United Nations Development Programme Global Environment Facility Full Project – Conservation and Sustainable Use of Biodiversity on the South African Wild Coast

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SECTION IV: Additional Information


Response to GEF Council Comments




Location where document was revised

United States of America

Recommend adding an indicator to capture the project’s impact on developing micro-enterprises based on sustainable natural resource use

The following indicator is added:

Number of local micro-enterprises providing a planning and management support service to the protected area estate

ProDoc: Logical Framework Analysis. Indicator 5 added under the Objective.

Result Measurement Table. Indicator 5 added under the Objective.


The project risk assessment does not address the current lack of an integrated spatial land use development plan for the Wild Coast – no mention in the proposal of how, when and by whom a spatial land development plan will be elaborated. Stakeholder buy-in into any conservation action will only be achieved through a truly participatory, multi-disciplinary, multi-sectoral, and multi-stakeholder approach to regional land use planning, a time- and cost-intensive procedure. However, the production of such a plan for the entire Wild Coast appears to be a key prerequisite for the project

The reason why the integrated spatial land use plan was not included in the project risk assessment is because a regional Strategic Environmental Assessment (SEA) and regional Land Use Plan (LUP) was prepared during the project preparation phase. Together with the regional Biodiversity Strategy and Action Plan, also prepared during the project preparation phase, these plans collectively provide the strategic framework for the operational co-ordination of conservation-related activities and projects across the Wild Coast. The process of developing these planning frameworks involved intensive and extensive stakeholder participation processes over a period of 18 months and costing in excess of ZAR 4.6m (approx US840,000).

The regional Land Use Plan and Biodiversity Strategy and Action Plan are, in turn, integrated upward into the Provincial Growth and Development Plan (PGDP) and downward into the municipal Integrated Development Plans (IDP’s). The national Department of Environmental Affairs and Tourism are currently in the process of preparing the gazetting of the regional Land Use Plan and Biodiversity Strategy and Action Plan as a bioregional plan for the Wild Coast in terms of the NEM: Biodiversity Act.

The project preparation phase further provided strategic and financial support to the local municipalities in the preparation of their respective local and site-based Land Use, and Structure, Plans. By August 2005, both District Municipalities and five (of seven) local municipalities had completed their municipal Land Use Plans.

ProDoc: Clarification provided in Policy and Institutional Context, Para. 26.

It is doubtful that establishment of a PA network can be accomplished through the chosen focus on multiple use areas (IUCN categories IV and VI). We question whether multiple use “protection” categories will be sufficient in providing the sustainable biodiversity conservation needed for Wild Coast Ecosystems that are currently under-represented in the National PA System

The point raised is acknowledged. Although the objective of the project is ultimately to proclaim as many parts of the protected area estate as practicable at a higher level of protection status (the target is category II), the initial focus on multiple use areas (IUCN categories IV and VI) is simply a question of pragmatism. In a region of such high levels of poverty where the majority of landscapes are occupied and used by rural communities, where there is an extensive subsistence dependence on natural resource utilisation and where the majority of the area is under communal land tenure, the establishment of effectively managed multiple use protected areas is considered an appropriate transitional strategic intervention that ensures that a significant proportion of the key Wild Coast ecosystems are under some form of protected area management while the socio-economic and developmental needs of the area are addressed.

ProDoc: Project Rationale and Project Conformity, Para. 77. Footnote added.

The land tenure issue is a serious obstacle to the proposed project since most communal lands are still without a land title, the process to obtain such titles may, in many cases, exceed the six-year project timeline, and the successful establishment of co-managed areas actually requires deeded land.

Tenure to land in the Wild Coast (and other communally owned land in South Africa) is currently in a state of flux as correctly indicated by the Swiss Government. The National Department of Land Affairs considers the newly enacted Communal Land Right Act, Act 11 of 2004 (CLRA) as the most appropriate mechanism for engaging with communities in respect of the transfer of land title, but acknowledges that the process of implementing the CLRA will take many years.

This issue has been addressed in considerable detail during project preparation. Legal and technical opinion reviewed during project preparation, and subsequent detailed discussions with the National Department of Land Affairs, demonstrated that there are adequate, if somewhat complex, processes and mechanisms still in place to satisfactorily enable to project to proceed without being constrained by transitional land tenure issues.

Legally tenure to the land is still currently held by the Department of Land Affairs on behalf of the communities. A number of intermediate arrangements are in place to protect this tenure until the process of tenure reform is completed. The Interim Protection of Informal Land Rights Act, 1996 (Act No. 31 of 1996) (IPILRA) is the most relevant interim measure for this project. This Act requires that developers (or in this instance, conservation agencies) negotiate with an affected local community (represented in the form of a legal entity, most commonly a Community Trust or Communal Property Association) to enter into what is termed a 25-30 year “back-to-back” lease between the lessor (the conservation agency in this instance) and the lessee who is jointly the community and the National Minister of Land Affairs. If an external developer is involved (such as a private concession), then a “joint venture” (JV) needs to be established with the legal community entity.

The CLRA provides for the transfer of any co-management or conservation agreement entered into between conservation agencies and local communities prior to the implementation of the CLRA into what is termed a ‘new order’ agreement.

ProDoc: Risks. Para 82. Risk mitigation measure for delays in transfer of tenure elaborated to reflect the transitional measures to be adopted by the project.

The six-year timeline appears too short for the achievement of the defined goals and objectives, especially in absence of an integrated spatial land use development plan for the entire Wild Coast

As indicated in the response to the GEFSEC Concept Agreement Review, the project is an integral component of the broader Wild Coast Program. The program implementation roll-out plan (the bioregional Biodiversity Strategy and Action Plan) is planned over a more realistic 15-year time horizon. The purpose of the project is to build the capacity in the different institutions to continue the process: 6 years is considered to be enough in this regard. Co-operative governance structures, funding support and implementation arrangements are being developed to ensure that the project will be sustained beyond the six-year time horizon for the GEF-funded project. As indicated above, the Land Use Plan has already been completed and directs the prioritization of and spatial context for, the Biodiversity Strategy and Action Plan.

Not applicable

None of the 24 million USD co-financing listed in the proposal has actually been committed by any of the sources cited. This dramatically increases the project risk and also does not comply with GEF principles that require proof of co-financing

The letters of financial commitment have now been secured.

Not applicable
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