Parks & Wildlife Amendment Bill H.B. 1, 2024

Anyone involved with wildlife, conservation, tourism or hunting needs to be aware of the Parks & Wildlife Amendment Bill H.B. 1, 2024 and its implications for the environmental health of our country and its people and wildlife.

This Bill was gazetted on the 19^thApril, 2024. Its officially stated purpose is to “To amend the Parks and Wildlife Act [Chapter 20:14]; to repeal the Trapping of Animals Control Act [Chapter 20:21]; to repeal the Quelea Control Act [ Chapter 19:10]; and to provide for matters connected therewith or incidental to or connected with the foregoing.”

(The Parks and Wildlife Act [Chapter 20:14] was in itself a re-working of legislation since November 1975 and subject to numerous Statutory Instrument tweaks in that time. The old Act was undoubtedly in need of revision.)

Z.P.G.A. Chairperson John Laing and legal advisors assisting Z.P.G.A. had the opportunity to express their concerns about elements of the new legislation as it was in the pipeline.

The following document was submitted in April 2024.

The Wildlife and Tourism Industry recognises the pivotal role of the Parks & Wildlife Estate in conserving wild landscapes and wildlife for the benefit and enjoyment of the nation. The industry also recognises the central role that policy and supporting legislation play in fostering a vibrant biodiversity-based economy. The Parks and Wildlife Management Authority (ZPWMA), as regulator of the Parks and Wildlife Act, plays a major role in shaping Zimbabwe’s biodiversity conservation agenda and in developing the industry based on expanding wild land and sustainable use of wildlife beyond the boundaries of state protected areas.

Wildlife industry stakeholders (“industry stakeholders”) also recognize that there are many reasons for amending the existing Parks and Wildlife Act of 1975, including aligning the Act with Zimbabwe’s constitution, providing for relief to victims of human-wildlife conflict, and incentives, such as secure resource access rights and least-cost regulatory requirements (ease of doing business), to stimulate and foster direct foreign investment in wildlife as a land use.

Industry stakeholders recognise the significant strides made in the Second Republic in the tourism sector, bouncing back and achieving the Government’s set goals for achieving a US$5 billion tourism economy by the year 2025. This is in line with the National Tourism Recovery and Growth Strategy Plan that was launched by His Excellency, the President in August 2020 in Victoria Falls. This also dovetails with the National Development Strategy 1 (2020-2025) aim of making Zimbabwe an attractive destination for investment and sustainable wildlife management. Industry stakeholders recognize the positive international image that Zimbabwe has created by accepting key global conventions including the Convention on Biological Diversity, which entail certain national commitments.

This document presents a condensed version of industry observations and recommendations on the Bill gazetted on the 19th April, 2024 and due to proceed to Parliament for consideration in May.

Key Observations and Recommendations

1. “Sustainable Use” as a primary pillar of conservation

• “Sustainable Use” has been the cornerstone of conservation policy in Zimbabwe and across southern Africa since the 1970s. This policy has served conservation and national economies well, with a 3-to-5-fold increase in wildlife across southern Africa vs. a 2/3rds reduction in countries like Kenya, which adopted a non-use policy, over the same period.
• Across southern Africa, nature-based tourism contributes more to the SADC GDP (~US$60 billion) than agriculture and fisheries combined (~US$20 billion) and is growing between 3 to 5 times faster year on year than the livestock industry for example.
• A fundamental prerequisite of the “Sustainable Use” policy has been devolution of appropriate authority and “legally clear and secure user rights” to land-holders/occupiers who have the right to use wildlife on their land under all land-use types. Under this arrangement, land-holders are incentivised to invest in wildlife and wildlife-based land-use.
• The gazetted draft of the Parks Amendment Bill, as currently worded, appears to change the Constitutional and Statutory user rights for land holders on all non-Parks land. If this is the case it will act as serious disincentive for investment in wildlife as a land use and compromise the development and sustainability of the industry.

Industry recommends that the wording in this component of the Bill be re-examined.

