botswana/namibia - Cour international de Justice

side of the sediment spit in the southern channel. This indicates that there is much greater
current and volume of water passing through the northern and western channel.
G10 - Mean monthly water levels at Kasane Gauging Station, compiled from Table 3, Sefe
2nd Opinion
G12 - Seasonal water level fluctuation along the Kwando-Linyanti-Chobe systems
278. At the eastern bifurcation it is clear that the zone of maximum velocity is in the middle
of the river and flows in a straight line into the western section of the northern channel, rather
than suddenly turning at right angles into the southern channel, the mouth of which is
protected by a sand bank only 1.5 metres under the surface as shown in the Joint Survey of
1985. Were it otherwise, the entire southern end of the island would have been eroded away
by the action of this current.
III. IT IS CORRECT TO DESCRIBE THE SOUTHERN CHANNEL AS A STAGNANT
POOL OF WATER
279. The southern channel is a backwater, not a live river. It is the first to dry out when the
water level drops below the very shallow thresholds of 1.5 to 2 metres depth at its entry point
to the west of the island, and at the south eastern end of the 'lagoon' sector at cross-sections 14
and 13, where depths of 3 metres are shown on the 1985 Joint Survey. The shallowness of the
southern channel is illustrated by the photograph, taken in September 1997, of an elephant
standing in mid-channel of the southern channel in the proximity of the 'lagoon' sector: see
photograph at page 107. In the absence of any through downflow the backflow resulting from
the Kasai channel fills the southern channel, a phenomenon which was noted a decade or so
after the 1890 Agreement was concluded and which was entered on the von Frankenberg map
of 1912 as "flüss-arm".
(F) The other serious Misrepresentations upon which the 'Alexandrine' Channel is
based
280. In consequence and in support of the above three fundamental misconceptions the
Namibian Memorial, in advancing the "Alexandrine" channel as the main channel, makes
many other serious misrepresentations. These include:-
(i) The misrepresentation that flow only occurs in time of flood
281. The Namibian Memorial restricts the time of flow:-
"Water flows through this sector of the Chobe River only during the season when the
Zambezi is in flood. Then it comes into the Chobe not from the upstream reaches to the west,
but across the whole width of the Zambezi floodplain, a front of over 60 kilometres, until
intercepted by the Chobe Ridge,which marks the right (south) bank of the Chobe River. When
the floodwaters reach the Ridge they turn into the bed of the Chobe River flowing through it
and, in the vicinity of the Island, through the southern channel to the confluence with the
Zambezi." (Namibian Memorial, p.7, para.22).
G13 - Photograph of elephant