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Environmental and Social
YoungProfsNet
Development Practitioners
Review and evaluation of environmental impact
assessment reports for petrol station projects in Kenya
YoungProfsNet Report No. 2018.001
1 October 2018
Environmental and Social
YoungProfsNet
Development Practitioners
An international on-line cooperative learning and development platform
for young environmental and social development professionals
www.youngprofsnet.org
LinkedIn: YoungProfsNet
Facebook: YoungProfsNet
Google+: YoungProfsNet
email: mail@youngprofsnet.org
PO Box 96992
2509 JJ The Hague
(the Netherlands)
Table of contents
Summary 1
Introduction 2
Objectives of the project 3
Project team 4
Environmental Impact Assessment reports 5
Evaluation criteria 8
Review of impact assessment reports 9
Rating results 10
Comparison of impact assessment reports 14
Discussion 17
References 19
Appendix 20
1
Summary
This report describes a cooperative learning project of members of YoungProfsNet of
environmental and social development practitioners, which is an international on-line learning
platform for young professionals.
The project comprised the review and evaluation of 41 (environmental) impact assessment
reports for petrol station development projects in Kenya. The Kenyan National Environment
Management Authority (NEMA) approved these reports between July 2013 and June 2014.
The objectives of the project were to provide learning on (environmental) impact assessment
and on the (environmental) impact assessment practice in Kenya; to review and evaluate the 41
(environmental) impact assessment reports; and to establish the quality of NEMA’s review and
approval process.
The project found that the quality of the (environmental) impact assessment, as evaluated
against a series of sets of evaluation criteria, was poor. None of the reports complied with the
requirements of the Kenyan Environmental (Impact Assessment and Audit) Regulations, 2003.
The project also showed that there is extensive copying of text between impact assessment
reports.
NEMA approves poor quality, non-compliant (environmental) impact assessments of projects
and does issue environmental impact assessment licenses to project proponents regardless.
2
Introduction
YoungProfsNet of environmental and social development practitioners is an international on-
line learning platform for young professionals. The objective of the network is to provide
opportunities for mutual and cooperative learning and development and for capacity building
for environmental and social development.
Typically, the activities of the network will focus on projects that will provide learning to project
members who will be learning by doing. Project results will be made available to provide the
lessons learned also to the wider membership. Ideally, projects will be on subjects that are
relevant to a variety of members and that deal with the environmental and social development
practice. If possible, project work products will be suitable for application in the environmental
and social development practice.
This report describes the review and evaluation of 41 environmental impact assessment reports
on petrol station development projects in Kenya that the National Environment Management
Authority (NEMA) approved between July 2013 and June 2014.
3
Objectives of the project
The first objective of the project was to provide learning to members of YoungProfsNet of
environmental and social development practitioners on (environmental) impact assessment
and on the (environmental) impact assessment practice in Kenya.
The second objective was to review and evaluate a series of 41 (environmental) impact
assessment reports on petrol station development projects in Kenya. The Kenyan National
Environment Management Authority (NEMA) approved these impact assessment reports
between July 2013 and June 2014. Therefore, it was reasonable to expect that all these reports
would comply with Kenyan impact assessment law and regulations. More generally, the review
and evaluation were also carried out against a number of series of more general quality criteria
for (environmental) impact assessment reports.
The third objective was to establish the quality of NEMA’s review and approval process of
(environmental) impact assessment reports.
4
Project team
The project team consisted of 17 members of YoungProfsNet with the following geographical
distribution:
Country First name Family name
Congo (DRC) Providence Simba
Croatia Ivana Dubravec
France Sofía Mata
Italy Annalisa Gionni
Kenya Nicholas Karani
Kenya Pauline Kiamba
Kenya Sharon Nelima
Kenya Robert Ngala
Kenya Sarah Njenga
Kenya Lorna Nyaga
Kenya Tabitha Ouso
Malaysia Alya Aljafri
Netherlands Maarten Smies
Netherlands Lavinia Warnars
Pakistan Sidra Butt
Togo Ibrahim Game
Uganda Dinah Nabahweesi
It must be noted that the number of members, who have been in some way involved in the
project, was much larger (in the order of 90 people) but these did not eventually contribute
actively to the project.
5
Environmental Impact Assessment reports
In the summer of 2015 we downloaded all the (environmental) impact reports available on the
website of NEMA. The number of approved impact assessment reports was approximately 145.
We divided these reports over a number of categories as follows:
Category Number of reports
Agriculture 10
Cement plant 4
Commercial building 8
Energy 6
Housing development 15
Industrial development 16
Infrastructure 12
Nature conservation 2
Oil and gas exploration and production 5
Parks and recreation 8
Petrol station and oil products facility 51
Public building 2
Quarrying and mining 4
Sewerage 4
As can be seen the category ‘Petrol station and oil products facility’ comprised by far the largest
number of (environmental) impact assessment reports in a single category. Forty-one of these
reports covered the impact assessment of a petrol station (filling station or service station)
development project. Moreover, these 41 reports covered projects for 32 different project
developers and they had been prepared by 32 different (environmental) impact assessment
consultants. We therefore felt that this set of reports would give a broad overview of the
(environmental) impact assessment practice in Kenya. It would also be possible to compare
impact assessment reports for different projects of a single project proponent and different
reports made by the same impact assessment consultant (for the same or for different project
proponents).
Petrol station projects are relatively simple projects that non-technical people can understand
well and that can be fairly easily compared. Typically, a petrol station will consist of a number
of oil product dispensing pumps to provide petrol (gasoline), diesel or kerosene to customers.
The oil products are stored in underground storage tanks. The dispensing pumps will be
located on pumping islands and a canopy is constructed over the pumping islands.
Petrol stations may have a number of ancillary facilities, such as a shop, rest rooms and washing
and service bays.
Here is an overview of the petrol station development projects (with the NEMA web code of the
report) for the different project proponents and for the different impact assessment
consultants:
6
NEMA code Date Proponent
eia_1005 Jul-13 National Oil Corporation of Kenya Ltd
eia_1006 Jul-13 National Oil Corporation of Kenya Ltd
eia_1007 Jul-13 National Oil Corporation of Kenya Ltd
eia_1010 Jul-13 Mr Shah Vishal Nemchand
eia_1026 Jul-13 Mrs Lucy Nyokabi Mathenege
eia_1027 Dec-12 Mr Christopher Chika
eia_1030 Undated Penko Refillers Ltd
eia_1031 Aug-13 Musipe Oil Resellers Ltd
eia_1033 Jan-13 Astrol Petroleum Company Ltd
eia_1037 Sep-13 Shibuli Filling Station
eia_1038 Aug-13 Mrs Ann Nyambura Maina
eia_1039 Aug-13 Wajibu Ventures Ltd
eia_1045 Oct-13 Mr Moses Parantai Shukuru
eia_1047 Sep-13 Mr Joseph Ngotiek
eia_1053 Oct-13 Kings Petroleum Filling Station
eia_1054 Sep-13 Mr Lawrence Mwagangi Mwania
eia_1056 Oct-13 Mr Thomas Mutugi Karunji
eia_1057 Nov-13 Mr Farah Mowlid Khalif
eia_1060 Nov-13 Mahadi Oil Kenya Limited
eia_1067 2013 Gulf Energy Ltd
eia_1068 Nov-13 Gulf Energy Ltd
eia_1087 Oct-13 Mr Wambua Kinyao
eia_1091 Jan-14 Mrs Beatrice Chelangat Biegon
eia_1099 Undated Mrs Agnes Mdunge Mutuku and Mr Reuben Mutuki Munguti
eia_1103 Feb-14 National Oil Corporation of Kenya Ltd
eia_1117 Mar-14 Gulf Energy Ltd
eia_1129 Mar-14 Kings Sent Petroleum Kenya Ltd
eia_1135 Feb-14 Astrol Petroleum Company Ltd
eia_1136 Feb-14 Astrol Petroleum Company Ltd
eia_1151 Apr-14 Tesa Holdings Company Ltd
eia_1152 May-14 Mr Peter Ndungu Mucuku Munga
eia_1155 May-13 Shajanand Hardwares Ltd
eia_1158 Jun-14 National Oil Corporation of Kenya Ltd
eia_1159 Feb-14 Mr Johnson Gakuru Gachoki
eia_1161 May-14 Mr Abdi Abdirahman Muhumed
eia_1173 Jun-14 Inego Investment Company Ltd
eia_1175 Jun-14 National Oil Corporation of Kenya Ltd
No code Undated Wolfenberg International Ltd
No code Nov-13 Naivasha Health Park Ltd
7
NEMA code Date IA Consultant
eia_1005 Jul-13 Sustainability Kenya Ltd Consultants
eia_1006 Jul-13 Justin Kabuiku Miano
eia_1007 Jul-13 Sustainability Kenya Ltd Consultants
eia_1010 Jul-13 Peman Consultants
eia_1026 Jul-13 Mr Maurice O Mbgera
eia_1027 Dec-12 Dayton Consultants
eia_1030 Undated Mr Francis K Mwaura
eia_1031 Aug-13 Purified Consultants Ltd
eia_1033 Jan-13 Mr Njogu Barua
eia_1037 Sep-13 Mr Walter Naroge Nyatwang'a
eia_1038 Aug-13 Messrs Fred Moniki Omosa & James Mithanga
eia_1039 Aug-13 Messrs Fred Moniki Omosa & James Mithanga
eia_1045 Oct-13 Ecohealth Co. Ltd
eia_1047 Sep-13 Geosmart Consultants Ltd
eia_1053 Oct-13 Mr Joseph Mahindo Manyako
eia_1054 Sep-13 Mr Lawrence Mwangangi Mwania
eia_1056 Oct-13 Mr Tom Kimanzi and company
eia_1057 Nov-13 Tehilla Company Ltd
eia_1060 Nov-13 Envassess Environmental Consultants
eia_1067 2013 Petrochem Associates Ltd
eia_1068 Nov-13 Messrs Joseph Mwaniki Kiaharo and Mugambi Alex
eia_1087 Oct-13 Mrs Faith Mozes and Mr Kenneth Bii Ng’eny
eia_1091 Jan-14 Mr Wesley Langat and company
eia_1099 Undated Mr James K Njeru
eia_1103 Feb-14 Earth Services Ltd
eia_1117 Mar-14 Pestavic EHS Services
eia_1129 Mar-14 Pestavic EHS Services
eia_1135 Feb-14 Mr Njogu Barua
eia_1136 Feb-14 Mr Njogu Barua
eia_1151 Apr-14 Mr Maurice O Mbgera
eia_1152 May-14 Tehilla Company Ltd
eia_1155 May-13 Not stated
eia_1158 Jun-14 Kurrent Technologies Ltd
eia_1159 Feb-14 Mr Anthony Njogu and Mrs Jane Ngonge
eia_1161 May-14 Green Globe Foundation
eia_1173 Jun-14 Prof. Vincent Sudoi (PhD)
eia_1175 Jun-14 Grinenvironment Consultants
No code Undated Mr Ngugi Muigai
No code Nov-13 Grinenvironment Consultants
A comprehensive listing of the (environmental) impact assessment reports can be found in the
Appendix.
8
Evaluation criteria
The project team agreed on a number (of sets) of evaluation criteria.
These consisted of five general criteria:
1. readability;
2. clarity;
3. comprehensiveness;
4. appropriate use of maps, tables, figures, graphs and other illustrations;
5. readability and clarity of the non-technical summary for the general public.
In addition, we used five criteria on completeness and comprehensiveness:
1. separate assessment of construction and operation;
2. assessment of normal and abnormal (maintenance, emergency situations) operations;
3. assessment of emergency control and recovery;
4. assessment of cumulative and possible future impacts of project extension;
5. assessment of abandonment and restoration.
We applied four criteria on conformity with ISO14000:
1. availability of a regulatory register;
2. availability of an aspects register;
3. availability of an impacts register;
4. compatibility of the environmental management plan(s) with ISO14000.
Also, we used the review criteria listed in the UNEP EIA Training Resource Manual (2002) (1).
These are in Handout 9-1 (Topic 9: Review of EIA quality) pp. 375-381. They cover the
description of the project, the local environment and the baseline conditions; the identification,
analysis and assessment of impacts; the alternatives and mitigation measures; and
communication. Of the 53 criteria 37 were used, as a number of the criteria listed turned out
not to be relevant or useful for the impact assessment reports reviewed. We do not think that
including these criteria, which the reviewers mainly disregarded anyway, would have had a
great effect on the rating results.
The Environmental (Impact Assessment and Audit) Regulations, 2003 (Kenya) (2) require
information on 15 items and these formed the fifth set of evaluation criteria.
Finally, we used the South African Gauteng Province’s EIA Administrative Guideline, Guideline
for the Construction and Upgrade of Filling Stations and Associated Tank Installations (2001)
(3) as guidance with regard to the completeness and comprehensiveness of the impact
assessment reports. These address 13 items of interest, but we did not use them as formal
evaluation criteria.
9
Review of impact assessment reports
Because of the changing composition of the project team, it was not possible to have a fixed
number of reviews of each of the individual reports.
The number of reviews of each individual report varied from 1 to 6:
No. of reviews 1 2 3 4 5 6
No. of reports 4 20 12 3 1 1
During the reviews of the impact assessment reports a rating was given for each of the 66
criteria:
Rating Description
3 Satisfactory or good
2 Needs to be improved
1 Unsatisfactory
0 Not applicable; not available for review; not relevant
Average ratings for the different reviews were obtained by dividing the sum of the scores given
for the different criteria and rounding these (down) to the nearest integer value.
We believe that this rating on a three-point scale is not only simpler than other ratings that have
been applied in reviews of environmental impact assessment reports, such as the six-point scale
presented in the UNEP EIA Training Resource Manual (2002), but is also more meaningful,
realistic and practical, certainly from a regulatory point of view.