2. Inconsistency between Policy and Legislation

• The current Parks Amendment Bill is at variance with the National Constitution, the National Wildlife Policy, as well as the existing Parks & Wildlife Act. The GoZ has made great strides in the ‘ease of doing business’ in Zimbabwe in order to attract investment and promote the private sector. The wildlife industry seems to be increasingly tied up in more red tape and permit fees than other sectors, negatively impacting the ease of doing business in this sector.
• The Bill is at variance with the Constitution as it relates to Environmental Rights and Ownership Rights.
• Policy is intended to inform legislative updates. In this case however, there are numerous examples of contradictions between the updated Wildlife Policy and the gazetted Amendment Bill – not least around issues of user rights and sustainable use.
• Legislative review is meant to create an even, equitable, yet well-regulated playing field for all stakeholders to participate in and grow any given industry. The CAMPFIRE programme was an attempt to even out the playing field by affording Communities a mechanism through which to participate and benefit from wildlife enterprise. Unfortunately, the proposed Amendment Bill skews this yet further – by removing user-rights and severely limiting ownership (thereby negating any reason to invest in the sector) for private sector and – by vesting community natural resource ownership in the hands of a few community leaders, the proposed Bill creates ownership models for community resources which will prove problematic from the points of view of accountability, sustainability, and beneficiation.
• In short, the proposed Amendment Bill undermines critical sections of the Constitution, Wildlife Policy, and existing Act which are fundamental to sustainable use and which incentivise investment and industry growth.

Industry recommends a review of Zimbabwe’s policy on wildlife management as a further consultative process before the proposed legislation is enacted

3. Observations on the Consultation and Review Process

A brief summary of the main aspects of the consultation and review process is presented here.

1. On 5 May 2021, a “Validation Workshop” was held at Cresta Oasis. The following points can be made: The current draft of the proposed Amendment Bill differs from the version presented for validation at that time.
2. At that meeting, Industry stakeholders were concerned about some aspects of the draft presented at that stage. It was agreed that a Working Groups would be formed to address specific topics, including mining in protected areas; appropriate authority, and user rights; CAMPFIRE; hunting; and prosecution of illegal wildlife trade. Furthermore, once these working groups had provided their input, it would be put back to a stakeholders’ consultation and validation workshop. These working groups were never convened and no feedback to stakeholders was provided until we received the draft of October 2023.
3. Industry representatives met with the Minister and Ministry and ZimParks officials on the 4th October 2023 to discuss the draft Bill. The Minister instructed that hand-picked officials from Ministry of Environment, ZPWMA, and the Attorney General’s office engage with Industry representatives to address concerns. A 3-day meeting was duly convened and the joint team went through the draft sentence by sentence and reached consensus on an amended draft. A detailed record of the amendments proposed by both parties was recorded and circulated thereafter.
4. No further formal stakeholder engagement has taken place and the Bill was gazetted on the 19th April 2024. Many of the previously agreed amendments have not been included in the gazetted version of the Bill.

Industry recommends that further stakeholder and public review of the Amendment Bill would ensure legislation that will achieve national objectives for both wildlife conservation and rural development, and the growth of a vibrant wildlife-based economy sector.

4. Other reviews related to the Amendment Bill

• Between 2016 and 2018, GoZ undertook the National CAMPFIRE Stakeholder’s Review of the policy, legislative, and institutional framework for CAMPFIRE in Zimbabwe. The initiative was undertaken under the auspices of the National CBNRM Steering Committee, which was an inter-Ministerial committee co-chaired by Ministry of Environment and Ministry of Local Government and containing all relevant departments and stakeholders. The process was funded by the European Union and was thoroughly consultative, including detailed baseline surveys and stakeholder consultations conducted in major CAMPFIRE communities around the country, followed by 4 regional and 2 national level stakeholder workshops. The recommendations of this 2-year-long exercise were submitted to GoZ in September 2020.
  • The recommendations of this extensive review, and the resulting CBNRM Policy that was endorsed by the Cabinet in September 2020, have not been fully incorporated in the Amendment Bill. It is proposed that the recommendations of the National CAMPFIRE Stakeholders Review are adopted and incorporated under Section 108 of the proposed Parks Amendment Bill
  • Similarly, in 2015 the Zimbabwe Professional Hunters and Guides Association, Safari Operators Association of Zimbabwe, other stakeholders and ZPWMA jointly instigated a Hunting Industry Review. This led to a lengthy exercise between ZPWMA and the hunting fraternity to develop a Wildlife Industry Control Council, which while included in the proposed Amendment Bill, varies with key recommendations and points of agreement reached during this very long (now 9 years long) engagement process.

Industry recommends further consultation with the Industry on this section of the Bill

• Further key Observations are outlined below that lists the sections of concern in the Bill, Industry requests, and implications of the wording in the draft Bill vis-a-vis the industry requested changes. These include issues relating to: (i) Ownership of wildlife, (ii) The proposed setting of quotas on all land by ZPWMA, (iii) Proposed amendments on conferring Appropriate Authority, (iv) Proposed amendments relating to mining in protected areas, (v) The proposed method of funding the human-wildlife- conflict relief fund, and (vi) Accidental killing of animals and burden of proof.
• Major Gaps. The draft Bill is silent on the question of Private Protected Areas (such as large-scale conservancies) and designated communal land conservancies, which feature in other regional and international conservation contexts. Small but significant conservation areas, such as important wetlands, and Zimbabwe’s two UNESCO registered Biosphere Reserves (one in the Zambezi Valley and another in Chimanimani) also lack statutory support.

Industry recommends that the opportunity to include these important components of conservation in the Bill should not be missed.

Definitions are a very important component of any legislation.

• The definition of an exotic animal in the Bill, namely, “exotic wild animal” means an animal that is not endemic to Zimbabwe would place elephants as an exotic species. An endemic species is one in which its distribution is confined to a particular locality, be it a particular forest, island, country, region, or continent. There is probably only one endemic mammal in Zimbabwe and that is a sub-species of squirrel that occurs in Chirinda Forest, namely, Paraxerus palliatus swynnertoni. There are several species of frogs that are endemic to the eastern highlands of Zimbabwe, i.e. they are found nowhere else in the world. An appropriate definition of an exotic wild animal would be – “an animal that is not native to Zimbabwe” or “an animal that is not indigenous to Zimbabwe”. For example, chimpanzees, tigers, bontebok.
• The definition of the Precautionary Principle, which is as follows: “the application of the precautionary approach to wildlife conservation (that is to say adoption of wildlife conservation measures is not precluded by the absence of full scientific evidence justifying such measures);”. This represents a misunderstanding of the precautionary principle which may require taking risk averse action in the face of uncertainty. It does not mean “take action in the absence of full scientific evidence” as implied in Bill.

“In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation

The definition following the Rio Declaration on Environment and Development (1992) was as follows:”

Environmental Law In the UK as an example: “Where there are threats of serious or irreversible environmental damage, a lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

Industry recommends that a careful scrutiny of definitions in the bill be undertaken to avoid any risk of ambiguity in the law.

Further key Observations are outlined the Table below that lists the sections of concern in the Bill, Industry requests, and implications of the wording in the draft Bill vis-a-vis the industry requested changes. These include issues relating to: (i) Ownership of wildlife, (ii) The proposed setting of quotas on all land by ZPWMA, (iii) Proposed amendments on conferring Appropriate Authority, (iv) Proposed amendments relating to mining in protected areas, (v) The proposed method of funding the human-wildlife- conflict relief fund, and (vi) Accidental killing of animals and burden of proof.

Draft Bill 2023/2024

Industry Requests (October 2023) and Implications

2B (1) Ownership of wildlife

Proposed changes to not allow any ownership of wild animals except for “captive” animals. Res nullius means wildlife is ‘nobody’s thing’.

(Page 4)   Ownership of wild animals on privately managed land was a pillar of the growth of the Industry and success of our wildlife Industry for many years. Why take it away and/or limit it to captive animals or subject to a permit?

Ownership was requested as essential for the survival and growth of the sector. Industry stakeholders who have invested heavily in the purchase and maintenance of wildlife cannot suddenly be told that they no longer own their investment, and indeed this would be unconstitutional in terms of Section 71 of the National Constitution and is likely to contravene some BIPPA agreements.

The introduction of res nullius as an over-arching principle will cause confusion and could be an avenue for poachers to attempt to escape liability as wildlife is nobody’s thing. Regulations only provide for animals harvested in error not willfully.

ZPWMA and Industry should work hand in glove to promote the growth of wildlife.

The right to own wildlife should be enshrined in the new Act under certain clear conditions and should only revert to being res nullius if they escape such conditions. Investors in wildlife will be reluctant to have their wildlife property rights based more upon variable attitudes of the authority responsible for issuing permits than on clear provisions in statute law. Ownership of animals is the fundamental cornerstone of any wildlife -based investment. It forms the basis of any successful wildlife -based industry worldwide. Eroding this may have severe economic repercussions.

This will likely dis-incentivise any further foreign and local investment in the wildlife sector. The knock-on effects of this will be severe: loss of sustainable ongoing revenue to ZPWMA, loss of revenue to Government, extensive job losses and economic opportunities for SMME’s in rural areas.

The issue of wildlife ownership by the State in many African countries, which do not follow the same common law as Zimbabwe, South Africa, and Namibia, is often viewed as a remnant of colonial times. The decline in wildlife populations outside of State Protected Areas can largely be attributed to Governments attempting to exert control and ownership over all wildlife resources, which goes against the principles of fairness and natural justice.

This approach, where Governments bear the responsibility of maintaining wildlife without adequately meeting the associated costs, while simultaneously removing incentives for private and communal landholders to conserve wildlife, creates a policy environment in which wildlife loses its value and gradually disappears.

To ensure the optimal use of land and necessary investments in wildlife conservation, it is crucial that landholders have clear rights to make decisions regarding the wildlife on their land. These rights should be on par with the rights that livestock producers have in managing their cattle and other livestock. Any regulations that unnecessarily restrict the sustainable use of wildlife, diminish its economic value, undermine investment confidence, or impose additional costs, ultimately hinder the cause of sustainable wildlife conservation.

By adopting a more inclusive and equitable approach that respects the rights of landholders and promotes sustainable use, Zimbabwe can foster an environment where wildlife conservation thrives and benefits both the natural heritage and the people who inhabit this country.

S 58A (1) proposed changes for Authority to determine and allocate quotas at its discretion.

It was further proposed that, for example a landowner “pay to the Authority the amount of the [penalty prescribed in section 104] for each animal hunted or killed in excess of the quota”;

(pages 10 -12, and 11 and 14)     Industry requested substantive changes to allow for it to participate in setting and using its own quotas (in consultation with ZWPMA) and for those lawful occupiers to be the AA.

The lack of clarity of AA status means, technically anyway, management and training quotas may be granted to third parties on alienated land. See para 58 A b).   Uncertainly on quotas will erode investment confidence.

•              Industry must have a say in setting its own quotas especially on land in which it is the AA.

•              Penalising industry for managing its own quotas will almost certainly ensure disinvestment in wildlife and no future investment in wildlife management. The proposed wording will result in landowners/occupiers being treated as a poacher for harvesting their own wildlife.

•              Without being able to participate in its quota setting private sector will not be viable. This would erode investor confidence.

•              Communities would suffer as the land use would be non-productive.

•              It is proposed that recommendations of the National CAMPFIRE Stakeholders Review (2016 – 2018) should be adopted and incorporated under Section 108 of the proposed Parks Amendment Bill as endorsed by Cabinet of the Government of Zimbabwe in September 2020.

Section 80 – of the principal act is repealed, (Problem Animals)       Time constraints did not permit this topic to be discussed at the Bubye workshop.   Although the proposed amendments attempt to align with progressive thinking not to align a species the legislative conformist proposals are neither feasible nor workable in Zimbabwe. Prior to enacting any changes to the legislation, it is suggested issues be work shopped and specialists such as Mike Le Grange and others with problem animal experience be consulted together with communities.

S 108 (1) Proposed amendments on Appropriate Authority (AA) status.

(pages 35-38)    Requested inclusion of Appropriate Authority (AA) as land and lease holders, councils and lawful possessors (expanded definitions). These definitions should include alienated land holders as the Appropriate Authority (AA) with a link that together with Parks and a scientific justification they have a say on the sustainable utilisation of their wildlife.

Requested reconsideration of the proposed cancelling of the schedule of problem animals.             Appropriate Authority allows the lawful landowner/occupier the ability to determine its own future regarding land use and is imperative to the success of the wildlife industry.

Devolution of AA status should be encouraged not hindered. This should be coupled with responsibility.

•              Local communities conducted via RDC’s, or as may otherwise designated, should be allowed to participate.

•              It is proposed that recommendations of the National CAMPFIRE Stakeholders Review (2016 – 2018) should be adopted and incorporated under Section 108 of the proposed Parks Amendment Bill as endorsed by Cabinet of the Government of Zimbabwe in September 2020.

S 119 Proposed amendments on prospecting and mining widened and expanded the definitions

(pages 39-40)    Industry requested Private Protected Areas (PPA)1s  to be included in a broader definition as well as Sanctuaries, Botanical Gardens, etc.    It is vitally important that that all conservation and wildlife areas, both public and private, and communal land have adequate protection with regards prospecting and mining.

S 16I-O(1) Human-wildlife conflict relief fund.

(Pages 7-9)   A noble and well received initiative.

Industry suggested a multi layered approach where everyone participates or is responsible for their wildlife. Possible Insurance underwriting.    Current wording places the burden of financing the relief fund on Private sector alone. Human -wildlife conflict a concern around all wildlife areas, private, communal or state owned. Further clarity is required to ensure the fund is transparent and sustainable. It is acknowledged however that this is an urgent mandate that requires urgent attention. Industry would stand ready to assist.

An alternative approach based on 3rd Party Insurance policies held by Appropriate Authority land holders might be considered and would relieve ZPWMA of an enormous administrative burden.

S 4 inclusion of paragraph ‘g’

“Promote community participation in consumptive and non-consumptive wildlife based commercial activities through conferment of delegated appropriate authority status and community partnerships”

(page 4)   An excellent amendment but it is underpinned by a viable and thriving private sector around which community partnerships can be formed.    Lack of Appropriate Authority status for PPA and councils will negate community participation and limit community benefits

•              While the proposed amendments take some welcome steps towards decentralizing wildlife use rights within the communal sector by conferring “delegated appropriate authority status” to defined community groups (by SI), they do not adequately incorporate Cabinet-approved revisions of policy on the CAMPFIRE Programme for community-based natural resource management.

•              Without provisions in the Act for capacity building in line with approved Policy, communities participation will be curtailed. Communities should be involved in understanding how they will participate (see comments relating to CAMPFIRE Review above)

S 63 “Report of killing of animals or injury of animals other than dangerous animals”

“(4a) It shall be presumed that the killing of an animal referred to in subsection (4) resulted from the negligence of the person responsible for the killing, unless the person satisfies the Authority by means of an affidavit that he or she was not so negligent”.   

Industry suggested a flat fee for breach of permit in event of wrong sex accidental harvest of an animal plus forfeit of the trophy.

Repeat offenders will be subject to disciplinary measures from the council but no party should be unduly enriched as a result of an accident.   The presumption of guilt is not in line with a lawful hunter with a lawful permit who is therefore lawfully hunting an animal.

•              Professional Hunters should take due care but accidents do and will happen particularly with the shooting of females of the species that physically appear the same as the male and in thick bush.

•              Under the proposals professionals are be deemed to be negligent and forced to pay penalties are higher than the actual value of the animal the same level as poachers. What is the incentive to be a lawful hunter and take out a licence?

•              This will dis-incentivise participation of ethical professionals in the hunting industry that contribute millions in US to the fiscus, provides employment and downstream benefits, and promotes conservation in marginal areas.

Stakeholder consultation – Inadequate consultation with industry stakeholders prior to Bill submission to Parliament for approval Industry stakeholders have not been adequately consulted on the proposed amendments to the Act, despite major economic implications for this industry. The amendments should fall in line with the Second Republic’s vision of attracting and promoting both foreign and local investment. Industry stakeholders play a key role in sustainable wildlife management and tourism in Zimbabwe.

It is unclear if any of the industry stakeholder inputs have been adopted in the Bill.

Wildlife Professionals Council.  The requirement for membership should be clarified further to allow for transparency and accountability in the Industry.   It is proposed that suggested amendments made during industry consultations in October 2023 be addressed and incorporated.

Concluding Comment

The combined effects of the above-listed concerns is likely to discourage investment in Zimbabwe’s wildlife industry and tourism. International and local investors will not feel the same confidence of investment in wildlife assets as they would expect from their investment in domesticated livestock or other business assets, or in wildlife assets in other countries.

Direct benefits associated with having a strong and secure private sector in wildlife include:

• Increased revenue to the country through nature-based tourism in USD and local currency;
• Substantial trophy hunting returns to ZPWMA in USD which benefit the management of all protected areas in Zimbabwe;
• Increased economic opportunities including job creation, SMME development and community upliftment in rural areas;
• Scientific research and environmental education;
• Carbon sequestration and mitigating against climate change; and
• Ecosystem and biodiversity preservation.

The increase in consumptive and non-consumptive tourism under the Second Republic is evident, posing yearly increases which are critical to Zimbabwe’s job creation stability and fiscus. Industry stakeholders would not want to see this eroded and want to continue with this trajectory. In order to do this public/ private consultations are imperative.

Government currently has the ability to intervene and curtail any abuse of wildlife resources, whether deliberate (such as persistent overharvesting), or simply arising from lack of understanding of key issues (such as genetic management of wildlife or ecological constraints). Dealing with such issues requires professional guidance coupled with incentives rather than inappropriate controls that stifle the industry.

It is critical that Zimbabwe’s legislation on wildlife management strikes the right balance at a time when other countries competing for the same investment are showing progressive policies that support the wildlife and tourism industry and encourage investment.

The private sector plays an integral role in wildlife, tourism, biodiversity and environmental services management in Zimbabwe. Privately-owned protected areas (PPAs) bring multiple direct benefits to both the environment and the human communities that interact with them, contributing to conservation efforts while also supporting sustainable development and local livelihoods. Community Protected areas (CPA) developed as envisaged under the CBNRM policy endorsed by Cabinet would expand the extent of conserved land in the country and its biodiversity economy.

The proposed amendments to the Act represent a significant policy shift in the way that Zimbabwe’s wildlife resources are managed, especially on alienated land. Lack of adequate consultation in the formation of the proposed amendments to the Bill is a fundamental concern of industry stakeholders (discussed further below).

Zimbabwe plays a key role in biodiversity conservation worldwide. The United Nations Convention on Biological Diversity (CBD) adopted the Kunming-Montreal Agreement in December 2022 to guide global action in biodiversity conservation up to 2030. Zimbabwe is among 6 countries working on a project titled “National planning for an inclusive and effective conservation approach to reaching global biodiversity Target 3”, the primary objective of which is to support country planning to achieve the target of 30% of its land under protected status. Zimbabwe presently has about 15% under protected area status. The often-quoted figure of 28% is not correct.

Much like the environment itself, all stakeholders need to work together in symbiosis: the three important pillars of the private sector, local communities and Government all rely on each other for strength and sustainable growth. When one of these pillars is eroded, the others will suffer to everyone’s detriment. At a time when the consumptive sector is under significant threat by trophy hunting bans and retrogressive legislation in source countries, it is vital for the stakeholders and the Government to work hand in glove to ensure that all parties collectively succeed.

We believe that the repercussions of the new Bill, created without adequate industry and public consultation, will result in Government and Zimbabwe, losing a significant opportunity to create a thriving wildlife industry that we estimate could be worth in the region of US$ 500 million – US$1 billion annually within the next 5 years, with the potential to attract substantial direct foreign investment, create many hundred thousand jobs and downstream opportunities, benefit communities, and make Zimbabwe a global conservation pioneer and leader again.

The role of the Industry in the diversification of revenue streams in the agriculture sector should also be considered. Private Protected Areas contribute significantly to wildlife conservation and to providing greater resilience to economic and climate related shocks, and importantly, provide additional and less ecologically damaging sources of protein through game meat production.

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The Consultation Process

After the Bill was passed a Parliamentary Committee (Parliamentary Portfolio Committee on Environment, Climate, Wildlife) was set up to travel around the country, including to many of the smaller centers, seeking the opinions of stakeholders, including community members, on the new legislation. The committee was made up of a number of Members of Parliament and Senators as well as civil servants of the Ministry of Wildlife, Climate and the Hospitality Industry.

NOTICE OF PUBLIC HEARINGS

The Portfolio Committee on Environment, Climate and Tourism will hold public hearings on the Parks and Wildlife Amendment Bill (H. B1,2024) from the 8^th to the 16^th of July 2024. The teams will cover various places in Zimbabwe as follows:

Team A

Team B

Z.P.G.A. asked its members to attend as many of these meetings as possible and to champion the arguments laid out in the document above.

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Report on meetings from ZELA

Hazel T. Chimbiro attended a number of the meetings representing the Zimbabwe Environmental Law Association with support from the Zimbabwe Accountability and Citizen Engagement (ZIMACE) project. Her report of July 26, 2024, entitled “Key reflections on the Parks and Wildlife Amendment Bill public hearings” can be found at this site – https://zela.org/key-reflections-on-the-parks-and-wildlife-amendment-bill-public-hearings/

She felt that the key issues that the meetings highlighted were:

• The need for more sensitization of communities before public consultations are done. It is crucial that communities are informed about proposed laws and their implications before they participate in consultations.
• The importance of abbreviated versions of the bill being transcribed into local languages. This will help ensure that all community members can understand the bill and participate effectively.
• The need for enhanced participation of youths in public hearings and deliberate inclusion of youth representation in the Authority’s board.
• Consideration of compensation of communities for crops and livestock destroyed because of human wildlife conflict.
• Although mining contributes significantly to national Gross Domestic Product, economic and social development must not be achieved at the expense of environmental protection. (The discussion underlined the need to harmonise the Parks and Wildlife Act and the Mines and Minerals Act (which is itself under review).

The Parks and Wildlife Amendment Bill H.B. 1 of 2024, while intended to modernize and align Zimbabwe’s wildlife legislation with contemporary policy and constitutional standards, presents significant challenges for the wildlife, tourism, and conservation sectors. Concerns have been raised about the bill’s potential to undermine private investment in wildlife-based land use, create inconsistencies with the constitution and national policies, and discourage both local and international participation in wildlife conservation. Despite the positive strides the government has made in promoting sustainable development and tourism, key stakeholders have expressed a need for more thorough consultation and revision of the bill. To ensure the success of Zimbabwe’s wildlife and tourism industries and uphold its commitments to sustainable conservation practices, further stakeholder engagement and review of the bill are critical. Implementing policies that align with constitutional provisions and fostering a collaborative approach between the private sector, communities, and the government will be essential to achieving the long-term goals of conservation and economic development.

[1] PPA is an abbreviation for a designation suggested by Industry as Privately Protected Areas. Successful wildlife policies and legislation around the world have such areas.

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