Environmental & Social Review Summary
Project Number
10171
Company Name
ABERCROMBIE & KENT BOTSWANA PTY LTD
Date ESRS Disclosed
Feb 5, 2010
Country
Botswana
Region
Africa
Last Updated Date
Jan 2, 2017
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Jun 30, 2000
Signed : Jul 13, 2000
Invested : Sep 5, 2000
Sector
Resort Hotel (Including Lodges)
Industry
Tourism, Retail and Property
Department
Regional Industry - MAS Africa
Project Description
ENVIRONMENTAL REVIEW SUMMARY
Project Name Botswana - Chobe Chilwero Lodge
Region Sub-Saharan Africa
Sector Hotels and tourism
Project No. 010171
______________________________________________________________________________
1. This project involves the reconstruction of an existing tourist lodge in Botswana by Abercrombie & Kent Botswana (Pty) Ltd. (A&K). A&K owns two tourist lodges in Botswana: Piajio (now called Chiefs) Camp in the Moremi Game Reserve in the Okavango delta, and Chobe Chilwero Lodge, adjacent to Chobe National Park. Chiefs Camp, for which IFC provided a construction loan, is a new 24-bed lodge that A&K opened in September 1999. The project was successfully completed ahead of schedule and is now experiencing healthy occupancies at average achieved rates that are well ahead of forecasts. Chobe Chilwero is an older lodge overlooking the Chobe River, just inside Botswana''s border with Zimbabwe, Zambia, and Namibia, about 90kms from Victoria Falls. A&K bought the lodge in 1998 and undertook a "soft" refurbishment of the property at that time, intending to rebuild much of the lodge at a later date. The new lodge is to be in the same ''footprint'' as the existing facility; however, the size will be increased from 8 to15 two-bed chalets, and a new central dining, lounge and administration block will be added. The new lodge will incorporate high quality materials and be of a more up-market design than the existing one.
2. This is a Category B project according to IFC''s environmental review procedure because specific impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. The key environmental health and safety issues that were analyzed are as follows:
• site selection criteria;
• compliance with all relevant laws and regulations of the Botswana Department of Wildlife and National Parks, Chobe Land Board and Northwest District Council;
• source of water and power including fuel storage, if applicable;
• recycling and disposal of solid wastes;
• disposal of liquid wastes, including grease, waste oils and sewage;
• impacts of construction and operation on the riverine ecosystem, including access of local wildlife populations to the Chobe rivers;
• impacts on the surrounding area of auxiliary recreation activities such as game viewing;
• impacts on vegetation and wildlife of infrastructure including game trails, roads, staff housing and air strip, if applicable;
• impacts on local communities;
• public consultation with all interested or affected parties;
• health and safety issues pertaining to game walks, boating and other recreation
activities;
• use of CFC-free cold storage;
• employee training, health and safety; and
• fire protection, life safety, and emergency response measures.
3. IFC has reviewed A&K’s architectural drawings for the renovation, as well as its plan for addressing each of the environmental issues listed above. IFC also discussed the legal authority and public consultation procedures under which the project was approved with representatives of the Botswana Department of Wildlife and National Parks, Chobe Land Board and Northwest District Council. In addition, IFC recently visited A&K''s camp in the Okavango, Chief''s Lodge, to assess compliance with environmental requirements. Key elements of the information reviewed are described below.
4. Site selection criteria: The 10 ha concession area is located in the Kasane Forest Reserve, which is under the jurisdiction of the Chobe Land Board, Northwest District Council and Department of Forestry (part of the Ministry of Agriculture). The reserve is adjacent to the Chobe National Park and 5km from the town of Kasane. The existing 16-bed lodge was constructed in 1984 and acquired by A&K in 1998. The plans to rebuild and expand the lodge to 30 beds were submitted to and approved by the Northwest District Council, which has planning authority jurisdiction under the provisions of the Town Planning Act. Because the land is located in a forest reserve and not a gazetted National Park or Game Reserve, the Department of Wildlife and National Parks (DWNP) does not have jurisdictional authority over planning and approving the development, although A&K''s lease is with the Land Board. However, both the Land Board and Department of Forestry were part of the Technical Team that reviewed the project proposal. A&K must obtain DWNP vehicle permits to enter the Chobe National Park, as well as for any boats used to take guests on to the Chobe River; these permits are obtained when paying Park fees. Boats are licensed by the Department of Water Affairs.
5. Compliance with all relevant laws and regulations of the Botswana Department of Wildlife and National Parks, Chobe Land Board and Northwest District Council: A&K has its own code of conduct for guides operating in wildlife areas. In addition, regulations established by the Department of Wildlife and National Parks (DWNP) include strict requirements for operators'' behavior while traversing inside a National Park. These include prohibitions on off-road driving, littering, and certain behaviors on the part of both guides and guests. Failure to comply with any of these requirements can result in fines or the loss of the guide''s and/or operator''s vehicle license. A&K has never been cited for a compliance violation at either of its operations in Botswana.
6. Source of water and power including fuel storage, if applicable: At the time A&K purchased the lodge, water for all purposes was extracted from the Chobe river by means of a diesel pump. A&K obtained the existing water right with the purchase of the lodge. At the request of DWNP, however, A&K replaced the aboveground diesel pump with a buried centrifugal pump to eliminate the noise created by pumping. The lodge consumes a total of 20m3 (20,000 liters) per day for all purposes, including irrigation of the lawn and gardens. Of this, 10m3 are used for domestic purposes, which is treated using a carbon/fiber/ultraviolet filtration system to ensure that it meets international standards for potability. Electricity is obtained from the national grid. At A&K''s request and cost, Botswana Power installed a new substation just inside the northern boundary of the concession to bring electricity to the site. The lines are taken from the existing overhead lines going to the nearby Chobe Game Lodge, at which point a buried line runs for over 1000 meters to the substation. The buried line, which runs through the Chobe National Park, was put in at the cost of A&K to avoid visual impacts on both the National Park and the forest reserve. New phone lines were also buried, at A&K''s cost, to reduce visual impact. Although power cuts are not frequent in the Kasane area, A&K has installed a backup generator to run essential appliances -- primarily refrigeration and cold storage equipment -- in the event of a power cut. The generator is equipped with a secondary containment structure to prevent contamination in the event of a leak, and is housed in a soundproofing structure to reduce noise impacts. All cooking will be done with gas. The cylinders will be fitted to a manifold for safety reasons, and located in a secure, covered area adjacent to the kitchen to facilitate removal and replacement. The storage area will be posted with appropriate warning signs (no smoking, no naked flames) in English and Setswana.
7. Recycling and disposal of solid wastes: It is A&K’s corporate policy to promote environmentally responsible management in all of its properties. Recyclable materials such as paper or cardboard, rather than plastic, are used wherever possible. Soaps, shampoos and other guest amenities are purchased from a British company specializing in safe, biodegradable products for the tourist industry. As at Chief''s Lodge, A&K will utilize stainless steel containers for these products, rather than the conventional plastic bottles that must be disposed after use. The stainless steel containers, on the other hand, can be sterilized and refilled. All organic wastes will be composted. All paper and other combustible wastes will be incinerated in a high performance unit to be imported from South Africa. Bottles, cans, and recyclable plastics will be collected, sorted and transported to Kasane to be recycled. Construction wastes are being utilized wherever possible: rubble is used in the foundations for new structures and wooden poles are being sold to local builders and farmers for re-use.
8. Disposal of liquid wastes including grease, waste oils, and sewage: All wastewater from the facility will drain to septic tanks and from there to a single french drain system. Grease traps will be installed in the kitchen to trap fats and grease before greywater is discharged. Vehicles and other equipment will be serviced in a central maintenance area, which will be equipped with a work pit and concrete floor, to retain any grease and oil spilled during maintenance activities and prevent contamination of soils. A&K is presently seeking a petroleum product supplier in Kasane or Victoria Falls to whom it can transport all waste oils and grease for recycling. The pool is salt chlorinated to minimize maintenance and prevent contamination to soils as a result of backwashing. Water discharged during backwash operations drains to a separate soakaway to prevent contamination of bacterial activity in the main septic tanks.
