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Sunday, 13 April 2008

Have your say!

The Environmental Council of Zambia are currently consulting on the social, economic and environmental impacts of two proposals : New Embassy Compound on Ibex Hill Road and Mukamunya Small Holdings Estate. Good chance to have your say on the robustness of the assessments. Deadline for comments 23rd April 2008.


  1. The EIA is pretty impressive, and seemingly the key elements of a typical EIA were followed.
    However, I have the following concerns:
    1) It does not spell out that the employees/labourers for the duration of the project will be locals mostly (and Zambians from other towns). The local community should be the beneficiaries of the development, after all they will the ones that will be inconvenienced the most.
    2) It says LWSC does not have enough capacity to supply all the water requirements, and hence the boreholes. But I did not see anything on charges for abstraction of borehole water. We should be capacitating or at least allowing LWSC to build capacity to supply development such as this. This should be part of LWSC's future development planning - sustainability strategy for development initiatives.
    3) It says LWSC treatment ponds cannot accommodate wastewater from the new facility. And that LWSC is planning a rehabilitation for the ponds. My concern is that an onsite treatment facility may potentially introduce other environmental impacts. As a mitigation, LWSC should speed up the rehabilitation so that by the end of the Embassy project, it will have completed the rehabilitation and ready to treat sewerage from the Embassy. Again this is part of basic sustainability strategy on new developments.
    4) The laws seem silent on abstraction of water from the ground (via boreholes)unless I missed that part. This is not sustainable - all users of water should pay for it to facilitate conservation and development practices.

  2. Hasys,

    Many thanks for your thoughts.
    I am planning to respond formally to the ECZ before the deadline. Have you already passed on your thoughts to them? If not, I would like to incorporate them in my response.

    In general I think the EIA does not go further enough in explaining issues and assessing the impacts. Here are my initial thoughts:


    The underlying proposal of the NEC is that it is a new hybrid (commercial / residential ) development primarily to be located in a residential neighbourhood (see paras 3.1.1 & 3.1.2), . The effects of the proposal should therefore be seen in that light. I do not think this point comes out comes out clearly in the EIA to enable readers to fully appreciate the likely impacts on the neighbourhood.


    The likely benefits of the proposal clear are that it will add to the existing housing and commercial pool in Lusaka. However, I think the EIA has clearly overestimated some of the benefits. These are the employment and construction benefits.

    The EIA argues as a positive impact, possible “multiplier effects resulting from increased employment will include increased public revenues such as (PAYE to ZRA) and contributions to NAPSA from formally employed persons” (para 6.2.1). There’s no evidence given in the document that demonstrates that these are likely.

    It is true that this development will need to be serviced by local employment, but it is unclear the extent to which this is additional to economy. The USA embassy already employs people, and hence these individuals will simply be relocated to this new compound. The EIA has not proved the additionality of these jobs in the operational phase, and hence it cannot be argued that their multiplier effects that may emanate from them.

    The other point relates to construction benefits. A key part of the construction proposal is that it will be done by a “reputable American constructor”. Is it not therefore the case that much of the payments for construction will not remain in the country? Whilst it is true the bulk of the raw material may well be sourced from within the country, the large part of the employment benefits from construction will not remain in Zambia.


    The EIA has concluded that there are no environmental problems that will arise from this project. However, this is contrary to the evidence that exists elsewhere within the EIA. A key area is that the EIA has not considered the negative environmental impacts of additional road traffic on noise and air quality. Additional traffic will lead to increase in noise and air quality pollution. No mitigation solutions have been proposed to handle this problem. This is extremely worrying given that this is a residential neighbourhood with a school nearby.


    The EIA does not address a couple of social issues:

     Safety of children – that much traffic that will emanate could impact negatively on the safety of children in what is essentially a residential neighbour. Traffic calming measures may be necessary to ensure that this problem is addressed.
     Security – the EIA claims that the neighbourhood would now be more secure because of the American presence, but it does not acknowledge that there is also an increased likelihood of terrorist attack. For this reason, embassies are generally not meant to be located in residential areas.
     Impacts on local land value – the NEC may increase the land values in the area and this could push up rentals in the area, possibly leading to poor renters to relocate. The ECZ should consider such redistribution issues and what appropriate mitigation measures may be necessary.


    In addition to the aforementioned concerns, the completed EIA suffers from a number of presentational issues:

     References – there’s no reference section given. The EIA quotes a number of sources but it is almost impossible for the reader to follow these up. A key example is paper by Phiri et al(2006).

     Missing documents – there are some missing Annexes in the report. It is unclear why these documents are not presented, and whether they make it difficult for readers to reach a robust view on the proposal.

    I would welcome your thoughts on this.


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