A UNESCO report, due to be
presented to the next meeting of the World Heritage Committee, warns that the
Victoria Falls World Heritage Site "is
facing increasing threats from individual and cumulative infrastructure
developments" and concludes that the Outstanding Universal Values for
which the Falls are globally recognised could be considered to be in danger if
current development proposals - most notably the Zambian Mosi-oa-Tunya Resort
development - proceed without the appropriate level of consideration for the environment.
Work started on the development in July 2020 with a ground-breaking ceremony held by then-President Edgar Lungu and has progressed rapidly, with the resort due to open before the end of this year (Victoria Falls Bits and Blogs, August 2020).
Mosi-oa-Tunya development (July 2022)
The report follows a
UNESCO Reactive Monitoring Mission to the site, first requested in 2019 but
delayed until February this year by the global pandemic. The objective of the
mission was recorded as being to “assess
the potential threat posed to the property’s OUV by the growing tourism
development pressure in and around the property, the potential impacts of the
Batoka Gorge Hydro Electric Scheme (BGHES), to review the regulations to
control this pressure and to make recommendations to the Committee on the proposed
boundary modification.”
The report was due to be
presented to the World Heritage Committee at their June Conference, planned to
be held in Russia but which
was postponed at the last minute due to the Russian invasion of Ukraine. While
the Conference is still to be re-scheduled the report, which had been
circulated to Zambia and Zimbabwe for information, has now entered the
public domain and has been picked up by press and media in England, Zambia
and Zimbabwe.
Mosi-oa-Tunya Resort
The report is especially
critical of the Mosi-oa-Tunya Resort development in Zambia, a development site with a
controversial history. Development of the site was first proposed in 2006,
resulting in a previous Reactive Monitoring Mission to the site, and resulting
in a recommendation that “the site should be considered for inscription on the
World Heritage in Danger List, if the project is approved for implementation.” The
development was subsequently abandoned, before being resurrected in 2018.
Site of Mosi-oa-Tunya Resort Development
The report highlights
several areas of concern relating to the development, most notably
confusion over whether the development was within the World Heritage Site, the
surrounding Buffer Zone, or outside both these areas - and the subsequent
implications for its approval by the Zambian Environmental Management Agency (ZEMA). (The
site borders the boundary of the World Heritage Site and is thus clearly
located within the Buffer Zone which surrounds the property.)
"Firstly, the ESIA states that 'the proposed
project site is in a World Heritage Site which has to be protected'. The ZEMA
decision letter however states that the 'project site is located near the
Victoria Falls World Heritage Property buffer zone' (point 3.1.2) and that 'no
construction shall be undertaken in the buffer area of the Victoria
Falls World Heritage Site area' "
In addition the report
raises further serious concerns over apparent infringements of the development guidelines
approved by ZEMA, including issues with the protected riverside margin, which is supposed to be left undeveloped, and consideration of wildlife movements, including elephant, through the site.
"Secondly, the decision letter specifies that
the structures shall be constructed 'at least 70 metres from the highest flood
line of the Zambezi and Maramba
Rivers' (point 3.1.7).
However, the construction appears to have been undertaken only in line with the
ESIA that 'the developer will leave 50m from the edge of the river'. Data on
the highest flood line was not made available to the mission and it is unclear
whether such data have been collected. The mission determines however, based on
presented information that the developer has not complied with this condition
of approval.
"Thirdly, the
letter states that 'site selection shall take the movement of animals into
consideration and wildlife/animal corridors shall be avoided at all times,
throughout the project cycle' (point 3.1.26). At the same time the letter also
acknowledges that the site is an active wildlife area frequented by elephant
and hippos, and that 'one of the corners of the project site is the confluence of the Zambezi and Maramba Rivers. Confluences are said to provide
unique habitats which support important ecosystem functions and may even be
biodiversity hotspots' (point 3.1.2). While noting that the project proposal
has already been amended to reflect the condition of ZEMA that no fencing will
be erected around the resort, the site selection would appear to be in
contradiction to the aim to ensure the natural movement of wildlife, especially
the area around the Maramba River, which is a known elephant corridor."
