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botswana/namibia - Cour international de Justice

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G28 - 1947 aerial photograph with labels<br />

G29 - 1962 aerial photograph with labels<br />

[9. Attention should, however, be drawn to a possible alternative interpretation of the May 1972 photograph<br />

namely that the southern channel is choked by a mat of Salvinia Molesta (Kariba weed). The Chobe/Linyanti<br />

system was known to have localised infestations of Salvinia at this time. However, it is not thought to have<br />

existed in the southern channel in May 1972 for the following reasons:-<br />

(i) Salvinia is a total infestation taking the form of an all-covering <strong>de</strong>nsely packed mat, which when established,<br />

can support a secondary growth of shrubs, grasses and other plants on its surface. The large open pool just<br />

opposite the Headquarters of the Chobe National Park is therefore completely uncharacteristic of a typical<br />

Salvinia infestation.<br />

(ii) Salvinia infestation is a very long lasting problem and can subsist for many years, yet in the November 1972<br />

photograph discussed below, which was taken only a few months later, there is no sign of the mat at all.<br />

(iii) The flow chart for the Zambezi given as table 1 on page 15 of the Expert Report, (Namibian Memorial,<br />

Vol.VI, part 1), shows that in 1972, the average flow of the Zambezi was at 640 cubic metres per second, the<br />

lowest flow since 1948 and also the 6th lowest since 1900. It is obvious that the volume of flow in the Zambezi<br />

was too low to push through the Kasai channel and back up the Chobe River as is normal when the average flow<br />

is around 1500 cubic metres per second.<br />

For the foregoing reasons, it is submitted that the correct interpretation of the May 1972 photograph is that it<br />

shows the southern channel to be dry for half its length.<br />

In any event, the Botswana case would still be assisted by this photograph, as Salvinia is normally associated<br />

with backwaters, very slow moving streams and inlets. As the northern and western channels are completely<br />

clear, it follows that the current running through these channels has prevented the spread of the weed, unlike the<br />

southern channel.]<br />

413. Most of the southern section of the Spur channel is also dried out indicating a very low<br />

water level. This photograph provi<strong>de</strong>s strong confirmation that the southern channel is only a<br />

seasonal backwater of the Chobe River, reduced to a trickle or drying out in a dry season.<br />

The November 1972 Photograph (Scale 1:10,000 approx.) Average mean flow 640m3.<br />

(1972). Reproduced with labels at page 175.<br />

414. This photograph is particularly valuable as a record of the actual manner in which the<br />

flood waters of the Zambezi enter the Chobe system. Contrary to Professor Alexan<strong>de</strong>r's<br />

assertions, there is no flood path across the flood plain but a channelled back flow through the<br />

cross-channels linking the Chobe with the Zambezi River. In the five months between the<br />

May and November photographs, the rising waters in the river north of the Island, caused by<br />

flood-water run-off from the Zambezi, have pushed upstream into the southern channel to link<br />

up with the western sector of the northern channel at the bifurcation zone marked B.<br />

However, the channel is barely visible on the north-west si<strong>de</strong> of the sediment spit marked A<br />

and is obviously very shallow as grass is still visible in the channel around the spit.Water has<br />

also pushed up the Spur channel past Kabuta.<br />

G30 - May 1972 aerial photograph with labels<br />

G31 - November 1972 aerial photograph with labels

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