Zimbabwe Parks and Wildlife Management Authority

ACRONYMS AND ABBREVIATIONS

AM Area Manager

CA CAMPFIRE Association

CE Chief Ecologist

DC Conservation Director

DG Director General

EM Elephant Manager

HEC Human Elephant Conflict

HMS Head Management Services

HRM Head Human Resources

IM Investigations Manager

NGO Non Governmental Organisation

PRM Public Relations Manager

RDC Rural District Council

RM Regional Manager

SOAZ Safari Operators Association Zimbabwe

ZHA Zimbabwe Hunters Association

ZPGHA Zimbabwe Professional Guides and Hunters Association

ZRP Zimbabwe Republic Police

TFCA Transfrontier Conservation Area

INTRODUCTION AND BACKGROUND

By any standards Zimbabwe has a proud history of successful elephant conservation. Elephant populations in most of Africa were reduced to very low numbers by the late 19th Century. In 1897 approximately 100,000 tonnes of ivory was exported from Africa [42]. In 1900 it was feared that elephant might become extinct south of the Zambezi River [6]. Using historical accounts of elephant numbers, backwards extrapolations based on population growth rates, and known levels of elephant kills it is unlikely that Zimbabwe held more about 4,000 elephants in 1900 [8,10,14,16]. More than one hundred years later, in 2014, this number had increased twenty-fold to nearly 83,000 elephants (Fig. 1 and Table 1) despite attempts to limit elephant population growth between 1960 and 1989 by culling 45,000 elephant in tsetse control areas and state protected areas (Fig. 1) [5,32]. The primary rationale for limiting elephant numbers in protected areas was to reduce their impact on woodland habitats and the loss of plant and animal species as result of elephant-induced habitat change [9,12,44]. Elephant impacts on woodlands and associated and biodiversity is still a concern today [15, 46,47].

Between 1990 and 2006 elephant populations grew exponentially but growth has since been limited by an escalation of illegal killing [18]. However, the overall population in the country remains at more than 80,000 elephants (Table 1), which is more than twice the national target population envisaged in the 1908s.

Figure 1. Growth of elephant population in Zimbabwe between 1900 and 2001, number of elephant killed (lower graph), and aerial census estimates (triangular point) in those years in which the entire elephant range was covered. The numbers killed before 1960 are based on the amount of ivory exported from the country. The high numbers killed in the 1980s represent the large-scale culls that were carried out during that period in an effort to reduce their environmental impact.

Zimbabwe is one of the key elephant range states and home to the second largest estimated elephant population of nearly 83,000 individuals following Botswana, which is estimated to hold Zimbabwe Elephant Management Plan: 2015-2020 4 more than 130,000 elephants. Zimbabwe thus has a clear obligation to ensure the survival of the species for the benefit of present and future generations of all stakeholders1.

Zimbabwe first adopted a specific Policy and Plan for Elephant Management in 1997 [33] with the long term vision to “Conserve elephants at levels that will enable them to contribute to the conservation of biodiversity, national development and Zimbabwe’s cultural heritage.” As a matter of policy the plan required that at least four demographically and genetically viable populations of elephants be maintained, that elephant densities be kept below the levels at which they might compromise biodiversity, and that elephant range remain at or above the 1996 level. At the time illegal killing of elephants was at a very low level and the plan placed little emphasis on law enforcement. That situation has since changed drastically, with poaching at a crisis state in some countries, although not to the same extent in Zimbabwe. Furthermore, elephant range has been constrained by increasing human population densities in many rural areas. Accordingly, the Zimbabwe Parks and Wildlife Management Authority (ZPWMA) convened a participatory workshop in Hwange Safari Lodge (from 2nd to 4th December 2014) to develop an agreed “Strategic Elephant Conservation Policy and Management Plan Framework”. The policy and primary objectives of the 1997 plan were incorporated into the December 2014 framework, and the objectives and action items were updated to reflect new challenges to elephant management that were not in focus in 1997. The framework developed at the December 2014 workshop, together with input from the two-day CAMPFIRE Association workshop held in November 2014, form the basis of the current elephant management plan. The national workshop included stakeholders with varied interests from the wildlife and tourism industry, conservation NGOs, technical experts from Zimbabwe and the international community, and government representatives from wildlife agencies in neighbouring countries that share elephant populations with Zimbabwe.

