Victoria Falls Bits and Blogs: UNESCO Report Raises Concerns Over Controversial Zambian Hotel Development at Victoria Falls

Friday 22 July 2022

UNESCO Report Raises Concerns Over Controversial Zambian Hotel Development at Victoria Falls

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.