9. Impacts of construction and operation on the riverine ecosystem, including access of local wildlife populations to the Chobe river: A&K has scheduled major construction activities to take place during the dry season, although the site is located at a significant distance from the Chobe river and thus construction is highly unlikely to impact river quality or flow. IFC recommends that the location of new structures be planned to ensure that no mature trees need be removed, and that this restriction be incorporated as legally binding covenants in the contracts entered into by the sponsor and construction contractor(s). A&K has agreed to this recommendation. A&K and Group Five Botswana, the prime construction contractor, recently completed a 3-day ''partnering'' workshop to review a number of issues, including environmental management. The purpose of the workshop was to identify issues that must be addressed in the context of the construction contract, in order to find ways to handle these more effectively. As noted above, the lodge has been in existence for 16 years, and the 10 ha property is completely surrounded by an elephant fence. As a result, there are no significant wildlife populations in the forest, and no migration routes pass through the property. In keeping with requirements of both the Department of Forestry and DWNP, no exotic species will be planted at the site, with the exception of a species of grass, which is permitted. A&K’s professional guides at the camp will assist the DWNP in monitoring wildlife populations and their movements through Chobe. A&K guides will also provide tracking and monitoring assistance and communications support to DWNP personnel involved in anti-poaching operations. A&K''s head guide at Chobe Chilwero is an honoree warden with the DWNP.
10. Impacts on the surrounding area of auxiliary recreation activities such as game viewing: A&K proposes to conduct wildlife viewing activities both in 4-wheel drive vehicles and by boats on the river, accompanied at all times by a professional guide. At the present time, DWNP regulations do not allow either night drives or guided walks in the Park. The Chobe Wildlife Trust, a non-governmental organization, is presently conducting a study that will result in a draft Chobe River Frontage Land Use Plan. It is expected that when the draft plan comes into force it will, inter alia, establish a permit system that limits the number of vehicles and boats that can enter the Park. DWNP has established and strictly enforces restrictions on vehicle and guide behavior. A&K will have a total of four vehicles for use in game viewing, transport of guests to and from the lodge, and any other guest activities. A&K has equipped its boats with new 4-stroke motors, which generate significantly less engine noise than do conventional engines. Because these motors do not have a fuel oil mixer, discharges of fuel and oil to the river are reduced considerably.
11. Impacts on vegetation and wildlife of infrastructure including game trails, roads, staff housing, and air strip if applicable: Unlike its operations in the Okavango, A&K will not be establishing new infrastructure such as game trails, roads and tracks, A&K will, however, be upgrading the staff and management housing, including rebuilding the entire staff village. When complete, staff housing will include 8 junior staff houses with shared men''s and women''s ablution blocks, 3 senior staff units with ablutions, and 3 manager''s houses. A&K will provide accommodation on the property for essential staff (e.g., the lodge manager) as well as for staff who work late shifts and are thus not able to return home. Staff housing exceeds the requirements of relevant national and municipal guidelines. All housing will be supplied with electric lights, electric outlets, furniture, linen, and hot and cold water from electric geysers. All staff will be provided with daily breakfast, lunch, dinner and morning tea prepared by the central kitchens; no cooking will be done in the staff units. The expansion plan for the facility includes construction of a staff dining area and recreation room, to be equipped with a television set. Transport will be provided daily for those staff who do not live on site. A&K are constructing changing facilities with lockers for staff who will live off site. All structures will be located within A&K''s fenced property. Guest activities in the Park and on the river are strictly controlled by DWNP.
12. Impacts on local communities: Because the lodge has been in operation for the past 16 years, the impacts of its renovation and expansion are expected to be minimal. As noted above, construction laborers, construction materials, and new lodge employees are being sourced locally, wherever possible. The construction contractors, a Botswana company, have hired a crew drawn largely from nearby communities, and these workers are being given on-the-job training in construction methods. The lodge curio shop will contain traditional handicrafts made by nearby villagers, who will retain all of the money earned from the sale of these items. A&K is also involved in an education program with a local school, which will be run by one of the managers at Chobe Chilwero, who is a qualified school teacher. The program is to be funded by A&K''s ''Global Foundation,'' a non-profit environmental organization. A&K funds the foundation by donating a portion of turnover from all of its companies around the world.
13. Public consultation with all interested and affected parties: At the time the original developers of the Chilwero property applied for the concession area in 1985, the allocation decision was made by the Chobe Land Board, in its capacity as "trustees" of tribal land in the Chobe area. As is required under Botswana regulations, the Land Board consulted with other members of the relevant Technical Team, including DWNP and the Forestry Department (which operates under the auspices of the Ministry of Agriculture). A concern was expressed at the time by the District Land Use Planning (DLUP) unit that allowing development within the Forest Reserve might establish a precedent that could eventually lead to an unacceptable level of development within a protected area. By the time this concern was articulated, however, the Technical Committee had already endorsed the development and the Land Board had approved the allocation of 10 ha of land to Chilwero Lodge. In light of the concern raised by DLUP, a decision was made that no further development would be allowed in the Kasane Forest Reserve.
14. At the time the 10 ha property was sold to A&K in 1998, the area around Kasane had undergone considerable development and hence been designated as an official intensive development "planning area" (the ''Kasane-Kazangula Planning Area''). As such, review and approval of A&K''s proposed redevelopment was handled by the Northwest District Council, which has planning authority jurisdiction under the provisions of the Town Planning Act. The Council is an elected body and represents the interests of the greater Kasane and Kazangula communities. The Council''s Physical Planning Committee first vetted the proposal, with advice and consultations from a Technical Team, which again included the Chobe Land Board, DWNP and Forestry Department. Public comments may be made on any such proposals either through the Land Board, as the tribal authority, or the Council, as the elected planning area authority. The proposal was approved in 1998.
15. Health and safety issues pertaining to game walks, boating and other recreation activities: All vehicles will be equipped with fire extinguishers, first aid kits and radio links with both the camp and A&K’s base operations in Victoria Falls. The camp will employ 5 licensed, experienced guides, and game viewing in vehicles or by boat will be done in the accompaniment of one of these guides. All licensed guides have received basic first aid, fire safety and emergency response training. The camp will have telephone, fax and email lines, and a medical emergency service will be on call 24 hours a day. Guests who become ill or injured while at the camp will be transported immediately to Kasane or Victoria Falls for treatment or, in serious cases, evacuated by aircraft to Johannesburg. A&K will install lights along all of the walkways between public areas and guest rooms (powered by electricity with generator back up), to ensure guest safety at night.
16. Use of CFC-free cold storage: A&K requires that its lodges be equipped with cold storage equipment that utilizes non-CFC refrigerants, in accordance with the provisions of the 1987 Montreal Protocol on Substances that Deplete the Ozone Layer.
17. Employee training, health and safety: A&K has retained all of the 18 existing employees, and retrained them in accordance with standards A&K training programs. In addition, the lodge will need to hire an additional 18 employees to handle the expanded number of rooms and to ensure the level of service that A&K requires of all its establishments. With the exception of staff requiring special skills and/or training (e.g., professional guides, food and beverage manager, general manager) every effort will be made to recruit staff locally, from Kasane or other nearby villages. All staff will be provided with basic training in hygiene, housekeeping, guest relations and fire prevention and response. Staff training will also include information on prevention of communicable diseases such as HIV and malaria, and materials will be provided so that staff can share this information with others in their home villages. Malaria prophylaxis will be available to all staff free of charge. A&K staff at the camp will be able to provide basic first aid for employees who sustain minor injuries on the job. In the event of a more serious injury, the staff member will be transported to the closest clinic or to hospital in Kasane. As is done at its other lodges, A&K will ask that a workers committee be established at the time the new lodge''s operations commence, through which employment and other issues can be discussed with camp management.
18. Fire protection, life safety, and emergency response measures: A&K has included extensive fire protection and life safety provisions in their plans for the camp. Each guest unit will be equipped with a fire extinguisher, and extinguishers will be placed in appropriate locations throughout the public areas. The kitchen will be housed in a brick and concrete structure, which will prevent a fire in the kitchen from spreading to other structures. The kitchen will be equipped with cylinder extinguishers (foam and dry powder) as well as an automatic fire suppression system (also powder or foam) in the main extraction hood over the stove. In the event of a major grease fire, heat from the fire activates the unit, which floods the area with a fire suppressant. All other structures – including public areas, back of house facilities and staff housing – will be equipped with appropriate fire extinguishers. Public areas will be equipped with appropriate signage (emergency exits, fire points). A&K will install fire hydrants that draw water from irrigation system. All staff will undergo requisite fire prevention and response training, and fire drills will be conducted on a regular basis.
19. Based on its review of available information regarding potential environmental impacts and proposed mitigation measures, IFC concludes that the proposed project is being designed and will be operated to meet pertinent Government of Botswana requirements and all relevant World Bank policies and environmental, health and safety guidelines.
20. IFC will monitor ongoing compliance with World Bank Group policies and guidelines during the life of the project by reviewing and evaluating the Environmental and Social Monitoring Reports (AMRs) to be submitted annually to IFC by the sponsor, and by conducting periodic site visits during project supervision.
Environmental and Social Mitigation Measures
Broad Community Support
Related SII
