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This document consists of formal submissions by Natural Justice to the Kenyan Ministry of Environment and Forestry regarding the Draft Forest Policy 2020. The submissions argue for a shift away from 'fortress conservation' and the current Community Forest Association (CFA) model toward a human-rights-based approach that recognizes the ancestral rights and conservation roles of indigenous and local communities.

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  • Natural Justice proposes that the policy explicitly acknowledge the vital role of forest communities in conservation, citing their sustainable cultural practices and ancestral attachments. They reference the African Court on Human and People’s Rights' judgement on the Ogiek Case to support the claim that indigenous people are critical to safeguarding local ecosystems.
  • The submissions argue that the draft policy unfairly portrays forest-dwelling and neighboring communities as the primary cause of forest degradation. Natural Justice asserts that the real drivers of biodiversity loss are unsustainable development projects by government agencies and Multinational Corporations (MNCs), specifically citing the Nairobi Expressway Project, the Standard Gauge Railway (SGR), and the Lamu Port South-Sudan Ethiopian Transport Corridor (LAPSSET) Project.
  • The document highlights specific instances of forest loss attributed to state actions or oversight, including the destruction of mangrove forests in Malindi due to salt farms and the cutting of 1,500 acres of indigenous trees in Menengai Forest, Nakuru County, by the Kenya Forest Service (KFS) to be replaced by eucalyptus.
  • Natural Justice criticizes the Kenya Forest Service (KFS) for conflicts of interest and corruption, alleging that KFS officials have been involved in systemic forest land grabs and logging. They cite the shrinkage of Ngong Forest from 7,231.6 acres in 1978 to 1,330.3 acres as an example of excisions involving KFS top officials and political leaders.
  • The submissions call for a reform of the participatory model, arguing that the Community Forest Association (CFA) and PELIS models are inadequate for indigenous forests. They advocate for the recognition of traditional governance systems and the application of the Community Land Act 2016 to allow indigenous communities to protect their territories.
  • Natural Justice recommends that financial resources for forest management, including those from market-based mechanisms like REDD+ and the Green Climate Fund, should trickle down to the community level. They suggest implementing transparency, accountability, and grievance mechanisms to ensure funding reaches those performing the actual conservation work.
  • The document proposes the inclusion of SDG 16 to promote peaceful, inclusive societies and access to justice, and suggests that all national values and principles of governance from Article 10 of the Constitution of Kenya be integrated into the policy's guiding principles.

Cite the original document

APA
Natural Justice (2020). Submissions on the Draft Forest Policy 2020. https://naturaljustice.org/wp-content/uploads/2020/07/NJ_Comments-on-the-Forest-Policy-2020_3-July-2020-2.pdf
Chicago
Natural Justice. Submissions on the Draft Forest Policy 2020. 2020. https://naturaljustice.org/wp-content/uploads/2020/07/NJ_Comments-on-the-Forest-Policy-2020_3-July-2020-2.pdf.
Wikipedia
{{cite press release |author=Natural Justice |title=Submissions on the Draft Forest Policy 2020 |date=17 July 2020 |url=https://naturaljustice.org/wp-content/uploads/2020/07/NJ_Comments-on-the-Forest-Policy-2020_3-July-2020-2.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{naturaljustice2020submissions, author = {{Natural Justice}}, title = {{Submissions on the Draft Forest Policy 2020}}, publisher = {Natural Justice}, year = {2020}, month = jul, url = {https://naturaljustice.org/wp-content/uploads/2020/07/NJ_Comments-on-the-Forest-Policy-2020_3-July-2020-2.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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