The six-point scale from the UNEP EIA Training Resource Manual provides for the following
ratings:
Rating Description
A Generally well performed, no important tasks left incomplete
B Generally satisfactory and complete, only minor omissions and inadequacies
C Just satisfactory despite omissions and inadequacies
D Parts well attempted but must, on the whole, be considered just
unsatisfactory because of omissions and/or inadequacies
E Unsatisfactory, significant omissions or inadequacies
F Very unsatisfactory, important task(s) poorly done or not attempted
N/A Not applicable, the review topic is not applicable in the context of the project
The reviewer must be a highly competent impact assessment practitioner to be able to make a
meaningful distinction between adjacent ratings.
The regulatory reviewer basically has three options for action following the review:
1. To approve the report
2. To send the report back to the project proponent for revision and resubmission
3. To reject the report as unsatisfactory.
While the ratings of the UNEP EIA Training Resource Manual can of course simply be converted
from letters to numerical values for easier processing, combination and integration, combined
and integrated scores will be more difficult to interpret for a required follow-up because of the
length of the rating scale.
10
Rating results
General criteria
The rating results for the general criteria are presented here, with the average scores rounded
down and rounded conventionally. Naturally, the rounded down scores are a more severe
rating.
It is remarkable in itself that in both presentations not a single (environmental) impact
assessment report achieved an overall score of 3 (satisfactory or good) for these very basic and
general criteria. The use of maps, tables and figures is rated very low, while digital maps and
images are or can be made easily available.
rounded down score 1 2 3 mean
general criteria
readability 0 38 3 2
clarity 3 38 0 2
comprehensiveness 11 29 1 2
use of maps, tables, figures etc. 38 3 0 1
readability of non-technical summary 19 22 0 2
overall score 17 24 0 2
rounded score 1 2 3 mean
general criteria
readability 0 10 31 3
clarity 0 26 15 2
comprehensiveness 1 28 12 2
use of maps, tables, figures etc. 28 12 1 1
readability of non-technical summary 8 31 2 2
overall score 2 39 0 2
Completeness and comprehensiveness
The rating results for the second set of criteria (on completeness and comprehensiveness) show
that subjects addressed in the Kenyan Environmental Regulations are generally rated higher
than those not specifically addressed in the Regulations. So, while some attention is given to
emergency control and recovery (which in a large number of reports is covered by the provision
to call the fire service), the more basic requirement that the impact assessment needs to cover
both normal and abnormal operations is also poorly addressed.
And while it should be relatively easy to assess the (environmental) impact of possible project
extension, because the design of petrol stations tends to be modular, this is hardly addressed
because it is not required by the Regulations.
Again, it is noted that none of the impact assessment reports reviewed merited an overall score
of 3 (satisfactory or good) as the overall rating result.
11
rounded down score 1 2 3 mean
completeness and comprehensiveness
construction and operation separately 8 23 10 2
normal and abnormal operations 33 8 0 1
emergency control and recovery assessed 31 10 0 1
possible project extension assessed 39 1 1 1
abandonment and restoration assessed 3 30 8 2
overall score 29 12 0 1
rounded score 1 2 3 mean
completeness and comprehensiveness
construction and operation separately 4 18 19 2
normal and abnormal operations 20 21 0 2
emergency control and recovery assessed 16 25 0 2
possible project extension assessed 28 12 1 1
abandonment and restoration assessed 0 26 15 2
overall score 5 36 0 2
ISO14000 conformity
ISO14000 (environmental management system standard) has been on the market since 1996.
While the Kenyan Environmental Regulations do not refer to ISO14000, it would make sense for
environmental impact assessment consultants to include the essential ISO14000 elements in the
(environmental) impact assessment reports that they prepare.
These include three registers: the regulations register, the aspects register and the impacts
register. The rating results for these criteria are pretty forgiving because none of the
(environmental) impact assessment reports actually features formal environmental regulations,
aspects and impacts registers. The reviewers clearly have considered that the regulatory
information provided and the description of environmental, social and cultural effects of the
project go some way to meet the ISO14000 requirements. At the same time, it is pointed out
that a systematic description of the environmental aspects of the projects, i.e. elements of an
organisation's activities, products, or services that have or may have an impact on the
environment, is generally lacking in the impact assessment reports.
There is little doubt that compatibility of the environmental management plans presented in the
impact assessment reports with ISO14000 would be of considerable value to the client company
(the project proponent) and to NEMA. However, not one of the environmental management
plans presented is really ISO14000 compatible.
rounded down score 1 2 3 mean
ISO14000 conformity
regulations register 24 17 0 1
aspects register 36 5 0 1
impacts register 19 22 0 2
management plan ISO14000 compatible 37 4 0 1
overall score 36 5 0 1
12
rounded score 1 2 3 mean
ISO14000 conformity
regulations register 5 32 4 2
aspects register 19 21 1 2
impacts register 4 34 3 2
management plan ISO14000 compatible 24 17 0 1
overall score 10 31 0 2
UNEP EIA Training Resource Manual (2002)
Project team members chose to use the criteria included in the UNEP EIA Training Resource
Manual as an external, comprehensive checklist for the quality of the impact assessment
reports.
Rather than giving the scores for all 37 criteria, against which the reviewers scored the reports,
we decided just to present the overall score. This is really a summary appraisal of
comprehensiveness and quality of the (environmental) impact assessment reports.
Again, it is remarkable that none of the (environmental) impact assessment reports achieved a
satisfactory overall score using the UNEP EIA Training Resource Manual review criteria.
rounded down score 1 2 3 mean
UNEP EIA Training Resource Manual
overall score (for 37 criteria) 26 15 0 1
rounded score 1 2 3 mean
UNEP EIA Training Resource Manual
overall score (for 37 criteria) 1 40 0 2
Environmental (Impact Assessment and Audit) Regulations, 2003
Arguably, the ratings given for compliance with the Environmental (Impact Assessment and
Audit) Regulations are the most important for this review and evaluation, as these demonstrate
compliance with the Kenyan Laws and Regulations on impact assessment.
The rating results show (both for the friendlier rounded scores and the more severe rounded
down scores) that NEMA should not have approved any of the (environmental) impact
assessment reports, as they all fall short of complying with the requirements of the
Environmental Regulations.
Markedly, the (environmental) impact assessment reports fail to set out the environmental,
social and cultural effects of the petrol station project satisfactorily, which is a central plank of
impact assessment.
Admittedly, for petrol stations there are no realistic alternative technologies and processes,
while project proponents were not normally in a position to offer an alternative site for the
project. So, low scores here may be considered to be reasonable.
13
The Environmental Regulations require an assessment of (occupational) health hazards and
security (for staff), but many environmental impact assessment consultants may not be
qualified to perform this task.
As will be discussed below, a proper and systematic review and appraisal of submitted
(environmental) impact assessment reports by the regulatory authority i.e. NEMA, is required.
It may be useful to use checklists, such as lists of rating criteria, for this purpose. While
participating in the review and appraisal process will be useful for internees and junior
graduate staff, experienced senior staff will be needed to direct and oversee the process.
rounded down score 1 2 3 mean
Environmental Regulations Kenya
project location 0 21 20 2
regulatory and baseline information 1 26 14 2
objectives of the project 0 22 19 2
technology, procedures and processes 4 25 12 2
materials to be used for the project 6 34 1 2
products, by-products and wastes 4 36 1 2
description of affected environment 2 34 5 2
environmental, social and cultural effects 7 33 1 2
alternative technologies and processes 37 3 0 1
alternative sites or designs for project 35 6 0 1
environmental management plan 1 40 0 2
action plan for accidents, hazards etc. 27 14 0 1
health hazards and security for staff 11 30 0 2
gaps in knowledge; uncertainties 34 7 0 1
economic and social analysis of project 28 13 0 1
overall score (for 15 criteria) 11 30 0 2
rounded score 1 2 3 mean
Environmental Regulations Kenya
project location 0 7 34 3
regulatory and baseline information 0 4 37 3
objectives of the project 0 7 34 3
technology, procedures and processes 1 20 20 2
materials to be used for the project 1 23 17 2
products, by-products and wastes 1 20 20 2
description of affected environment 0 27 14 2
environmental, social and cultural effects 2 36 3 2
alternative technologies and processes 28 13 0 1
alternative sites or designs for project 19 22 0 2
environmental management plan 1 22 18 2
action plan for accidents, hazards etc. 11 30 0 2
health hazards and security for staff 3 24 14 2
gaps in knowledge; uncertainties 23 17 1 1
economic and social analysis of project 14 27 0 2
overall score (for 15 criteria) 1 40 0 2
14
Comparison of impact assessment reports
As can be seen from the list of Environmental impact assessment reports, there are a limited
number of project proponents, which commissioned impact assessments for more than one
project. These are:
Report Proponent IA Consultant
eia_1033 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1135 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1136 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1068 Gulf Energy Ltd Messrs Joseph Mwaniki Kiaharo & Alex Mugambi
eia_1117 Gulf Energy Ltd Pestavic EHS Services
eia_1067 Gulf Energy Ltd Petrochem Associates Ltd
eia_1103 National Oil Corporation of Kenya Ltd Earth Services Ltd
eia_1175 National Oil Corporation of Kenya Ltd Grinenvironment Consultants
eia_1006 National Oil Corporation of Kenya Ltd Mr Justin Kabuiku Miano
eia_1158 National Oil Corporation of Kenya Ltd Kurrent Technologies Ltd
eia_1005 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants
eia_1007 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants
Similarly, a limited number of impact assessment consultants worked on multiple projects,
sometimes for different project proponents:
Report Proponent IA Consultant
No code Naivasha Health Park Ltd Grinenvironment Consultants
eia_1175 National Oil Corporation of Kenya Ltd Grinenvironment Consultants
eia_1038 Mrs Ann Nyambura Maina Messrs Fred Moniki Omosa & James Mithanga
eia_1039 Wajibu Ventures Ltd Messrs Fred Moniki Omosa & James Mithanga
eia_1026 Mrs Lucy Nyokabi Mathenege Mr Maurice O Mbgera
eia_1151 Tesa Holdings Company Ltd Mr Maurice O Mbgera
eia_1033 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1135 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1136 Astrol Petroleum Company Ltd Mr Njogu Barua
eia_1117 Gulf Energy Ltd Pestavic EHS Services
eia_1129 Kings Sent Petroleum Kenya Ltd Pestavic EHS Services
eia_1005 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants
eia_1007 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants
eia_1057 Mr Farah Mowlid Khalif Tehilla Company Ltd
eia_1152 Mr Peter Ndungu Mucuku Munga Tehilla Company Ltd
While we do not think it useful to compare these reports in depth, we present a number of
examples that demonstrate that there is extensive copying and pasting of text between a
number of these reports. This is partly a demonstration of the lack of business ethics and of
quality control by the impact assessment consultants and the project proponents. However, it
also shows that the review, appraisal and approval process of NEMA is failing.
15
Astrol Petroleum Company Ltd – Mr Njogu Barua
All three (environmental) impact assessment reports submitted by Astrol Petroleum Company
had been prepared by Mr Njogu Barua.
The tables of contents of the three impact assessment reports (eia_1033, eia_1135 and
eia_1136) are identical, even though the actual number of pages of the three reports are
different. In addition, the actual contents of report eia_1136 are in part very different and very
differently organised than indicated in the table of contents.
Reports eia_1033 and eia_1135 cover projects in Nairobi and in Kikuyu respectively. The site
descriptions characterise both sites as: ‘Soil cover is shallow overlaid by volcanic rocks. The
neighbouring developments are of varying sizes and topography’. In the baseline information
the descriptions of Topography and drainage, of Geology and soils, of Hydrology, of Vegetation,
of Water resources and of Energy resources are identical for both projects.
The texts of Chapter 4 Impacts and Chapter 5 Potential environmental impacts and mitigation
measures are identical for all three reports and this includes the contents of the Environmental
Management Plans presented for the three projects.
National Oil Corporation of Kenya
The National Oil Corporation of Kenya is represented in our project by six (environmental)
impact assessment reports. Of these we compared four (eia_1005, eia_1006, eia_1007 and
eia_1175). Three impact assessment consultants prepared these reports: Sustainability Kenya
Ltd Consultants (eia_1005 and eia_1007), Mr Justin Kabuiku Miano (eia_1006) and
Grinenvironment Consultants (eia_1175).
The Exective summaries for reports eia_1005, eia_1006 and eia_1007 are identical. Large parts
of the text of Chapter1 Introduction are identical for the four reports. Large parts of the text of
Chapter 2 Project description, design and construction are identical for reports eia_1005,
eia_1006 and eia_1007.
The texts of Chapter 5 Environmental impacts and mitigation, Chapter 6 Project alternatives,
Chapter 7 Environmental management and monitoring plan, Chapter 8 Public consultation,
Chapter 9 Environment, health and safety issues and Chapter 10 Conclusions and
recommendations are essentially identical in reports eia_1005, eia_1006 and eia_1007. Many of
these texts can also be found in report eia_1175, but in this report they may be placed in
differently organised chapters.
Mr Maurice O Mbgera
Mr Maurice O Mbgera prepared (environmental) impact assessment reports (reports eia_1026
and eia_1151) for petrol station development projects proposed by Mrs Lucy Nyokabi
Mathenege and by Tesa Holdings Company Ltd respectively.
The texts of Chapter 5.0 Analysis of project alternatives, Chapter 6.0 Environmental impacts and
mitigation measures, Chapter 7.0 Recommended mitigation measures, Chapter 8.0 Consultation
and public participation, Chapter 9.0 Environmental Management Plan, Chapter 10.0
Environment, health and safety (EHS) and Chapter 11.0 Recommendations and conclusion of
these two reports are essentially identical.
16
Messrs Fred Moniki Omosa and James Mithanga
Messrs Fred Moniki Omosa and James Mithanga prepared (environmental) impact assessment
reports (eia_1038 and eia_1039) for petrol station development projects proposed by Mrs Ann
Nyambura Maina and by Wajibu Ventures Ltd. While from the dates of these two reports and
their NEMA webcodes it appears that these two reports were produced side-by-side and while
there is considerable overlap of texts between the two reports, it is also amazing how poorly
these two reports appear to have been coordinated.
The chapters on the Environment and social management plan and on the Conclusion (and
recommendations) of the two reports have widely different contents.
Pestavic EHS Services
Pestavic EHS Services prepared (environmental) impact assessment reports (eia_1117 and
eia_1129) for petrol station development projects proposed by Gulf Energy Ltd and Kings Sent
Petroleum Kenya Ltd. These reports are both dated March 2014.
The Chapter Project overview and baseline information shows essentially the same texts in both
reports for many sections. The Chapters on Construction safety, Public consultation,
Description of the existing and anticipated impacts, Issues of concern and mitigation measures,
Project completion and decommissioning, Alternatives including the proposed action,
Environmental and monitoring plans and Conclusion and recommendations are essentially
identical. This includes the analysis of the public consultation and it includes mitigation
measures in relation to above-ground storage tanks (for both projects), while such tanks do not
feature in the design of any of the two projects.
17
Discussion
Rating results
Generally, the quality of the (environmental) impact assessment reports reviewed is poor as
shown by the rating results. This is for relatively simple projects, so there are two possibilities:
(1) because of the simplicity of the projects the importance of the (environmental) impact
assessment is rated low (and the quality of EIAs for more complex projects is probably better);
(2) if EIAs of these simple projects are so poor, one may expect that EIAs for more complex
projects will also be poor and that will present a much bigger problem.
NEMA approves poor quality, non-compliant (environmental) impact assessments of projects
and does issue environmental impact assessment licenses to project proponents regardless.
Comparison of impact assessment reports
Comparison of impact assessment reports shows massive duplication of text between reports
and poor business ethics and quality control by impact assessment consultants and project
proponents. (Environmental) impact assessment is obviously one of the boxes to be ‘ticked’ on
the list of required actions, not an exercise to inform project development.
NEMA’s review and approval process appears not be designed to pick this up, even though some
of the reports concerned were submitted for approval almost simultaneously, as indicated by
the NEMA code and report date.
Environmental Impact Assessment for petrol stations (EIA or checklist ?)
The results of this project beg the question whether a full (environmental) impact assessment is
the best tool to assess and approve the (environmental) impact of petrol station development
projects. A checklist with clear pass/fail criteria may be more appropriate (see also the Gauteng
EIA Administrative Guideline (3)).
Improvements of NEMA review and approval procedure
Review, appraisal and approval (or rejection) of impact assessment reports is a very important
regulatory activity, as it determines the quality of development projects that are carried out.
Review, appraisal and approval (or rejection) must be centralised (or be carried out/overseen
by members of a dedicated task force of senior graduate staff with a solid experience in and
knowledge of the EIA process and EIA reports). Checks must be built in to be able to spot poor
quality and duplication of text between reports.
Templates may be made available for regulatory, aspects and impacts registers for different
categories of projects. Templates for ISO14000 compatible management plans may be useful.
Guidance should be provided on the integration of ISO14000 elements in environmental impact
assessment work.
Learning value of the project
Project members were advised to read the ‘Overview of IOGP’s Environmental-Social-Health
Risk and Impact Management Process’ (4) as a brief and clear introduction to (environmental)
impact assessment.
18
Project members commented on the sets of review criteria to be used. Individual project
members were asked to review and rate four (environmental) impact assessment reports.
Combined scores for the different reviewers of all the reports were returned to the project
members.
Towards the completion of the project it became clear that at least one project team member
should cover the work of all the other project team members. As four EIA reports were
assigned for review and appraisal to each individual project member, the entire issue of
widespread duplication of texts would not have been picked up without the project lead having
read and rated all the 41 reports.
Projects members were able to comment on the draft project report. This report provides more
learning to project members, as it is covering all the 41 (environmental) impact assessment
reports and after publication will provide learning to all interested YoungProfsNet members.
Organisation of the project as a learning experience
Originally the project was started as an autonomous exercise carried out independently by the
project team. There was a project proposal with a number of appendices, including the
proposed evaluation criteria.
The project was relaunched twice. A large number of YoungProfsNet members (about 90)
committed to contribute but in the end only 16 members contributed in practice. For the re-
launch a more detailed project proposal and appendices were distributed and in the course of
the process early scoring results were evaluated and feedback provided to participants. A flow
chart for the completion of the project was provided.
So, generally the preparation for projects as these must not be underestimated. This may
appear to be unexpected in view of the fact that most YoungProfsNet members are university
graduates. There appears to be a fine balance between under- and over-documentation and
guidance for these projects.
For this project we used Slack (www.slack.com) to make the (environmental) impact
assessment reports and the worksheets with the appraisal criteria available to the project team
members. While this worked well, we did not make more extensive use of Slack for team
communications. Probably, it would have been easier to use an application such as Dropbox or
Google Drive to have all relevant project documents available in the cloud.
19
References
(1)
United Nations Environment Programme
Division of Technology, Industry and Economics; Economics and Trade Branch
Environmental Impact Assessment Training Resource Manual
Second edition 2002
Geneva
https://www.sprep.org/att/IRC/eCOPIES/Global/217.pdf
(2)
Republic of Kenya
Environmental (Impact Assessment and Audit) Regulations, 2003
Kenya Gazette Supplement No. 56 of 13th June 2003
2003
http://faolex.fao.org/docs/pdf/ken53040.pdf
(3)
Gauteng Provincial Government
Department of Agriculture, Conservation, Environment and Land Affairs
EIA Administrative Guideline
Guideline for the Construction and Upgrade of Filling Stations and Associated Tank Installations
