Meet SANParks’ new TCIP…*

Introduction

On 19 May 2023, SANParks unveiled its Revised Draft Tokai and Cecilia Implementation Plan (TCIP) and provided a Template for Comments on its website. If you’d like to have your say on this revised draft and remain part of the Public Participation Process (PPP), you have until 19 June 2023 to do so.

Considering it took SANParks 13 months to transform an unsatisfactory 56-page draft into an equally unsatisfactory 108-page draft, the brief commenting period seems rather audacious. But, as South Africans, we thrive on tight deadlines. We won’t let our conveners down.

So, what’s wrong with it?

The title of this piece suggests that little has changed in the newly released draft implementation plan for Tokai and Cecilia, aside from a plethora of typos, literals, and grammatical errors. Perhaps I’m being hasty in my judgement after only a quick glance at the document, but nothing new catches my eye. In fact, SANParks starts off with grand promises but fails to deliver.

It’s a familiar tale.

For instance, under the heading Legal, Governance and Policy (p16), SANParks states:

Stakeholders raised concerns as to whether the outcome of the TCMF review process and the implementation of proposals would fulfil the requirements of a multitude of legal, governance and policy ‘layers’ that are applicable to the Protected Area. These include international agreements and targets (e.g. Convention on Biological Diversity and the subsequent Aichi Targets), South African Constitution, national environmental legislation, SANParks’ mandate and policies, and the Park Management Plan. Included in this are references to historical work to protect the CPPNE such as the Fuggle ‘multi-use’ studies and the Huntley report. A few stakeholders also point to the more recent ‘Court Order’ and ‘Court Judgement’ that need to be recognised. Stakeholders would like to see that these be considered in line with the current TCMF’s overarching vision of managing Tokai and Cecilia into the future in terms of legal requirements, applicable policies, and agreements.

Well, would they? Will they? Should they?

We aren’t told.

And then, at 4.3.10 under ‘Blank Page’ Future Approach (pp23/4), SANParks concedes that:

Stakeholders commented on the lack of a SANParks position in the review process. Although the process had been described as a review of the current TCMF, at the same time stakeholders were given ‘a blank page’ with which to work with no clearly defined parameters. At the initial public information sessions, a review of some of the plans prepared was presented but no SANParks’ view or vision was put forward. Stakeholders noted that the planning framework must support the long-term survival (more than 100 years) of the Protected Area and, within it, must clearly explain SANParks’ mandate inclusive of the whole history and environment, a heritage for all in South Africa.

In the revised Draft TCIP, where does SANParks clarify or state its stance on any of the issues raised?

Such positions are nowhere to be found. We, as stakeholders, are left in the dark.