With the Tokai Cecilia Management Framework (TCMF) Review Process now entering its third year, stakeholders can hardly be blamed for getting impatient as the public participation process drags on.
South African National Parks (SANParks) was assigned management of the Table Mountain National Park (TMNP) – including Tokai and Cecilia forest plantations – in 1999.
In 2005, SANParks presented its Draft Management Plan for TMNP in which the organisation stated that both Tokai and Cecilia would be clear-felled and given over to biodiversity conservation and the regeneration of indigenous fynbos.
Following a public outcry, a compromise was reached: the TCMF. The objective of the framework was to provide for shaded recreation on a transitional basis, providing for both shade and biodiversity conservation on a rotational basis.
In essence, it would buy Capetonians another 40 years of shade.
The TCMF was meant to be reviewed every five years but for various reasons – the 2015 Peninsula fires, 2016 to mid-2018 litigation and the Covid-19 pandemic – the process only got underway on 25 May 2021.
Following intense stakeholder engagement, the Draft Tokai Cecilia Implementation Plan (TCIP) was released just under a year later on Tuesday 12 April 2022.
With the comment period for the draft document ending on Friday 20 May last year, another 14 months passed before a Revised Draft TCIP was revealed on Friday 19 May this year.
When the comment period for the revised draft closes on Monday 19 June, the review process will have been two years and one month in the making.
When SANParks was asked why there was such a long delay between the release of the draft and the subsequent revised draft (and if there was even supposed to be one originally), it said that the decision had been made to allow for the public consultation process to go through another round of stakeholder engagement “to ensure that stakeholder concerns and inputs are fully appreciated and considered towards the final Tokai Cecilia Implementation Plan”.
“The conveners made a concerted effort to consolidate the comments on the Draft Tokai Cecilia Implementation Plan into a single document given the overwhelming range and scope of the comments received and the challenge of addressing these in the revised plan,” said SANParks.
But despite this “concerted effort”, it seems that stakeholders across the board find the revised draft lacking.
Nicky Schmidt, the chair of Parkscape, says the general perception among several of her colleagues involved in the review process is that the revised draft is simply another version of the original draft.
“Repackaged and with an acknowledgment of the importance of shaded landscapes and recreation. We are hard-pressed to see any commitment or confirmative approval of the items that gave rise to the revision of the original draft,” says Schmidt.
In an online article titled “Meet SANParks’ new TCIP . . . Same as SANParks’ old TCIP”, Mike Golby, who is on the Friends of Tokai Park’s committee, writes that SANParks fails to 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,” writes Golby.
At the crux of stakeholders discord it seems is the difference of opinion on fynbos conservation versus the retention of shade space.
Listed under Section 7 in the revised draft is the implementation plan; its outcome goals, strategic actions and milestones. Altogether there are 12 outcome goals. Two of these are “shade and planted landscapes” (Goal 4) and “biodiversity and ecosystem services rehabilitation” (Goal 9).
An objective of Goal 4 is “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”.
An objective of Goal 9 is “to implement active and passive rehabilitation interventions and processes in Tokai and Cecilia plantation areas”. The strategic action under this objective is “rehabilitation of suitable plantation areas for the natural environment and the protection of its biodiversity” with “identify pockets of plantation areas suitable for rehabilitation” listed under the Strategic Performance Plan.
Both the fynbos and shade camps have called out SANParks for the apparent juxtaposition of these two goals. SANParks, however, says these two outcomes are not contradictory.
“The outcome will be informed by an investigation into the possible extension of the standing commercial plantation compartments, which is subject to negotiations between the Department of Environment, Forestry and Fisheries and MTO Forestry (the agency doing the commercial harvesting of the plantations).”
And even if the conveners, this time round, do manage to sift through the revised draft public comment in record time, another lengthy process lies ahead once the TCIP has been signed off.
A “fundamental change” to the revised draft is the inclusion of an “Implementation Roadmap” (Section 8); the first step of which is the development of a detailed “Programme of Work” for each outcome goal in consultation with stakeholders.
“The intent is to get the relevant stakeholders to refine the actions and milestones of their respective interests in the form of a programme of work with clear indication of how best to implement all the actions and the potential source funding for the implementation thereof,” the revised draft reads.
All of this is supposed to take about five months (according to a timeline provided under Section 8).
Schmidt says this is concerning given the plantations are due to be felled next year.
“To quote a colleague and with reference to the implementation roadmap ‘the can has just been kicked further down the road’, ” she says.
Another “fundamental change” to the revised draft is that instead of the open-ended timeline, “strategic actions and associated milestones will run along SANParks five-year Strategic Performance Plan”.
According to SANParks, the first year of this plan will commence upon the adoption and signing off of the Revised TCIP.
In another twist, the latest draft states that the Revised Draft TCIP “is to be considered for incorporation into the revised Park Management Plan for TMNP during the Park Management Plan review process”.
People’s Post asked SANParks when this review process was set to start.
“DEFF and SANParks schedule arrangements for Park Management Plan reviews and are still confirming the timeline. It is likely that the revision of the Park Management Plan for TMNP will be delayed due to the restrictions during Covid lockdown when SANParks was not able to engage in functional stakeholder engagement processes for the national parks due for review, which resulted in a backlog of review processes,” SANParks stated.
