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COMMENTS ON THE DRAFT NATIONAL ENERGY POLICY 2025
Natural Justice critiques the draft National Energy Policy (NEP) 2025 for Kenya, highlighting a contradiction between its clean energy goals and its proposal to continue oil, coal, and nuclear development. The organization argues that these fossil-fuel and nuclear pathways risk creating stranded assets and undermine climate commitments. Key recommendations include the adoption of a dedicated Just Energy Transition chapter, the mandatory use of Community Development Agreements (CDAs), and the alignment of land acquisition practices with World Bank standards. Natural Justice specifically urges the removal of nuclear energy and liquefied natural gas (LNG) from the policy in favor of geothermal, solar, and wind alternatives.
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Document type: Statement
Scaling climate-smart solutions for hardest-to-reach MSMEs and farmers in Kenya (CST Facility) Kenya
The Green Climate Fund (GCF) and KCB Bank Kenya Limited propose a 10-year, USD 96.9 million blended finance programme to increase climate resilience and reduce GHG emissions in Kenya. The programme targets 'hardest-to-reach' MSMEs and farmers, particularly in Arid and Semi-Arid Lands (ASALs), through a tiered vulnerability cluster framework. Key interventions include a USD 65 million CST facility consisting of concessional loans and a USD 20.3 million GCF guarantee to de-risk lending. The project aims to reduce 3.93 million tCO2e and reach 935,692 beneficiaries, with a strong focus on women-led enterprises and the integration of digital lending and climate risk assessment tools.
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Document type: Report
Safeguarding Lives and Livelihoods in Kenya
The document details a pilot flood insurance initiative in Kenya designed to provide financial resilience to vulnerable populations in flood-prone areas. Following a feasibility study in Tana River, Kilifi, and Kisumu counties, Britam Insurance Kenya and FSD Africa launched a product that provided payouts to 300 families in Tana River County during the October–December 2023 floods. The programme specifically targeted marginalized groups, with 75% of insured households headed by women, youth, or persons with disabilities. The initiative utilized catalytic funding from FSD Africa and premium subsidies from Oxfam Kenya, with Swiss Re covering 80% of claims, establishing a model for scaling climate adaptation and disaster response in other Kenyan regions.
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Document type: Case study
The Unwavering Faith of Bora Imani: Lessons from Environmental Injustices
The document details how quarrying by H-Young for the Malindi-Lamu road project in Kilifi County, Kenya, exacerbated water scarcity and health risks for the Bora Imani community, despite promises of poverty alleviation. While interventions by Natural Justice led to temporary remedies from NEMA and the Public Health Office, the company's eventual decommissioning of the site in February 2023 left the community struggling with water scarcity. The case emphasizes the need for sustainable environmental remedies, robust decommissioning plans, and climate-sensitive Environmental Impact Assessments.
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Document type: Case study
Water access in Kenya: institutions are failing to act
The statement highlights a gap between Kenya's robust legal framework—including the Constitution and the 2016 Water Act—and the reality of water pollution caused by industrial activities. It cites specific examples of contamination from battery recycling and the salt industry, and warns against the water-related risks associated with oil and gas production, calling for stronger regulatory oversight and corporate accountability.
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Document type: Statement
Lockdown in Kilifi County Kenya: What lies on the other side?
The document details how Kurawa Industries Limited illegally expanded its salt pans in Magarini Sub County, Kilifi, causing saltwater seepage that killed the coconut crops of the Mwangi family. Despite efforts by Natural Justice to secure accountability through Access to Information requests to NEMA and inquiries with the Department of Physical Planning, the company operated without the required permits. The case highlights how COVID-19 lockdowns in Kilifi County have further hindered the agricultural assessment needed for compensation and increased the family's vulnerability by restricting access to water.
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Document type: Case study
SUBMISSIONS ON THE KILIFI COUNTY ENVIRONMENT (REGULATION AND CONTROL) (AIR QUALITY REGULATIONS) 2018
Natural Justice submitted a set of recommendations to the County Government of Kilifi to improve the 2018 draft Air Quality Regulations. The organization argues for the inclusion of more stringent penalties, the removal of exemptions for contaminant discharge, and the requirement that the County Director of Environment (representing NEMA) be involved in notifications and monitoring to ensure transparency and compliance with national laws and the Constitution of Kenya.
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Document type: Statement
The race to the bottom: we need fundamental change
The author describes a series of visits to mining and development sites in South Africa and Kenya, highlighting environmental destruction and human rights violations. The text criticizes the South African government's support for the mining industry and the New Development Bank's funding of coal-fired power plants, while warning against the dangers of geoengineering funded by carbon emitters.
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Document type: Statement
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.
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Document type: Statement
SMALLHOLDER FORESTRY VEHICLE INSTRUMENT ANALYSIS
The Smallholder Forestry Vehicle is a proposed financial instrument designed to enable forestry companies in Africa to access long-term, low-cost finance by aggregating smallholder tree production contracts into a Special Purpose Vehicle (SPV). By separating the high-risk establishment and harvest phases from the lower-risk growth phase, the vehicle aims to attract institutional investors, including pension funds and impact investors. A proof-of-concept facility targeting US$ 35 million in coastal Kenya is proposed to demonstrate risk-adjusted returns and climate resilience benefits, such as land restoration and diversified income for farmers. The analysis suggests that the instrument can leverage significant private capital and be replicated across other East African nations to meet land restoration targets.
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Document type: Report
EIA Study for proposed Salt Works
The minutes detail a public hearing where Al-Sherman Limited and an EIA expert presented plans for a proposed salt works in Kilifi County. While some residents supported the project for potential employment, significant opposition emerged regarding unresolved squatter issues on the project land, with many demanding a written agreement and National Lands Commission (NLC) resolution before work begins. Environmental concerns were raised regarding vegetation clearing, mangrove protection, water well contamination, and the impact of salt brine on marine life and local infrastructure.
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Document type: Report
RAISING RISK AWARENESS: USING CLIMATE SCIENCE FOR DISASTER RISK MANAGEMENT
The document examines how climate science, specifically attribution science, can be used to link extreme weather events to climate change and inform disaster risk management. It highlights a case study of the 2016/2017 drought in Kenya, noting that while human-induced climate change signals were not strong for rainfall, hotter temperatures influenced by climate change and La Nina patterns contributed to the event. The brief recommends increased investment in national and subnational capacities for climate services, better inter-agency coordination, and the alignment of early warning systems with forecast-based early action.
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Document type: Policy brief
The drought in Kenya, 2016–2017
The 2016–2017 drought in Kenya, declared a national emergency in February 2017, was primarily driven by sea surface temperature patterns, specifically La Niña. While attribution analysis found no strong climate change signal in rainfall trends, it concluded that temperatures during the drought were hotter than they would have been without human-induced climate change. The drought severely impacted 23 counties, leaving up to 4 million people in need of food aid by April 2017, though it was less extreme than the 2010–2011 event.
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Document type: Research paper
BRITAM PAYS 300 TANA RIVER FAMILIES KSHS.15 MILLION FLOOD INSURANCE: THE FIRST EVER IN KENYA
Britam Insurance Kenya, with support from FSD Africa, developed and piloted a flood insurance product in Tana River County to mitigate climate risks for vulnerable households. Following heavy rains between October and December 2023, 300 families received total payouts of Kshs. 47,000 each, totaling Kshs. 15 million. The pilot demonstrated a demand for such products, with over 70% of surveyed households in flood-prone areas expressing willingness to invest in insurance. Britam is now scaling the project in partnership with the Tana River County Government to reach 20,000 families and is exploring a separate proof of concept for urban flood risks in Kisumu.
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Document type: Case study
Source to Sea: Enhancing blue carbon ecosystems and community resilience in Kenya
The project targets Kwale, Kilifi, Tana River, and Lamu counties to combat impacts from drought, storms, and coastal erosion. It proposes a 'Source-to-Sea' framework that links upstream agricultural management with downstream coastal ecosystem restoration. Key interventions include restoring mangroves, coral reefs, and seagrasses, implementing climate-resilient farming to reduce riverbank erosion and sedimentation, and establishing sustainable finance mechanisms like Payment for Ecosystem Services (PES) and blue carbon markets. The project aims to benefit approximately 323,100 direct beneficiaries, focusing on vulnerable fisherfolk and small-scale farmers, while addressing social issues such as gender-based violence and sex trafficking linked to economic desperation.
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Document type: Report
A HANDBOOK FOR ENVIRONMENTAL AND LAND RIGHTS DEFENDERS IN KENYA
The document serves as a legal empowerment guide for environmental and land rights defenders (ELRDs) in Kenya, detailing the constitutional and statutory protections available to them. It identifies key threats faced by defenders—such as harassment, illegal arrests, and forced evictions—and attributes these to drivers like competition over scarce natural resources and power inequality. The guide outlines how to lodge complaints with national bodies including the Commission on Administrative Justice (CAJ), the Independent Policing Oversight Authority (IPOA), and the Kenya National Commission on Human Rights (KNCHR). It also lists various international and regional civil society organisations that provide emergency funding and legal support to defenders.
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Document type: Guide
krystalline-marereni-expansion-licence-1-f1315293f9edf179.pdf
This NEMA license outlines the environmental and operational requirements for Krystalline Salt Limited's 800-hectare expansion of the Marereni salt works in Kilifi County, Kenya. Key conditions include the protection of riparian zones and wetlands, the regularization of mangrove area use via the Kenya Forest Service, and a requirement to prioritize clean energy over wood fuel for salt drying.
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Document type: Briefing
www.naturaljustice.org [email protected] Tel +254 704 864 853
A statement from Natural Justice providing comments and recommendations on the Kilifi County Solid Waste Management Bill, 2019, focusing on administrative oversight, environmental licensing, and penalty structures.
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Document type: Statement
tors-and-annexures-to-tors-ea867b519f405544.pdf
This document contains the Terms of Reference (TOR) for an Environmental Impact Assessment (EIA) study for the construction of salt works by Al-Sherman Limited in Kilifi County, Kenya. The proposed facility will use solar technology to produce salt from seawater and will occupy approximately 753.8 hectares of land.
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Document type: Briefing
What You Need to Know About the Proposed Nuclear Power Plant in Uyombo, Kilifi
The document critiques the proposed nuclear power plant in Uyombo, Kilifi, Kenya, highlighting a lack of transparency in the Strategic Environmental Assessment (SEA) and a failure to follow legal requirements for public participation. It warns of severe health and environmental risks, including radioactive waste management failures and marine ecosystem disruption. The text further notes that Kenya lacks membership in key international nuclear safety agreements and that the estimated USD 5 billion cost per plant could increase electricity tariffs for consumers. The author calls for the Parliamentary Committee on Environment and Natural Resources to halt the process and prioritise renewable energy alternatives like solar, wind, and geothermal.
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Document type: Fact sheet