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

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.

• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.

APA

Natural Justice (2018). 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. https://naturaljustice.org/wp-content/uploads/2019/11/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018-1.pdf

Chicago

Natural Justice. 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. 2018. https://naturaljustice.org/wp-content/uploads/2019/11/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018-1.pdf.

Wikipedia

{{cite press release |author=Natural Justice |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 |date=27 November 2018 |url=https://naturaljustice.org/wp-content/uploads/2019/11/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018-1.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2018submission, author = {{Natural Justice}}, 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 = {Natural Justice}, year = {2018}, month = nov, url = {https://naturaljustice.org/wp-content/uploads/2019/11/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018-1.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }