GLOBAL ENVIRONMENT FACILITY PROPOSAL FOR REVIEW
Project Title:
Rehabilitation of Protected Areas Republic of the Congo
in the Democratic
GEF Implementing Agency: Executing Agency: Local Counterpart Agency: Requesting Country: Eligibility: GEF Focal Area: Operational Programmes:
UNDP UNOPS Institut Congolais pour la Conservation de la Nature (ICCN) Democratic Republic of the Congo CBD ratified 3 December 1994. Eligible for UNDP support. Biodiversity Forests, Coastal & Marine, Mountains
Summary of Expected Outcomes: This project will contribute directly to the conservation of biological diversity in the Democratic Republic of the Congo by creating a supportive policy, legislative, financial, institutional and social environment for protected areas while at the same time setting in motion a long term process to both rehabilitate and strengthen these protected areas. Rather than attempting to carry out the latter in its entirety, the project will take the initial steps of assisting ICCN to undertake a fundamental restructuring towards a decentralized management organization, of restoring essential functioning to the 16 priority protected areas, and assisting ICCN to develop new approaches to protected area management based on a more participatory approach to conservation. In this way the project will provide a sound structural and functional basis for the long term rehabilitation of the entire protected area system of the DRC. GEF Financing and Leverage GEF Financing (inc. PDF A): US$ 6.32 (PDF Allocation: US$25,000) Cofinancing – IA: US$ 7.16 - Donor: US$ 0.50 UNHCR US$ 1.80 EU Kivu & Virungas (1) US$ 1.20 EU ECOFAC (1) US$ 1.20 GTZ Kahuzi-Biega (1) - Natl. Govt: US$ 1.78 Total Project Costs: US$ 19.96 Associated Financing: US$ US$ US $ 339,000 Biodiversity Country Study (UNEP-GEF) 333,000 Biodiversity Enabling Activity (UNDP-GEF) 623,000 National Environmental Action Plan (UNDP)
Operational Focal Point Endorsement: Ir. Benoit KENA MWAUKE, Secrétaire Générale pour l’Environnement Ministére de l’Environnement, Conservation de la Nature et Tourisme. 20 August 1997
1. Estimated and provisional depending on final donor decision
Congo Protected Areas
Contents
Proposal:
Country / Sector Background / Context Project Objectives and Description Rationale for GEF Financing Sustainability and Participation Lessons Learned and Technical Review Project Financing and Budget Incremental Costs and Cost Effectiveness Issues, Actions, and Risks Institutional Framework and Project Implementation
Annexes:
1. 2.a. 2.b. 3. 4. 5. 6. 7. 8. 9.
Project Financing and Budget ICCN Basic rehabilitation needs Budget for equipment for ICCN basic operations Project Logframe Incremental Cost Analysis Synopsis of 1991 Review of ICCN by the World Bank Technical Review Map of Congo’s Protected Areas Government Letter of Endorsement References Cited
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Congo Protected Areas COUNTRY/SECTOR BACKGROUND/CONTEXT Introduction: 1. The Democratic Republic of the Congo (RDC), until recently known as Zaire, is recognized as being among the two most important countries in Africa in terms of biological diversity given its genetic, specific, and ecosystemic diversities (Mittermeier and Werner 1989, Doumenge 1990; McNeely et al. 1990). Protected areas represent approximately 7.7% (18,050,690 ha) of the countries land mass (234,488,500 ha). However, as a consequence of the policies of the previous political regime the country’s protected areas have suffered a long period of decline culminating in the appropriation of most of their remaining management resources during the recent liberation war. In view of the new political regime a number of major donors are preparing to restart their assistance programmes to the RDC and these are expected to include investments in biodiversity conservation. However, there is an immediate need to restore basic functions to protected areas and to put in place a conducive policy, legislative, and institutional environment on which these longer term rehabilitation efforts can be built. This is the purpose of this initial three year GEF contribution. Context 2. Over the past 32 years, the RDC has been through tremendous economic, social, and political difficulties including a stagnant economy, hyperinflation, precipitous declines in real wages, and the subsequent dependence of a majority of the citizenry on an informal subsistence economy based on uncontrolled natural resource exploitation. These political, economic, and social forces caused most donor organizations- including the World Bank and USAID, to suspend their aid programs in the early 1990s. In 1996 the IMF/World Bank concluded that economic stability and recovery were progressing, given that inflation fell in 1995 from an estimated 9,000% to only 189%, and that the government showed a surplus in its operating budget. While against this background a number of the major multilateral and bilateral donors were considering restarting their normal assistance programmes and UNDP had been asked to prepare a donor Round Table, major political changes in May 1997 have provided new impetus to these initiatives. The replacement of the previous 32 year long political regime, following a brief liberation struggle by the Allied Democratic Forces for the Liberation of the Congo (AFDL), has established new era of hope and rapid social, political and economic transformation is being effected. In this new context many donors are restarting their normal assistance programs and UNDP, for example, is reinforcing its on-going aid program, which now has a current balance of $41 million. 3. While it is anticipated that within two years many of these donors will restart their assistance programmes to biodiversity conservation activities in the RDC, there is a need to establish a sound political, legislative and institutional base for this work, as well as to immediately restore basic functions at priority protected areas. This is a short, three year, project designed to do exactly this. It will lay the groundwork for more ambitious donor funded biodiversity planning and management efforts by a number of donors including the World Bank, USAID, the European Union and the German government who have all encouraged UNDP to develop this project. The major international Non-Governmental Organizations (NGO), who have been continueing biodiversity conservation work in the Congo over the last few years, have also participated in its development. These include WWF, DFGF, and WCS. 4. Over the past two years, important progress in environmental planning on the part of governmental and non-governmental organizations has been taking place in the Democratic Congo. Playing a key role in this is the Ministry of Environment, Nature Conservation and Tourism
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Congo Protected Areas (MENCT). As part of a long-term planning programme started after the Earth Summit on Environment and Development in 1992, the ministry established the special multi-agency Comité Interministériel de Coordination (CIC), to focus on: (a) formulating a National Environmental Action Plan (NEAP), with assistance from UNDP; (b) completing a Biodiversity Country Study, sponsored by UNEP-GEF; and (c) developing a National Biodiversity Strategy and Action Plan (NBSAP), again with UNDP-GEF support. 5. During 1996 and 1997, again with UNDP support, the CIC formulated a NEAP for the country. The NEAP recognizes biodiversity as a major component of the environmental sector in the Democratic Congo and key priorities laid out in the NEAP are: (a) the establishment of a supportive policy, legislative, financial and social environment for both environmental activities in general and biodiversity activities in particular; and (b) an emergency rehabilitation of RDC’s protected areas (PA) to ensure biodiversity conservation. 6. With support from UNEP and UNDP, the CIC organized the first national biodiversity seminar from 1-4 July 1995. At this time priorities were agreed on for development of the NBSAP and the first outline of the present project was developed. Project preparations were completed at a second national planning workshop on 9 and 10 July 1997, again supported by UNDP, where details of the immediate rehabilitation of the protected areas system were worked out. Biodiversity Overview and Global Importance: 7. The Democratic Congo harbors an unusually wide range of biomes, ecosystems and habitats when compared to other African countries including: tropical forests (52% of total land area), woodland savannas (30% of total land area), grassland savannas (16% of total land area), and, to a lesser extent, afromontane forests, mangroves, papyrus, peat bogs, pools and seasonally inundated savannas (dambos), dry evergreen forests (muhulus), and dry woodlands (miombos) (Goodson 1988; Hedeberg 1979). In terms of species diversity, the Congo is ranked first among African countries for several taxonomic classes including: 409 species of mammals; 1086 species of birds; 216 species of amphibians; 280 species of reptiles; 48 species of butterflies; 10,000 species of angiosperms of which 3,000 are endemic to the Congo (McNeely et al. 1990). Rates of endemism for freshwater fish species in the Congo's lakes and rivers is estimated at 70% (Seligman 1991, McNeely et al. 1990). Threats to Biodiversity: 8. Historically, low overall human population densities (17 inhabitants/km²) and low deforestation rates (0.5% per annum) have resulted in low human land-use impacts on the Congo's biodiversity resources. Nevertheless, a sustained 3.9% per annum growth in human population since 1950 in the Kivu region of east (Wils et al. 1976; Institut National de la Statistique 1984) has resulted in permanent conversion of vast forested areas into a mosaic of agricultural and degraded landscapes. Representative ecosystems in the Albertine rift, an area with extremely high endemism (Pomeroy 1993), have become surrounded by areas where the human population density exceeds 300 individuals per square kilometre (Institut National de la Statistique 1984; Shiva 1995).
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Congo Protected Areas 9. In western Congo the Marine Mangrove Park, which houses endangered West African manatees, off-shore oil drilling and commercial fishing have left only 50% of the coastal marine ecosystem intact. In the north-east human pressures on resources have been further exacerbated by the arrival of refugees from the Sudan in 1991 and Rwanda in 1994 and rapid habitat degradation has been experienced in the areas around the Okapi Wildlife Reserve (Ituri Forest), and Garamba, Kahuzi-Biega, and Virunga National Parks (Languy 1995, Biswas et al. 1994). New settlers have invaded protected areas such as Kundelungu, Garamba, Maïko, and Upemba National Parks. At Salonga National Park organized teams have poached elephants in areas where exploitation by local populations is reportedly otherwise negligible. Social/Cultural/Economic Issues: 10. Until recently the Congo has had one of the most unstable economies in the world including a drop in GDP from US$ 14.76 billion in 1980 to US$9.56 billion in 1990. The annual inflation rate was estimated at 6,000% and annual per capita income stood at US$ 90. Under these dire conditions, the informal economic sector thrived in the Congo with more than 75% of the population making a living from informal activities such as subsistence agriculture, including animal husbandry, and hunting and gathering. The Congo possesses unusual cultural diversity with some 360 recognized tribal groups that complicate governance by a central government as well as attempts at community-based development. On the ground, dual conflicting land tenure systems greatly complicate all aspects of daily living. While local people claim ancestral rights over land, the State has enacted a law (Bakajika Law) asserting exclusive ownership and control over access of land and the natural resources on it. Institutions/Regulations: 11. Two key institutional and regulatory factors, including a weak policy, legislative and institutional environment, and a weak protected areas management agency, currently impede effective management for biodiversity conservation. These issues are noted in the NEAP. The conflict between the traditional land tenure systems and centrally enacted legislation is be addressed through new legislation. New environmental legislation will establish a National Environment Agency (NEA) and National Environment Fund (NEF). Environmental considerations are also to be introduced into all regional and sectoral planning and procedures for environmental impact assessments are to be put in place. A national environmental education programme is also to be carried out, focusing on the areas around protected areas and using the church as one vehicle of communication. 12. While the NEA will take over the broader environmental policy and regulatory responsibilities of the Ministry of Environment Nature Conservation and Tourism (MECNT), the latter is expected to retain responsibility for policy and regulatory issues associated with nature conservation and tourism. Responsibility for the management of protected areas will remain with the parastatal Congolese Institute for Nature Conservation (ICCN). Currently the government has no plans to change the status of ICCN. However, recommendations from the first national seminar on biodiversity as well as conclusions from existing studies (e.g. World Bank Assessment of ICCN in 1991, European Community Review of ICCN in 1990), Biodiversity Country Study, NEAP, and the July 1997 project development workshop, all point to the need to review and streamline the functioning of ICCN through decentralization and adoption of improved management approaches. Major institutional issues include: (a) insufficient financial, material, and trained human resources to ensure basic operations of Protected Areas;
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Congo Protected Areas
(b) excessive centralization in the management of protected areas; and (c) non-participation of local communities in the conservation and management of protected areas. The new government of the DRC is committed to addressing these issues and a restructured and decentralized ICCN is a key output of this project. Project History: 13. The project development process, funded under GEF PDF Block A ($25,000), included a combined UNEP-UNDP organized national biodiversity seminar (also attended by the World Bank and other bi- and multi-lateral donor agencies as well as local and international NGO) which identified priorities for the development of a National Biodiversity Strategy and Action Plan (NBSAP) to be completed following the UNEP-GEF sponsored Biodiversity Country Study. The seminar also called for immediate action to safeguard 16 active sites(1) for protected areas already identified as the most important sites for biodiversity conservation in the Democratic Congo. These are: Virunga, Garamba, Kahuzi-Biega, Maïko, Upemba, Kundelungu and Salonga National Parks, as well as Nsele, Muanda (mangroves park), Ituri (Okapi Wildlife Reserve) Bombo-Lumene, Swa-Kibula, Mangaï, Bushimaï, Bili-Uere, Luama Forest or Game Reserve. These sites were identified over a period of time and on the basis of various studies, most notably a series of studies undertaken by the Food and Agricultural Organization, the World Conservation Union (IUCN), and the World Bank, and on which there is consensus amongst both national and international experts on their importance in preserving critical habitats and biodiversity in the Congo. However there are non-active conservation sites such as Itombwe, that will need intervention on a later stage. 14. The project forms a part of a broader UNDP program of environmental support and training to the Congo. It also builds upon and complements several past and on-going projects including those of: the Wildlife Conservation Society (WCS) and Gilman Investment Corporation (GIC) at the Okapi Wildlife Reserve and Ituri Forest; the German Technical Assistance (GTZ) at Kahuzi Biega National Park; the Dian Fossey Gorilla Fund (DFGF)’s initiatives in Mount Tshiaberimu and Virunga Conservation Center; WWF projects in Garamba and Virunga National Parks; previous World Bank (Japanese Trust Fund) support to protected area planning; USAID support to NGO initiatives; the European Union to the Kivu region and the Virungas in particular; and UNESCO support to various World Heritage Sites. More recently the UNHCR, UNDP, EU and GTZ have been assisting in mitigating the impacts of the large refugee camps in eastern Zaire on the Virungas and Kahuzi-Biega national parks. UNHCR will continue to support some basic environmental rehabilitation measures through the first part of the project period – the refugees having now departed and the camps closed. Relevant GEF support includes the country study (UNEP), National BSAP (UNDP), Emergency Support to the Virungas (UNDP), and the Regional Environmental Information Management Project -REIMP (World Bank).
(1)
The sixteen ICCN active sites for protected areas are altogether subdivided into twenty-eight management units or “STATIONS,” here reside local park managers and their administrative support staff. Generally national(l) parks have each several such management units (stations), whereas game and forest reserves each has only one station.
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Congo Protected Areas PROJECT OBJECTIVES AND DESCRIPTION Project Strategy: 15. This project will contribute directly to the conservation of biological diversity in the Democratic Republic of the Congo by creating a supportive policy, legislative, financial, institutional and social environment for protected areas while at the same time setting in motion a long term process to both rehabilitate and strengthen these protected areas. Rather than attempting to carry out the latter in its entirety, the project will take the initial steps of assisting ICCN to undertake a fundamental restructuring towards a decentralized management organization, of restoring essential functioning to the 16 priority protected areas, and assisting ICCN to develop new approaches to protected area management based on a more participatory approach to conservation. In this way the project will provide a sound structural and functional basis for the long term rehabilitation of the entire protected area system of the DRC. Project Objective: 16. Within the overall objective of ensuring conservation of the important biodiversity of the Congo basin the specific objective of the project is: To establish a sound structural and functional basis for protected area planning and management in the Democratic Republic of Congo. 17. Four specific objectives or outputs are anticipated (these and the activities associated with them are detailed in the logical framework table - Annex 2.): Output 1. A supportive policy, legislative, institutional, financial, institutional and social environment for protected areas is created. 18. This will be achieved through supporting the establishment of the National Environment Agency and a National Environment Fund (no GEF resources will be used in this work which will be entirely supported by UNDP); updating national legislation on the environment, and particularly that relating to land tenure; elaborating procedures for environmental impact assessment and incorporating environmental issues into regional and sectoral planning; establishing a national environmental information system; and supporting the development of environmental education programmes targetted at the populations living around key protected areas. Output 2. The Congolese Institute for Nature Conservation is restructured and a decentralized system of protected area management is put in place. 19. In accordance with the various institutional analyses of ICCN conducted in recent years, and in particular the World Bank study of 1991, ICCN will restructure itself towards a decentralized institution with a small headquarters policy, planning, monitoring and technical support unit providing support to relatively autonomous protected area management units. Similarly a new system of financial management and accounting will be put in place. Associated with its new decentralized structure, the vast size of the country, and the difficulty in communications, ICCN will design and implement a system for communication and information gathering and exchange between its functional units. It will also develop a national protected areas system plan. Output 3. Essential functioning is restored to all protected areas through supply of essential human, material, and financial resources.
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Congo Protected Areas
20. The minimum essential equipment for protected area and headquarters operation, including vehicles, radios, bicycles, camping equipment, etc (see Annex 3) will be acquired. A technical retraining programme will be established and all “Conservator” level staff will receive refresher training, including instruction in their new responsiblities under a decentralized management system. Revenue generating systems, based on tourism receipts, will also be re-established and essential visitor services put back in place. These activities are specifically designed to facilitate the planning and launching of broader rehabilitation efforts supported by other donors and specific details of essential support will be adjusted as appropriate as such programmes are launched. Output 4. Approaches to participatory and community-based management of protected areas in the Congo are defined on the basis of analysis of experience at pilot sites. 21. Current protected area management approaches in the Congo are primarily based on historical exclusionary systems of management. Alternative approaches involving local community participation have in the past been experimented with by a number of NGO’s. These activities will be restored as pilot demonstration sites for use both in staff retraining, and, on the basis of analysis and lessons learned from them, as the basis for developing more general participatory approaches to protected area management in the Congo.
RATIONALE FOR GEF FINANCING 22. The project responds directly to the “Forests” operational programme of the GEF. Maintaining an effective network of protected areas in the Congo is essential for in-situ forest conservation. In terms of globally significant biological diversity Zaire is one of the two richest countries in Africa. In addition to a known 409 species of mammals, 1,086 species of birds, 216 species of amphibians, 280 species of reptiles and more than 10,000 species of angiosperms, of which at least 3,000 are endemic to the congo, it is thought that there are many species as yet undescribed in the dense tropical forests that cover 52% of the country’s land area. A number of these, such as the northern white rhinoceros, African elephant, mountain and Grauer’s gorilla, manatee, okapi, bonobo and Congo peacock, are well-known flagship species and sub-species. In addition to its species diversity Congo supports a wide range of ecosystems including marine, montane and lowland forest, and savanna habitats. 23. Currently an unknown number of species and ecosystems are under direct threat because of the virtually complete breakdown in the ability of the national protected areas institution to manage these protected areas. Basic essentials for management do not exist at most parks. 24. This project is very much country-driven. The Democratic Congo was among the first countries to sign at the United Nations Conference on Environment and Development (1992) and to ratify (1994) the Convention on Biological Diversity. Despite the political and economic conditions of the last 32 years the country has made important steps towards improved environmental management in general and biodiversity conservation in particular. Through the Ministry of the Environment, Nature Conservation and Tourism, the country is engaged in an active long-term participatory process for environmental planning which includes biodiversity conservation as a primary objective. Activities already carried out, or in process, include: i) the development and implementation of a National Environment Action Plan;
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Congo Protected Areas ii) a comprehensive assessment of the status and threats to its biological diversity, from the formulation of a Biodiversity Country Study to the development of a NBSAP; the organization of a series of national seminars on biodiversity conservation and sustainable use; and the organization in July 1997 of a project planning workshop by ICCN.
iii)
iv)
25. The project prevents the loss of previous investments. Organizations such as the Wildlife Conservation Society (WCS), the Dian Fossey Gorilla Fund (DFGF-Europe), World Wide Fund for Nature (WWF-Int.), the European Union (EU), German Technical Assistance (GTZ), and the World Conservation Union (IUCN) already have invested considerable human, material, and financial resources at protected areas such as Salonga, Garamba, Virunga, and Kahuzi-Biega National Parks. The World Bank, through a Japanese Trust Fund, has provided extensive assistance to ICCN and partner NGOs such as WWF and IUCN to develop management plans for many of the Congo's gazetted protected areas. The European Union has offered general support for refugee relief and agricultural development in the Kivu province and is in the process of restarting its support to Salonga National Park under the ECOFAC programme. While some of the benefits of these previous investments have already been lost because of the recent political and economic situation, action at this time when the adverse political and economic forces have been removed can prevent further losses. 26. The project leverages significant additional financing immediately as an essential part to a broader UNDP environmental support program in the Congo, the project includes cross-sectoral co-financing with government agencies and partner NGOs. It also lays a critical foundation for the revival of other bi-lateral and multi-lateral donor financed biodiversity conservation programs in the Congo.
SUSTAINABILITY AND PARTICIPATION Sustainability: 27. By building a sound structural and functional foundation for protected area management in the Congo this project will create an effective operational context for long-term in-situ conservation measures. While financial means for long-term protected areas management do not currently exist in the Congo important components of the project include the establishment of an environmental tust fund, the establishment of a new system of financial management, the restoration of basic revenue generating functions, including gorilla based tourism, and the development of a protected areas system plan that will include a long term financial plan for sustainability taking into account both the economic realities in-country and the need to design a lower-cost, more financially sustainable, decentralized approach to protected areas. Further, financial sustainability is not anticipated at the end of this first three year GEF capacity building investment. An explicit result of this project is to have laid the groundwork for further donor support to protected areas and biodiversity conservation in the Democratic Congo, as well as creating the conditions whereby the once lucrative eco-tourism industry based on gorilla visitation can restart. Participation: 28. Project preparation has involved extensive discussions with and between many government departments, academic institutions, and NGOs. The first national biodiversity seminar joined 130
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Congo Protected Areas participants including representatives from local communities and local and provincial administrators as well as central government and donor representatives. The ICCN project planning workshop was attended by managers from various Protected Areas, NGO representatives, advisors to the MECNT, and UNDP personnel. 29. The planning components of the project will follow a participatory methodology designed to engage representatives from all sectors of society in a process of consultation and decision-making regarding the direction and scope of protected areas planning and management in the Congo. In this it will draw on the pilot activities in community participation to be restored at various key protected areas. The refresher training of managers will include lessons from these participatory activities and should lead to further discussions between managers and local communities at all of the country's sixteen active protected areas.
Lessons Learned and Technical Review Lessons Learned: 30. The development of this project draws on a wide range of experience both in the Congo and elsewhere by a wide range of actors including IUCN, ICCN, WWF, DFGF, WCS, GIC, GTZ, the EU, UNHCR, UNDP, the World Bank, and GEF STAP technical reviewers. At a macro level it was guided by the need to have in place a supportive poltical, legislative, institutional, financial and social environment. At the middle level it was guided particularly by the conclusions from the World Bank (1991) institutional review of ICCN, as well as increasing experience with protected areas worldwide which points to the need to decentralize protected area management retaining a core policy, planning and monitoring unit while giving management responsibility to protected area units. It was also guided by experience throughout Africa which shows that lower cost more participatory approaches to protected areas management are essential for financial sustainability. At the micro-level project design is guided by a number of innovative pilot activities in community participation in protected area management which, like numerous similar experiments worldwide, suggest that carefully organized participatory management activities with community members can increase mutual understanding regarding on-site management objectives and subsequently reduce over-exploitation in protected areas. Finally the project is guided by UNHCR’s and UNDP’s own recent experience over the last three years in the Congo in both managing and administering environmental projects associated with refugee impacts in eastern Zaire and the preparation of the NEAP and the implementation of the GEF financed biodiversity country study and biodiversity strategy and action plan. Technical Review: 31. A 1996 an earlier version of this proposal was reviewed by Drs. Michael Harrison and Annie Gauthier-Hion from the GEF STAP roster. Harrison's comments reflected a general precautionary approach regarding the implementation of projects in the Congo, then Zaïre, because of the risks associated with the then political and economic situation. Gauthier-Hion shared several of Harrison's concerns and identified an apparent overemphasis on sites focusing on endangered mega-fauna in northeastern Congo. The reason for the latter was that at that time these sites were the most critically threatened, are considered vitally important biologically because of their very high rates of endemism, and were sites where international NGO’s were still active and success could be reasonably anticipated. In view of the changed political and social circumstances this proposal now addresses all 16 priority sites as identified by the various biodiversity planning processes described above. These 16 priority sites are divided into 31 management units or stations.
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Congo Protected Areas
32. This project recognizes fully the difficulties of working in the Democratic Congo, but in view of recent political developments there is hope for social, economic, and political stability and further improvement in the near future. Also in view of the experience of CIC and UNDP in implementing various environmental activities, including emergency response measures in the Virunga’s and the preparation of a NEAP, biodiversity country study, and now the BSAP, it is felt that a carefully designed and closely monitored three-year project geared specifically at addressing the inherent problems of the Democratic Congo can be effectively carried out at this point in time. This project is also critical to paving the way for other donor investments in that in addition to establishing a sound basis for future biodiversity conservation activities it demonstrates the feasibility of biodiversity support activities under current conditions. 33. The STAP technical review of the latest proposal assists in highlighting the critical delicate balance that must be achieved during project implementation. On the one hand “protective” functions must be restored to existing protected areas as an urgent priority, while on the other hand a new more participatory and community development based approach to protected area management must be introduced and adopted. In this regard lessons from the APN approach in Madagascar, which show that individual and institutional reorientation are more important in the short term than the provision of alternatives, are relevant. Similarly, the history of the COBRA project in Kenya demonstrates the difficulties associated with achieving such reorientation. Project design takes these lessons into account by providing only for the restoration of critical basic protective functions and combining these with retraining that addresses the need for more participatory and developmentally oriented approaches. While the STAP reviewer particularly notes the need for close integration of outputs 3 and 4 in order to address this issue, project design assumes that there will be close integration of all 4 outputs since outputs 3 and 4 are both fundamentally linked to political commitment and decentralization at both ICCN (output 2) and higher government (output 1) levels. Again, as the reviewer notes, the key will be to ensure that the correct balance and timing is achieved throughout implementation and this has been clarified in the text. The above is critically related to project duration. This project provides for an initial GEF contribution over a period of 3 years. However, the background context includes other interventions that have a longer duration. The first 5 years of what can be taken as a rolling programme is described. Currentl there is commitment from the highest levels of government for an election process to take place two years from now. It is assumed that in the light of political developments and commitments over the course of the next two years a second phase of GEF investment will follow. Consequently the time frame for the present GEF intervention, including one year for the design of the follow-on investment project, is three years. The text of the proposal has been reworded to clarify this. PROJECT FINANCING AND BUDGET 34. Summary Budget by Component (US$)
