The East African Wild Life Society (EAWLS) participated in the review of the Environmental and Social Impact Assessment (ESIA) report of the proposed expansion of Ndaragwa Township.
Pursuant to registration 21 Environmental Management and Coordination (Impact Assessment and Audit ) Regulations 2003, the National Environment Management Authority (NEMA) had received the Environment Impact Assessment Study for this proposed expansion and was thus seeking comments from the public before issuing a license.
The proponent of the expansion of Ndaragwa Township, Honourable Jeremiah N. Kioni, is proposing to hive 300 acres off the Aberdare (Ndaragwa Block) forest to allow expansion of Ndaragwa Township in Ndaragwa Sub-County Nyandarua County.
In response, the East African Wild Life Society brought together stakeholders in the forest sector through the Kenya Forests Working Group (KFWG) for a virtual meeting on 30th June 2020 to review the Environmental and Social Impact Assessment (ESIA) report with the following observations:
- No specialist(s) on plants and animals was involved in the team conducting the Environmental and Social Impact Assessment (ESIA), hence the findings on the impacts of the project on biodiversity cannot be depended upon.
- The proposed greening of all the streets, parking areas and other infrastructure of the town using indigenous tree species found in the Aberdare Forest (Ndaragwa Block), in order to attract birds and other wildlife including monkeys back to the town fails to take into account that monkeys have the potential to become a menace in the town.
- Proof of public participation including signed participant lists that should be annexed to the report are missing. Photos do not qualify participation. Concerns about whether the participants were clearly informed of the impact of the decision have been raised.
- Stakeholder participation reports on the Environmental and Social Impact Assessment (ESIA) report are missing. These reports inform how stakeholder participation is conducted and indicates whether the relevant lead agency; Kenya Forest Service (KFS) was adequately consulted. It is also not clear whether other relevant lead agencies including the Kenya Water Towers Agency (KWTA), the Water Resources Authority (WRA) and the Kenya Wildlife Service (KWS) were consulted.
- Considering the nature of the project, the level of authorizing officers should rank from the Ecosystem Conservator (EC) upwards. What appears in the report are the individual comments of a forest officer and a letter from the Director of Forests of the now defunct Department of forests of Nyandarua County. Additionally, comments from FCC (Forest Conservation Committee) should have been sought that would then have made recommendations to the Kenya Forest Service (KFS) board.
- The proponent of the expansion of Ndaragwa Township into Aberdare forest has not explicitly cover the impacts of cutting down the forest on the environment. For instance, as much as the proponent admits that variation of the boundary as proposed will significantly negatively affect all the three rivers (Mbombo, Pesi and the seasonal stream) the report does not go to further explain the ripple effect of this impact, say, to downstream users like the communities in Samburu County who will undoubtedly suffer water supply shortages.
- The proponent of the expansion of Ndaragwa Township into Aberdare forest has not considered total economic valuation of the forest and the subsequent economic loss of hiving off the forest. Forests provide direct and indirect benefits that should be quantified during conversion.
- The proponent has not explored alternatives/options to hiving off forest land. For example, there is a lot of private land that is available yet this land is not clearly shown on the map. The map only shows forest blocks.
- It has been determined and confirmed from the Ndung’u report that the land intended for the expansion of the town was illegally acquired.
- Expansion of the township would cause a lot of pressure on the adjacent forest ecosystem and many resources including but not limited to, fuel wood and water. For instance, the expansion will mean more people coming to settle-in hence increased demand for fuel wood and water.
- The ESIA report keeps referring to documents in the appendices yet they are not attached to the report hence difficult for reviewers to verify/make proper references.
- Hiving 162.52 acres of forest land in Nyandarua County will set a bad precedent for other counties who are likely to demand more forest land. This in contradiction to the government’s efforts, through the Ministry of Environment and Forestry, to recover areas of Mau and Ngong Road Forest.
With the above observations, the stakeholders concluded that conversion of the forest to a township will have un-repairable damage to the environment and lives of the people in the long run. They consequently opposed the conversion and urged NEMA NOT to approve the ESIA report. This position was stated in a Memorandum to NEMA which will be followed by lobbying the Kenya Forest Service (KFS) not to allow excision of the forest for the expansion of Ndaragwa Township.