Controversy Over EIA

The EIA report was prepared by a team of high level experts of various disciplines and from various institutions. According to this document, the Rufiji Delta Prawn Farming Project would be financed under a credit facility extended by the European Investments Bank (EIB) and European Development Fund (EDF) to the tune of US$ 180 million¹. On the other hand, the EIA report detailed various social and economic benefits to be derived by the nation at large as well as by the local communities, chief of which was foreign exchange earnings projected at between US$ 200 and 300 million annually throughout the entire life of the project. The EIA report also identified several negative 'externalities' which will ensue from the implementation of the project. These included clearing of mangroves, pollution arising from the disposal of wastewater effluents, contamination of fresh water sources and agricultural land from the saline seawater, possible outbreak of infectious diseases, etc. The report, therefore, proposed mitigation measures such as replanting of cleared mangroves, the use of solid waste for construction of roads and for earthwork repairs and close project monitoring to avoid the negative impacts.

The EIA report nevertheless raised more controversy especially after one of the consultants disowned it claiming that it had been falsified to suit AFC's ends. To sort these controversies out, the Government directed the National Environment Management Council (NEMC) to coordinate the review of the EIA report by a team of Government experts and submit recommendations to the Government. This was in June 1997. NEMC was required to draft experts from various Government departments and elsewhere for this task and to take into account laws and policies which regulate the sector. NEMC undertook this task by drafting a review team consisting of experts from NEMC itself and several other ministries and Government departments plus three foreign consultants. The review team submitted its report in August 1997.

NEMC's review report found that the EIA report submitted by AFC contained, among other things, substantial errors, omissions and misrepresentations. The review report attacked the conclusions of the AFC consultants and the research methodology they adopted, arguing that fieldwork had not been properly carried out. According to one member of the review team: "This lack of academic rigidity in performing the field work severely undermines the credibility of the rest of the document" (Vergne, 1997: 2-3)(Original emphasis).

The review report also found, for instance, that whereas AFC was proposing to import arms and ammunition for the Project to the tune of US$ 570,000 per annum, there were no budgetary commitments for provision of social services that AFC had promised. There was also no budgetary allocation for compensation and resettlement of people who will be displaced by the Project. The review report also found a far higher danger of socio-economic and ecological damage than AFC had admitted in its EIA report.

On the contribution of the Project to the national economy and to the well being of the local people, the review report found the foreign exchange projections given by AFC to be grossly inflated, employment figures more than twice hiked, while potential risks and dangers for the project were downplayed or suppressed. Furthermore, the review report found that without the Project and its attendant dangers, the Rufiji Delta region was far more economically productive than with the Project. On legal and policy issues, the review report found that serious abrogation of the law will occur if the Project is approved for implementation as conceived. The review report also examined land tenure issues and found that serious land use conflicts will ensue as a result of the implementation of the Project.

On participation of, and consultation with, the local communities, the review noted with considerable dismay how high ranking Government leaders had openly campaigned for AFC and the approval of the project in the face of massive opposition from the local people and their representatives and questioned the propriety of this action. The report also noted the lack of good faith and arrogance on the part of AFC and its supporters in dealing with the genuine concerns and fears of the local people. Finally, the review report also dealt at length with the views of the representatives of the Delta communities, individuals and other institutions which were given at a public hearing for the Project. The latter had been organized by NEMC and it showed considerable opposition to the implementation of the Project. The conclusion that the review team reached in its report was that the Project should not be approved for implementation!

The report of the review team was submitted to the NEMC's Board of Directors towards the end of July 1997. The Board deliberated upon the findings and recommendations contained in the experts' report and observed, inter alia:

• "That the proposed project will have deleterious impacts on the environment and the people in the Rufiji Delta and surrounding areas.
• "That the proposed project is in contradiction to the [sic] existing legislations [sic] of forests and marine reserves";
• "That there is doubtful economic advantage to be accrued to the Government of Tanzania";
• "That the proposed project will have serious cultural and social impacts";
• "The project is to be located in an area where a license for oil exploration has been granted to another company by the Ministry of Energy and Minerals";
• "The integrity of the project is doubtful as it does not reveal all the necessary baseline information on economic, social and ecological implications";
• "The promised benefits to the local communities can not be guaranteed as they are not part of the investment plan";
• "The rehabilitation of the area after the project's economic life is estimated to be 30 years."

In view if these negative impacts, the NEMC Board resolved that "the government be accordingly advised to reject the project." The final report of the review team and a summary thereof were submitted to the government later the same month. The NEMC, which had coordinated the activities of review team, adopted the team's findings in their entirety, concluding:

The NEMC went on to advice the Government:

• "Prawn farming 'on a commercial scale' should not be allowed until such time as the Fisheries Department has promulgated rules and guidelines to regulate these activities.
• "These activities should not be carried out in ecologically sensitive areas such as mangroves.
• "For this project to be approved, amendments to the legislation and policies which contradict with the objectives of the project must first be effected and not otherwise" (NEMC, 1997b)

The NEMC also noted that similar projects had been proposed for the coastal belt from Tanga to Lindi. Other projects have also been proposed for River Matandu, Temeke District in Dar es Salaam, Bagamoyo and Tanga. NEMC warned:

1. It is now confirmed that neither the European Investment Bank nor the European Development Fund, which had also been identified as another source of funding for the project, have approved or will approve funding for it. The former is quoted as saying in a communication to the Swedish Society for Nature Conservation (SSNC) that ' "although the promoter of the shrimp farm in Tanzania contacted the European Investment Bank (EIB) some time ago, the EIB will not finance the project."' As for the EDF, a desk officer in charge of Tanzania at the DG VIII, which is in charge of the EC development aid, informed the SSNC that Nolan and his representative (an American lawyer) had been in touch with them several times asking about funding but EDF has declined mainly because it finds the project environmentally inappropriate (Karin Gregow, e-mail comm. 18 August, 1998)