{"query_echo":{"q":"","filters":{"analysis_type":["Environmental Impact Assessment Critique"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'Environmental Impact Assessment Critique' for facet 'analysis_type' is not in the controlled vocabulary."}]},"total":{"value":4,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?analysis_type=Environmental+Impact+Assessment+Critique","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"natjust-000272","url":"https://climateinsightsdirectory.org/document/natjust-000272","title":"SUBMISSION OF COMMENTS TO THE ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE PROPOSED SALT WORKS IN A SECTION OF LAND PARCEL L.R. NO. 13536, MARERENI, KILIFI COUNTY","publisher":{"name":"Natural Justice","organization":"natural-justice"},"document_type":"statement","language":"en","date_published":"2018-11-27","source_url":"https://naturaljustice.org/wp-content/uploads/2019/11/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018-1.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"Natural Justice submitted comments to the National Environmental Management Authority (NEMA) on November 27, 2018, challenging the Environmental Impact Assessment (EIA) for a proposed salt works project by Al-Sherman Limited in Kilifi County. The submission argues that the EIA fails to adequately address risks to water sources, climate change impacts, local ecosystems, and community livelihoods, while also citing failures in the public participation process.","ai_generated":true,"unit":"natjust-000272#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The EIA fails to provide sufficient detail on the protection of critical water sources, including four ephemeral streams and forty-nine underground wells. Natural Justice argues that the project's land requirements—estimated to exceed 800 hectares—leave insufficient space for these water points and community access, making the proponent's claim that they will not block streams or encroach on wells unrealistic.","ai_generated":true,"unit":"natjust-000272#insight-1","date_modified":"2026-08-17"},{"text":"The project poses a risk of salinizing fresh ground and surface water through underground leaching and the discharge of hyper-saline water. The submission notes that the EIA does not specify the 'impermeable material' proposed for brine ponds or provide quantitative projections for the increased fresh water demand during the operational phase.","ai_generated":true,"unit":"natjust-000272#insight-2","date_modified":"2026-08-17"},{"text":"The EIA completely omits an assessment of climate change impacts. Natural Justice highlights that the project will contribute to greenhouse gas emissions through the use of diesel and the clearing of vegetation on 753.8 hectares of land, which reduces carbon sequestration capacity. This is particularly critical as coastal East Africa is highly susceptible to rising temperatures and water stress.","ai_generated":true,"unit":"natjust-000272#insight-3","date_modified":"2026-08-17"},{"text":"There is a lack of adequate information regarding the project's impact on the bordering mangrove swamps and local wildlife, such as hippopotamuses, cranes, buffalo, and dik-dik. Specifically, the EIA does not detail the impact of extracting 45,000 litres of water per minute from a creek, nor does it provide a comprehensive waste disposal plan for human waste.","ai_generated":true,"unit":"natjust-000272#insight-4","date_modified":"2026-08-17"},{"text":"The project threatens local community livelihoods by potentially displacing residents and blocking access to beaches and fish landing sites. Natural Justice criticizes the proponent's plan to identify access routes only after receiving a license, and notes that the EIA does not address dust pollution from dykes, which has previously led to NEMA stop-orders for other salt companies like Krystalline Marereni.","ai_generated":true,"unit":"natjust-000272#insight-5","date_modified":"2026-08-17"},{"text":"The EIA fails to consider the cumulative environmental impact of the proposed works alongside six other existing salt works in the Magarini salt belt, including Kensalt Limited and Kurawa Industries Limited. These existing projects have a history of diverting rivers, destroying mangroves, and causing water shortages.","ai_generated":true,"unit":"natjust-000272#insight-6","date_modified":"2026-08-17"},{"text":"The public participation process was inadequate and discriminatory. The proponent failed to publish notices in the Kenya Gazette, did not engage community members living upstream or downstream (such as those in Kamale and Mto wa Mbono), and relied on questionnaires that likely excluded non-literate stakeholders.","ai_generated":true,"unit":"natjust-000272#insight-7","date_modified":"2026-08-17"}],"climate_tags":["climate change adaptation","greenhouse gas emissions","carbon sequestration","water scarcity","coastal vulnerability"],"geography_discussed":["Kamale","Mto wa Mbono"],"frame_perspective":[],"analysis_type":["Environmental Impact Assessment Critique","Policy Submission"]},{"id":"natjust-000273","url":"https://climateinsightsdirectory.org/document/natjust-000273","title":"SUBMISSION OF COMMENTS TO THE ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE PROPOSED SALT WORKS IN A SECTION OF LAND PARCEL L.R. NO. 13536, MARERENI, KILIFI COUNTY","publisher":{"name":"Natural Justice","organization":"natural-justice"},"document_type":"statement","language":"en","date_published":"2018-11-27","source_url":"https://naturaljustice.org/wp-content/uploads/2021/01/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018.pdf","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"Natural Justice submitted comments to the National Environmental Management Authority (NEMA) on November 27, 2018, challenging the Environmental Impact Assessment (EIA) for proposed salt works by Al-Sherman Limited in Marereni, Kilifi County. The organization argues that the EIA fails to adequately address risks to water sources, climate change impacts, local ecosystems, and community livelihoods, while also citing deficiencies in the public participation process.","ai_generated":true,"unit":"natjust-000273#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The EIA fails to provide sufficient information on how the project will protect critical water sources, including four ephemeral streams and forty-nine underground wells. Natural Justice argues that the project's scale—requiring over 800 hectares for components like 17 evaporators and 20 crystallisers—makes it unlikely that these water sources can be preserved, especially since the EIA does not map their exact locations.","ai_generated":true,"unit":"natjust-000273#insight-1","date_modified":"2026-08-17"},{"text":"There is a significant risk of salinization of fresh ground and surface water due to the potential discharge of hyper-saline water and underground leaching. The document notes that the EIA mentions using \"impermeable material\" in brine ponds but does not specify what that material is or how it will prevent contamination.","ai_generated":true,"unit":"natjust-000273#insight-2","date_modified":"2026-08-17"},{"text":"The project is expected to increase the demand for fresh water, which is already a scarce resource in the area. Natural Justice claims the EIA provides no qualitative or quantitative projections for this increased demand and offers inadequate mitigation measures, failing to identify alternative water sources.","ai_generated":true,"unit":"natjust-000273#insight-3","date_modified":"2026-08-17"},{"text":"The EIA completely omits an assessment of climate change impacts. Natural Justice highlights that the project will contribute to greenhouse gas emissions through the use of diesel for machinery and the clearing of vegetation on 753.8 hectares of land, which removes carbon sinks.","ai_generated":true,"unit":"natjust-000273#insight-4","date_modified":"2026-08-17"},{"text":"The project's proximity to mangrove swamps and wetlands is not sufficiently detailed, posing a risk to species such as shrimps, crabs, hippopotamus, and cranes. The document notes a \"fatal flaw\" in the EIA's failure to describe the impact of extracting 45,000 litres of water per minute from a creek.","ai_generated":true,"unit":"natjust-000273#insight-5","date_modified":"2026-08-17"},{"text":"The project may negatively impact the local community through the displacement of residents, blockage of beach access routes, and dust pollution. Natural Justice points out that the proponent intends to document access routes only after receiving a license, which they deem inadequate.","ai_generated":true,"unit":"natjust-000273#insight-6","date_modified":"2026-08-17"},{"text":"The EIA fails to consider the cumulative environmental impact of the proposed works alongside six other existing salt works in the Magarini salt belt, such as Krystalline Salt Limited and KenSalt Limited, which have histories of river diversion and mangrove destruction.","ai_generated":true,"unit":"natjust-000273#insight-7","date_modified":"2026-08-17"},{"text":"The public participation process was allegedly inadequate and discriminatory. Natural Justice claims the proponent failed to notify the public via the Kenya Gazette, relied on questionnaires that favored literate stakeholders, and failed to engage community members living upstream and downstream of the affected streams.","ai_generated":true,"unit":"natjust-000273#insight-8","date_modified":"2026-08-17"}],"climate_tags":["climate change","greenhouse gas emissions","carbon sequestration","water scarcity","sea level rise"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["environmental impact assessment critique","community submission"]},{"id":"cer-000764","url":"https://climateinsightsdirectory.org/document/cer-000764","title":"ARCELORMITTAL SOUTH AFRICA (AMSA), VANDERBIJLPARK LAND CONTAMINATION SITE ASSESSMENT REPORT","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2018-03-01","source_url":"https://cer.org.za/wp-content/uploads/2018/03/CER-to-DEA-Chemicals-Waste-re-AMSA-Land-Contamination-Site-Assessment-Report-01.03.2017.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The CER argues that AMSA's land contamination report for its Vanderbijlpark site is deficient and non-compliant with the National Environmental Management: Waste Act (NEMWA). Key criticisms include the exclusion of the site's northern portion, inadequate sampling of boreholes, and the use of incorrect soil screening standards. Despite these flaws, the report confirms serious contamination, including a 3.02m thick coal tar pool (DNAPL) and plumes of organic chemicals migrating off-site. The CER highlights the presence of Group 1 carcinogens like arsenic, cadmium, and chromium (VI), and notes that sensitive receptors, including a vegetable garden and a lodge, are within a 1km radius. The CER demands that DEA require AMSA to urgently address these gaps and implement remediation measures to prevent further environmental and human health harm.","ai_generated":true,"unit":"cer-000764#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The AMSA report identifies significant soil contamination, with the majority of samples exceeding the Soil Screening Value 1 (SSV1) threshold for arsenic, copper, manganese, and lead, as well as exceedances for cadmium, nickel, vanadium, fluoride, nitrate, and sulphate.","ai_generated":true,"unit":"cer-000764#insight-1","date_modified":"2026-10-23"},{"text":"Groundwater analysis revealed a 3.02m thick dense non-aqueous phase liquids (DNAPL) coal tar pool in borehole T-11D, and data from 2014-2016 indicates that dissolved phase organic compounds (LNAPL) are increasing and migrating off-site.","ai_generated":true,"unit":"cer-000764#insight-2","date_modified":"2026-10-23"},{"text":"The report identifies sensitive receptors within a 1km radius, including a borehole (HCBH1) used to irrigate a small vegetable garden and another (HCBH2) located at a lodge/homestead.","ai_generated":true,"unit":"cer-000764#insight-3","date_modified":"2026-10-23"},{"text":"The CER asserts that the assessment is deficient because it excluded the northern portion of the site, which contains a waste dump, several dams, and a central effluent treatment plant.","ai_generated":true,"unit":"cer-000764#insight-4","date_modified":"2026-10-23"},{"text":"The CER criticizes the sampling methodology, noting that only 15 boreholes were analyzed for the assessment despite AMSA having a network of over 150 monitoring wells and data available since 2000.","ai_generated":true,"unit":"cer-000764#insight-5","date_modified":"2026-10-23"},{"text":"The CER argues that AMSA used incorrect standards by referencing SSV2, asserting that only the stricter SSV1 should be used because the site is adjacent to surface water and has groundwater users within 1km.","ai_generated":true,"unit":"cer-000764#insight-6","date_modified":"2026-10-23"},{"text":"The site contains highly toxic Group 1 carcinogens, including cadmium, arsenic, benzo[a]pyrene, and chromium (VI), which the CER notes can cause various cancers and organ failure.","ai_generated":true,"unit":"cer-000764#insight-7","date_modified":"2026-10-23"}],"climate_tags":["environmental justice"],"geography_discussed":["Leeuspruit","Rietspruit","Boipatong","Sebokeng","Steel Valley","Linkholm"],"frame_perspective":[],"analysis_type":["compliance review","environmental impact assessment critique"]},{"id":"cer-000352","url":"https://climateinsightsdirectory.org/document/cer-000352","title":"ADDITIONAL SUBMISSIONS REGARDING THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S KRIEL POWER STATION","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2014-01-16","source_url":"https://cer.org.za/wp-content/uploads/2014/02/Annexure-2_CER-additional-submission-on-variation-of-Kriel-AEL_16-Jan-20141.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a response to the Nkangala District Municipality opposing Eskom's application to vary the atmospheric emission licence for the Kriel Power Station. The CER argues that the variation would permit increased emissions of particulate matter (PM10) and mercury, leading to significant public health risks and economic costs, while challenging Eskom's dispersion modelling and cost calculations for abatement technology.","ai_generated":true,"unit":"cer-000352#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The CER alleges that Kriel Power Station is operating with a malfunctioning particulate matter (PM) emission control system, noting that particulate matter emissions increased from an average around 125mg/Nm3 (June-December 2011) to approximately 250mg/Nm3 between February 2012 and October 2013, with frequent peaks of 450mg/Nm3.","ai_generated":true,"unit":"cer-000352#insight-1","date_modified":"2026-08-17"},{"text":"The CER estimates that if the variation request is granted, it would allow for 14,000 tons of excess PM10 emissions over the period compared to full compliance with the 125 mg/m3 limit.","ai_generated":true,"unit":"cer-000352#insight-2","date_modified":"2026-08-17"},{"text":"The document states that installing particulate control devices at Kriel would increase the mercury removal rate from 10% to 50%, which would reduce annual mercury emissions by 900 kg; without these devices, total excess mercury emissions over a 15-month period would be 1,100 kg.","ai_generated":true,"unit":"cer-000352#insight-3","date_modified":"2026-08-17"},{"text":"The CER disputes Eskom's cost calculations for a fabric filter plant retrofit, arguing that Eskom's method double accounts for the difference between US Dollar/South African Rand exchange rates and inflation rates, thereby failing to accurately reflect costs.","ai_generated":true,"unit":"cer-000352#insight-4","date_modified":"2026-08-17"},{"text":"The CER challenges Eskom's dispersion modelling, asserting that Eskom failed to provide an atmospheric impact report to support claims that Kendal emissions do not significantly contribute to ambient particulate levels near Kriel, and that Eskom's data does not prove its contribution to ambient PM levels in Kriel Village is negligible.","ai_generated":true,"unit":"cer-000352#insight-5","date_modified":"2026-08-17"}],"climate_tags":["energy transition","air quality","particulate matter","mercury emissions","coal power plants"],"geography_discussed":["Kriel Village","Nkangala District Municipality","Mpumalanga"],"frame_perspective":[],"analysis_type":["policy objection","environmental impact assessment critique"]}]}