Case Study 2: EIA in National Parks

In their recent study of the EIA practice in Tanzania, Mwalyosi and Hughes (1998) have underscored the ad hoc, unplanned and shoddy manner in which EIA has been undertaken in Tanzania. They reveal, for instance, that of the 50 documents "described or purporting to be environmental assessments" which they examined, only 26 were genuine. They argue that EIA has been undertaken not as an intrinsic part of the projects concerned but appear as an afterthought relevant only for purposes of public relations and as a result their contribution to project design and implementation appear to be marginal. The study carried by the two researchers covered, among other areas, the construction of tourist facilities such as hotels and lodges in the Serengeti National Park and Ngorongoro Conservation Area in Northern Tanzania. We present herein some of their findings on the EIA as practiced in these areas.

Mwalyosi and Hughes write that the EIA studies for construction of the Serengeti Serena Lodge National Park and the Ngorongoro Conservation Area (NCAA) were commissioned on very short notice when "detailed project designs had already been prepared … and severe time constraints were imposed on the EIA team in order to minimise delays in the implementation of the project" (Mwalyosi and Hughes, 1998:59). As a result "the recommendations for (modest) design modifications … were not considered acceptable by the lodge company on the grounds that the project design had already been completed..." Consequently, "one of the key recommendations of the EIS - the integration of adequate liquid waste treatment facilities into project design - had clearly not been implemented, and the lodge was facing a considerable problem in dealing with the disposal of such wastes. At the time of the evaluation visit, waste water overflowing from inadequate waste pits had created a new wetland microhabitat" (ibid., 61). Similar findings were also recorded in respect of the Grumeti Serena Tented Camp in the Serengeti National Park (ibid., 63-64).

As in Serengeti National Park, the construction of huge tourist facilities has been going on apace in the Ngorongoro Conservation Area which adjoins the Serengeti to the southeast. This is part of the government strategy to cash in on the tourism industry as one of the engines for economic growth in Tanzania as part of the larger economic liberalization package. One result of this policy is that in the four years leading up to 1997, four big tourist hotels had already been commissioned and a fifth was under construction. The four - Ngorongoro Serena Lodge, Ngorongoro Crater Lodge and Sopa Lodge - are dotted around, an in fact stand on the rim of, the Ngorongoro Crater.

This expansion in tourist facilities has not come without a cost. The facilities are huge steel and concrete structures which are potentially more harmful to the ecological integrity of the fragile Ngorongoro ecosystem as they require huge and continuous supply of water and waste treatment or storage facilities. But in what appears to be typical practice whenever powerful foreign investors are involved, these lodges were built against the wishes of the Ngorongoro Conservation Area Authority (NCAA) which has legal mandate to authorize construction of such facilities; and no environmental impact assessment was conducted prior to their construction.

As a result, serious environmental problems are already emerging in relation to them. Sopa Lodge has, for instance, been accused of diverting for its use the Oljoronyuki Stream which is used by both Maasai pastoralists for their cattle and by wildlife as well as of dumping solid waste from the hotel into the Crater (Lissu, 1998). This Lodge also caught the eye of the Warioba Commission which observed that the construction site for it was shifted twice due to "pressure" from the top leadership in the Ministry of Tourism after to NCAA had refused to issue construction permit on the sites chosen by the owners of the Lodge (Tanzania, 1996, Vol. 2:431).

In reviewing the evidence on the processes leading up to the construction of the tourist facilities in the National Parks and other protected areas such as public beaches, the Warioba Commission further observed that "often the investors have been insisting to be permitted to build (hotels) inside protected areas hence endangering the environment. Pressure to facilitate such requests sometimes has been originating from the top leadership in the Department (of Tourism)" (ibid., Vol. 2:431). The Commission gave a long list of the hotels and lodges which have been built within National Parks and other protected areas as a result of these "pressures" (See Appendix D, ibid., Vol. 2:439).

That convergence of interests - the "closeness between leaders and corrupt businessmen" - between high state officials on the one hand and powerful corporate interests on the other can be seen by looking at the corporate interests which are behind the development of the tourist facilities in the protected areas. Serena Lodge is part of H.H. the Aga Khan's business empire, and President Mkapa himself cut the tape to officially open the hotel in 1996. The Ngorongoro Crater Lodge is a subsidiary of the Conservation Corporation (Africa) Ltd., a South African conglomerate with business interests in a number of African countries; while Sopa Lodge is also owned by wealthy business interests of Asian origin with foreign connections.