March 2001
http://home.intekom.com/salbu/a_R21/FillingStationsGuidelines.html
(4)
International Association of Oil and Gas Producers
Overview of IOGP’s Environmental-Social-Health Risk and Impact Management Process
IOGP Report 529
London, November 2014
https://www.iogp.org/bookstore/product/overview-of-iogps-environmental-social-health-
risk-and-impact-management-process/
20
Appendix
List of (environmental) impact assessment reports reviewed by this project
Code Date Location
eia_1005 Jul-13 King’ong’o, Nyeri County
eia_1006 Jul-13 Kisauni, Mobassa County
eia_1007 Jul-13 Kamulu, Nairobi County
eia_1010 Jul-13 Thika-Garissa highway
eia_1026 Jul-13 Embakasi Ranching –P-6966, Nairobi County
eia_1027 Dec-12 Chianda Uyoma along Ndori-Luanda Kotieno road
eia_1030 Undated Kiambu-Githunguri Road, Kiambu County
eia_1031 Aug-13 Stanley Mathenge Road, Nakuru Town (Industrial Zone)
eia_1033 Jan-13 Eastern Bypass, Nairobi
eia_1037 Sep-13 Kakamega Mumias Highway, Shibuli
eia_1038 Aug-13 Mugaga Shopping Centre, Thika-Garissa Highway, Thika, Kiambu County
eia_1039 Aug-13 White Sisters Road, Thika, Kiambu County
eia_1045 Oct-13 Kiserian-Isinya highway
eia_1047 Sep-13 Plot L.R No. Kjd/Kaputiei North/57039 at Isinya
eia_1053 Oct-13 Jomvu Raod, Jomvu
eia_1054 Sep-13 Nairobi – Mombasa road, Kiboko, Makueni County
eia_1056 Oct-13 Embu-Kiritiri Road, Muraru shopping centre, Mbeere South County
eia_1057 Nov-13 Eldoret Jua kali road, Eldoret West District, Uasin Gishu County
eia_1060 Nov-13 Plot L.R No. 209/11827 along Mombasa Road, Nairobi County
eia_1067 2013 Nairobi – Nakuru Highway, within Limuru Municipality, Rironi
eia_1068 Nov-13 Off Kangudo Road, 600m along the Eastern By-pass towards Thika Road
eia_1087 Oct-13 Kibwezi-Kitui Road in Kalamba market Kibwezi, Makueni County
eia_1091 Jan-14 Plot No. Ker/Sil/2128 Bomet Township, Bomet County
eia_1099 Undated Garrissa highway between Kithimani market and Matuu market
eia_1103 Feb-14 Nairobi-Nakuru Highway, Gilgil, Nakuru County
eia_1117 Mar-14 Namanga-Nairobi road, Namanga, Kajiado County
eia_1129 Mar-14 Matiliku Market, Emali-Matiliku Road, Matiliku, Makueni County
eia_1135 Feb-14 Plot L.R No. 4885/124 AND 4885/125 Rironi, Kikuyu, Kiambu County
eia_1136 Feb-14 Plot L.R No. 1/168 Lenana Road, Kilimani, Nairobi County
eia_1151 Apr-14 Plot L. R. No.899, Maseki, Mutulu, Matinyani District, Kitui County
eia_1152 May-14 Eldoret-Ziwa road, Eldoret East District, Uasin Gishu County
eia_1155 May-13 Kericho-Nakuru road and Kimungu Road, Kericho, Kericho County
eia_1158 Jun-14 Mombasa-Nairobi Highway, Mtito Andei
eia_1159 Feb-14 Samson Corner-Mwea –Nairobi highway, Nyangati, Kirinyaga County
eia_1161 May-14 Pumwani Petrol Station, Plot L. R. No. 209/14652, Nairobi
eia_1173 Jun-14 Kamwasor trading centre, Keiyo south district, Elgeiyo Marakwet County
eia_1175 Jun-14 Naivas supermarket off Nakuru -Nairobi highway, Nakuru, Nakuru Cty
No code Undated Kisumu-Ahero road, Buoye
No code Nov-13 Moi South Lake Road, Karagita market, Naivasha,Nakuru County
21
NEMA Webcode: eia_1005
Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol
Station on Plot Title No. 753, King’ong’o, Nyeri County, July 2013
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Sustainability Kenya Ltd Consultants
NEMA Webcode: eia_1006
Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol
Station on Plot Title No. MN/II/12385, Kisauni, Mombasa County, July 2013
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Mr Justin Kabuiku Miano
NEMA Webcode: eia_1007
Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol
Station on Plot Title No. 11594, Kamulu, Nairobi County, July 2013
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Sustainability Kenya Ltd Consultants
NEMA Webcode: eia_1010
Environmental Impact Assessment Study Report for the Proposed Petrol Service Station on L.R
Thika Municipality Block 8/181 along the Garissa Highway, [July 2013]
Proponent: Mr Vishal Shah Nemchand
Consultant: Peman Consultants
NEMA Webcode: eia_1026
Environmental Impact Assessment Study Report for the Proposed Filling Station cum
Commercial Services, on Plot L.R. No. Embakasa Ranching, -P-6966, Nairobi County, July 2013
Proponent: Mrs Lucy Mathenge
Consultant: Mr Maurice O Mbgera
NEMA Webcode: eia_1027
Environmental Impact Assessment Project Report: Proposed Filling Station and a Hotel at
Chianda in Uyoma Along Ndori-Luanda K’otieno Road on Plot No. Siaya/Kobong/2893,
December 2012
Proponent: Mr Christopher Chika
Consultant: Dayton Consultants
NEMA Webcode: eia_1030
Environmental Impact Assessment Study Report for the Proposed Petrol Station on 0.25 acres
excised from L.R. No. Githunguri/Githunguri Township/422 along Kiambi-Githunguri Road,
Kiambu County, Not Dated
Proponent: Penko Refillers Ltd
Consultant: Mr Francis K Mwaura
NEMA Webcode: eia_1031
Environmental Impact Assessment (EIA) Project Report for the Proposed Musipe Oil Resellers
Ltd’s Oil Storage Facility and Filling Station on Plot L.R. No. Nakuru Municipality/Block 8/6 in
Industrial Zone, Nakuru, August 2013
Proponent: Musipe Oil Resellers Ltd
Consultant: Purified Consultants Ltd
22
NEMA Webcode: eia_1033
Environmental Impact Assessment Project Report on Plot L.R No. Nairobi Block 115/14 and
115/15, Eastern Bypass, Nairobi; Project: the Proposed Construction of Fuel Station, January
2013
Proponent: Astrol Petroleum Company Ltd
Consultant: Mr Njogu Barua
NEMA Webcode: eia_1037
Environmental Impact Assessment for Proposed Shibuli Filling Station Plot No. Butsotso/
Shibeye/ 5034 in Shibuli on Kakamega Mumias Highway, September 2013
Proponent: Shibuli Filling Station
Consultant: Mr Walter Naroge Nyatwang'a
NEMA Webcode: eia_1038
Environmental Impact Assessment Study Report Petrol Station Development-Muguga Shopping
Centre; Title: the Proposed Petrol Station, Restaurant, Swimming Pool and Convenience Store
on Plot LR No. Kiambu/Gatuanyaga/446 off Thika-Garissa Road, Thika West District. within
Kiambu County, August 2013
Proponent: Mrs Ann Nyambura Maina
Consultant: Messrs Fred Moniki Omosa & James Mithanga
NEMA Webcode: eia_1039
Environmental Impact Assessment Study Report Petrol Station Development-Ngoingwa
Shopping Centre; Title: the Proposed Service Station Development on Plot LR No. Thika
Municipality Block 2/404 off White Sisters Road, Thika West District. within Kiambu County,
August 2013
Proponent: Wajibu Ventures Ltd
Consultant: Messrs Fred Moniki Omosa & James Mithanga
NEMA Webcode: eia_1045
Environmental Impact Assessment Study Report for the Proposed Petrol Service Station on L.R
Nos. KJD/Kipeto/6613 & 6614 along the Kiserian – Isinya Highway, October 2013
Proponent: Mr Moses Parantai Shukuru
Consultant: Ecohealth Co. Ltd
NEMA Webcode: eia_1047
Environmental Impact Study Report for Proposed Development of a Petrol Station on L.R. No.
KJD/Kaputei North/57039, at Isinya – Kajiado County for Mr. Joseph Ngotiek, September 2013
Proponent: Mr Joseph Ngotiek
Consultant: Geosmart Consultants Ltd
NEMA Webcode: eia_1053
Environmental Impact Assessment for Proposed Kings Petroleum Petrol Station Jomvu
Mikindani Area, Mombasa County Railways Land Plot No.697, October 2013
Proponent: Kings Petroleum Filling Station
Consultant: Mr Joseph Mahindo Manyako
NEMA Webcode: eia_1054
Environmental Impact Assessment Study Report: Proposed Construction of a Filling Station on
Plot No. Makindu/Kiboko B/687 Makindu. Makueni County, September 2013
Proponent: Mr Lawrence Mwagangi Mwania
Consultant: Mr Malachi O. Okello
23
NEMA Webcode: eia_1056
Environmental Impact Assessment Study Report for Proposed Petrol Filling Station on Parcel
No. Mbeti/Gachoka/3295, Mbeere County Council, October 2013
Proponent: Mr Thomas Mutugi Karunji
Consultant: Mr Tom Kimanzi and company
NEMA Webcode: eia_1057
Environmental Impact Assessment Study Report for Proposed Development of Petroleum
Filling Station on Plot 64, Baharini,along Eldoret Jua Kali Road, Eldoret West District, Uasin
Gishu County, November 2013
Proponent: Mr Farah Mowlid Khalif
Consultant: Tehilla Company Ltd
NEMA Webcode: eia_1060
Environmental Impact Assessment (EIA) Study Report for the Proposed Development of a
Petrol Station and Commercial Building on Plot L.R No. 209/11827 along Mombasa Road,
Nairobi County, November 2013
Proponent: Mahadi Oil Kenya Ltd
Consultant: Envassess Environmental Consultants
NEMA Webcode: eia_1067
Environmental Impact Assessment Study Report: Proposed Service Station for Gulf Energy Ltd,
Rironi, Plot No. Limuru/Rironi/233, [2013]
Proponent: Gulf Energy Ltd
Consultant: Petrochem Associates Ltd
NEMA Webcode: eia_1068
Environmental Impact Assessment Study Report for the Proposed Gulf Energy Ruai Junction
Service Station on Plt L.R. No. V. 13106 & V. 13101 off Kangudo Road, 600 m along the Eastern
By-pass towards Thika Road, November 2013
Proponent: Gulf Energy Ltd
Consultant: Messrs Joseph Mwaniki Kiaharo and Mugambi Alex
NEMA Webcode: eia_1087
Environmental Impact Assessment Study Report: Proposed Filling Station Land Parcel No. 143
along Kibwezi-Kitui Road, Kalamba in Kibwezi, Makueni County, October 2013
Proponent: Mr Wambua Kinyao
Consultant: Mrs Faith Moses and Mr Kenneth Bii Ng’eny
NEMA Webcode: eia_1091
Environmental Impact Assessment Study Report for the Proposed Filling Station Project on Plot
No.KER/SIL/2128 Bomet Township, Bomet County, January 2014
Proponent: Mrs Beatrice Chelangat Biegon
Consultant: Mr Wesley Langat and company
NEMA Webcode: eia_1093
Environmental Impact Assessment Full Study Report for the Proposed Waste Oil Facility and
Petrol Station on Plot No. LR. 17/Kaliang’ombe/Jimba Adjudication Section, Kilifi County,
January 2014
Proponent: Patkey Energy Ltd
Consultant: Messrs Justin Kabuiku and George Morara
24
NEMA Webcode: eia_1099
Environmental Impact Assessment Full Study Report for the Proposed Petrol Station on Land
Registration Ndalani/Ndalani Blocks 1/1705, Not Dated
Proponent: Mrs Agnes Ndunge Mutuku and Mr Reuben Mutuku Munguti
Consultant: Mr James K Njeru
NEMA Webcode: eia_1103
Environmental Impact Assessment Study Report for the Proposed NOC Service Station along
Nairobi-Nakuru Highway, Gilgil, L.R. No. Gilgil/Gilgil Block 1/18243 (Kekopey), Nakuru County,
February 2014
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Earthcare Services Ltd
NEMA Webcode: eia_1117
Environmental Impact Assessment Full Study Report for the Proposed Construction of a Petrol
Station, on LR No 1499 Namanga, off Namanga – Nairobi Road, March 2014
Proponent: Gulf Energy Ltd
Consultant: Pestavic EHS Services
NEMA Webcode: eia_1129
Environmental Impact Assessment Full Study Report for the Proposed Construction of a Service
Station, on LR No 29C Matiliku, off Emali – Matiliku Road, March 2014
Proponent: Kings Sent Petroleum Kenya Ltd
Consultant: Pestavic EHS Services
NEMA Webcode: eia_1135
Environmental Impact Assessment Project Report on Plot L.R No. 4885/124 and 2885/125,
Rironi Kikuyu, Kiamy County; Project: the Proposed Construction of Fuel Filling Station,
February 2014
Proponent: Astrol Petroleum Company Ltd
Consultant: Mr Njogu Barua
NEMA Webcode: eia_1136
Environmental Impact Assessment Study Report; Project: the Proposed Construction of Fuel
Filling Station on Plot L.R No. 1/168 Lenana Road, Nairobi County, February 2014
Proponent: Astrol Petroleum Company Ltd
Consultant: Mr Njogu Barua
NEMA Webcode: eia_1151
Environmental Impact Assessment Study Report for the Proposed Maseki Filling Station on Plot
L.R. No.899, Kitui County, April 2014
Proponent: Tesa Holdings Company Ltd
Consultant: Mr Maurice O Mbgera
NEMA Webcode: eia_1152
Environmental Impact Assessment Study Report for Proposed Development of Petrol Service
Station on Plota Uasin Gishu /Kimumu/6594 & 6595, along Eldoret-Ziwa Road, Eldoret East
District, Uasin Gishu County, May 2014
Proponent: Mr Peter Ndungu Mucuku Munga
Consultant: Tehilla Company Ltd
25
NEMA Webcode: eia_1155
Environmental Impact Assesement Report: Proposed Petrol Station Development on Plot
L.R.No. 631/1183, Kericho Municipality, Kericho County for Shajanand Hardwares Limited, May
2013
Proponent: Shajanand Hardwares Ltd
Consultant: Not Stated
NEMA Webcode: eia_1158
Environmental and Social Impact Assessment Study of the Proposed Remodeling of a Service
Station on Plot L.R No. 11487/1 in Mtito Andei, June 2014
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Kurrent Technologies Ltd
NEMA Webcode: eia_1159
Environmental Impact Assessment Study Report for the Proposed Construction and Operation
of Fuel Service Station at LR Kabare/Nyangati/5735 at Kimbimbi Market, Nyangati Location,
Mwea Sub County, Kirinyaga County, February 2014
Proponent: Mr Johnson Gakuru Gachoki
Consultant: Mr Anthony Njogu Njurai and Mrs Jane Ngonge
NEMA Webcode: eia_1161
Environmental Impact Assessment Study Report for the Proposed Patrol Station at Pumwani,
May 2014
Proponent: Mr Abdi Abdirahman Muhumed
Consultant: Green Globe Foundation
NEMA Webcode: eia_1173
Environmental Impact Assessment Report for the Construction of Proposed Petrol Station by
Inego Investment Company Limited, Located at Kamwosor Trading Center, Keiyo South District,
June 2014
Proponent: Inego Investment Company Ltd
Consultant: Prof. Vincent Sudoi (PhD)
NEMA Webcode: eia_1175
Environmental Impact Assessment Study Report for the Proposed Petrol Station on Plot Title
L.R No. Nakuru Municipality Block 16/263, Nakuru Town, June 2014
Proponent: National Oil Corporation of Kenya Ltd
Consultant: Grinenvironment Consultants
No NEMA Webcode
Environmental Impact Assessment Study Report: Proposed Development of a Petroleum Service
Station on Eldoret Municipality Block 21 (Kingongo)/91 & 92, along Eldoret Jua Kali Road,
Eldoret West District, Uasin Gishu County, March 2014
Proponent: Ainu Shamshi Energy Ltd
Consultant: Tehilla Company Ltd
No NEMA Webcode
Full Study Report for the Proposed Petrol Station on Plot L.R No. Naivasha Plot 396/71
(Previously 396/28) on Moi South Lake Road, Naivasha Municipality of Nakuru County,
November 2013
Proponent: Naivasha Health Park Ltd
Consultant: Grinenvironment Consultants
26
No NEMA Webcode
Environmental Impact Assessment Report: the Proposed Wolfenberg International Service
Station Project at Buoye on Kisumi-Ahero road, Kisumi, Not Dated
Proponent: Wolfenberg International Ltd
Consultant: Mr Ngugi Muigai

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Review and Evaluation of EIA Reports - Kenya

  • 1. Environmental and Social YoungProfsNet Development Practitioners Review and evaluation of environmental impact assessment reports for petrol station projects in Kenya YoungProfsNet Report No. 2018.001 1 October 2018
  • 2. Environmental and Social YoungProfsNet Development Practitioners An international on-line cooperative learning and development platform for young environmental and social development professionals www.youngprofsnet.org LinkedIn: YoungProfsNet Facebook: YoungProfsNet Google+: YoungProfsNet email: mail@youngprofsnet.org PO Box 96992 2509 JJ The Hague (the Netherlands)
  • 3. Table of contents Summary 1 Introduction 2 Objectives of the project 3 Project team 4 Environmental Impact Assessment reports 5 Evaluation criteria 8 Review of impact assessment reports 9 Rating results 10 Comparison of impact assessment reports 14 Discussion 17 References 19 Appendix 20
  • 4.
