NECSA Kenya Memorandum on the Environmental and Social Impact Assessment for the Naivasha-Kisumu Standard Gauge Railway (SGR) and Kisumu Port
- Category: NECSA Memoranda
- Date 08-10-2024
Introduction
On August 28, 2024, the National Environment Civil Society Alliance of Kenya (NECSA-K) submitted a memorandum to the Kenya Railways Corporation (KRC) regarding the Terms of Reference (ToR) for the Environmental and Social Impact Assessment (ESIA) study of the proposed Naivasha-Kisumu Standard Gauge Railway (SGR) (Phase 2B) and Kisumu Port. NECSA-K is a coalition of over 100 civil society organizations advocating for sustainable natural resource management in Kenya.
The proposed project entails the construction of the SGR from Naivasha to Kisumu, including an 8 km branch line to Kisumu Port. Given the scale and potential environmental and social impacts of the project, NECSA-K convened a workshop between August 20 and 22, 2024, to review the ToR and provide recommendations to ensure the project adheres to best environmental practices.
General Recommendations
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Phased Reporting and Milestone Reviews
NECSA-K recommends introducing interim reports, such as an inception report and mid-term progress report, to keep stakeholders informed throughout the ESIA process. This phased reporting will ensure transparency, accountability, and timely feedback. -
Stakeholder Feedback Mechanism
A mechanism for gathering stakeholder feedback is crucial. NECSA-K suggests integrating provisions that ensure feedback from affected parties is incorporated into the draft ESIA report before finalization. -
Penalty Clauses and Subcontractor Performance
The memorandum calls for penalty clauses in the contract to address delays, non-compliance with regulatory standards, and failure to achieve agreed milestones. Additionally, it stresses the need for clear performance standards for subcontractors involved in the ESIA process. -
Post-Project Environmental Monitoring
NECSA-K recommends a long-term monitoring plan to track ongoing environmental and social impacts after the construction phase. This would include defined indicators and roles for stakeholders. -
Adaptive Management Framework
The ESIA should incorporate an adaptive management framework, allowing for real-time updates to mitigation measures based on monitoring data and emerging risks. This would ensure flexibility in addressing unforeseen environmental and social challenges.
Specific Recommendations
NECSA-K’s memorandum provides detailed recommendations for various sections of the ESIA process, with a strong focus on stakeholder engagement, data collection, climate change adaptation, and occupational health and safety.
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Comprehensive Stakeholder Consultations
The memorandum emphasizes the need for a detailed stakeholder engagement plan, including consultations with local communities, government agencies, and non-governmental organizations. It highlights the importance of securing free, prior, and informed consent (FPIC) from indigenous populations and ensuring gender equity and social inclusion (GESI) considerations. -
Baseline Data Collection and Analysis
NECSA-K suggests using a mix of data collection techniques, including surveys, interviews, and focus group discussions, to gather high-quality data. It also recommends incorporating geospatial analysis (GIS) for environmental mapping and impact visualization. -
Climate Change Vulnerability and Risk Assessment
The ESIA should include a climate risk and adaptation strategy that identifies specific mitigation measures for extreme weather events such as floods and droughts. NECSA-K stresses the need to limit adaptation strategies to nature-based solutions. -
Occupational Health and Safety (OHS)
The memorandum calls for aligning national and international environmental, health, safety, and social standards, with specific corrective measures for each aspect of the project. This would ensure that any OHS risks are adequately mitigated. -
Development of an Environmental and Social Management Plan (ESMP)
The ESMP should include a detailed community health, safety, and security plan to address potential risks to local communities during construction. Additionally, NECSA-K recommends the inclusion of a livelihood restoration plan for populations affected by land acquisition and construction activities.Other suggested plans within the ESMP include a biodiversity action plan, soil and water management procedures, and a cultural heritage management plan.
Social and Environmental Issues
NECSA-K emphasizes the need to address several key social and environmental concerns during the ESIA process:
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Land Usage and Aesthetic Impact: NECSA-K advises avoiding unnecessary landscape defacement, including tree removal, earth cuts, and borrow pits that could scar the landscape. The organization also recommends protecting wildlife, wetlands, and other ecological systems.
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Training and Capacity Building: The memorandum suggests the inclusion of training programs for local authorities and community members to ensure effective participation in project monitoring and implementation.
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Grievance Redress Mechanism (GRM): To ensure transparency and accountability, NECSA-K recommends establishing a structured process for addressing complaints and concerns raised by stakeholders throughout the project’s lifecycle.
Conclusion
NECSA-K's memorandum reflects a commitment to ensuring the proposed Naivasha-Kisumu SGR and Kisumu Port projects adhere to the highest environmental and social standards. By incorporating these recommendations, Kenya Railways Corporation can promote sustainable infrastructure development while safeguarding the environment and ensuring community well-being. NECSA-K remains ready to engage further in the process and ensure these critical recommendations are implemented.