Environmental & Social Review Summary
Project Number
9608
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 23, 1999
Signed : Jul 10, 1999
Invested : Aug 12, 1999
Sector
Resort Hotel (Including Lodges)
Industry
Tourism, Retail and Property
Department
Gbl Ind, Manufact, Agribus & Services
Project Description
ENVIRONMENTAL REVIEW SUMMARY
Project Name: AEF/BOTSWANA: Abercrombie & Kent
Region: Sub-Saharan Africa
Sector: Hotels and tourism
Project No: 009608
1. This project, which is to be financed through the Africa Enterprise Fund (AEF), involves development of a new tourist camp in Botswana by Abercrombie & Kent (A&K). A&K is an international tour operator/destination management company with 3000 employees and 27 offices worldwide. It specializes in packaging vacations for the mid to upper range of the tourist market. Having successfully operated its destination management companies in Africa for a number of years, A&K is now developing high quality lodges of its own in prime areas. In southern Africa it has focused on Botswana, and the Okavango and Chobe areas in particular. In a recent tender process, A&K was awarded a 15-year concession to construct a 24 bed camp at a site in the Mombo medium density tourism zone in Moremi Game Reserve in the Okavango delta. Work has already started on this project.
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 and land lease arrangements with Government;
• distribution and administration of fees, rent, lease payments to tribal and other authorities;
• compliance with all relevant laws and regulations of the Botswana
Department of Wildlife and National Parks;
• 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 Okavango ecosystem, including access of local wildlife populations to the delta;
• impacts on the surrounding area of auxiliary activities such as game viewing
and other activities;
• impacts on vegetation and wildlife of infrastructure, including game trails, roads, staff housing, and airstrip if applicable;
• potential 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. Regulations established by the Department of Wildlife and National Parks (DWNP) and Ministry of Local Government and Lands include strict requirements for the environmental management of all lodge developments in Botswana, both during construction and operation. As part of the tendering process, A&K was required to submit a detailed project proposal, which included an environmental impact summary and management program for the proposed project. According to the DWNP, this summary and management program are equivalent to a stand-alone Environmental Impact assessment (EIA). These documents include detailed plans for avoiding or mitigating negative environmental impacts, ensuring minimal use of water resources, preventing any unnecessary disruption to or destruction of vegetation, and ensuring compliance with the environmental management requirements of the DWNP. In addition, A&K has retained an independent environmental professional to provide on-site oversight and supervision during the construction period, and to prepare an environmental management plan for the camp. This individual will visit the site on a regular basis to ensure that all construction activities are carried out in accordance with the environmental management plan. IFC has reviewed the environmental issues summary of A&K’s tender documents, as well as the preliminary environmental management plan for project construction and management. In addition, IFC has reviewed the Government’s Guidelines for Tender for the site, and all relevant regulations for tourism ventures established by the DWNP, Ministry of Commerce and Industry, and Ministry of Local Government and Lands. Key elements of the information reviewed are described below.
4. Site selection criteria and land lease arrangements with Government: Botswana law requires that land use decisions in communal lands such as the Moremi Game Reserve (MGR) be made by the relevant local Tribal Land Board. There are 12 Land Boards in the country; for the MGR the relevant authority is the Tawana Land Board. The site in question was identified by the Tawana Land Board, in accordance with the land use planning authority delegated by the Ministry of Local Government and Lands. Unlike most of the tourism concessions, this is a new site, with no previous development. It is one of only five photographic tourism sites located in the Moremi Game Reserve (MGR), and is identified as MGR 5 or the Piajio site. As with all game reserves in Botswana, MGR is managed in accordance with a management plan developed by DWNP in consultation with the Tawana Land Board and other interested and affected parties. This plan establishes zoning and visitor carrying capacities, as well as the maximum size for each lodge development. The plan divides the MGR into two broad zones. One is designated as the Mombo “Medium Density Tourism Zone” (MDTZ); the other is designated as a Wilderness Zone. Within the MDTZ, two non-permanent lodges are permitted, one of which is Piajio. The Management Plan for MGR was most recently revised in 1992. At this time it was recommended that additional photographic tourism sites be designated, and the Piajio site is one of these new sites. It is one of only five tourism sites within the MGR; the total number of beds within the Reserve is approximately 580. A&K is being given a five-year lease, which may be renewed twice (for a maximum of 15 years in total) provided none of the lease conditions is violated.
5. Distribution and administration of fees, rent, lease payments to tribal and other authorities: The Land Boards establish the basic parameters for all land leases, requiring operators to pay a fixed annual fee to the relevant Tribal Land Board, as well as a percentage of turnover as a royalty to the relevant District Council. In the case of the Piajio, the operators negotiate individually with the Tawana Land Board and North West District Council to determine the amount of the fee and royalty arrangements, respectively. As the authority with jurisdiction over communal lands, the Land Boards include representatives of traditional leaders. Fees to the Land Boards are used to finance their administrative operations and to carry out inspections of all tourism operations at least twice a year. Royalties to the District Council are used to finance community projects such as schools, clinics and other public services.
6. Compliance with all relevant laws and regulations of the Botswana Department of Wildlife and National Parks: As described above, DWNP has established detailed regulations regarding all aspects of tourism developments (codified in Appendix 2 to the Wildlife and National Parks Act of 1992). In addition, the Tawana Land Board has established Management and development guidelines for entities submitting tenders for tourism concessions under its jurisdiction. Taken together, these regulations stipulate a wide range of conditions with which operators must comply, including the types of building materials that may be used, maximum number of structures allowed in each development, and acceptable specifications for ablutions, lighting, water supply, water reticulation, energy sources, vegetation removal and planting. Total site developments at sites in the MGR are limited to a maximum area of three hectares (ha). Road development is limited to a maximum of 60 kms within the entire Mombo MDTZ. Total vehicles in the Mombo MDTZ are limited to four for each of the two lodges, to be used for game viewing and transport of guests. In addition, a maximum of four additional vehicles is allowed in the Mombo zone, for use by either of the lodges for research and filming groups. All tender documents submitted to the Tawana Land Board for the Piajio site had to stipulate that the operators were aware of all relevant requirements and agreed to comply fully with them. Tender documents must include detailed designs for all lodge facilities, including stores, kitchen, staff housing, and workshops, in addition to guest units and public areas. In addition, the DWNP requires that all concessionaires assist in game tracking and tsetse management activities. In their tender documents, A&K were required to provide specific details and management plans as to how they intend to comply with all relevant Government regulations and guidelines. According to officials of the Tawana Land Board, A&K’s tender documents addressed to their satisfaction all relevant Government requirements and regulations.
7. Source of water and power including fuel storage, if applicable: In accordance with DWNP requirements, water will be obtained from boreholes. A&K has already drilled two test holes and preliminary results indicate that these will be capable of supplying the total volume of water required, estimated to be approximately 10,000 liters per day. Two state-of-the-art 40kVa diesel generators will provide electricity for the camp, which will charge a 32-volt battery to power the lights, refrigerators, borehole pumps and ceiling fans. The generators and an 8000-liter fuel tank will be housed in a separate, soundproofed structure equipped with bunded concrete containment devices, capable of holding the entire contents of the generators and fuel storage tanks in the event of a breach or spill. Hot water for guest rooms and public areas will be generated by gas-fired geysers. Electricity and hot water for staff quarters will be provided by solar units. Cooking will be with gas, as stipulated in the tender guidelines. The cylinders will be 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.
8. 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. At Piajio, A&K propose for the first time to utilize small stainless steel containers for these products, rather than the conventional plastic bottles which 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. Under the provisions of the National Parks and Game Reserve Regulations, the design of the incinerator must be approved in writing by the Director of DWNP. Bottles, cans, and recyclable plastics will be collected, sorted and transported to Maun to be recycled.
9. Disposal of liquid wastes including grease, waste oils, and sewage: The Tawana Land Board tender guidelines stipulate that ablution facilities should consist of showers, flush toilets and hand basins only. It further requires that these facilities, as well as wastewater from the kitchen and public areas, drain to septic tanks with french drains. The architect’s design for the camp includes one septic tank for every two guest units, plus one tank for the public areas, for a total of seven. All septic tanks will be connected to the same drainage system which will flow to a single french drain system. In accordance with the tender requirements, the project architect has taken ground water levels and potential for flooding into account in designating the location for the drainage field. This will be constructed in the center of the site, some distance from the main building and guest rooms, in an area of sandy soils to with adequate drainage properties. Grease traps will be installed in the kitchen to trap fats and grease before greywater is discharged to the soakaway. Vehicles and other equipment will be serviced in a central maintenance area, which will be equipped with a heavy-duty plastic tarpaulin “floor.” This will retain any grease and oil spilled during maintenance activities and prevent contamination of soils. A&K will purchase fuel from Engen, a South African supplier with whom the company is negotiating to recycle all waste oils and grease. Oils and grease will be stored in drums and transported to Maun when full for recycling and/or proper disposal. The pool will be salt chlorinated to minimize maintenance and to prevent contamination to soils as a result of backwashing. Water discharged during backwash operations will drain to a separate soakaway to prevent contamination of bacterial activity in the main septic tanks.
10. Impacts of construction and operation on the Okavango ecosystem, including access of local wildlife populations to the delta: The tender requirements established by the Tawana Land Board and DWNP include a multitude of requirements to ensure that the impacts of any tourism project have minimal short-term, and no long term, impacts on the delta. The Mombo MTDZ is an area of 300 km2, of which approximately 8 ha are allocated for lodge developments. The camp at Piajio has been designed and sited to fit in with the surrounding terrain and vegetation. Acceptable construction materials are specified by the Land Board and DWNP with the goal of minimizing long-term impacts; for example, no cement may be used. A&K propose to construct the entire facility of timber, thatch, canvas and – where necessary for safety or fire prevention purposes – metal sheeting. All construction will utilize pre-assembled components, transported from South Africa by rail and road and assembled on site using bolts rather than nails. At such time as the camp is closed, it can if necessary be disassembled and all of the components removed from the site. As the presence of game is the primary attraction in the Okavango delta, the camp will be staffed by professional guides and mangers and operated so as to minimize disruptions to resident and migratory wildlife. As noted above, A&K’s professional guides at the camp will assist the DWNP in monitoring wildlife populations and their movements through the MGR. A&K will also provide logistical and communications support from the camp to DWNP personnel involved in anti-poaching operations.
11. Impacts on the surrounding area of auxiliary activities such as game viewing and other activities: The tender guidelines specify the activities that are allowed in the MGR. A&K proposes to conduct wildlife viewing during the day and at night, and wildlife viewing walks during the day, accompanied by a professional guide. These activities are permissible under DWNP regulations and Land Board tender guidelines. As noted above, road development is limited to a maximum of 60 kms within the entire Mombo MDTZ. Any proposals for realigning existing roads or developing new roads must first be discussed with both DWNP and the Tawana Land Board to ensure that these developments minimize disturbance to ongoing activities in the area. As discussed above, total vehicles in the Mombo MDTZ are limited to 12. A&K will have four vehicles for use in game viewing, transport of guests to and from the lodge, and other guest activities. The tender guidelines require that refuse generated or collected during walking activities not be buried but rather be taken back to the camp for proper disposal. Given the types of activities to be conducted, and the fact that the maximum number of guests at the camp at any one time will be 24, impacts on the surrounding area are expected to be minimal.
12. Impacts on vegetation and wildlife of infrastructure including game trails, roads, staff housing, and air strip if applicable: The camp facilities have been designed and sited to ensure minimal disruption to trees and other vegetation. Only three trees on the entire 3 ha site will need to be removed as a result of construction. The verandah around the main complex will be built around existing trees, and the dining room will be constructed around one large jackalberry tree. All walkways in the camp will be made of compacted earth and anthill material, edged with timber to ensure that disturbance to vegetation is contained within the pathways. Staff housing and all other structures must conform to DWNP and Land Board requirements in terms of the construction materials to be used; these specifications were required as part of the tender documentation. A&K is planning to construct an airstrip for the camp, for which permission has been requested from the Tawana Land Board and DWNP. The airstrip will not be constructed until permission has been granted.