Component Policy Environment Restructuring Essential Eqpt & Training
GEF
Government
UNDP 7,160,000
Other Donor
Total 7,160,000 745,017 9,282,930
580,756 3,572,486
164,261 1,010,444
4,700,000
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Congo Protected Areas Participatory Management Total 2,154,199 6,307,441 609,295 1,784,000 2,763,494 19,951,441
7,160,000
4,700,000
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Congo Protected Areas Detailed Budget for GEF Financed Component
Year 1 220,000 120,000 60,000 40,000 70,000 15,000 25,000 30,000 820,000 50,000 30,000 30,000 40,000 125,000 30,000 145,000 200,000 25,000 125,000 20,000 Year 2 190,000 120,000 30,000 40,000 70,000 15,000 25,000 30,000 1,120,000 80,000 65,000 50,000 100,000 250,000 50,000 145,000 200,000 20,000 125,000 35,000 150,000 25,000 125,000 10,000 Year 3 190,000 120,000 30,000 40,000 70,000 15,000 25,000 30,000 720,000 25,000 10,000 30,000 100,000 15,000 145,000 200,000 20,000 125,000 50,000 135,000 10,000 125,000 45,000 TOTAL 600,000 360,000 120,000 120,000 210,000 45,000 75,000 90,000 2,660,000 155,000 105,000 110,000 240,000 375,000 95,000 435,000 600,000 65,000 375,000 105,000 2,135,120 150,000 1,985,120 65,000 170,104 467,218 6,307,441
1. Personnel (SUBTOTAL) a) Chief Technical Advisor (24person months) b) international consultants (12person months) c) national technical consultants (60person months) 2. Operating Costs (SUBTOTAL) a) air travel b) ground travel c) project operations 3. Activities and Subcontracts (SUBTOTAL) 2.1 Institutional assessment, restructuring and decentralization 2.2 Design and installation of financial management systems 2.3 Design and implement information & communication system 3.2 Design and implementation of re-training system for ICCN staff - Virunga Training Center rehabilitation (DFGF) 3.3 Re-activate revenue generating systems 4.1 Restore and maintain pilot activities with participating organizations - Ituri Forest Reserve sub-component (WCS & GIC) - Garamba National Park sub-component (WWF) - Maïko National Park sub-component (ADEDE) - Kundelungu and Upemba National Parks sub-component (NGO) 4.2 Monitor, evaluate and design community based approaches
4. Project Equipment (SUBTOTAL) 1,850,120 - 2 vehicles, 2 computers, 2 printers, telephone, faxes, photocopiers, supplies, 115,000 etc. 3.1 Critical basic equipment for 31 PA management units 1,735,120 5. Monitoring and Evaluation Contingency @ 3% Project Support Services GEF TOTAL (US$) 10,000 89,104 244,738 3,303,961
46,200 34,800 126,896 95,584 1,713,096 1,290,384
INCREMENTAL COSTS AND COST EFFECTIVENESS Incremental Costs: 35. The incremental cost analysis (see Annex 4 for details) illustrates that the level of financial and technical resources dedicated to protected areas management in the baseline is not sufficient to conserve the extraordinary species diversity and endemism in the Democratic Republic of Congo. In order to secure these benefits, significant actions need to be taken to address weaknesses in the policy, institutional, and regulatory environment. Further, the need to create an institutional and legal environment conducive to conservation efforts is particularly important to revitalize efforts from other parts of the donor community. 36. The cost of baseline activities, including projected expenditures on all aspects of conservation management at the national level and field sites, amounts to US$ 13,150,000 over five years. The costs of incremental activities under the GEF alternative amount to US$ 19,951,441, of which US$ 7,160,000 will be provided by UNDP as co-financing for implementation of the NEAP. US$ 1,784,000 will be provided by the government, US$ 500,000 by UNHCR, US$ 1,800,000 by EU, US$ 1,200,000 by EU/ECOFAC, and 1,200,000 by GTZ. The GEF will contribute US$
11
Congo Protected Areas 6,307,441 towards these incremental costs. GEF financing amounts to 19% of the total costs of the alternative course of action and 32% of the incremental costs. Cost Effectiveness: 37. The project will achieve long-term cost effectiveness by creating an environment conducive to effective protected area planning and management in the Congo and by assisting ICCN restructure itself towards a decentralized, more cost-efficient organization. In addition its actions provide immediate support to simply reestablish the essential minimum basic management functions of protected areas. These investments will allow preventive planning and capacity building which will leave ICCN better able to handle situations on the ground and thus reduce future costs incurred by such real pressures on protected areas as human encroachment, and prepare ICCN for additional donor financing which this project will actually directly leverage. ISSUES, ACTIONS, AND RISKS 38. (i) The project rests on five premises: that the new government of the Congo will continue to change the political, social and economic environment in the direction of stability and transparancy; that the government of the Congo, including MECNT, CIC, ICCN, and other partner agencies, is making a genuine attempt to establish an effective structural and functional environment for biodiversity planning and management; that suitable national legislation is enacted that resolves the conflict between central and traditional approaches to land tenure; that ICCN accepts the institutional restructuring recommendations included in the World Bank report and is willing to undertake the restructuring process; that other donors are indeed ready to return to support the more extensive rebuilding of Congo’s protected areas after this initial rehabilitation.
(ii)
(iii)
(iii)
(v)
39. There are reasons to expect that all these assumptions will be met. Government reforms are continueing to move forward and a two year transition period has been set. Both the MECNT, CIC, and ICCN have been closely involved in the development of this and the NBSAP development process is already underway. All parties seem to accept and support the project's objectives. The need for new legislation is clearly laid out in the NEAP and the government seems committed to the development of the NEA and the incorporation of environmental concerns into all sectoral and regional planning. Most of the major donors have made concrete steps towards restarting their activities in the new Democratic Congo, and the World Bank as well as the International Monetary Fund are renegotiating their programs with the new political leadership of the country. USAID is considering restarting its development program in the Democratic Congo with the extension of the CARPE (Central African Regional Programme for the Environment) project into Congo and the organization of a donor round table. 40. Despite this the project must deal with significant issues pertaining to the ongoing fragility of political, economic, and social systems in the Congo. These factors, include: hyperinflation; conflicting land tenure policies and local landlessness; migration; influxes of refugees from Rwanda, Burundi, and Sudan; and wide dependence on the land-based informal economy. The
12
Congo Protected Areas new government has promised economic and monetary reforms to lead first to stabilization of the economy and later on to its growth. However, the project's approach of decentralization, institution building, and a strong move towards more participatory approaches to protected area management, represent fundamental shifts in current administrative direction and, if successful, are expected to make biodiversity planning and management less dependent on centralized bureaucracies and less susceptible to waves of economic, political, and social instability. INSTITUTIONAL FRAMEWORK AND PROJECT IMPLEMENTATION Institutional Framework and GEF Implementing Agency and other Donor Coordination: 41. In view of the need to overcome the legacy of the corruption which was widespread under the previous regime, UNOPS will serve as the executing agency that will procure and contract (under the guidance of ICCN), the partner NGO’s (both national and international), specialist technical consultants, and equipment, as well as providing monitoring and evaluation services. The local UNDP office will also monitor the project closely. The lead national institutions are the MENCT, the CIC, and the ICCN. MENCT is the parent ministry for both CIC and ICCN (a parastatal). It is also directly responsible for all activities under output 1 - establishment of a supportive policy, legislative, institutional, financial and social environment - with appropriate tasks being delegated to the CIC. ICCN is responsible for the outputs directly related to protected areas, ie. outputs 2-4. 42. A Steering Committee will be established which will include: representatives of CIC and, once established the NEA; ICCN; international NGO’s involved in pilot activities; and key donors such as UNDP, the World Bank, USAID, GTZ and the European Union. The steering committee will ensure overall coherance of the programme as well as approving annual work plans, reports, and all contracting arrangements. Project Monitoring, Evaluation and Overall Supervision: 43. In view of past circumstances in the country this project will be subject to particularly intense monitoring and scrutiny by UNDP and the Steering Committee will also establish and closely monitor project checkpoints. Overall monitoring and supervision will be carried out in accordance with standard UNDP and GEF procedures. The project will be subject to an annual TPR and PIR and a final independent evaluation.
13
Congo Protected Areas
Annex 1. PROJECT FINANCING AND BUDGET
Year 1 A. UNDP Contribution 3. Activities and Subcontracts (SUBTOTAL) 1.1 Establish National Environment Agency 1.2 Establish National Environment Fund 1.3 Establish National Environmental Legislation 1.4 NEAP provisions into regional & sectoral planning 1.5 Environmental Education programmes 1.6 Procedures for Environmental Impact Assessments (EIA's) 1.7 National environmental information system 2.4 Protected Area Systems Plan 3.4 Support to management of mountain forests B. GEF Contribution 1. Personnel (SUBTOTAL) a) Chief Technical Advisor (36person months) b) international consultants (12person months) c) national technical consultants (60person months) 2. Operating Costs (SUBTOTAL) a) air travel b) ground travel c) project operations 3. Activities and Subcontracts (SUBTOTAL) 2.1 Institutional assessment, restructuring and decentralization 2.2 Design and installation of financial management systems 2.3 Design and implement information & communication system 3.2 Design and implementation of re-training system for ICCN staff - Virunga Training Center rehabilitation (DFGF) 3.3 Re-activate revenue generating systems 4.1 Restore and maintain pilot activities with participating organizations - Ituri Forest Reserve sub-component (WCS & GIC) - Garamba National Park sub-component (WWF) - Maïko National Park sub-component (ADEDE) - Kundelungu and Upemba National Parks sub-component (NGO) 4.2 Monitor, evaluate and design community based approaches 2,192,000 388,000 76,000 295,000 468,000 651,000 314,000 0 0 0 Year 2 2,129,000 303,000 126,000 156,000 681,000 402,000 263,000 198,000 0 0 Year 3 1,668,000 166,000 106,000 60,000 703,000 303,000 0 102,000 228,000 0 Year 4 892,000 0 0 0 497,000 0 0 0 0 395,000 Year 5 279,000 0 0 0 135,000 0 0 0 0 144,000 TOTAL 7,160,000 857,000 308,000 511,000 2,484,000 1,356,000 577,000 300,000 228,000 539,000
220,000 120,000 60,000 40,000 70,000 15,000 25,000 30,000 820,000 50,000 30,000 30,000 40,000 125,000 30,000 145,000 200,000 25,000 125,000 20,000
190,000 120,000 30,000 40,000 70,000 15,000 25,000 30,000 1,120,000 80,000 65,000 50,000 100,000 250,000 50,000 145,000 200,000 20,000 125,000 35,000 150,000 25,000 125,000 10,000 46,200 126,896 1,713,096 371,000 141,500 15,000 192,000 22,500 600,000
190,000 120,000 30,000 40,000 70,000 15,000 25,000 30,000 720,000 25,000 10,000 30,000 100,000 15,000 145,000 200,000 20,000 125,000 50,000 135,000 10,000 125,000 45,000 34,800 95,584 1,290,384 371,000 141,500 15,000 192,000 22,500 1,200,000 600,000 300,000 300,000 4,529,384
0
0
600,000 360,000 120,000 120,000 210,000 45,000 75,000 90,000 2,660,000 155,000 105,000 110,000 240,000 375,000 95,000 435,000 600,000 65,000 375,000 105,000
0
0
0
0
4. Project Equipment (SUBTOTAL) 1,850,120 - 2 vehicles, 2 computers, 2 printers, telephone, faxes, photocopiers, supplies, 115,000 etc. 3.1 Critical basic equipment for 31 PA management units 1,735,120 5. Monitoring and Evaluation Contingency @ 3% Project Support Services GEF TOTAL (US$) C. Government Contribution (In-Kind- US$) TOTAL 1. Personnel 2. Equipment 3. Facilities 4. Operating Costs D. Other Contributions (SUBTOTAL) 3.4 UNHCR - rehabilitation at Virunga & Kahuzi Biega 3.4 EU - Kivu & Virunga Support (1) 3.4 EU/ ECOFAC - Salonga National Park support (1) 3.4 GTZ - Kahuzi-Biega support (1) TOTAL COMBINED BUDGET (A+B+C+D) Notes: (1) = estimated and provisional depending on donor decision (2) = to be determined for years 4-5 and onwards 10,000 89,104 244,738 3,303,961 371,000 141,500 15,000 192,000 22,500 500,000 500,000
0
0
2,135,120 150,000 1,985,120 65,000 170,104 467,218 6,307,441 1,784,000 676,000 60,000 938,000 110,000 4,700,000 1,800,000 1,200,000 1,200,000 19,951,441
0
0
0 300,000 110,000 0 170,000 20,000 1,200,000 600,000 300,000 300,000 2,392,000
0 371,000 141,500 15,000 192,000 22,500 1,200,000 600,000 300,000 300,000 1,850,000
300,000 300,000 6,366,961 4,813,096
14
Annex 1. Budget
Congo Protected Areas
Annex 2.A. ICCN BASIC REHABILITATION NEEDS Sites # of Stations
(2)
Need for Training Park Rangers Conservators 8 4 6 4 4 2 4 2 2 2 2 2 2 2 2 2 50 Vehicles 1 1 1 4 2 3 3 3 1 3 1 1 1 1 1 1 1 1 1 31
Needs in Basic Equipment for Protected Areas Operations Radio Transceivers 1 1 1 4 2 3 3 3 1 3 1 1 1 1 1 1 1 1 1 31 WalkieTalkies 10 2 2 20 10 10 10 20 10 4 4 4 4 4 4 4 4 4 130 Motor cycles 2 2 4 2 2 4 1 1 1 1 1 1 1 23 Bicycles 10 10 20 10 20 6 2 2 2 2 2 86 Outboards 3 2 1 4 1 1 1 13 Typewriters 1 1 1 4 2 3 3 3 1 3 1 1 1 1 1 1 1 1 1 31 Tents 2 2 2 5 2 2 2 1 2 1 1 1 1 2 1 27
HQ Kinshasa PD Goma PD Bukavu Virunga NP Garamba NP Kahuzi-Biega Maïko NP Upemba NP Kundelungu Salonga NP N’sele Muanda Epulu RFO BomboLumen e Swa-Kibula Mangaï Bushimaï Bili-Uere Luama TOTAL
1 1 1 4 2 3 3 3 1 3 1 1 1 1 1 1 1 1 1 31
200 200 100 300 200 100 400 20 50 50 50 50 20 30 100 20 1,890
(2 )
Stations constitute administrative management units within protected areas in the Democratic Congo. There operate a conservator, park rangers and other ICCN administrative support personnel. Forest and game reserves generally has each only one such station or management unit, whereas national parks often harbor each several stations. These are: (a) Rwindi, Lulimbi, Rumangabo, and Mutsora for Virunga National Park; (b) Lubutu, Loya, and Manguredjipa for Maïko National Park; (c) Tshivanga, N’djovu, and Itebero for Kahuzi-Biega National Park; (d) Mabwe, Kayo, and Lusinga for Upemba National Park; (e) Nagero and Gangala na Bodio for Garamba National Park; (f) Anga, Botshima and Monkoto for Salonga National Park; and (g) Katwe for Kundelungu National Park.
Annex 2. Budget Details 15
Congo Protected Areas
Annex 2.B. Budget for equipment needed for ICCN basic operations
Quantity and Item 31 Vehicles (4x4) Land cruiser 31 radio-transceivers (Yaesu) 130 walkie-talkies 23 motorcycles 86 bicycles 13 outboard engines (Yamaha) 31 typewriters 27 heavy duty tents (5-7 persons) Fuel, insurance, spareparts, repairs, etc. TOTAL Unit cost (US $) 40,000 2,000 300 3,000 120 1,000 800 1,000 Total costs (US $) 1,240,000 62,000 39,000 69,000 10,320 13,000 24,800 27,000 500,000 $1,985,120
17
Annex 2. Budget Details
Congo Protected Areas
Annex 3. PROJECT LOGFRAME
Project Strategy Global Objective To ensure conservation of biodiversity in the Congo through an effective protected areas system To establish a sound structural and functional basis for protected area planning and management in the Democratic Republic of the Congo (DRC) A supportive policy, legislative, institutional, financial and social environment for protected areas is created. Establish a functional National Environment Agency Establish a functional National Environment Fund Objectively Verifiable Indicators Rare and threatened species in Congo remain extant or increase in numbers. New species are not added to these lists. Protected areas and protected areas system functioning effectively. Means of Verification Periodic scientific inventories. Assumptions/Risks Protected areas can provide an effective means of conserving biological diversity in the DRC. Governmental policy is favorable to improving PA management. Governmental policy favors increase of ICCN resources. as above
Specific Objective
Functional evaluations and audits. Donor support forthcoming.
OUTPUT 1
NEA and NEF in place. Legislation updated. Govt. financial support to PA’s. Community level hostility reduced.
Evaluations PRA’s
Activity 1.1
Activity 1.2
Activity 1.3
Activity 1.4
Activity 1.5
Activity 1.6
Activity 1.7
OUTPUT 2
Update national environmental legislation Incorporate NEAP provisions into regional and sectoral planning. Establish functional environmental education programmes around key protected areas Elaborate and apply procedures for environmental impact assessments Establish a national environmental information system ICCN is effectively restructured and a decentralized system of PA management is in place
NEA in place with clear mandate, staffing, reponsibilities, budget. Fund in place. Board in place. Appropriate disbursements being made Legislative Code
Evaluation
Evaluation
Government follows through on its commitment Government successful in reducing levels of corruption.
Legislative Code
Planning documents
Planning documents PRA’s
Legislature able to act during interim government Sectoral and local planning institutions operating.
Level of knowledge and awareness re environment increased
Texts Application to development plans Availability of Information ICCN is providing effective planning and monitoring support to protected areas. Protected areas functioning effectively. Protected area managers have authority to make decisions Existence of plan spelling out roles and responsibilities of different organizational units, job descriptions of key personnel, etc. ICCN core unit reduced in size.
Texts Evaluation
Appropriate legislation enacted.
Evaluation
Institutional rivalries do not become a problem ICCN core administration prepared to devolve power to decentralized structure. Sufficient trained managers to staff decentralized organization.
Evaluations
Activity 2.1
Update the 1991 WB institutional assessment of ICCN. Design & implement restructuring and decentralization.
Institutional organigramme. Procedures manuals
The plan is adopted by the ICCN board of trustees. Commitment to the plan by ICCN senior management. Resistance to change is overcome.
18
Annex 3. Project Logframe
Congo Protected Areas
Project Strategy Objectively Verifiable Indicators Protected Area managers have increased authority. Protected Areas receive regular disbursements from HQ. Protected Areas retain a proportion of the revenues they generate. Internal policy cohesion across organization. Data on protected area performance available Means of Verification Assumptions/Risks
Activity 2.2
Design and establish a decentralized system of financial management and accounting.
Audits Institutional audit
Secure local systems can be put in place.
Activity 2.3
Activity 2.4
OUTPUT 3
Activity 3.1
Design and implement an ICCN communication and information system to serve technical and administrative functions. Develop national protected areas system plan. Essential functioning is restored to all protected areas through supply of essential human, material and financial resources Provide critical basic equipment for management to all protected area units and their supporting provincial offices.
Institutional audit
Identification and establishment of viable and measurable indicators feasible.
Existence of plan
Evaluation
Sufficient capacity exists State subsidies to ICCN are timely released
Current activities by poachers and bandits are diminished in the PA
PA program commonly agreed between ICCN and the Government Financial statements vs annual budgetary provisions Periodic reports from AP stations
Activity 3.2
Design and establish a technical training system within ICCN
Activity 3.3
Activity 3.4
Re-activate revenue generating systems from ecotourism. Facilitate the launch of long term rehabilitation efforts.
1 vehicle & 1 radio transceiver are provided to each PA station and ICCN HQ. All staff have uniforms. Basic camping equipment is available in all PA’s. Training manual in place. 50% ICCN staff received at least 1 3 week training session. Motivation and skills increased. Records of revenues and visitor statistics. Donor efforts launched.
Training report
Governmental policy promotes training on PA management
Reports and audits
Reports & evaluations
OUTPUT 4.
Approaches to participatory and community-based management of protected areas in the Congo are defined on the basis of experience and analysis of activities at pilot sites.
Analyses and plans in place.
Evaluations PRA’s
Activity 4.1
Activity 4.2
Restore and maintain existing pilot activities with participating organizations Monitor and evaluate pilot activities and
Pilot activities functioning
Evaluations PRA’s
The country remains stable and government policy favours tourism. Government carries through on its political commitments and donor confidence is restored Traditional societies are willing to share their wisdom and knowledge on traditional management systems Suitable legislation (land tenure reforms, conservation, participation of communities in PA management, etc.) is enacted and applied Participating institutions fulfill their commitments Community cooperation
Monitoring reports. Analyses.
Evaluation PRA
19
Annex 3. Project Logframe
Congo Protected Areas
Project Strategy develop approaches for application at other sites. Objectively Verifiable Indicators Plans Means of Verification Assumptions/Risks
20
Annex 3. Project Logframe
Congo Protected Areas Annex 4. Incremental Cost Analysis 1. Broad Development Goals
1.1. Following a sustained period of political instability and economic decline, government policies in the Democratic Republic of Congo are geared towards facilitating political and economic reconstruction. Despite severe political, economic, social and institutional constraints, the government is committed to supporting conservation, with an emphasis on rehabilitating and strengthening the system of Protected Areas. Given the inter-determination of ecological systems and the RDC’s economy, support for conservation makes strategic sense3. 1.2 The RDC ratified the Convention on Biological Diversity in late 1994 and has established a broad network of Protected Areas, encompassing just over 7.5% of the landmass. As a follow up to the Earth Summit in 1992, the government instituted a long-term environmental planning programme with an interagency government committee, the Comité Interministériel de Coordination (CIC), established to co-ordinate it. The programme has focused on finalising and implementing a National Environmental Action Plan, completing a UNEP-sponsored Biodiversity Country Study, and developing a National Biodiversity Strategy. 1.3 In addition, a national biodiversity seminar held in July 1995 that was attended by a cross-section of stakeholders in the conservation arena called for immediate action to safeguard the 16 existing or proposed Protected Areas. These sites, though not fully representative of the country’s biological diversity, nevertheless harbour a great range of endangered flora and fauna and are deemed by conservation biologists to have an especially high conservation value. 2. Global Environmental Objective
2.1 The global environmental objective of this project is to establish the foundations for the long-term conservation of the country's rich storehouse of biological diversity. The project has leveraged significant co-financing from UNDP which at the macro-level will improve the environment within which conservation projects must operate. The dual initiatives represent a substantial window of opportunity for securing future conservation with potentially sizeable benefits at the global level. 2.2 In overall terms, the country ranks as the richest in Africa in terms of its biodiversity. A range of habitat types are represented, including tropical moist forests, montane forests, woodland and grassland savannahs (both the northern and southern savannahs are represented), miombo woodlands, dry evergreen forests and important wetlands. Though the inventory is incomplete, the known species endowment includes 409 species of mammals, 1086 species of birds, 216 species of amphibians, 280 of reptiles, a huge range of invertebrate species, and 11,000 species of flora of which 3,000 are endemic. Some 70% of freshwater fish species are believed to be endemic. A great range of flagship species for conservation are represented, including three sub species of gorillas, common and pygmy Chimpanzees (plus an additional 29-30 species of primates), forest and savannah Elephants, Northern White Rhinos, 30 species of antelopes including the Okapi, and predators such as Lions, Leopards and the African Golden cat. 2.3 The global community stands to benefit substantially from the conservation of biodiversity in the RDC, and conversely, to face a welfare loss if species and key habitats are extirpated.
3
The rural populace is in large part dependent on subsistence agriculture, hunting, fisheries and the harvest of forest products for survival, and ecological goods and services provided by the country’s rich endowment of biological diversity underpin these systems of production.
21
Annex 4. Incremental Cost Analysis
Congo Protected Areas Benefits include future recreational use values, including nature and adventure tourism, existence values derived from knowledge of the existence of wild flora and fauna, particularly flagship species, and future productive uses of wild resources. 3. Baseline
3.1 There is considerable spatial variation in both the type and magnitude of threats facing biodiversity in the RDC. Protected Areas have not been immune from anthropogenic pressures. Proximate threats include hunting, both for protein and the local and international trade in wildlife4, forest clearance for agriculture, the unsustainable harvest of biological resources, including fuelwood and minor forest products, and the direct and indirect impacts of mineral exploration and development in ecologically sensitive areas. Unsustainable logging poses a growing threat. Finally, in western Congo, commercial fishing and offshore oil drilling have degraded the coastal marine ecosystem. 3.2 The root causes of these threats are complex and interconnected. Though the country is potentially wealthy, with a sizeable minerals sector, past economic mismanagement has led to a dislocation of the rural economy. The livelihood options of the vast majority of the rural populace are extremely limited, and conditions of poverty have forced poorer communities to degrade wildlands and unsustainably exploit wildlife. These problems have been compounded by a lack of surety over land tenure, and forced expulsions of communities from ancestral lands in the past have led to invasions of several National Parks by the landless poor. Finally, in the country’s eastern regions, pressures on natural environments have been exacerbated by a string of recent refugee crises. 3.3 A critical lacuna in addressing the threats to biodiversity loss is the weakness in the policy, institutional, and regulatory environment. Indeed, this has been identified as a priority concern by the National Environment Action Plan. In particular, there is a fundamental conflict between traditional land tenure arrangements wherein local people claim ancestral rights and State-enacted laws. This conflict over ownership and control of land and its natural resources poses daunting impediments to community-based development, making it more difficult to secure efficient and equitable solutions. 3.4 The country has little capacity to manage Protected Areas and regulate uses of biological resources. The institutional capacity of the Institut Congolais pour la Conservation de la Nature (ICCN), the agency responsible for conservation management, is especially weak. A fundamental problem is that Parks management has tended to be highly centralised, with little delegation of authority to the regions. Moneys tend to be absorbed at the central level rather than allocated to field operations, the financial management system is extremely weak, and communications poor. Reviews of the ICCN conducted by the World Bank and the European Union in 1991 and 1990 respectively, have emphasised the need to restructure the ICCN as a catalytic step in rehabilitating, strengthening and extending the Protected Areas system. The results of the World Bank review are presented in annex 4. [The situation has worsened since the review was undertaken.] 3.5 The costs of conservation management have historically been met through Government budget appropriations, and revenues from Gorilla trekking tours in the Virunga and Kahuzi Biega
4
Poaching has been a substantial problem in all Protected Areas, with antelopes, hippopotamuses and other large fauna being taken for protein and elephants, cats, gorillas and other species being culled for the trade in wildlife parts. Hunting pressures on primates are heavy throughout the country.
22
Annex 4. Incremental Cost Analysis
Congo Protected Areas Protected Areas. The country has in the past received substantial donor support, but many donors suspended their programmes in the early 1990’s to protest non-payment of external debt and economic maladministration. There has been little funding available for conservation from the public purse in the past five or so years owing to a serious fiscal crisis. To cap this, civil strife has caused the eco-tourism industry to all but collapse. Limited site-specific support for conservation management activities has been provided by international NGOs, but resources have been inadequate. These circumstances have had serious repercussions for the Parks, with no moneys available for the maintenance of infrastructure and equipment. In areas where civil disorder has been a problem, theft of equipment has been rampant. The Parks lack even the most basic resources needed to maintain operations5. 3.6 The funding crisis has often meant that field staff have been forced to endure long periods without being paid, compelling them to seek alternative means of livelihood. This in turn has led to a serious loss of morale and dereliction of duty. The conjunction of all these factors has meant that many Protected Areas have become “paper parks”, lacking active management operations. The result has been an increase in poaching, illegal harvesting of wild resources, incursions by local communities and other problems. 3.7 A major problem is that conservation management programmes have tended to be administered from the top-down. The needs and priorities of local communities have tended to be ignored by park managers, leading to growing conflicts. There has, however, been some experimentation with involving communities in conservation management at the Okapi Wildlife reserve, Kahuzi-Biega, Virunga and Garamba National Parks, with the support of various donor bodies and NGOs. The challenge remains to apply the lessons learned at these sites, plus those learned from community conservation efforts in neighbouring countries, to the Protected Area system as a whole. 3.8 The baseline is the "business as usual" situation, whereby the country’s Protected Areas system will continue to collapse, except where supported or managed by international NGO's and other donors. These threats will only be ameliorated over time (their resolution is contingent on political stability, good governance and sound economic management). In the longer term, there is a need to extend coverage of the protected area system to make it more representative of the country’s diverse ecosystems. The immediate challenge, however, is to create a more conducive institutional environment for future conservation efforts through restructuring the ICCN, to provide Protected Areas with basic operating equipment, to provide basic training to field personnel, and to support and extend community conservation programmes. 4. GEF Alternative
4.1 Quite clearly, given prevailing financial and human capital constraints and the magnitude of the unmet need for conservation, substantial financial and technical assistance will be required from the international community to achieve conservation objectives. Although the government is committed to making fundamental institutional and operational management changes, it simply cannot shoulder the costs without assistance. Though donor bodies are considering rebuilding their conservation programmes as the political situation stabilises, they are loath to do so unless the existing institutional structures are overhauled. This project, designed to do just this, is needed as a long-term investment catalyst (i.e. to increase confidence in the system of conservation management). A related point is that other donor programmes will take time to come on stream – given that they remain on the drawing board. Basic equipment and training is required at the field
5
Several Protected Areas have been virtually abandoned for lack of resources and infrastructure.
23
Annex 4. Incremental Cost Analysis
Congo Protected Areas level to enable a minimal level of operations to occur in the interim period. Failure to provide such support is likely to have grave consequences in terms of foreclosing future conservation, as already severe pressures spin out of control. 4.2 The GEF sponsored alternative will improve prospects for biodiversity conservation by establishing a sound structural and functional basis for the management of Protected Areas. In summary, the project will: i. Create a supportive policy, legislative, institutional, and social environment for Protected Areas, by establishing a National Environment Agency and a National Environment Fund. Environmental legislation, particularly that relating to land-tenure, will be updated and procedures for mainstreaming environmental issues into regional and sectoral planning such as, Environmental Impact Assessments will be elaborated. This component will also establish a national environment information system and initiate environment education programmes among populations bordering key protected areas. ii. Restructure the ICCN as a sound and viable decentralised agency with the technical, administrative and financial capacity to plan and manage the Democratic Republic of the Congo's Protected Areas, with the goal of ensuring a more effective and cost-efficient delivery of conservation programmes. The project will implement the recommendations made in the 1991 assessment of the institutional capacity of the ICCN, though as a first step, this assessment will be updated and revised. Amongst other things, the project will clarify the roles and responsibilities of staff, improve the financial management and accounting system, formalise reporting structures and strengthen systems of communication. iii. Provide minimal ongoing support to ICCN field units to maintain critical basic protected area functions. The project will supply basic equipment to these units and provide some training to field staff. The project will perform a training needs assessment for ICCN staff and design and establish a technical training system within the agency. Options for generating revenues at the field level will be investigated, including from hunting and tourism activities, but mainly from other donor bodies. An assessment of the unmet need for conservation and review of funding shortfalls will be undertaken at each site, as a basis for planning and prioritising future interventions. iv. Restore past NGO initiatives that experiment with involving local communities in Protected Area management as pilot demonstration sites. Review the strengths and weaknesses of of these pilot sites with a view to assessing the lessons learned and applying best practice methods at other sites. This component will help establish suitable decision making mechanisms that involve local community representatives in conservation, and provide training to park personnel in methods and tools for participatory management. 5. Scope of Analysis
5.1 The project will impact a wide swathe of conservation management activities. The systems boundary for the incremental cost estimation includes planning and administrative systems, operations at the PA site level plus community conservation activities. The analysis includes existing and proposed Government programmes and those of NGO’s that would occur in the baseline situation irrespective of the GEF intervention, plus those known interventions that will be sponsored by other donor bodies and that will follow on from implementation of this project. For the purposes of this assessment, the former activities are treated as baseline, and the latter set, including co-funding from UNDP for implementation of the NEAP, treated as incremental. 5.2 In the short-term, few incidental domestic benefits are envisaged resulting from this project.
24
Annex 4. Incremental Cost Analysis
Congo Protected Areas In the longer term the sound institutional basis established will provide a basis for additional donor investment. As a result of this, communities living around Protected Areas should benefit from clearer arrangements for access to resources, and at certain sites, such as the Virungas, benefit from considerable tourism revenues. In the longer term, RDC will also benefit significantly from having avoided the loss of some its significant biodiversity heritage at a time when it was unable to prevent this loss itself. In particular, contributory values of biodiversity to primary resource production will have been safeguarded. These benefits are not treated as avoided costs in this analysis because they fall mainly in the future, are uncertain, and are highly discounted in present value terms at the national level. In addition, because they are diffuse, being captured by a number of stakeholders, cost-recovery is largely precluded. 7. Incremental Costs
7.1 The cost of baseline activities, including projected expenditures on all aspects of conservation management at the national level and field sites amounts to US$ 13,150,000 over five years. This includes government funding plus expenditures by donor bodies and NGOs that are not contingent on the implementation of the GEF Alternative. 7.2 The costs of incremental activities under the GEF alternative amount to US$ 19,951,441 of which amount US$ 7,160,000 will be provided by UNDP as co-financing for implementation of the NEAP. US$ 1,784,000 will be provided by the government as funding (above and beyond what would have occurred in the absence of the GEF intervention) to operate the restructured ICCN, US$ 500,000 by UNHCR, US$ 1,800,000 by EU, US$ 1,200,000 by EU/ECOFAC, and 1,200,000 by GTZ. The incremental costs financed by the GEF amount to US$ 6,307,441. These costs amount to 32% of the incremental costs.
25
Annex 4. Incremental Cost Analysis
Congo Protected Areas
Cost/ Benefit Domestic Benefits
Global Benefits
INCREMENTAL COST MATRIX: Baseline (B) Alternative (A) Protected Areas provide opportunities for Improvement of protected area tourism development, but poor management management safeguards biodiversity is eroding development potential. and its economic values. Biodiversity provides contributory values to Steps to improve protection of primary production by mediating the supply representative ecosystems within PA of ecological goods and services, but the network. future productivity of the primary resource Enhancement of institutional sectors is threatened by a loss of ecological capacity of ICCN and facilitation of integrity. basic operations in PAs. Options values for future uses of biodiversity, including from biotechnology and pharmaceutical industries diminishing. Weak institutional capabilities and capacity of ICCN serve as a disincentive for donor investment in PA system. Direct and indirect use, option and existence Catalytic steps to rehabilitate, values captured from biological diversity but strengthen, and extend the system of threatened by anthropogenic pressures. Protected Areas. Lack of effective institutional mechanism for Strengthening of institutional managing Protected Areas resulting in poor capacity of ICCN and of returns from conservation investments and administrative, financial limiting sustainability. management /accounting, and Lack of even the most basic equipment and communications and reporting dearth of trained field personnel is systems. hampering PA operations. Minimal equipment provided and Lack of suitable participatory models to training conducted involve local communities in conservation Review and application of lessons management; growing conflicts between learned from existing participatory/ communities and park authorities with community conservation schemes in contra-conservation implications. the RDC and neighbouring countries, with training of park personnel in methods and tools for enabling participation.
Increment (A-B) Options for future income generation from recreational uses of Protected Areas maintained. Functional values of biodiversity as a natural capital element in the production functions of primary resource industries protected. Maintenance of option values for future uses of biological resources. Improved opportunities for leveraging donor moneys for conservation activities.
Enhanced foundations for successful long-term biodiversity conservation. Conservation management capacity enhanced at the national and local levels improving ability to respond to threats. Basic PA operations facilitated as interim measure until other donor sponsored programmes come on stream and political and economic situation fully stabilises. Management measures more responsive to needs and priorities of communities reducing conflict between them and PA authorities and lessening pressures on biodiversity.
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Annex 4. Incremental Cost Analysis
Congo Protected Areas
Cost/ Benefit Costs Supportive policy, legislative, financial, and social environment for PAs. Costs Restructuring and decentralization of ICCN Costs Essential equipment and training for PAs
Baseline (B)
Alternative (A) Total: US$ 7,160,000
Increment (A-B) GEF: none Cofinancing: US$ 7,160,000 Total: US$ 7,160,000
Total: US$ 5,000,000
Total: US$ 5,745,017
GEF: US$ 580,756 Cofinancing: Govt: US$ 164,261 Total: US$ 745,017 GEF: US$ 3,572,486 Cofinancing: Govt: US$ 1,010,444 UNHCR: US$ 500,000 EU: US$ 1,800,000 EU/ECOFAC: US$ 1,200,000 GTZ: US$ 1,200,000 Total: US$ 9,282,930 GEF: US$ 2,154,199 Cofinancing: Govt: US$ 609,295 Total: US$ 2,763,494 Incremental Costs to be funded by GEF: US$ 6,307,441 Co-financing: US$ 13,644,000
Total: US $ 5,825,000
Total: US$ 15,107,930
Costs Participatory Management in PAs Cost Totals
Total: US$ 2,325,000
Total: US$ 5,088,494
Total: US$ 13,150,000
Total Costs: US$ 33,101,441
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Annex 4. Incremental Cost Analysis
Congo Protected Areas Annex 5. A Synopsis of the 1991 Review of ICCN by the World Bank The institutional review of ICCN by the World Bank was made in July 1991, and it was articulated in two axes: (a) a technical review, that was conducted by two consultants (Drs. Bosquet and Vangu); and (b) a review of the organization (ICCN), its management, and its human resources that was performed by two other consultants (Mrs Laura McPherson and Mr. Tshimanga). The review pointed out that ICCN was clogged with bureaucracy, that it was lacking clarity in its management systems, that there was a insufficient training for the personnel, and the inadequacy of the financial resources for its functioning. Specifically, from the institutional review of ICCN by the World Bank, the following constraints and problems that impeach ICCN capacities to conserve and manage sustainably the protected areas in the Democratic Congo became apparent and were formulated. 1º Most financial resources of ICCN (75 to 85%) are spent in the park headquarters in Kinshasa for only 5% of ICCN's personnel due to a strong centralization of its management system. In the field, within the protected areas, the administrative organization follows a military structure, and it is aimed at fighting poachers and punishing people caught to contravene the parks and reserves' rules. As a corollary, the park rangers and staff have not had much training or experience on how to deal more friendly with the neighboring people, nor how to interpret natural wonders to tourists. The ICCN is lacking material resources, and its financial resources for functioning are very slim. ICCN internal revenue originate mainly from the tourism visitation of Virunga and Kahuzi-Biega National Parks, which organize visits to the Mountain Gorillas. Other income for ICCN originates mainly from the Public Treasury, and it supports personnel salaries and operating costs. Unfortunately, funds from the Democratic Congo's public treasury are unreliable, and public servants in the Democratic Congo and public sector personnel often go without pay check for more than 12 consecutive months. Park rangers and ICCN staff are also underpaid ($2 to $5 per month per park ranger), and as a consequence they are not motivated to perform their duties. Decisions are extremely centralized at the level of the ICCN, Chief Executive Officer (PDG), who does not delegate power to the local park managers. The World Bank's review recommended the decentralization of the ICCN management system. Because of the inadequacy of the financial and management capabilities at ICCN, the review recommends to strengthen the financial management system and move it toward accountability and transparency. Also the review calls for training a cadre of accountants as requested and started by the European Economic Community (EEC) after its financial review of ICCN in 1990. The review recommends to rapidly perform a legal revision and devise a coherent policy toward conservation of nature and biodiversity resources in the Congo, and to put in place a better surveillance capability for national parks. Also it is recommended to devise a sound scheme to generate sustainable income from game reserves, that are under the management of ICCN. This would include the Zoo of Nsele and the Bombo Lumene Game Reserve, which are located in the vicinities of Kinshasa, a large city of 4,000,000 people. A restruction of the ICCN park headquarters is called upon by the review, and the acquisition of a suitable, better equipped building for the park headquarters. The communication system, particularly the ICCN radio network (of transceivers) linking parks and the headquarters, has to be improved. The radio network should be used in conjunction with an ad hoc operational manual for park managers to help in the
2º
3º
4º 5º
6º
7º
8º
9º 10º
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Annex 5. ICCN Review
Congo Protected Areas decentralization and fast response to field problems. The operational manual has been developed with the help of the European Community in 1990, but it is not yet applied. The review calls for the redynamization of ICCN research capabilities in regard of the specificities of each protected area. Fundamental and applied research may be performed under contracts with ICCN by outside individual researchers and research institutions. A management plan has to be made for each protected area in the Congo, and every plan should be integrated into local development schemes. Also ICCN should introduce the use of personal computers for the management of protected areas. Revenue generating capabilities of ICCN have to be strengthened, such as tourism through adequate determination of visitation fees, a better bookkeeping and accounting, a ban of tourism monopoly (such as the gorilla touring at Djomba as well as the management of the Rwindi's Hotel in Virunga National Park), etc. Game ranching and farming alternatives could be considered as well by ICCN, which should particularly identify in that field potential private managers to work in partnership with ICCN. Alternative venues to generate (non-traditional) income by park resources, such as the lease for tourism of ICCN's fixed wing planes, etc., should be devised. ICCN, in consultation with local tribal leaders, should proceed in gazetting all protected areas. There is urgency, to do so, for Upemba and Kundelungu National Parks in the Katanga province, where park rangers are being repelled by the local people. GoZ should set aside more protected areas to cover critical sites and other center of endemisms, such as forest refugia rich of biodiversity resources, which are not yet represented in the current network of protected areas. New sites would include: the Okapi National park; the Mangrove Marine Park; the Lomako Forest Reserve; and the Luo, Semliki, Tongo and Mount-Hoyo Reserves. The review recommends to develop anew, under new terms and grounds, the system of assistance to ICCN's protected areas by international NGOs in conservation to lead to a genuine partnership for a shared leadership.
11º
12º
13º
14º 15º
16º
17º
29
Annex 5. ICCN Review
Congo Protected Areas Annex 6.Technical Review of GEF Proposal Michael Harrison
30
Annex 6. STAP Technical Review
Congo Protected Areas
Annex 7. Map of the Congo's Protected Areas
37
Annex 7. Map
Congo Protected Areas
Annex 8. Government Letter of Endorsement
38
Annex 8 Government Letter of Endorsement
Congo Protected Areas
Annex 9. References Cited Anonymous 1995. Plan de gestion du parc marin des mangroves. Rapport provisoire de Janvier 1995. Projet ICCN/Banque Mondiale K.77209. 50pp Mimeographed. Anonymous 1992. A Management and Development Plan for the Ituri Forest Reserve and Okapi Wildlife Reserve (the Congo). Summary and outline document. 19pp. ICCN, WWF Anonymous 1990. Project Brief, the Congo, forest and environment project. November 13, 1990. Agriculture Operations Division, South Central and Indian Ocean Department. The World Bank. 14pp. Bieme, L. 1990. La formation des formateurs: l'expérience de l'ICCN et du WWF en zones de Wamba et de Mambasa. Pp. 195-198, In Actes du Séminaire-Atélier Sous-Régional de formation et de recyclage des conservateurs des parcs nationaux et des aires protégées: Burundi, Congo Brazzaville, Ouganda, Rwanda, the Democratic Congo. Rwindi, Parc National des Virunga du 7 au 10 Août 1989. ICCN, UNESCO, MAB, Paris. Biswas, A.K., H.C. Tortajada-Quiroz, L. Vangu, and L. Gayo 1994. Impact environnemental de la présence des réfugiés rwandais dans le Nord et le Sud Kivu (Congo). PNUD, Bureau Régional pour l'Afrique. Rapport polycopié soumis au PNUD-BSP en Novembre 1994. Cummings, G. 1997. Virunga Conservation Center. A proposal by the Dian Fossey Gorilla Fund. Colyn, M. 1990. L'enjeu du Parc National de la Salonga dans le maintien de la diversité de la faune et de la flore forestière de l'Afrique Centrale. Pp. 213-218, In Actes du Séminaire-Atélier Sous-Régional de formation et de recyclage des conservateurs des parcs nationaux et des aires protégées: Burundi, Congo-Brazzaville, Ouganda, Rwanda, the Democratic Congo. Rwindi, Parc National des Virunga du 7 au 10 Août 1989. ICCN, UNESCO, MAB, Paris. Doumenge, C. 1990. La conservation des écosystèmes forestiers du the Congo. IUCN, Gland, Switzerland, 242pp. Goodson, J. 1988. USAID memorandum (concerning biodiversity conservation in the Congo) of 27 June 1988 to the program Office. USAID-Kinshasa. Hedeberg, I. 1979. Possibilities and needs for conservation of plant species and vegetation in Africa. In Systematic botany, plant utilization and biosphere conservation. Proceedings of a symposium held in Uppsala in commemoration of the 500th anniversary of the University. Uppsala. Hillman Smith, K. 1995. Problématique de la conservation à partir des stocks génétiques réduits, cas des rhinos et autres espèces rares dans le contexte de la conservation de la
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Annex 9. References
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biodiversité. Document de travail nº 018 du 1er Séminaire National sur la Biodiversité au Congo. 11pp polycopiées. Languy, M. 1995. Problèmes environnementaux au nord-Kivu liés à la présence des réfugiés rwandais: Identification des interventions réalisées, coordination entre les organismes et propositions d'interventions complémentaires. Rapport de Mission auprès du PNUD; le 21 février 1995. 45 pages polycopiées. Mbayma, A. 1995. Quelle stratégie pour la conservation des rhinocéros blancs du nord. Document de travail nº 019 du 1er Séminaire National sur la Biodiversité au Congo. 9pp polycopiées. McNeely, J.A., K.R. Miller, W.V. Reid, R.A. Mittermeier, and T. Werner 1990. Conserving the world's biological diversity. The World Bank, World Resources Institute, IUCN, Conservation International, and WWF; Gland Switzerland, and Washington, DC. 193pp. MECNT 1996. Etat de la Biodiversité au Congo-Kinshasa. Premier Rapport Biodiversity Country Study. Kisantu, Premier Draft, 158pp. Mittermeir, R.A. and T.B. Werner 1989. Wealth of plants and animal unites "Megadiversity" countries. Tropicus. 4(1): 1, 4 and 5. Mugangu, T.E. 1995. Vision globale d'une Stratégie Nationale pour la Biodiversité au Congo. Document de travail nº 000 du 1er Séminaire National sur la Biodiversité au Congo. 10pp polycopiées + 1 figure. Mugangu, T. E. 1995. Catalyzing grassroots sustainable development in the tropical forest of eastern the Congo. An action research proposal submitted to the Rockefeller Foundation by ADEDE, April 3, 1995. 30pp + appendices. Mugangu, T.E. 1997. Two Mountains-Two Spirits: Involving Local Communities in Gorilla Conservation at Mount Tshiaberimu. 11pp. Muhindo, M. 1990. Révision du dispositif de surveillance et ébauche du plan d'aménagement du Parc National de la Garamba. Pp 169-177, In Actes du Séminaire-Atélier Sous-Régional de formation et de recyclage des conservateurs des parcs nationaux et des aires protégées: Burundi, Congo, Ouganda, Rwanda, the Congo. Rwindi, Parc National des Virunga du 7 au 10 Août 1989. ICCN, UNESCO, MAB, Paris. Seligman, N. 1991. An overview of the Congo for strategic planning in biological diversity and tropical forestry issues. Compiled and edited for the World Wildlife Fund. Mimeographed document without page numbering. Sherburne, J.A., J. Buursink, and T.E. Mugangu 1995. Assessment of needs for wildlife conservation and training in sub-Saharan Africa. An Unpublished Report to the United States Fish and Wildlife Service. The University of Maine, Orono, 123pp.
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Annex 9. References
Congo Protected Areas
Smith, F. M. Muhindo, K. Hillman Smith, A. Mbayma 1995. Conservation and development of Garamba National Park and protected areas, the Congo. A project proposal January 1995. 23pp. WWF. Rham, U. 1966. Les mammifères de la forêt équatoriale de l'est du Congo. Musée Royal de l'Afrique Centrale. Tervuren, Belgique. Annales, Série in 8º Sci. Zool. 149:36-121 Vangu, L. 1995. Profil socio-économique et stratégies de développement au Congo. Document de travail nº 010 du 1er Séminaire National sur la Biodiversité au Congo. 9pp polycopiées.
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Annex 9. References
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39
Government Support Letter