Papers from Dr SCJ Joubert for your discussion - Tue Aug 23,

General Information & Discussion on Hotels in Kruger
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Papers from Dr SCJ Joubert for your discussion - Tue Aug 23,

Post by iNdlovu » Mon May 21, 2012 12:40 pm

Over the weekend of 5 -7 August 2011 various invited media representatives were hosted in the Kruger National Park. The visit was ostensibly to allay the fears expressed by conservationists regarding the building of hotels in the Park. Media reports following the site visit and briefing of the proposed Malelane Safari Resort have, however, not put oil on troubled waters but rather raised a number of seriously disturbing concerns.

If the media reports are anything to go by, the following needs to be noted:

• According to Die Burger (8.08.2011) Dr Mabunda, CEO of SANParks, asserted that nature lovers and visitors to the Kruger Park have nothing to fear regarding the two proposed hotels, at Malelane and Skukuza. Translated from the Afrikaans he was quoted as saying “if anyone can come with a better suggestion to generate funds on a sustainable basis for SANParks’ continued conservation efforts, we will be keen (willing) to look at them. In the meantime we would like to assure the public that the hotels pose no threat to the biodiversity of the Park.”

It should be pointed out that three requests submitted to SANParks to open the proposed hotels to public debate, the first in April 2010, were totally ignored. In the same Beeld article Dr Mabunda is quoted as stating that there is no law that compels SANParks to share their decisions with the public. Furthermore, it continues with: “in addition it would have been insensible earlier, while the hotels were in a conceptual stage, to start a public debate. It is a huge challenge to convince people with an ‘antiquated (verouderde) philosophy of nature conservation’ of the value and necessity for sustainable development in parks.”

These are highly contentious statements. “If anyone can come with a better suggestion …” How on earth can it be expected of the public to make constructive contributions if deliberately excluded from the conceptual phases of a project?!! It is, furthermore, acknowledged by Dr Mabunda that the public were deliberately excluded. This is in contravention of the principles and prescriptions of the National Environmental Management Act which makes public participation compulsory. NEMA also makes it compulsory that all possible options be thoroughly investigated. It is obvious that SANParks conveniently ignored this in their ill-considered quest to go ahead with the two hotels.

Is SANParks above the law?

• In several of his public statements Dr Mabunda has tried to justify his pursuit of the hotels by brushing aside the sentiments of stakeholders in the most arrogant and offensive manner. In the latest media reports this attitude is, again, clearly evident. People with ‘an antiquated philosophy of nature conservation’ or those who “… do not consider the scientific viability of such developments” (The Citizen, 13.08.2011).

Dr Mabunda needs to know that he is addressing the legitimate stakeholders of our national parks. His attitude reflects a total disregard and contempt for stakeholders and this attitude is both in violation of the NEMA and is intolerable of a person holding high public office.

• Business Day (8.08.2011) reported as follows: “SANParks CEO Dr David Mabunda said promoting biodiversity conservation was not the only purpose of environmental legislation. ‘A view that national parks are proclaimed to be pristine areas managed exclusively for solitude untrammeled by commercial and social activities is incongruent with … the constitution, which requires the simultaneous promotion of justifiable economic and social development,’ he said.”

This is a most disturbing statement, coming from the CEO of our national parks. National parks are the highest tier in the different levels of conservation areas. They are, indeed, created to represent the biodiversity of our country in its most pristine state possible. This guideline is contained in the guiding principles of the International Union for the Conservation of Nature (IUCN) and our own Protected Areas Act. National parks are set aside for spiritual, educational, scientific, recreational and tourism purposes and may contribute to the economy, where feasible. Visitors are, therefore, allowed access to national parks to experience, appreciate and be inspired by the wilderness ambience and ‘solitude untrammeled by commercial and social activities …’ This is also the very reason why up to 94% of the national parks stakeholders voted against conferences and ‘events’ in national parks and voted for wilderness opportunities and “close-to-nature” experiences – the results of attitude surveys commissioned by SANParks but conveniently ignored.

It is not clear how Dr Mabunda can reconcile the building of two hotels in the most overcrowded area of the Kruger Park with “justifiable economic and social development”. And that by using the constitution as a smokescreen. That is ludicrous.

In any event, the Kruger Park already contributes more than R2billion per annum towards the national economy. A subsidy in the region of a mere R160m/annum would suffice to help sustain all our national parks!

• According to The Citizen (13.08.2011) Dr Mabunda “claimed that overdevelopment in the Kruger Park would not happen as South Africa was limited by international standards to which they adhered.” The two proposed hotels are in an area of the Park that has been identified as overcrowded since the 1960’s. Can SANParks please let us know what the limits of overdevelopment will ultimately be and where the line will be drawn!