13. Potential impacts on local communities: There are no local communities living within the Moremi Game Reserve, although there are a number of villages on the perimeter. According to the tender guidelines, habitation in the Okavango delta this century has been determined by two main factors: the presence of disease vectors (primarily malaria mosquitoes and tsetse flies) and hydrological fluctuations. After a significant rinderpest epidemic in 1896, which killed most of the cattle in the delta, tsetse flies were virtually absent. The subsequent return of tsetse flies in the 1930s resulted in a movement of local populations out of the delta area. The tender guidelines stipulate that traditional rights in wildlife management areas such as the MGR must be recognized, especially those concerning access, gathering of veld products such as thatching grass and reeds, and fishing. A&K’s tender included additional proposals to ensure that the development has a positive impact on nearby communities. Wherever, possible, construction materials and laborers are being sourced locally. The construction contractors are South African but A&K have required that they hire a crew drawn largely from communities on the periphery of the MGR, and that these workers be given on-the-job training in construction methods. The camp curio shop will contain traditional handicrafts made by nearby villagers, who will retain all of the money earned from the sale of these items.
14. Public consultation with all interested and affected parties: Botswana has a long history of participatory governance, based on the traditional kgotla, or tribal meeting, at which all members of a community are allowed to speak on any given issue or decision. Only when all views have been heard and considered are final decisions made. The current system of land allocation is based on this form of public consultation, debate and decision making, and has evolved over the 30-odd years since Botswana achieved independence. Under the present land use system, both communal and state lands are held in trust for the benefit of all Botswana citizens. National parks are considered state lands and managed and administered by DWNP. Game reserves such as Moremi are considered communal lands and managed by the Tribal Land Boards, with administrative and wildlife management support from DWNP. Thus, all land use allocations – such as the identification of specific sites for tourism development – in the Moremi or any other game reserve must first be made by the Land Board in consultation with all interested or affected parties. By the time a site like Piajio is designated for development, there has been considerable opportunity for public consultation, comment and review. Moreover, the Land Board and DWNP requirements are so stringent and well-defined that the key parameters of the development (size, number of beds, construction materials) are fairly well circumscribed before tender decisions are actually made.
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 Maun. The camp will employ five licensed, experienced guides, and game viewing – either on foot or in vehicles – will only 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 a radio link with its operations base in Maun, with a doctor on call 24 hours a day. Guests who become ill or injured while at the camp will be transported immediately to Maun for treatment or, in serious cases, evacuated by aircraft to Johannesburg. Battery-powered lights will be installed along the walkways between the public areas and guest rooms, 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: The camp will employ a total of 32 staff. 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 from local villages on the perimeter of the MGR. The tender guidelines require that operators provide accommodation for all staff including temporary or casual laborers and mekoro (traditional dugout canoes) polers. This accommodation must be of a standard that guarantees proper living quarters, sanitation facilities and basic privacy. All staff will be provided with basic training in hygiene, housekeeping, guest relations and fire prevention and response. Staff at the camp will be encouraged to construct septic tanks at their homes and provided with plans and drawings to do so. Staff training will 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 Maun. A&K will ask that a workers committee be established at the time camp operations commence, though which employment and other issues can be discussed with camp management.
18. Fire protection, life safety, and emergency response measures: Because of the remote location of the camp, 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 equipped with a false aluminum ceiling under the canvas roof, to prevent a fire in the kitchen from spreading to other structures. The kitchen also 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. As has been done at its other lodges, A&K will fit the swimming pool with a separate pump to enable water to be piped to the roof of the main building, which is thatched, and flood the structure in the event of a major fire. All public areas will be equipped with appropriate signage (emergency exits, fire points). To reduce the likelihood of a veld fire resulting in a fire emergency at the camp, A&K will cut and maintain a firebreak around the entire camp. 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
