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 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.

• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.
• 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.

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/2021/01/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018.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/2021/01/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018.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/2021/01/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018.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/2021/01/NEMA_Al-Sherman_Submissions-to-the-Proposed-EIA_2018.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }