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ORIGINAL ARTICLE
Safeguarding Archaeological Cultural Resources
in Africa—Policies, Methods and Issues
of (Non) Compliance
Noemie Arazi
Published online: 31 March 2011
#
Springer Science+Business Media, LLC 2011
Abstract This paper approaches the safeguarding of Africa’s physical cultural resources
in the context of development cooperation, infrastructure and environmental manage-
ment. I focus on the World Bank’s physical cultural resource policy, as it constitutes to
this day the most comprehensive tool for mitigating the adverse impacts of infrastructure
development. However, it will also be shown that issues of noncompliance still persist in
bank-financed projects, especially concerning Africa’s cultural resources. The European
Commission’s policies toward heritage preservation will also be touched upon for
purposes of contrast. I will close with suggestions for future activities that may have a
positive impact on safeguarding those resources.
Résumé Cet article traite la question de la protection du patrimoine culturel en
Afrique dans le contexte de la coopération au développement, l’infrastructure et la
gestion environnementale. L’accent est mis sur la politique opérationnelle de la
Banque Mondiale car cela constitue actuellement l’outil le plus complet pour
atténuer les impacts négatifs suite au développement industriel. Toutefois, il sera
témoigné que les probl èmes de non-conformité persistent dans les projets financés
par la Banque Mondiale, particulièrement par rapport à la sauvegarde du patrimoine
culturel. La politique de l’Union Européenne sur la protection du patrimoine culturel
sera aussi mentionnée pour la comparer avec celle de la Banque Mondiale. L’article
clôturera avec des suggestions pour des activité s futures qui pourront avoir un
impact positif sur la sauvegarde de ces ressources.
Keywords Development cooperation
.
Culture
.
Infrastructure
.
World Bank
.
European Union
.
Environmental impact assessment
.
Noncompliance
.
Heritage
legislation
Afr Archaeol Rev (2011) 28:27–38
DOI 10.1007/s10437-011-9090-8
N. Arazi (*)
Heritage Management Services, Brussels, Belgium
e-mail: n.arazi@hms-archaeology.com
N. Arazi
Université Libre de Bruxelles, Brussels, Belgium
Introduction
The last decade has been an important period for cultural heritage management
(CHM) in Africa. This has resulted partly from bridging the artificial gap between
culture and develo pment and the recognition of incorporating cultural policies in
development processes.
1
Regional CHM institutions have opened, and international
agencies involved in cultural cooperation have contributed considerable sums to the
restoration and rehabilitation of historic city centres and monuments. Archaeological
sites, however, are often left out of cultural cooperation programs, except for sites
inscribed on the World Heritage List.
A real threat to the continent’s archaeological resources is Africa’s current
infrastructure boom, even though the opposite could be true. What is known as
salvage, preventive or commercial archaeology attests nowa days to the most widely
practiced form of archaeology within Europe and the United States, especially since
the application of the “polluter pays” principle (Organization for Economic
Cooperation and Development 1992) or the replacement of governmental funding
for rescue or salvage excavations by developer funding (Aitchison 2000). However,
in sub-Saharan Africa, most heritage legislation still dates to the 1960s and 1970s
(Munjeri 2008), an era during whi ch the notion of protecting cultural heritage from
destruction by changing socia l and economic conditions was only starting to take
shape. In fact, only South Africa (1999), Namibia (2004), Botswana (2001) and
Kenya (2006) have overhauled their heritage legislations to adapt to recent
international developments in the legal prote ction of cultural resources (Ndoro et
al. 2008). Indeed, Africa’s archaeological record becomes an endangered species,
comparable to the continent’s vast holdings of nonrenewable resources, threatened
by weak legislation that lacks provisions for the management of cultural resources in
the context of infrastructure development.
Currently, one of the few legal frameworks allowing for the protection of
archaeological resources impacted by infra structure is environ mental impact
assessment (EIA). EIA has bec ome a standard procedure for evaluating the impacts
that infrastructure projects are likely to have on the environment (Campbell 2000),
including cultural heritage and archaeological sites. This paper focuses on the
approach used by the World Bank, as it has been in the forefront of establishing
operational safeguard po licies to wards the environme nt and physical cultural
resources (PCRs) in conjunction with large-scale infrastructure projects. However,
it will also be shown that in spite of the bank’s seemingly thorough mechanisms,
many projects are being approved without any professional assessment and/or
implementation of a cultural resource management plan. The European Union’s(EU)
approach to cultural cooperation and heritage protection will also be brought up in
order to contrast its policies with that of the World Bank. As far as recommendations
go, it will be argued, as it has already been done by Ndoro et al. (2008), that until
effective in-country legislation and monitoring systems have been established, the
confrontation on issues of noncompliance between the various stakeholders will
remain a great challenge.
1
See for instance Intergovernmental Conference on Cultural Policies for Development, held in Stockholm
in 1998 (www.unesco.org/cpp).
28 Afr Archaeol Rev (2011) 28:27–38
The Cultural Dimension of Development
In the early 1980s, the UN and UNESCO initiated the idea of putting the cultural
dimension of development back on the international agenda. This was followed by
the creation of a World Commission for Culture and Development in the early 1990s
that culminated in a report entitled “Our Creative Diversity” (1995). The latter lists
as its main premise, to regard culture as the basis for all human development, and it
states that sustainable development and the flourishing of culture are interdependent.
Other international efforts to bridge the gap between culture and development soon
followed.
2
Indeed, the work of those commissions acknowledges that culture matters
as much as economics or politics to the process of development, but as Yousfi (2007:
5) remarks, “there remains some confusion about precisely ‘how’ it matters.” The
“how” question on the relat ionship between culture and development remains a
complex issue. Not only do these terms mean different things to different people, but
the concepts of culture and development have also undergone fundamental changes
in the last decades. Culture, once perceived to stand in the way of development, has
become a driving force within the development paradigm.
Culture as defined by UNESCO is “the whole complex of distinctive spiritual,
material, intellectual and emotional features that characte rize a society or social
group. It incl udes not only arts and letters, but also modes of life, the fundamental
rights of the human being, value systems, traditions and belief.”
3
This concept of
culture should therefore be a fundamental consideration for development cooperation.
This is at least what the UN and UNESCO aim to achieve, instead of conceiving growth
only in quantitative terms.
Cultural Industries and Development Cooperation
At the s ame time, the need to promote cultural industries i n development
cooperation has also been recognized. So where does the protection of cultural
heritage come into the equation? In the framework of the European Union’s
development cooperation with African, Caribbean and Pacific (ACP) countries,
culture and cultural heritage more specifically were firmly integrated in 2000 by the
Cotonou Agreement (2005), acknowledging the social and cultural dimension of
cooperation projects and programs.
Hence, from the EU’s point of view, the preservation and promotion of cultural
heritage constitutes a vital element in the union’s international relations . However, it
needs to be stated that in this context most attention is directed to the preservation
and conservation of World Heritage sites, the rehabilitation of historic city centres
and the enhancement of museums and their collections. Projec ts financed by the EU-
2
At around the same time, the Council of Europe commissioned its own review on culture and
development, which resulted in the report “In from the Margins” (1998). In 1992, the World Bank
organized a conference on “Culture and Development in Africa,” in which several Africanist
archaeologists and cultural heritage specialists took part (Serageldin and Taboroff 1994).
3
UNESCO Mexico City Declaration on Cultural Policies, World Conference on Cultural Policies, Mexico
City, July 26–August 6, 1982.
Afr Archaeol Rev (2011) 28:27–38 2929
ACP cultural industry support program included the Lalibela churches (10.6 million €),
the National Museums of Kenya (8 million €), the Elmina and Old Accra preservation
project in Ghana (2 million €) and the national and regional museums in Mali (Héau
2009). Indeed, World Heritage sites and museums represent the most important
categories for development cooperation due to their potential for economic growth.
