SUBMISSION OF COMMENTS FOR THE ESIA STUDY FOR THE LAMU-GARISSA ROAD SECTION OF THE LAMU PORT SOUTHERN SUDAN-ETHIOPIA TRANSPORT (LAPSSET) PROJECT

The document critiques the ESIA for the 250km Lamu-Garissa road, highlighting risks to the critically endangered Hirola antelope and the Tana River ecosystem. It argues that the preferred route (Alternative I-1) lacks species-specific wildlife crossing data and fails to allocate budget for wildlife protection in its management plan. Additionally, the authors identify failures in stormwater management planning, a lack of impact analysis for the extraction of approximately 1.375 million cubic meters of construction materials, and procedural violations of Kenyan law regarding public participation and gazette notices.

• The preferred route, Alternative I-1, poses significant risks to wildlife as it runs parallel to the National Arawale Wildlife reserve for 40km, which is a critical habitat for the IUCN red list species Hirola (Beatragus hunteri).
• The ESIA fails to provide species-specific data or allocated funding for wildlife protection; the Proposed Environmental and Social Management Plan (ESMP) does not mention 'wildlife' or the costs for proposed animal overpasses and fences.
• The ESIA lacks adequate hydrological analysis and mitigation details for flood risks and water pollution, particularly concerning the Tana River, which is the only permanent natural water source for Garissa town.
• The document identifies a total absence of impact assessments regarding the extraction of construction materials, estimating that the project may require up to 1.375 million cubic meters of aggregate sourced from 18 potential gravel sites.
• The project's claim that the new road will reduce CO2 emissions by decongesting the Mombasa to Uganda Northern Corridor is presented without sufficient explanation or evidence.
• The project proponent failed to comply with Kenyan environmental laws (EMCA and EIA Regulations) by failing to issue a mandatory Gazette notice and only advertising the invitation for public comments for one week instead of two.
• Public consultations were deemed inadequate due to a significant time lag, with some consultations occurring over two years before the filing of the EIA Study in April 2016.

APA

Natural Justice (2016). SUBMISSION OF COMMENTS FOR THE ESIA STUDY FOR THE LAMU-GARISSA ROAD SECTION OF THE LAMU PORT SOUTHERN SUDAN-ETHIOPIA TRANSPORT (LAPSSET) PROJECT. https://naturaljustice.org/wp-content/uploads/2021/02/Letter_NEMA_Lamu-Garissa-Road_EIAcomments_2016.11.13.docx.pdf

Chicago

Natural Justice. SUBMISSION OF COMMENTS FOR THE ESIA STUDY FOR THE LAMU-GARISSA ROAD SECTION OF THE LAMU PORT SOUTHERN SUDAN-ETHIOPIA TRANSPORT (LAPSSET) PROJECT. 2016. https://naturaljustice.org/wp-content/uploads/2021/02/Letter_NEMA_Lamu-Garissa-Road_EIAcomments_2016.11.13.docx.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=SUBMISSION OF COMMENTS FOR THE ESIA STUDY FOR THE LAMU-GARISSA ROAD SECTION OF THE LAMU PORT SOUTHERN SUDAN-ETHIOPIA TRANSPORT (LAPSSET) PROJECT |date=13 November 2016 |url=https://naturaljustice.org/wp-content/uploads/2021/02/Letter_NEMA_Lamu-Garissa-Road_EIAcomments_2016.11.13.docx.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2016submission, author = {{Natural Justice}}, title = {{SUBMISSION OF COMMENTS FOR THE ESIA STUDY FOR THE LAMU-GARISSA ROAD SECTION OF THE LAMU PORT SOUTHERN SUDAN-ETHIOPIA TRANSPORT (LAPSSET) PROJECT}}, publisher = {Natural Justice}, year = {2016}, month = nov, url = {https://naturaljustice.org/wp-content/uploads/2021/02/Letter_NEMA_Lamu-Garissa-Road_EIAcomments_2016.11.13.docx.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }