We have just submitted our comments to NEMA on the ESIA 1215 – Proposed realignment of Single Gauge Railway through Nairobi National Park. The following are our summary comments:
REF: GAZETTE NOTICE NO. 3921 THE ENVIRONMENTAL MANAGEMENT AND CO-ORDINATION ACT (No. 8 of 1999) THE NATIONAL ENVIRONMENT MANAGEMENT AUTHORITY ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE PROPOSED REALIGNMENT OF THE STANDARD GAUGE RAILWAY (SGR) WITHIN NAIROBI NATIONAL PARK, NAIROBI COUNTY.
INVITATION OF PUBLIC COMMENTS
The citizens of Kenya pride themselves on having one of the most unique destinations, a capital city with a National Park, the one and only Nairobi National Park. Every year, millions of visitors flock to Kenya and the majority of them make a pit stop at the Nairobi National Park bringing in much needed tourism dollars into our economy. Today, the future of this Park is being called into question as infrastructure development is pressurizing the park – whether it be the Southern bypass or the Standard Gauge Railway.
As was specifically pointed out in the “Report of the Task Force on Wildlife Security 2014” (pg 82)
“ Space for wildlife is increasingly diminishing due to land conversion, land subdivisions, loss of wildlife habitats.”
The proposed realignment of SGR through NNP would take up more than 215 acres of protected area land, this is 10 times the amount that was initially proposed. In this context, and the ever-increasing pressure on Nairobi National Park, we believe that if the SGR is allowed to be realigned into Nairobi National Park (NNP), as per ESIA – 1215, it would greatly impact the wildlife within NNP and thereby also affect the economy of Kenya.
Furthermore, we find that the ESIA submitted by LIMCOM AFRICONSULTS on behalf of the Kenya Railway Corporate (KRC) inadequately addresses the negative environmental impact of heavy construction within a pristine area of the NNP, includes glaring omissions, and has a flawed cost comparison analysis with no value given to the protected area land or inclusion of funds required to buy land as per the mitigation measure proffered. Moreover, it appears after independent study of the stakeholders who were interviewed, the ESIA consultations excluded some of the key stakeholders during the process, which would render it null and void under the EMCA 1999 act.
While we do agree that the need to upgrade our railway network is increasingly paramount, the previous plans that did not include hiving off 87 hectares or 215 acres of NNP land clearly indicates that there are options available that do not involve destroying Kenya’s heritage and pride. Accordingly, we strongly object to the proposed realignment of SGR into Nairobi National Park and respectfully request that NEMA reject ESIA-1215.
[To read our detailed analysis – please click KUAPO Submission_ESIA 1215]