At the Hwange workshop, participants agreed that each of the four primary elephant ranges needed a regional plan to address the specific challenges and advantages of elephant in that area. Accordingly, from 30 April to 2 May, 2015, a workshop was held to discuss an antipoaching strategy for Mana Pools National Park, which was later expanded to cover the midZambezi Valley region. Similarly, in May and September 2015, workshops were held in the Sebungwe and the South East Lowveld, respectively, to develop action plans for each region. An anti-poaching strategy workshop for Hwange National Park was held in June 2015 and, together the management plan for the park, provided a basis for completing an action plan for Northwest Matabeleland. These action plans are appended in Annexes 9.4 to 9.7.

The current conservation status of African elephants is that they are listed as Vulnerable under the IUCN Red List, as Endangered in CITES Appendix I, apart from the populations of Botswana, Namibia, South Africa and Zimbabwe that are listed under CITES Appendix II. In Zimbabwe, African elephant are not included on the list of “specially protected animals” because their population is so large. However, they are listed on the “Schedule of Animals with High Economic Value.”

1.1 Numbers, distribution and regional trends of elephant in Zimbabwe

Elephants are distributed in four main regional populations in Zimbabwe, namely, Northwest Matabeleland, the Sebungwe, the mid-Zambezi Valley, and the South East Lowveld (Fig. 2). Crude ecological densities vary between 2.16 elephant/km2 in Northwest Matabeleland and

1 Note that the African elephant comprises two species, namely the forest elephant and the savanna elephant. Given the high proportion of the continent’s savanna elephants that occur in Zimbabwe this places increasing responsibility for their conservation on the country.

The elephant population in Hwange National Park was approximately 2,000 animals when it was first declared a Game Reserve in 1928 [10]. Elephant impacts on vegetation reached alarming levels by 1964 and a representative of WWF-US advised the then minister of natural resources to act on what was perceived to be an over-population of elephants. The first major cull of elephants took place in the park in 1965 [10]. A major factor contributing to the growth of the elephant population (with a current density of 3/km2 in 2014), and of other species, was the provision of artificial water supplies through the dry season [10,37]. The Matetsi Safari Area to the north of Hwange National Park was established in 1972, on what had been a commercial farming area, and the complex, that includes two national parks, carries a lower density of elephant (1.1/km2). Estimated growth of the elephant population since 1980 in Northwest Matabeleland is shown in Fig. 3 below.

Following the large culls of the 1980s the elephant population of Hwange National Park grew rapidly from 13,000 in 1986 to about 35,000 in the early 1990s and appeared to stabilise at about this number [7]. However, the 2001, 2007 and 2014 dry season estimates of between c. 35,000 and 45,000 [23] suggest that the elephant population in the park may now have stabilised at about this number (or a density of 2 to 3 elephants/km2), with rainfall and water supplies acting as limiting factors.

The Sebungwe region covers an arc of 15,000 km2 to the south of Lake Kariba. Historically the area was demarcated by tsetse control fences that ran from Binga on the lakeshore in the west southwards to the Sengwa Wildlife Research Area and then north-eastwards to the Kanayati River and Matusadona National Park (Fig. 2). The Parks and Wildlife Estate covers 6,234 km2 and includes two national parks and two safari areas. There is a single forest area within the region and the remaining area of c. 9,000 km2 is communal land. As in the other regions the elephant population grew from about 2,000 elephant in the 1920s to c. 15,000 in 2006 [9,17]. It was recently reduced to an estimated population of 3,500 in 2014 [23] (Fig. 4). The human population in the three districts of the Sebungwe has increased from 45,000 in 1950 to some 700,000 in 2013 with population densities of more than 30 per km2 in Gokwe North and Gokwe South. The threshold human density at which elephants disappear from settled areas is approximately 15 people/km2 [27].

The mid-Zambezi Valley area of 11,000 km2 includes Mana Pools National Park, six safari areas and small, adjacent areas of communal land. Returns from hunting leases and quotas provide an important source of revenue for ZPWLMA. Unlike the Sebungwe the protected areas are contiguous. The elephant population reached a high of 19,000 in 2001 and between 2001 and 2014 was reduced to 11,000 elephants [22] (Fig. 5). Culling took place in the escarpment areas of Charara, Nyakasanga and Mana Pools during the 1980s. As in North West Matabeleland, the elephant population in the mid-Zambezi Valley is shared with Zambia in the Lower Zambezi National Park and with Mozambique.

Recent estimates of elephant in the adjacent 16,500 km2 in Mozambique south of Cabora Bassa are 1,985 elephants in 2010 [19], and 1,600 in 2014 – a decline of 19%. In Zambia, an aerial survey of the Chiawa Game Management Area and of the Lower Zambezi National Park in Zambia in October 2013 [45] estimated elephant populations of 405 and 1,795 in the two areas respectively. The elephant density in Chiawa GMA was 0.16/km2 and in the Lower Zambezi National Park was 0.41/km2.

The South East Lowveld elephant population is centred on the Gonarezhou National Park population of c. 11,000 elephant in 5,000 km2 that has been growing at about 5% per annum for the last 20 years (Fig. 6). The population falls within the Great Limpopo Transfrontier Conservation Area (TFCA) and there is some movement of elephant between Gonarezhou and Kruger National Park and across the park boundary into Mozambique. Separate elephant populations occur in the Malilangwe, Savé Valley, and Bubye Valley conservancies. There is also a small population in the Tuli Safari Area that is shared with South Africa and Botswana in the Mapungubwe TFCA. Overall there are about 13,000 elephant in this range [25]. The 2014 survey recorded no live elephants in the Mozambique blocks adjacent to Gonarezhou National Park but returned an estimate of more than 160 elephant carcasses [25].

Summary Comment. Law enforcement, mitigating human-elephant conflict [27,35,36], and building supportive and beneficial relationships between protected areas and their neighbours [41] are key issues in all regions. In the Sebungwe, rapid human population growth and settlement in previously uninhabited areas is reducing the range available to elephants and limiting movement between protected areas. Here, rehabilitating protected areas and implementing strong incentives [43] for elephant conservation in the communal lands will be strategically important steps for that region. For all of the four elephant ranges in the country further key specific issues and actions to tackle them will be tackled through the action plans that have been developed for each region (Annexes 9.4 – 9.7). The development of regional action plans and the devolution this involves will also serve to reduce the risk of scale mismatches between institutional/social and ecological scales [17].

1.2 Targets for elephant numbers in relation to conserving biodiversity

Specifying a positive target figure for the number of elephants a country wishes to conserve is entirely appropriate where an elephant population has been greatly reduced as, in the Sebungwe region. In countries, or areas of countries, where there may be an over-population of elephant a legitimate objective may be to reduce their number. The three targets that were adopted as a matter of policy in 1997 by the Zimbabwe Government are:

1. To maintain at least four demographically and genetically viable elephant populations in Zimbabwe
2. To maintain or increase core protected area range of elephant in Zimbabwe
3. To maintain numbers / densities of elephant at levels that do not adversely impact on biodiversity conservation goals while contributing to economically viable and sustainable wildlife-based land uses in Zimbabwe

Maintaining four regional populations each of between 5,000 and 10,000 elephants would meet the first target of maintaining four demographically and genetically viable populations [2]. However, the third target is not likely to be met unless there is sufficient range, in each of the four regions, in which to hold these numbers without compromising the range of biodiversity that the country is committed to protecting in terms of its policy and legislation. The core state protected area (National Parks and Safari Areas) of elephant range in Zimbabwe is close to 42,000 km2. At present this area is carrying more than 70,000 elephants (Table 1) or a crude density of about 1.75 elephants/km2, a density at which woodlands and biodiversity are compromised [1,3,9,12,15,31,46]. At densities as low as 0.3 elephants/km2 woody plant species can be lost and species diversity of birds and invertebrates reduced [15,34]. In miombo woodlands, which form the predominant type of protected habitat in the Zambezi Valley, woody plant species and some animal species will be lost at elephant densities as low as one elephant to 10 km2 [31]. As an example, in a miombo woodland area in the Sengwa Wildlife Research Area (southern Chris) elephants at a density of < 1/km2 were responsible for removing 45% of the woody biomass in just four years [26]. In Chizarira National Park, with elephant densities in excess of 1 per km2 tree canopy cover declined from 75% in 1979 to less than 10% in 1993 [44,11]. The only tall trees remaining with dead wood to provide refuges for hole-using birds were found on large termitaria [28].

These examples highlight the dilemma that arises between attempting to protect as many elephants as possible at all costs on the one hand, and to preserve a full range of plant and animal species in protected areas on the other hand [14]. These examples also highlight the consequences of making single resource decisions (e.g. preserve all elephants) that can result in multiple resource consequences (e.g. loss of large trees, plant species, and animal diversity). Recent work in Addo Elephant National Park in South Africa shows that high elephant densities do not increase eco-tourism opportunities and their associated ecological costs are not a requirement for eco- tourism financial sustainability [30].

It is clear that the choice of target elephant population size and density for a particular area or country depends on peoples’ values and the values of decision-makers involved [4]. Ecological science can only provide guidance on the likely consequences of the targets that are chosen. For Zimbabwe the current elephant population is considerably higher than was envisaged in the 1980s when the target was to maintain a countrywide population of about 35,000 elephants [13,15]. Elephants are clearly a keystone species and primary ecological engineers in savanna ecosystems [12], and particularly so at high densities in confined ranges. A sensible strategy, therefore, would be to match targets to different areas and habitats and to vary these targets adaptively in time and space depending on long term trends and the results of appropriate programs monitoring the impacts of elephants on ecosystem structure, function and species diversity.

As a result of the above considerations a decision on a target number of elephant for the country is expressed in terms of an upper and lower limit of elephant density that is presently set at between one and two or three square kilometres per elephant (i.e. 0.3 to 0.5 elephants per km2). However, ZPWMA recognises that density is only one factor to be considered as part of population target setting. All the regional population densities except Sebungwe already exceed these density limits, and this will be taken into account in each regional action plan in establishing thresholds of potential concern relating to ecological, economic and social impacts of elephants.

A series of regional action plans has been developed and in the Sebungwe a tentative target of 5,000 elephant has been set where the present population is approximately 3,000 in about 7,000 km2 of available habitat. This is based on the likelihood that a population of 5,000 will be both genetically and demographically viable[2] and attainable given the land presently available to elephants. The elephant populations in the remaining regions are well above the thresholds established in the 1980s. An important component of the regional management plans is to carry 2 / This concept arose following the re-introduction of wolves into Yellowstone National Park in the USA. Elk avoided habitats in which they were likely to be killed by wolves and this allowed a rapid regeneration of woody plant species that had been over-browsed for years [29, 39].

Zimbabwe Elephant Management Plan: 2015-2020 11 out the necessary research on the ecological, economic and social impacts of elephants and to develop appropriate, spatially nuanced thresholds, for the management of these populations

Management approaches to maintain elephant populations within the still to be set acceptable upper and lower limits will vary with each region but will, in all areas, focus on improved protection and minimising the illegal killing of elephant. In some areas the management of water supplies may be used and the protection of sensitive habitats may require creating a “landscape or ecology of fear”2 through appropriate disturbance of elephants visiting such areas. The most straightforward method of dealing with over-population of a species is culling. However, because the sale of ivory was previously required to cover the costs of large-scale population reductions this option was effectively closed in 1989 by the CITES listing of elephant on Appendix I. Despite the listing of Zimbabwe’s elephant on Appendix II in 1997 and the subsequent sales of stockpiled ivory in 1998 and 2008 trade in ivory has since continued to be constrained by a nine-year moratorium on the sale of ivory. The moratorium is unlikely to be lifted in 2017. The present poaching crisis affecting elephant populations in central and eastern Africa and associated public sentiment also militates against the introduction of culling to manage elephant populations in Zimbabwe.

1.3 Implementation of the Strategy

1.3.1 Institutions and Roles
i) Zimbabwe Parks and Wildlife Management Authority

ZPWMA, through the Parks and Wildlife Act Chapter 20:14, has a national mandate to manage wildlife in the country. By the same instrument it is the lead agency in elephant management, i.e. protection, research, monitoring and sustainable utilization. It forms collaborative arrangements with other institutions to manage elephants in the country.

ii) Intra-governmental institutions

ZPWMA works jointly with security organizations such as Zimbabwe Republic Police (ZRP), Zimbabwe Defence Forces, and the President’s Office to protect the elephant and curb illegal trade in elephant products. ZPWMA works with these institutions through the Joint Operation Command and also on bilateral arrangements. ZPWMA also works with Customs at ports of exit and entry to improve control of the illegal movement of wildlife products across boundaries. iii) Intergovernmental organizations

ZPWMA works closely with sister organizations from neighbouring countries such as Zambia, Mozambique, South Africa and Botswana in wildlife protection, information sharing and elephant monitoring through bilateral and regional arrangements (SADC). At international levels, ZPWMA is both the CITES Management Authority and CITES Scientific Authority and works with other countries through CITES and other inter-governmental agreements to control trade in elephants and to protect elephants.

iv) Non-governmental organizations

Both local and international organizations partner with ZPWMA in elephant management. They mobilize resources for protection, research and monitoring, and assist with elephant monitoring and research, information sharing and advocacy.

v) Private sector

The corporate community participates in elephant management mainly through resource mobilization. Safari operators report poaching and assist in anti-poaching patrols. Through lease and trophy fees they provide revenue to ZPWMA. They help develop infrastructure, provide funds to communities and supplement diets with meat from trophy animals.

Zimbabwe subscribes to the principle of sustainable utilisation of wildlife resources including elephants. Sport hunting is the principal form of wildlife utilisation whereby offtakes are adaptively managed and monitored through a participatory and science based process. This process allows for sustainable offtakes, and rigorous resource monitoring programmes that allow recruitment within a population to ensure the continued survival of the population in the wild. The high economic value conferred to the elephant through consumptive utilisation has also resulted in increased tolerance by local communities.

vi) Local communities

Local communities are involved in elephant management in CAMPFIRE areas, through sharing

of information, advocacy and wildlife protection. They report human-elephant conflicts and carryout some of the conflict management activities.

1.3.2 Funding and resource mobilization

Adequate and sustainable funding and provision of other resources are important to effective protection of the elephant and curbing illegal trade in elephant products. Resources are mobilized from within ZPWMA, by the private sector, and by intergovernmental and nongovernmental organizations. Partnerships between ZPWMA and other stakeholders are some of the innovative measures being developed to secure funding for elephant conservation. There may be a need for the Government to provide additional support to the conservation of elephants given the present poaching crisis affecting the species continentally.

1.3.3 Coordination i) ZPWMA

ZPWMA takes the lead in coordinating other institutions in elephant conservation activities in the country. It will convene and chair the Elephant Management Committee meetings. ii)

Elephant Manager

This Action Plan provides for the appointment of an Elephant Manager within ZPWMA who will be responsible for coordinating elephant management in the country. The Elephant Manager will primarily work through various Elephant Management Committees that will be established pursuant to this Action Plan. The Elephant Manager will liaise with the International Conservation Office on international matters affecting elephant conservation and also liaise with the CAMPFIRE office for matters affecting the conservation of elephants in CAMPFIRE districts. The draft Terms of Reference for the Elephant Manager are provided in Annex 9.7. iii) Elephant Management Committees

A National Elephant Management Committee and four Regional Elephant Management Committees (Zambezi Valley, Sebungwe, Northwest Matabeleland and South East Lowveld) will be established. The National Elephant Management Committee will meet at least once annually to review progress in implementing the Action Plan. The National Committee will document that progress in implementing and any suggested revisions to the Action Plan, and make their report available to the Director General of ZPWMA.

The four Regional Elephant Management Committees will meet at least twice in a year to review the implementation of each regional plan. The Committees will strengthen links with various bodies at national and regional levels including within the TFCA framework. ZPWMA will convene and chair the regional Committee meetings. The draft Terms of Reference for the Elephant Management Committees are provided in Annex 9.5.

1.3.4 Monitoring and evaluation

Monitoring implementation of this Action Plan will be done using the Key Performance Indicators contained in Section 4. Monitoring the implementation will be done and reported on by the Elephant Manager on a monthly and annual basis. A major evaluation of progress will be done every five years. Monitoring and evaluation will be done at each area level in a given elephant region, at the regional level and at the national level.

1.3.5 Links with continental (African Elephant Action Plan / SADC) and other regional initiatives

This Action Plan recognizes the existence of the African Elephant Action Plan and initiatives that are currently taking place at a continental level, including by the African Union. These include the development of the Common Strategy on Combating Illegal Exploitation and Illegal Trade in Wild Fauna and Flora in Africa. At the SADC level initiatives involve developing a Plan of Action and implementing the SADC Protocol on Wildlife Conservation and Law Enforcement. This Action Plan will be reviewed periodically in the light of developments that are taking place in the SADC Region, Africa and beyond.

1.3.6 Regional strategies within Zimbabwe

The devolution of management oversight to regional levels, with more detailed action plans within the national plan, provides the basis for effective adaptive management at regional and local levels.

As set forth in the framework below (Sections 3 and 4), four regional plans have been drafted to address the unique challenges of each region, and will implement the broader goals of this national Action Plan at a more specific level.

In addition, Park-level plans for specific protected areas (including Hwange National Park, Mana Pools National Park, and Gonarezhou National Park) contribute to this Action Plan and govern the management of elephant within those protected areas.

1.3.7 Protecting elephant for the future

Poaching and the illegal wildlife trade are serious concerns for all range states. Poaching has decimated elephant populations in central and eastern Africa, and in Mozambique. Although the 1997 Policy and Plan for Elephant Management in Zimbabwe did not need to prioritise law enforcement, protecting elephant for the future has become a primary objective of this Action Plan, and will be a primary focus of resource utilisation by ZPWMA.

1.3.8 Human elephant conflict

As Zimbabwe’s human population grows, elephant are being restricted to smaller areas and as their populations expand they increasingly move out of their designated habitat, and raid crops and sometimes threaten human lives. As a result in many rural areas where elephants exist in Zimbabwe, human-elephant conflicts are increasing, creating substantial negative attitudes to the conservation efforts of elephants. These are often among the poorest rural farmers, which makes the issue complex in social and economic terms. Unresolved conflicts stimulate poaching or retaliation. Poachers or retaliators can be seen as “local heroes” because they provide meat to the communities and resolve the conflict. A major challenge for elephant management is keeping human-elephant conflicts to a minimum.

Developing a Social, Economic, and Cultural Framework has been identified as a Key Component of this Action Plan in an effort to address and reduce human-elephant conflicts.

2. LOGIC AND STRUCTURE OF THE PLAN

The strategic framework developed at the Hwange workshop in December was based on the Logical Framework structure and the development of clearly stated objectives, outputs and the necessary and sufficient activities (or actions) required to achieve the outputs within a specified time frame (Table 2). The structure requires a set of key performance indicators that are intended, as far as possible, to be SMART, i.e. Specific, Measurable, Achievable, Realistic and Time- bound. The five key components of the plan are:

1. Protection and law enforcement
2. Biological monitoring and management
3. Socio-economic and cultural sustainability
4. Building conservation capacity
5. Coordination, collaboration and programme management

Table 2. Structure of the Action Plan for Elephant Conservation and Management in Zimbabwe

The top-level strategic components of the Action Plan encompassing the Long-term Vision, Targets, Key Components, Strategic Objectives and Outputs are summarised on page 17 in Section 3 below. The top-level components of the plan are then followed by a set of tables in Section 4 (page 18) that provide action plans for the expected Outputs (or outcomes) of each the five strategic components of the plan. The Activities and KPIs within these tables are set at a national strategic level. They will be taken up, as appropriate, during the development of

Regional Action Plans for each of the four regional elephant populations in the country. Activities listed at the national level will, for the most part, form Outputs at the regional level. These Outputs have generated more detailed regional and local specific activities and actions with specific KPIs and means of verification.

The four regional Elephant Action Plans that have been developed as part of the National Action Plan are included in Annexes 9.1 to 9.4.

3. VISION, TARGETS, AND KEY COMPONENTS

4. ACTION PLANS

4.1 Protection and Law Enforcement – Ensuring effective protection of all populations of elephant in Zimbabwe
Output: Management actions, security and law enforcement to minimise illegal losses of elephants and their habitats from all populations implemented KPI: Illegal losses of elephant from at least 90% of elephant populations reduced to less than 5% by 2020, and less than 5% of elephant habitats encroached by settlements by 2020
MV: National level monitoring data on illegal activity, successful convictions, carcass records, status and trends of all elephant populations; verified data on extent of encroachment and of available elephant habitat

An example of a National level Activity being used as an Output at the regional level is provided on below. The example is drawn from the Action plan for the Sebungwe region. It can be seen that what was an Activity (#2 in the table above) at the national strategic level can be defined more specifically to suit the local situation and in much greater detail at this level than is appropriate in the national Action Plan.

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