• “Mabunda said there were more than 200 hotels in national parks in the US and more in Canada” reported The Citizen (13.08.2011). This figure is questioned and should be challenged. It will be followed up with the relevant authorities.

Hotels in the US, Canada or anywhere else in the world are irrelevant to the debate on the hotels in the Kruger Park. This is Africa, in fact, South Africa. Our ecosystems and untrammeled pristine areas all have their own ambience. Those of the Kgalagadi, Highveld, Lowveld, montane regions, coastal areas, etc all differ and have their own attractions. The Lowveld, in general and the Kruger Park, in particular, has its own ambience. Through the years the Kruger Park has established its own ethos and this has contributed towards its international iconic status. To equate Kruger with the US, or any other national parks, is senseless and off the mark.

The hotel in the Golden Gate National Park was a mistake. It should never have been built.

• The assertions given by the Deputy Minister of Environment, Ms Rejoice Mabudafhasi, are most unfortunate. The perception created is that the government has already approved the hotels (caption: ‘State backs plan for 5-star hotel in Kruger Park’, Business Day, 8.08.2011), subject to environmental impact assessments. The question is whether she has, in the process, compromised her department. What she failed to state is that the EIA being undertaken for the Malelane Safari Resort is a scaled down process which does not include public scrutiny of the strategic decision which has paved the way for the hotels. The possibility of hotels has, at no stage, been subjected to a public debate and neither has the rejection of conferences and ‘events’, let alone hotels, by an overwhelming majority (average 90%) of stakeholders been taken into account.

The Kruger National Park, as all national parks, is on the highest conservation tier. It justifies a full EIA. Not the scaled down version presently being undertaken.

• In an email, dated 14 April 2010, Dr Mabunda stated that “… the survival of the entire national park system, in my view, supercedes (sic) that of an individual park like Kruger or Table Mountain.” This remark is disturbing. What is Dr Mabunda getting at? Is he prepared to sacrifice the Kruger Park, by way of commercial exploitation, for the sake of other national parks? Is he, once again, prepared to exclude stakeholders from his plans and arrogantly proceed on his own?

South Africans have the right to know what is implied in the statement.

Finally, the assertion that “the face of the Kruger National Park is set to change quite drastically in the future, but SANParks say that there should not be such controversy about it” is anything but comforting. SANParks is losing its credibility, its dignity and the respect of its stakeholders. This is not a healthy situation and should be addressed as a matter of urgency.

The statements above, correctly or incorrectly quoted from public briefings and the perceptions they are wilfully or incidentally intended to create, give credence to recommendations made in a separate document and worth repeating here with the plea that they be given urgent attention:

1 It is contended that the two upmarket hotels proposed for the Kruger National Park are contrary to the intent and spirit of the guidelines of the International Union for the Conservation of Nature (IUCN) and the Protected Areas Act.

RECOMMENDATION: If there is any ambiguity in the interpretation of the intent and spirit of the Protected Areas Act it should be subjected to independent legal opinion before the hotel projects commence. If necessary, amendments to the Act should be considered to ensure accurate assessment and interpretation for this and future generations.

2 It is contended that the principles and several of the clauses of the National Environmental Management Act have been breached with regard to the proposed Malelane hotel and the conference centre at Skukuza.

RECOMMENDATION: The fact that various parties have questioned SANParks’ compliance with NEMA justifies a thorough investigation by independent legal experts. The credibility of SANParks, South Africa’s premier conservation agency, should be without blemish in its adherence to the intent and spirit of the laws intended to protect its core interests.

3 It is contended that the commercialisation policy is invalid, if not illegal, due to the lack of stakeholder endorsement via public consultation / participation, as prescribed by the National Environmental Management Act. Fear exists that there are no limits or restrictions to the commercialisation programme.

(a) independent legal guidance be sought on the legality of the commercialisation policy;
(b) if accepted, clear, unambiguous and transparent parameters be set for the further implementation of the commercialisation policy.

4 The essential and immense socio-economic obligations of the Government are acknowledged and respected. The expected revenue of the State is R755bil, the required annual SANParks grant is in the region of R160m, i.e. 0.02% of the total revenue. The KNP contributes R2bil / annum to the national economy. The State has a responsibility towards the environment, and in particular to its national parks.

1. The State needs to be engaged to secure its commitment towards its national parks and not be allowed to abrogate on its responsibility regarding financial support for our national parks.
2. SANParks needs to investigate all possible avenues of generating funds within its legal and operational limits, and in an open, participatory manner. This has not been done though mandatory under NEMA.
3. Under the present economic situation SANParks needs to implement austerity measures to limit expenditure to essential services.

Dr SCJ Joubert
22 August 2011

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