SUBMISSION OF COMMENTS FOR THE DRAFT ENVIRONMENTAL (STRATEGIC ASSESSMENT, INTEGRATED IMPACT ASSESSMENT AND AUDIT) REGULATIONS, 2017

The document outlines a series of recommendations to strengthen the draft 2017 Environmental Regulations in Kenya, focusing on expanding definitions of cumulative impacts, enhancing public participation, and ensuring more rigorous oversight of environmental audits and licenses.

• The authors argue that the draft definition of 'cumulative impacts' is too narrow because it focuses on minor incremental processes and ignores impacts resulting from 'successive and/or combined impacts' as well as social aspects.
• The submission identifies significant gaps in public participation, noting that the 14-day notification period for project reports is insufficient and that the draft regulations lack clear directions on how notifications should be delivered to affected parties.
• The document recommends that public hearings be made mandatory rather than optional, particularly for high-investment projects such as mining, power, and port construction, to serve as a 'social audit' for citizens with literacy or language barriers.
• The authors propose that the National Environment Management Authority (NEMA) should not have broad discretion to modify license terms without public participation, suggesting instead a threshold for when a fresh EIA study is required for variances.
• The submission calls for the removal of 'self-audits' due to the high risk of bias, arguing that all environmental audits must be conducted by independent, qualified, and authorized auditors.
• The document suggests implementing 'tiering' for Strategic Environmental Assessments (SEA) and Integrated Environmental Impact Assessments (IEIA), ensuring that broader program-level SEAs are completed before site-specific IEIAs.

APA

Natural Justice (2017). SUBMISSION OF COMMENTS FOR THE DRAFT ENVIRONMENTAL (STRATEGIC ASSESSMENT, INTEGRATED IMPACT ASSESSMENT AND AUDIT) REGULATIONS, 2017. https://naturaljustice.org/wp-content/uploads/2018/05/Submission-Comments-Draft-Environmental-Regulations-2017.pdf

Chicago

Natural Justice. SUBMISSION OF COMMENTS FOR THE DRAFT ENVIRONMENTAL (STRATEGIC ASSESSMENT, INTEGRATED IMPACT ASSESSMENT AND AUDIT) REGULATIONS, 2017. 2017. https://naturaljustice.org/wp-content/uploads/2018/05/Submission-Comments-Draft-Environmental-Regulations-2017.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=SUBMISSION OF COMMENTS FOR THE DRAFT ENVIRONMENTAL (STRATEGIC ASSESSMENT, INTEGRATED IMPACT ASSESSMENT AND AUDIT) REGULATIONS, 2017 |date=25 May 2017 |url=https://naturaljustice.org/wp-content/uploads/2018/05/Submission-Comments-Draft-Environmental-Regulations-2017.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2017submission, author = {{Natural Justice}}, title = {{SUBMISSION OF COMMENTS FOR THE DRAFT ENVIRONMENTAL (STRATEGIC ASSESSMENT, INTEGRATED IMPACT ASSESSMENT AND AUDIT) REGULATIONS, 2017}}, publisher = {Natural Justice}, year = {2017}, month = may, url = {https://naturaljustice.org/wp-content/uploads/2018/05/Submission-Comments-Draft-Environmental-Regulations-2017.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }