Meet SANParks’ new TCIP…

Same as SANParks’ old TCIP*

*With apologies to Pete Townsend of The Who and Won’t Get Fooled Again (1971)

Reading Time: 12 minutes

By Mike Golby

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.

SANParks refuses to commit

The 12 Outcome Goals listed seem to be a more detailed and unnecessarily repetitive version of the goals expressed in the April 2022 Draft TCIP, and span 108 pages.

Following the legally mandated PPP in 2021/2, last year’s Draft TCIP at least provided some indication of which proposals SANParks deemed acceptable or not (as outlined in Annexure 1 of the Draft Implementation Plan for management of Tokai and Cecilia areas – Phase 3: Table Mountain National Park, released for public comment on 12 April 2022). It found 18 proposals relating to the Arboretum, Biodiversity, Tourism and Recreation, Planted Landscapes, and Tokai Manor and its precinct to be unfeasible or impractical for implementation.

In this revised draft implementation plan, however, SANParks offers no such guidance.

In fact, on page 3 of the PREAMBLE, the revised document informs us that one of the fundamental changes to the Draft TCIP is the abandonment of “(1) the grouping of proposals into projects and programmes, and (2) the two-tick/dash classification system used to review proposals in terms of their suitability and feasibility for implementation.“

If SANParks shares the expressed goals, strategic actions, and milestones of the TCIP Working Groups under IMPLEMENTATION PLAN: OUTCOME GOALS, STRATEGIC ACTIONS AND MILESTONES on page 77 of the revised Draft TCIP, it may be showing support for proposals that exceed its legal mandate.

But we can assume that there’s no need for concern. State agencies responsible for enforcing South African legislation on invasive species extend beyond SANParks. They include:

And, under the National Environmental Management Act (1998) (Act No 107 of 1998), managers of state-owned land such as SANParks are specifically required to control invasive species.

Given the proliferation of alien vegetation at Tokai Park, the above-listed organisations all have a stake in the eventual implementation plan – and will ensure that reason prevails.

So, everything’s fine then? Not quite. The public-participation stage of the TCMF Review Process was launched on 26 May 2021. The final report was supposed to be submitted six months later in November 2021.

That certainly didn’t go according to plan.

Here we are, 18 months later after a hiatus of over a year, with SANParks issuing yet another largely unchanged draft for public comment. It aims to finalise and adopt Programmes of Work – which still need to be discussed, considered and costed – in just nine weeks’ time, on Monday 3 July 2023.

As the saying goes: fat chance.

Or as another saying goes: meet the new boss – same as the old boss.

That said, I have a soft spot for the old boss. Despite being somewhat obtuse and unable to distinguish its left hand (Pretoria) from its right (Table Mountain National Park (TMNP)), SANParks’ heart is in the right place. Its actions – as evidenced by its TMNP staff – are well-intentioned and focused on fulfilling its conservation mandate. TMNP’s staff consists largely of highly qualified and hard-working professionals who always make time to engage with stakeholders.

But, faced with a fractious public, SANParks and TMNP must strike a balance between practicality (their mandate) and politics (TMNP’s neighbouring community). A meaningful, consultative PPP – as detailed in the Park Management Plan (see Section 4: Consultation pages 26-27) – is very much a structured political process.

A flawed context and process

I often wonder if TMNP staff understand the intricacies of public participation as well as SANParks’ skilled operators in Pretoria. According to its definition and our legislation, public participation is a tiered process in which consultation serves a specific purpose. Its hierarchy is well-illustrated by the image below.

In my initial comments to SANParks in 2021, I outlined my view of the context and purpose of the Tokai-Cecilia Management Framework Review Process. I believe my interpretation of both the context and purpose of this consultative PPP accords with that of SANParks’ senior management in Pretoria (with whom I have been party to productive and cordial meetings) and it may be helpful for readers to familiarise themselves with it.

Ultimately, though, the onus is on SANParks to make, and take responsibility for, all decisions pertaining to the TCIP.

In this revised draft, I cannot accept SANParks’ failure to advise stakeholders on the feasibility of their proposals within its mandate. By continuing to include illegal or contradictory proposals in the nine-week discussion, consideration, and costing of the many Programmes of Work needed to meet the expressed goals, strategic actions, and milestones of the 12 Outcomes identified in this Draft TCIP, SANParks again risks wasting TMNP stakeholders’ time.

I hope this won’t be the case and that certain Programmes of Work will be quickly dismissed at the start of the discussions phase.

Case study: Shade and planted landscapes

For instance, Outcome Goal 4: Shade and planted landscapes should not be an issue at all in the Fynbos Biome. Our heritage trees should receive the same management and care as those in the Arboretum. There are very few “shade trees” in our arid parks such as /Ai/Ais Richtersveld, Augrabies, Kgalagadi, Mokala, Namaqua, and Tankwa Karoo. I doubt their absence detracts from these parks’ appeal.

Why then should parks within the Fynbos Biome be subject to demands for shade? What about other sections of TMNP? Why are they “denied” similar cover?

Objectives i and ii call for SANParks to:

Acknowledge that trees and associated landscapes (including Constantia-Tokai Valley) are valued by many stakeholders and provide a range of values and benefits (e.g. scenic, cultural, recreational shade)
Recognise that treed areas include both naturally occurring indigenous trees as well as planted trees such as those in commercial plantations

What does SANParks have to do with trees and commercial plantations? Apart from our Afromontane trees found in kloofs and gullies throughout the park, the Fynbos Biome has no trees. Nor should a National Park designated a World Heritage Site and biodiversity hotspot in an age of irreversible climate change and mass species extinction. What are Capetonians thinking? Do they not realise how strange the inclusion of this outcome and its objectives must appear to conservationists worldwide?

The accompanying strategic actions call on SANParks to:

Create awareness of the value of trees and associated landscapes, including Constantia-Tokai Valley cultural landscape
Create awareness of the different treed areas

To achieve this, it should:

Create a repository of information showcasing the value of trees
Compile a brochure of the value of trees and associated landscapes
Identify and map all the different treed areas
Identify the variety of both naturally occurring indigenous trees as well as planted trees in the different treed areas

…before compiling “a brochure of all different treed areas, including the variety of both naturally occurring indigenous trees as well as planted trees” to be displayed “at entry points and during events“.

To put it bluntly, this is beyond ludicrous. It’s madness. TMNP – and Tokai Park in particular – is home to critically endangered Cape Flats Sand Fynbos and Peninsula Granite Fynbos as well as our endangered Sandstone Fynbos. If any brochures are to be compiled or distributed at events, they should highlight TMNP’s value as a significant part of a global biodiversity hotspot where endangered species are restored and conserved. TMNP and SANParks staff have no business promoting trees in the Fynbos Biome.

Capetonians are dangerously ill-informed (and misinformed) about the role of trees in “human wellness” and mitigating climate change. A website can only publish so many articles debunking tree-planting campaigns. Professors Paul and Eileen van Helden’s recent article, The Tree Myth, on the Friends of Tokai Park website, is therefore a must-read. Additionally, the Friends of Tokai Park site features videos by Professor William Bond, in which he explains in detail how tree-planting advocates serve the interests of a global forestry lobby.

Watch Professor Bond’s videos, The Trouble with Trees and The Untold Story of Grasses. Then spend 45 minutes watching his video “Mythbusting Forests” below.

Assuming Professor Bond represents the scientific and academic communities and that he emphasises the value of grasslands and savannahs (perhaps more than fynbos), does SANParks not see how foolish it looks entertaining Objective iv) of the same outcome: to “develop and implement a range of options and identify appropriate sites for the retention and introduction/provision of continued trees and planted landscapes (including replanting and inter-planting of appropriate indigenous tree species), including possible extension (and possible amendments) of Tokai Cecilia Exit Lease for the remaining plantations beyond 2024 for recreation in shaded landscapes“?

It is proposed that, as a strategic action, SANParks should:

Investigate extension (including possible amendments) of the plantations Exit Lease with a view of retaining trees (1) in perpetuity or for the course of their lifetime and (2) as nursery zones in which new indigenous tree species can be grown…

…and give itself a year to do so? Has it forgotten about telephones? I’m sure it would take less than 10 minutes for someone to point out that retaining such plantations solely for recreational shade is illegal and goes against SANParks’ legislated mandate.

Furthermore, has it forgotten that TMNP is home to a severely underrepresented number of critically endangered species in need of restoration? Each season lost is another in which the seed banks beneath Lower Tokai Park’s pine trees are further depleted.

I urge all SANParks staff to watch Friends of Tokai Park‘s film Extinction Rebellion – The story of Tokai Park’s plant diversity. Extinction waits for no one. If SANParks takes another five years to get its act together at Lower Tokai Park, it may find itself responsible for the extinction of many plants it is mandated to conserve and protect in perpetuity.

As for the R80 million Manor House boutique hotel and gardens I consider in my introductory image? It seems it didn’t make the cut into the Outcome Goals. Unless, of course, it is viewed as a strategic action, i.e., “the restoration upgrade of heritage facilities, supporting the management of heritage areas in accordance with heritage guidelines and recommendations.“

I sincerely hope that, during forthcoming discussions, sanity – along with science, sense and reason – will prevail.

Could it have been otherwise?

Very easily. The problem with this Draft TCIP is that it mixes the good with the unconscionable. By sticking to the context and process originally set for stakeholders in the TCMF PPP, SANParks would have eliminated unfeasible, impractical or illegal proposals from this draft.

Its IMPLEMENTATION ROADMAP on page 107 would constitute a welcome programme of action rather than a promise of yet more interminable meetings attempting to reconcile the irreconcilable.

In my submission of 31 May 2022 on the first Tokai–Cecilia Draft Implementation Plan (TCDIP), I warned SANParks gain of the dangers inherent in neglecting a full appreciation of the term “consultation”.

Because a consultative process ultimately vests the power to make decisions in SANParks, it is not a given that meaningful input from the public must drive SANParks’ decisions. Nor is it a given that all input from the public should be considered meaningful. Much of it, in the context of the Tokai-Cecilia Management Framework Review Process, the TMNP PMP, and SANParks’ eschewal of them in Annexure 1, may be considered meaningless. And yet SANParks has seen fit to include many of these “meaningless” recommendations into the TCDIP, rendering it meaningless or, at best, contradictory and insubstantial. In so doing, SANParks has … clogged its channel of communication to interested and affected stakeholders, obfuscated communication between SANParks and the public and “blown out of the water” any nascent opportunities for building understanding between different parties.

Nobody, least of all participants in the process, can say that SANParks has not been willing to meaningfully countenance or consider all proposals made to it by the public. On the contrary, many stakeholders fear that SANParks lends too much weight to proposals that contradict not only our Fynbos Biome’s biodiversity, but consultation itself.

Yet, had it stuck to the contextual and procedural limitations imposed by the TCMF Review’s PPP on its public, and participated fully in the process itself (as it should have done), we could well have been looking at a restoration burn in the old plantations at Lower Tokai Park next year.

We no longer have the luxury of time. SANParks must “come to the party” and spell out its vision. Extinction means that sometimes it is too late to change your mind.

View or download

SANParks (May 2023) – Revised Draft Tokai and Cecilia Implementation Plan TMNP
SANParks (April 2022) – Draft Tokai-Cecilia Implementation Plan TMNP
SANParks (April 2022) – Draft Tokai-Cecilia Implementation Plan TMNP – Annexure 1
Comment (2021) – TCMF issues relevant to revised Tokai and Cecilia Draft Implementation Plan (May 2023)
Comment (2022) – Tokai Cecilia Draft Implementation Plan TCDIP 31 May 2022
Arnstein SR (1969) – A Ladder of Citizen Participation
De Villiers S (2001) – A Review of Public Participation in the Law and Policy-Making Process in South Africa
Department of Provincial and Local Government (DPLG) (2007) – National Policy Framework for Public Participation
EPA – Public Participation Guide: Selecting the Right Level of Public Participation
SALS (2013) – Public Participation Framework for the South African Legislative Sector
SANParks (2011) – Stakeholder Participation in Developing Park Management Plans

Note

The above article, published first at The Cape Aflame website, reflects the views of one of our current committee members and not necessarily those of Friends of Tokai Park (FoTP). We replicate it here with a view to encouraging debate and comment, by 19 June 2023, on the Revised Draft Tokai and Cecilia Implementation Plan TMNP. FoTP and its members will submit their own comments on this document to SANParks.

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This Post Has One Comment

Patricia Holmes 10 June, 2023 Reply

Good article – thanks!