 1030 Arrive Twyfelfontein airstrip. We were met by Allan Kirby of Wild Dogs/Crazy Kudu Safari Company and FENATA, whose company transported us in safari vehicles throughout the trip. Went to Namibia Country Lodges Twyfelfontein Lodge for refreshments. Met Willem de Wet, owner, Namibia Country Lodge and three leaders of the Uibasen-Twyfelfontein Conservancy. • 1130 Toured Twyfelfontein National Monument • 1300 Lunch, Twyfelfontein lodge and presentations by Willem de Wet and the conservancy chairperson (Johannes _____) and conservancy coordinator (Maurice ______) Were met by four additional members of the safari party: Brian Jones (social scientist and consultant to MET), Joe Tag (MET), Peter Erb (MET), and Graig Stewart-Hill (WWF) • 1400 Depart lodge, visit proposed Twyfelfontein tourism information hub site • 1530 Arrive at Torra Conservancy, presentation by Emil Roman (conservancy manager) and Vitalis Florry (field officer, Torra conservancy)
49 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
• 1830 Arrive at Doro !Nawas Lodge, dinner and overnight
Wednesday, April 11, 2007 • 0800 Depart Doro !Nawas • 1030 Arrive at Palmwag Lodge, Sesfontein Conservancy • 1100 Presentations by o Malan Lindeque and Brian Jones on Kunene Contractual Park and concessions o John Kasaona, Sesfontein Conservancy on conservancy overview and views of contractual park o Obed Hambo, Chairman, Anabeb Conservancy on conservancy overview and views of contractual park o Jennifer Lalley, Save the Rhino Fund & Wilderness Safaris & University of Pretoria on the history of the area and land use o David van Smeerdyk – Wilderness Safaris on Wilderness Safaris, their operations, and their work in the Palmwag Concession • 1300 Lunch, Palmwag Lodge • 1400 Depart Palmwag • 1500 Arrive Grootberg Lodge, #Khoadi //Hoas Conservancy Presentations by Barnadus Guibeb, Conservancy coordinator/manager and Ecologistics, managing partner, Grootberg Lodge • 1800 Arrive Hoada Campsite, eat dinner, sleep
Thursday, April 12, 2007 • 0800 Depart Hoada Campsite • 0930 Arrive at #Khoadi //Hoas Conservancy offices Presentations by Barnadus Guibeb, Conservancy coordinator/manager Helga Howoses, Information Liaison Officer Asser Ndjitezeua, Conservancy chairperson • 1230 Depart #Khoadi //Hoas for Hobatere Lodge • 1600 Vehicle accident occurs somewhere outside of Kamanjab, 3 members of team are badly injured: Campbell, Iihuhua, and Kirby • 2330 Arrive at the hospital, Otjiwarongo Spend night at Out of Africa Lodge, Otjiwarongo
Friday, April 13, 2007 • 1200 We abort field portion of trip, return to Windhoek • 1430 Arrive Windhoek One contingent of the safari party remains in field to complete field component of trip: Gogan, Tag, and Stewart-Hill
Saturday, April 14, 2007 • 1000 Team meeting at WWF office in Windhoek Presentation on Human/Wildlife Conflict Management by Brian Jones
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Presentation on Etosha Management Plan and tourism development in Etosha by Peter Erb Group dinner
Sunday, April 15, 2007 • 0900 We are informed that Allan Kirby passed away during the night following surgery. I am asked by MCC to return home. • 1500 Wrap-up meeting at Kalahari Sands between Charnley, Harpman, Osborne, Seitz, and Campbell
Monday, April 16, 2007 • 1250 Depart Windhoek with Osborne • 1545 Arrive Johannesburg • 1915 Depart Johannesburg
Tuesday, April 17, 2007 • 0530 Arrive Frankfurt • 0945 Depart Frankfurt • 1155 Arrive San Francisco
51 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
Appendix V: Persons Consulted
MCC Namibia Due Diligence Mission, February 24, 2007 – March 10, 2007 Incomplete and unordered list, excluding MCC Staff
Dr. Malan Lindeque, Permanent Secretary Jennifer Lalley Ministry of Environment and Toursim The Nature Conservancy – Namibia
Colgar Sikoko, Acting Deputy Director Almut Kronsbein, CEO Parks and Wildlife, Ministry of Environment and Namibian Professional Hunting Association Tourism Collin Christian, Consultant Freddy Sikabongo, Impact Assessment Chief Collin Christian & Associates Ministry of Environment and Toursim Phellep Styn, Chief Warden Ed Humphrey, Project Manager Ministry of Environment and Tourism, Kavango Caprivi Parks Consultants Parks
Horst Kock, Lodge Manager Apollonaris Kannyinga, Chief Control Warden Ndhovu Safari Lodge Ministry of Environment and Tourism, North East Park Dr. Jonathan I. Barnes, MET Economics Ministry of Environment and Tourism Andries Alberts, Park Warden Ministry of Environment and Tourism, Khaudum Allan Kirby, Director National Park & Tsumke Conservancy Wild Dog & Crazy Kudu Safaris Richard Diggle Dr. Chris Brown, Executive Director Integrated Rural Development & Nature Namibia Nature Foundation Conservation
Mr. L. Chris Weaver, Chief of Party Penny T Akwenye LIFE Plus Project, World Wildlife Fund Namibia National Planning Commission
Mr. Andee Davidson, Tourism & Business Helmut Tijikurudu Specialist Ministry of Environment and Tourism LIFE Plus Project, World Wildlife Fund Shadrack Siloka Ernst Simon, Managing Director Ministry of Environment and Tourism Urban Dynamics Chrispin Mulisa, Park Warden Jonathan Smith, Special Assistant to the Permanent Ministry of Environment and Tourism, Mamili Park Secretary Ministry of Environment and Tourism Brian Jones, MET Consultant for Social Assessment Issues Jacqueline W. Asheeke, CEO Federation of Namibian Tourism Associations Ben Beytell, Director, Directorate of Parks and (FENATA) Wildlife Management, MET
Midori Paxton, Project Coordinator, SPAN Project Ulrich Boois, Deputy Director, Parks and Wildlife Management, MET Mannfred Goldbeck, Managing Director, Gondwana Desert Collection
52 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
Appendix VI: Partial list of Environmental, Social, Health And Safety Issues & Effects Reviewed During Field Visits
Water Management o Increase traffic o Water scarcity and pollution o Trail impacts o Ground water availability & use o Road and trail construction or o Fresh water scarcity & increase demand reconstruction o Self-drive control and impacts Waste Water and Sewage o increase of waste water & sewage on Social existing systems o Need for rezoning o sewage disposal o Impacts of moving people/populations (resettlement) Aquatic, Marine and Riparian o Effects to local indigenous populations o Proximity to floodplains, wetlands or and traditional customs and practices other water bodies. o Insensitivity of tourists to indigenous o Proximity to ephemeral stream courses cultures o Water quality, flow or volume o Increase in population and resulting o Fisheries stocks demands o Employment or changes to local or Energy regional work force o Energy use impacts (i.e. fuelwood o Archeological resources, including gathering and resulting deforestation) monuments o Electrical grid use o Creation of employment opportunities o Use of solar projects by gender, age, etc. o Gas consumption Wildlife Air o Game reserve impacts o Emissions & burning (air pollutants) o Interruption of migratory patterns o Smell & odor o Feeding and breeding patterns
Construction and Landscaping Health, safety & environmental pollutants o Materials, borrow sites o Use of toxic or hazardous substances o Site clearing requirements and o Domestic or industrial waste disposal disturbance (hectares) o Noise & light pollution o Appropriate design & aesthetics o Pesticides and herbicide use o Wood use and scarcity o Scale of structural developments Biodiversity (housing & offices) o Unique or sensitive landscapes, scenery, o Aesthetics of proposed construction habitats, ecosystems or species o Soil erosion potential o Introduction of invasive, exotic or alien species Vehicles and transportation o Increase of wildfire o Vehicle oil & fluid issues o Illegal or unsustainable harvesting of o Off-road vehicle use (quads) plant and animal products
53 USFS Trip Report: MCC Namibia Tourism Due Diligence, Social and Environmental Assessment
Figure 1: Namibian Environmental Assessment Procedure
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