Archaeological components, in contrast, are rarely included in those programs.
In 2009, the European Commission (2009) and Europe Aid organized an
international colloquium on “Culture and Creativity as Vectors for Development” in
the framework of EU cooperation with the ACP countries. The objective was to
demonstrate the importance and contribution of culture for the identity of people, peace
and stability of societies, and the economic development of ACP countries. Another
significant aim of the conference was to identify and optimize strategies for integration
of culture into international cooperation programs. However, cultural heritage was
regrettably underrepresented with only six speakers on the “creative management of
cultural heritage and its priorities.” Most case studies came from museums, cultural
tourism and the restoration of historic city centres. Moreover, most participants at the
colloquium came from the cultural sector with no representatives invited from other
sectors of development such as infrastructure, conflict resolution, health, etc. The aim of
the conference, which was to bridge the gap between culture and the traditional notions
of and activities in development, has therefore only partially succeeded. The following
section will provide further testimony about how reticent the EU still is towards
recognizing what, in my opinion, is one of the most direct links between culture and
development: the potential of heritage protection via environmental evaluations related
to infrastructure.
Environmental Impact Assessment
The evaluation and protection of cultural resources, including archaeological sites, have
become part and parcel of EIAs for public and private sector infrastructure development.
EIA has become the most widespread method for achieving a balance between
development and environmental protection at the individual project level (Campbell
2000). It is designed to determine the geographical, biophysical, social and cultural
features likely to be affected by a project. The EIA process thus involves a variety of
specialized disciplines and skills in a spatial approach (Fleming and Campbell 2010)
and is used as a planning tool for information gathering and decision making.
EIA in Africa
During the past two decades EIA has also become established in virtually all regions
of Africa. A recent study has shown that 18 African countries have either an
enabling legislation and/or specific legislation/regulations on EIA in place
(Economic Commission for Africa (ECA) 2005). Ten of these countries have
explicit formal provisions for public participation. While the aforementioned study
has not attempted to rank the EIA systems of countries, it observes that Ghana and
Tunisia have functional and relatively robust EIA systems, while Benin, Egypt,
30 Afr Archaeol Rev (2011) 28:27–38
Algeria, Uganda, Botswana and South Africa also have good systems in place.
However, many other countries in the continent are yet to fully develop the
institutional and regulatory frameworks for EIA, which are indeed nonexistent or
quite rudimentary.
Moreover, the advent of EIA in most African countries was enabled by natural
science professionals and newly formed governmental agencies for environmental
protection. Individuals and institutions responsible for cultural heritage were
generally not consulted or included. As a result, in many countries there is a
knowledge and communication gap between environmental and cultural heritage
authorities (Fleming and Campbell 2010). Hence, the cultural heritage component of
EIA often has been treated in a cursory fashion or even neglected. Tanzania’s
Antiquities Act, for instance, provides for the cultural heritage component within an
EIA, but it has been pointed out that usually the team s involved in such assessment
do not include cultural resource specialists (Ndoro and Kiriama 2008: 60). As a
result of this, nothing of significance is reported. In the case that cultural resources
are reported, the results do not always reach the relevant authorities.
Only Botswana, Namibia and South Africa have explicit legislation that requires the
cultural heritage component within an EIA and/or an archaeological impact assessment
(AIA) prior to infrastructure development (Ndoro and Kiriama 2008). AIAs are
required prior to any infrastructure development in Namibia by the National Heritage
Act 27 of 2004 (Subsection 6) and in Botswana by Section 19 of the Monuments and
Relics Act of 2001. In South Africa the overarching national legal frameworks for the
protection and management of the natural and cultural environment are the National
Heritage Resources Act (NHR) (Act No. 25 of 1999), the Environment Conservation
Act (ECA) (Act No. 73 of 1989) and associated EIA regulations and the National
Environmental Management Act (NEMA) (Act No. 107 of 1998) (Bauman and
Winter 2005). It is Section 38 of the NHR Act that makes specific reference to the
requirements of heritage assessments, either as a stand-alone Heritage Impact
Assessment (HIA) or as a specialist component of the EIA process. According to
Ndoro and Kiriama (2008), other countries are contemplating taking this direction.
Multilateral Organizations
To its credit, the World Bank Group has incorporated cultural heritage (also termed
cultural property or cultural resources) into its requirements for safeguarding the
environment since 1986. Indeed, loans and grants provided by the World Bank to its
client countries must comply with provisions of 11 safeguard policies: Environ-
mental Assessment (which covers the World Bank’s EIA requirements), Natural
Habitats, Forests, Pest M anagement, Physical Cultural Resources, Involuntary
Resettlement, Indigenous Peoples, Safety of Dams, International Waterways,
Disputed Areas, and Use of Country Systems (see www.worldbank.org). The policy
for cultural heritage, issued in 1986 as Operational Policy Note (OPN) 11.03—
Management of Cultural Property in Bank-Financed Projects, was actually one of the
first and predated EIA by three years. In April 2006, the World Bank replaced OPN
11.03 with OP 4.11—PCR which explicitly states that cultural resources must be a
component of environmental assessment.
Afr Archaeol Rev (2011) 28:27–38 3131
The European Commission (EC), in contrast, has no systematic approach to
carrying out EIAs in development cooperation. Hence, infrastructure projects
financed by the EC do not have to conform to any specific environmental
management schemes. A recent study carried out in 63 EC delegations across
Africa, the Caribbean, Pacific, Asia and Latin America has found that only 24%
have carried out an EIA in the context of EC development funding since 1996
(Nicholson and Riesco 2007). This alarming situation is further aggravated by the
fact that there is no systematic approach to the publishing of EIAs, which means
that civil society organizations cannot actively engage in consultation and
dialogue. However, there might be hope for improvement through the recent
establishment of Country Environmental Profiles (CEPs), which are meant to be
the “key tool” for addressing environmental issues from the start of the cooperation
process. The place of cultural heritage within CEPs is yet to be determined
however.
The World Bank’s Opera tional Policy 4.11
The World Bank’s safeguard policy towards physical cultural resources (PCR)
4
applies only to tangible or physical, cultural resources, which are defined as:
movable or immovable objects; sites; structures; groups of structures and natural
features and landscapes that have archaeological, paleontolo gical, historical,
architectural, religious, aesthetic or other cultural significance.
One has to appreciate the inclusive nature of the World Bank’s definition of PCR. For
one thing, PCR do not have to be human-made, as they also include natural features,
such as a sacred grove of trees (i.e., Osun-Osogbo Sacred Grove, Nigeria), a cave, or
holy waters, which have become culturally important to a particular community or
religion. They can also include items that are partly human-made and partly natural,
such as a cemetery or a garden. According to the World Bank, PCR can also incorporate
contemporary cultural assets, which has important implications for archaeologists
involved in EIAs as they have a tendency to focus on cultural resources from the past. A
cultural heritage specialist, therefore, also needs to liaise with affected communities and
register their cultural resources. The World Bank’s inclusive approach to cultural
heritage assets can also be recognized in that it values all resources whether located in
urban or rural settings, above, below ground or underwater, be they of interest at the
local, provincial or national level, or within the international community.
It has also been acknowledged that PCR are often unregistered, unrecognized and
invisible if they are below ground. Official inventories maintained by cultural
authorities are commonly limited to monumental buildings of national interest, and
established archaeological sites. In some cases, and especi ally in Africa, they are out
of date. Thus, PCR may be affected by development projects and are frequently not
identified on government inventories or on official maps. Surveys of the area to be
4
http://web.worldbank.org/WBSITE/EXTERNAL/PROJECTS/EXTPOLICIES/EXTOPMANUAL/0,,
contentMDK:20970737~menuPK:64701637~pagePK:64709096~piPK:64709108~ theSitePK:502184,00.
html
32 Afr Archaeol Rev (2011) 28:27–38
impacted by a future infrastructure project are therefore of utm ost importance when
conducting the cultural heritage aspect of EIAs.
According to the World Ban k, it is not necessary to ascribe an absolute value to a
PCR and to evaluate it vs. the financial or econom ic advantages of going ahead with
the project on a traditional cost–benefit basis (Campbell 2009). However, EIA teams
are required to assess the cultural significance of the PCR concerned, which often
involves a three-part hierarchization. Sites can be classified as important, of
uncertain importance and as not important, and this classification directly affects
the choice of mitigation measures. However, in Africa experts tend to have
difficulties using those cultural resource management (CRM) procedures that have
mainly evolved in a Western context, as primary challenges have historically
involved the lack of funding and resources to initiate any kind of archaeology
program (MacEachern 2010). Moreover, only a handful of archaeologists have so far
participated in CRM projects, except for countries such as South Africa and
Botswana where CRM projects have become integrated into heritage legislation.
The policy also requires the project management plan to include procedures for dealing
with PCR that may be encountered unexpectedly during project implementation (OP 4.1 1,
paragraph 9, and BP 4.11, paragraph 1 1). Such procedures normally involve collaboration
with the authorities legally responsible for dealing with such chance finds. In some cases
they may include having an archaeologist on site and will typically incorporate a “rapid
response” arrangement designed to minimize disruption of the project.
Provisions for projects to include capacity building for policy implementation
support are included in the World Bank’s Environmental Assessment Policy. This is
important in the context of PCR because in many countries the cult ural resour ce
authorities are as yet unfamiliar with EIA procedures and have yet to be
mainstreamed into the development process. This requirement will often be in the
area of PCR inventory and mapping, human resource development and the
development of rapid response systems for handling chance finds.
The findings of the PCR component are normally included in the final EIA report,
which is accessible to the public, especially if commissioned by financial
development institutions. This brings us to the issue of noncompliance, as it was
through the consultation of EIA reports that the author was able to identify that
numerous World Bank-financed projects in Africa do not seem to implement the
proper operational safeguard policy on physical cultural resources.
Issues of (Non)Compliance
In spite of the World Bank’s rigorous safeguard policies, there are ongoing issues of
noncompliance, especially regarding OP 4.11 on Physical Cultural Resources. This is in
itself nothing new, as others have already noted the bank’s lack of implementing its own
safeguard policies towards PCR (Brandt 2000;MacEachern2001). However, the
disturbing fact is that noncompliance seems to be common for projects in Africa.
Recent research on EIAs of World Bank -fin anced roa d projec ts provid es
testimony to this worrisome situation. In Mali, for instance, there has been the
Second Transport Sector Project, which involves a substantial road rehabilitation
project between Kita – Toukoto–Bafoulabé (210 km) in the Baoulé region and
Afr Archaeol Rev (2011) 28:27–38 3333
between Bandiagara–Douentza–Bretelle Togo Tongo (140 km) in the Mopti region.
The entire EIA (Ingénieurs Conseils 2006 ) in this case does not mention one single
site, despite the fact that both regions, Mopti and Baoulé, are known for their wealth
of archaeological remains, including cave and rock art sites (especially in the Baoulé
region). Another example is the rehabilitation of the Kintampo–Paga Road (396 km)
in Ghana, which is part of the West Africa Regional Transport and Transit
Facilitation Project. The only mention of physical cultural resources is reduced to
one sentence, “that there will not be any direct impacts on sensitive environmental
areas (e.g., habitat, wildlife or cultural heritage)” (Sai Consulting Engineers Pvt. Ltd.
2008). And, finally, there is the Second Transport Sector Deve lopment Project in
Uganda, which plans on rehabilitating the Kampala–Gayaza Road (67 km) and the
Soroti–Lira Road (125 km). The EIAs do not mention a single site, except for the
Buganda King’s Palace in Bumunanika (Kampala–Gaya za Road), while the stretch
between Soroti– Lira seems empty of any PCR: “It is not anticipated that sites of
cultural, historic or traditional significance will be affected during construction or
operation, as the road design should avoid any such sites” (Gauff Ingenieure 2004).
Similar observations have been made for other World Bank-financed road projects in
Mauritania (Mauritania Road Corridor ACGF), Senegal (Diamniadio Highway) and
Tanzan ia (Transport Sector Support Project). Partial and inadequate statements, as
the ones mentioned above, usually sum up the entire PRC content, which goes
directly contrary to the World Bank’s guidebook on the PCR Safeguard Policy. The
latter states that, “authors should be more specific, should describe the nature and
extent of the impacts, and state precisely why they are considered to be insignificant
or minor” (Campbell 2009: 51). It appears that the EIAs containing these inadequate
appraisals are almost always approved by the Bank’s task-team leaders and others
involved in the process.
5
The experience on the Chad–Cameroon Oil Pipeline,
however, has shown that absence of previously known cultural remains in a region
was always due to a lack of previous resear ch, not due to a lack of such ancient
cultural rema ins (MacEachern personal communication, July 2009). This seems to
be a general situation across many African countries.
The aforementioned examples provide testimony on several issues. On the one
hand, there seems to be general unawareness towards heritage preservation, despite
the fact that the majority of financial institutions providing loans employ the World
Bank’s environmental safeguard standards. This unawareness might have resulted
from traditionally focusing on the biophysical as well as on the socioeconomic
impacts of a proposed project, while cultural heritage has often been and still is
regarded as an “add-on” (Campbell 2000). As a result, consultancy firm s have
tended to employ experts from other disciplines to cover the cultural heritage
assessment as part of their job. In other words, the cultural heritage aspect of EIAs
has often been done by nonexperts, as a result of either unaware project managers or
alternatively, to provide firms with a higher turnover by employing limited teams.
5
It needs to be said that in July 2009, a letter was sent to the World Bank regarding the above mentioned
projects, signed by Paul Lane as former president of the Society of Africanist Archaeologists (SAfA),
Pierre de Maret, Scott MacEachern and the author. The World Bank has responded positively to our
queries on the issues of noncompliance and took up contact with all national institutions responsible for
heritage preservation in order to initiate an archaeological assessment for each project.
34 Afr Archaeol Rev (2011) 28:27–38
The aforement io ned c as e stud ies from Mali, Gh a na an d Uga nda p rov ide
testimony to the low ranking of cultural heritage preservation in regard to physical
planning, environmental management and land use, despite the presence of relatively
well-functioning institutions and dynamic teams of heritage professionals. Moreover,
those three are countries that are represented on UNESCO’s World Heritage List,
which indicates that cultural resources have a considerable profile in public life. So
what is the element that makes noncompliance possible in countries that have the
required resources and expertise and which are internationally known for their
cultural assets? One explanation might be the lack of enhanced communication and
exchange between cultural heritage authorities and all other governmental
authorities. Albert Mumma (2008: 102) summed it up as follow s:
“Immovable cultural heritage encompasses the entire corpus of nationa l life.
Legislation applicable to immovable cultural heritage, there fore, is to be found
embedded in other legislation, administrative mechanisms and policy tools,
dealing with physical planning, environmental management, agriculture,
wildlife conservation, forest management and so on. … The conservation of
cultural heritage cannot effectively be achieved without integrating heritage
conservation policy and law into all areas of national life. Integrated planning
and conservation of heritage is best achieved by means of legislation and
policy mechanisms. It imposes responsibility on state organs, municipal
authorities and comm unities to take into account and give effect to the
conservation of heritage in their day-to-day activities. Heritage conservation
should be considered as a major national policy object ive that cuts across
policies and laws affecting all areas of national life.”
Indeed, cultural heritage profession als need to bec ome part of the committees that
assist the EIA administrative agencies in the execution of their duties. National
authorities responsible for cultural heritage might also have to make EIA application a
policy or legislative requirement as has been done in South Africa, Namibia and
Botswana. This might actually be one of the most important directions to follow, as
many environmental professionals do not yet consider cultural heritage as part of the
EIA process. The latter is attested by the “Review of the Application of Environ mental
Impact Assessment in Selected African Countries” (ECA 2005), which mentions in
the section on other integral components of impact assessment, social impact
assessment, health impact assessment, biodiversity assessment, but not cultural
heritage assessment. This omission might also reflect current degree programs
offered in EIA. Professional EIA bodies should therefore be contacted and made
aware of this issue. On a more general note, it has been stated that “capaci ty, in terms
of human, material and financial, still remains the biggest challenge to the effective
institutionalization and application of EIA in Africa” (ECA 2005: XVII).
Conclusion
Nonmonumental sites are usually left out of cultural cooperation programs, as they
might lack the capacity for economic return from cultural tourism. They are, thus, a
fragile resource and at high risk to neglect, looting and destruction. Moreover, financial
Afr Archaeol Rev (2011) 28:27–38 3535
resources for purely research-oriented projects are becoming increasingly scarce with a
direct bearing on site preservation activities. Another risk to Africa’sarchaeological
resources is the acceleration in pace, volume and scale of construction projects, which
require increased attention and rapid action by cultural heritage professionals and
archaeologists (Arazi 2009; Naffé et al. 2008). In the face of this challenge,
individuals, organizations and institutions responsible for cultural heritage must
evolve from mere custodians of the past to become an integral part of the modern
construct for socioeconomic development and environmental management (Fleming
and Campbell 2010). This will not be an easy task, as we have to “compete” with
social and environmental issues, which are often of more immediate concern to
affected communities. On the other hand, multilateral lending institutions such as the
World Bank have integrated physical cultural resources as one of the vital elements
within their environmental safeguard policies. Hence, the cultural heritage aspect in
EIAs should be given the opportunity to be conducted as thoroughly as other aspects
involving health, gender, social and environmental issues. It is often argued, especially
in the context of Africa, that because governments will have to repay those loans,
experts need to stay “pragmatic” and “realistic” concerning their recommendations on
aproject’s socioenvironmental and cultural impacts. However, nowadays, govern-
ments applying for loans know that a specific sum needs to be set aside for investing
in EIAs and environmental management plans. The costs, therefore, cannot be the sole
reason for not implementing certain safeguard policies, especially the cultural heritage
aspect that usually takes up the smallest amount. What might be happening instead is
that many agencies and consultancies that have gathered extensive experience in the
“development business” know the loopholes of getting around the PCR content.
Indeed legislation might be one of the most pressing issues that need to be tackled for
compliance with heritage preservation. An initiative could also be to set up an external
monitoring group that examines the PCR content of projects financed by multilateral
institutions, as otherwise EIAs will continue to present African countries “empty” of
any noteworthy physical cultural resources.
Acknowledgments I would like to thank Federica Sulas and Stephanie Wynne-Jones for having
organized a very timely and stimulating conference on Africa’s Fragile Heritage in October of 2009 and
for their invitation to Cambridge. Special thanks go to Federica Sulas for her support and encouragement
to publish this piece and her helpful comments. Special thanks also go to Prof. Pierre de Maret and his
continued involvement and support for Heritage Management Services, and lastly I would like to thank
Arlene Fleming, who has assisted me in identifying the right people at the World Bank to whom we could
address our enquiries concerning compliance.
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