Despite UNESCO apparently believing the development had been amended to not include fencing, recent photographs of the development appear to show fences surrounding the riverside margins of the site.
In addition to these concerns, it appears the developer has constructed an additional floor to the main hotel building, which has been constructed with four levels, against the plans for a three-floor building approved by ZEMA.
"Fourthly, the
ZEMA authorisation is given on the basis of the proposal in the ESIA that the 'hotel
will have three floors that are: ground floor, first floor and second floor'
and a building will have a height of 16.15m. However, the mission observed that
the middle section of the building comprises four floors (see aerial image in
figure 1). There is therefore a need to clarify whether the building, as
constructed, is still within the approved height limit.
Mosi-oa-Tunya Resort Development (April 2022)
The report concludes that the developers appear to have failed to comply with several of the conditions of approval for the construction and that ZEMA should consider the suspension of their approval of the project until the identified concerns are resolved.
"Fifthly it
requires that 'Mukuba Property Development Company Limited shall restrict
construction activities to the dry season throughout the project cycle' (point
3.1.45). The mission visited the project site during the
wet season in February 2022 and observed that the construction activities were
actively taking place. Noting that the dry season is generally between July and
December, it would appear that the
developer has not complied with this condition of approval."
"Taking note of
the provision in the ZEMA decision letter that the 'Agency may suspend or
cancel the Decision Letter without notice should Mukuba Property Development
Company Limited fail to comply with any
condition of approval' (point 3.6), the mission considers that there are
important gaps that should trigger at least the suspension of the project until
the matters above are addressed.
"The mission
additionally observed other ecological modifications including artificial
reinforcement of the embankment thereby altering the natural processes of
erosion and deposition of the riverine system, but it appears that the impact
of such alterations has not been considered. This further supports the
mission’s view for the need to strengthen the environmental considerations
through a revised ESIA."
The report goes on to make
the following specific recommendations:
"Suspend the
construction and operation of the Mosi-oa-Tunya Livingston Resort, located
within the buffer zone of the property in Zambia, until the legality of the
project is verified in line with the conditions of approval
issued by the Zambian Environmental Management Authority (ZEMA), which:
a) does not permit any
construction within the World Heritage site buffer zone; and
b) requires a
guaranteed minimum distance of 70 metres between the resort and the highest
flood line of the Zambezi and Maramba
Rivers.
"Continue the
suspension of the Mosi-oa-Tunya Livingstone Resort development as a follow on
from R1 until the Environmental and Social Impact Assessment (ESIA) for the
project has been revised to adequately
demonstrate that there will be no impact on the Outstanding Universal Value
(OUV) of the property including its conditions of integrity, in line with
Committee Decision 44 COM 7B.177, and a
comprehensive Environmental and Social Management Plan (ESMP) for the implementation
of mitigation measures has been developed. Both the revised ESIA and ESMP
should be submitted to the World Heritage Centre for review by IUCN before the
project resumes, in the case that the legal suspension according to the
compliance with the ZEMA conditions of approval is lifted."
It should be noted that
the report has not been officially released by UNESCO (and may be subject to
final amendment) and that it is the World Heritage Committee, when they finally meet for their rescheduled Conference, that will decide
on whether or not to formally adopt the reports recommendations.
In April 2021 Radisson
Hotel Group announced that it would operate the management of the new hotel, to be
called Radisson Blu Resort Mosi-oa-Tunya and that the resort was on track to open in late 2022 (Victoria
Falls Bits and Blogs, April 2021).
"Late 2022 will see
Radisson gain a foothold at the Unesco World Heritage-listed Victoria
Falls... The sustainability-focused
resort... aims to obtain Edge green building certification as well as sign
the Unesco Sustainable Tourism Pledge." (Top Hotel News, December 2021)
Construction of the hotel is believed to be progressing.
Mosi-oa-Tunya Resort Development (July 2022)
Download the report: 2022 World Heritage Centre/IUCN Reactive Monitoring Mission Report.
Read more on the background to this development: Victoria Falls Bits and Blogs (August 2020) New Hotel Development Threatens Livingstone's Elephants
Read more on current wave of tourism developments which threaten Victoria Falls: Keep Victoria Falls Wild.