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Zimbabwe’s Wetlands: Policy Concerns & Recommendations

The following is an illustrated text version of a presentation Wetlands given by Julia Pierini, C.E.O. of Birdlife Zimbabwe at the Highlands Presbyterian Church, Harare on the 3rd February, 2024 in honour of World Wetland Day.

(At the same event Dorothy Wakeling spoke on the function of wetlands and Monavale Vlei, also reproduced on this site.)

WETLANDS 03 FEBRUARY 2024 – presentation by Julia Pierini

Change of land use resulting in natural habitat loss, indiscriminate development, destruction through deforestation and agriculture, wetland degradation and mining pose major threats to sensitive ecosystems such as wetlands that support wildlife and also human life

These changes are inducing BIODIVERSITY LOSS

Biodiversity loss affects all of us because when species disappear the value of the places where people live is diminished, and the ecosystem goods and services that the environment provides – like food, shelter, clean water and recreational space – decline. These places have significantly important value to the local communities living adjacent them.

Concern No. 1 – Wetlands not protected

The current wetland policy and guidelines do not afford wetlands any specific protection

(This also applies to Ramsar Sites which do not enjoy any additional protection.)

Existing legislation allows for the designation of any wetland as an “ecologically sensitive area” (ESA).

This has largely been done.

Existing legislation also allows the Minister of Environment, Climate and Wildlife to “impose limitations on development in or around designated Ecologically Sensitive Areas (ESAs)

But this has not been done.

The result is that the bulk of the Ecologically Sensitive Areas are treated exactly the same as any other area regardless of wetland or ESA status.


The Minister of the Environment, Climate and Wildlife needs to introduce specific development controls that prohibit development on designated Ecologically Sensitive Areas (ESAs)

Concern No. 2 – EIAs Not Working

The Environmental Impact Assessment Process remains the primary tool for the protection of wetlands – but this is not working and perversely is being exploited to facilitate development on wetlands

  • EIA Consultants are paid by the developer and thus are not independent.
  • EIA consultant teams typically lack skills relating to biodiversity, ecology in general and wetlands in particular, such that the description and analysis of the baseline environmental conditions is often inadequate. Eg. the presence of wetland conditions is often ignored or strongly downplayed in EIA reports. It seems that it is not a requirement for EIA consultants to recognise and address the wetland environment even for projects being implemented within wetlands. Similarly biodiversity information is usually highly inadequate with no attempt to make use of existing available information
  • The description of project works in EIA reports, including timing and phasing of different components, is often incomplete
  • Where baseline information on the natural environment and proposed project are lacking or incomplete it necessarily follows that is not possible to reliably predict potential environmental impacts
  • Environmental Management Plans are an integral part of the EIA report but are typically unrealistic and are never monitored or followed up, such that once a developer has an EIA certificate there is no further recourse regardless of what is implemented on the ground
  • There are no guidelines as to how an EIA report should be assessed and to inform the decision as to whether an EIA Certificate should be issued or
  • not; EMA should be required to clearly state their reasons as to why an EIA Certificate is being issued or withheld
  • The stakeholder consultation process for most EIA studies is almost always inadequate. (For example consultations are typically restricted to neighbouring property owners such that downstream residents and water users are not consulted nor are broader civil society, nor are environmental NGOs
  • Concerns raised by stakeholders are frequently misreported and/or dismissed in EIA reports and are equally dismissed
  • by EMA during their consideration of the EIA report (for example Monavale Ramsar Site EIA)
  • EIA reports are still difficult to access.

Despite all these shortcomings, EMA continues to issue EIA certificates authorising new developments within wetland ecosystems.

The issuing of EIA certificates appears to be based less on scientific rationale and more on the influence that project proponents can bring to bear on the regulatory authority.

The reliance on the EIA process to protect wetlands is premised on the assumption that the regulatory authority has a sincere desire to protect the environment but this appears questionable.

There is need to introduce the option of an appeal against EIA Certificates to an independently constituted body of experts and to establish guidelines for the appeal process


  1. EIA legislation/regulations should be updated to ensure that wetland conditions are identified where present
  2. To strengthen consideration of biodiversity, ecology and wetland issues
  3. To strengthen the consultation process and to ensure that stakeholder concerns are meaningfully addressed
  4. To provide guidelines for assessing and providing reasons regarding decisions on the issuing or not of EIA Certificates
  5. To improve the EIA appeal process and develop guidelines for this
  6. All EIA reports should be published on the EMA website

Concern No. 3 – National water policy doesn’t include wetlands

Wetlands play a critical role in the delivery of fresh water and thus in the management of water supplies

The management of water is included under the Ministry of Agriculture with key responsibility being designated to ZINWA

ZINWA is dominated by engineers who lack ecological understanding of the critical importance of wetlands and sound catchment management to water provisioning

The result is that the management of catchment areas is being neglected throughout the country

Concern No. 4 – Difficult for civil society to champion wetlands

The current wetland policy and guidelines do not provide a clear framework for the full participation of CBOs and civil society in the management of wetlands

It is difficult for civil society to make their voice heard and concerns raised are often not addressed

We are concerned that what engagement is availed to civil society is largely a greenwashing exercise

Video: The Management & Restoration of Harare’s Wetland Ecosystem
Julia Pierini

C.E.O. of BirdLife, Zimbabwe

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