  • 5. 1 Summary This report describes a cooperative learning project of members of YoungProfsNet of environmental and social development practitioners, which is an international on-line learning platform for young professionals. The project comprised the review and evaluation of 41 (environmental) impact assessment reports for petrol station development projects in Kenya. The Kenyan National Environment Management Authority (NEMA) approved these reports between July 2013 and June 2014. The objectives of the project were to provide learning on (environmental) impact assessment and on the (environmental) impact assessment practice in Kenya; to review and evaluate the 41 (environmental) impact assessment reports; and to establish the quality of NEMA’s review and approval process. The project found that the quality of the (environmental) impact assessment, as evaluated against a series of sets of evaluation criteria, was poor. None of the reports complied with the requirements of the Kenyan Environmental (Impact Assessment and Audit) Regulations, 2003. The project also showed that there is extensive copying of text between impact assessment reports. NEMA approves poor quality, non-compliant (environmental) impact assessments of projects and does issue environmental impact assessment licenses to project proponents regardless.
  • 6. 2 Introduction YoungProfsNet of environmental and social development practitioners is an international on- line learning platform for young professionals. The objective of the network is to provide opportunities for mutual and cooperative learning and development and for capacity building for environmental and social development. Typically, the activities of the network will focus on projects that will provide learning to project members who will be learning by doing. Project results will be made available to provide the lessons learned also to the wider membership. Ideally, projects will be on subjects that are relevant to a variety of members and that deal with the environmental and social development practice. If possible, project work products will be suitable for application in the environmental and social development practice. This report describes the review and evaluation of 41 environmental impact assessment reports on petrol station development projects in Kenya that the National Environment Management Authority (NEMA) approved between July 2013 and June 2014.
  • 7. 3 Objectives of the project The first objective of the project was to provide learning to members of YoungProfsNet of environmental and social development practitioners on (environmental) impact assessment and on the (environmental) impact assessment practice in Kenya. The second objective was to review and evaluate a series of 41 (environmental) impact assessment reports on petrol station development projects in Kenya. The Kenyan National Environment Management Authority (NEMA) approved these impact assessment reports between July 2013 and June 2014. Therefore, it was reasonable to expect that all these reports would comply with Kenyan impact assessment law and regulations. More generally, the review and evaluation were also carried out against a number of series of more general quality criteria for (environmental) impact assessment reports. The third objective was to establish the quality of NEMA’s review and approval process of (environmental) impact assessment reports.
  • 8. 4 Project team The project team consisted of 17 members of YoungProfsNet with the following geographical distribution: Country First name Family name Congo (DRC) Providence Simba Croatia Ivana Dubravec France Sofía Mata Italy Annalisa Gionni Kenya Nicholas Karani Kenya Pauline Kiamba Kenya Sharon Nelima Kenya Robert Ngala Kenya Sarah Njenga Kenya Lorna Nyaga Kenya Tabitha Ouso Malaysia Alya Aljafri Netherlands Maarten Smies Netherlands Lavinia Warnars Pakistan Sidra Butt Togo Ibrahim Game Uganda Dinah Nabahweesi It must be noted that the number of members, who have been in some way involved in the project, was much larger (in the order of 90 people) but these did not eventually contribute actively to the project.
  • 9. 5 Environmental Impact Assessment reports In the summer of 2015 we downloaded all the (environmental) impact reports available on the website of NEMA. The number of approved impact assessment reports was approximately 145. We divided these reports over a number of categories as follows: Category Number of reports Agriculture 10 Cement plant 4 Commercial building 8 Energy 6 Housing development 15 Industrial development 16 Infrastructure 12 Nature conservation 2 Oil and gas exploration and production 5 Parks and recreation 8 Petrol station and oil products facility 51 Public building 2 Quarrying and mining 4 Sewerage 4 As can be seen the category ‘Petrol station and oil products facility’ comprised by far the largest number of (environmental) impact assessment reports in a single category. Forty-one of these reports covered the impact assessment of a petrol station (filling station or service station) development project. Moreover, these 41 reports covered projects for 32 different project developers and they had been prepared by 32 different (environmental) impact assessment consultants. We therefore felt that this set of reports would give a broad overview of the (environmental) impact assessment practice in Kenya. It would also be possible to compare impact assessment reports for different projects of a single project proponent and different reports made by the same impact assessment consultant (for the same or for different project proponents). Petrol station projects are relatively simple projects that non-technical people can understand well and that can be fairly easily compared. Typically, a petrol station will consist of a number of oil product dispensing pumps to provide petrol (gasoline), diesel or kerosene to customers. The oil products are stored in underground storage tanks. The dispensing pumps will be located on pumping islands and a canopy is constructed over the pumping islands. Petrol stations may have a number of ancillary facilities, such as a shop, rest rooms and washing and service bays. Here is an overview of the petrol station development projects (with the NEMA web code of the report) for the different project proponents and for the different impact assessment consultants:
  • 10. 6 NEMA code Date Proponent eia_1005 Jul-13 National Oil Corporation of Kenya Ltd eia_1006 Jul-13 National Oil Corporation of Kenya Ltd eia_1007 Jul-13 National Oil Corporation of Kenya Ltd eia_1010 Jul-13 Mr Shah Vishal Nemchand eia_1026 Jul-13 Mrs Lucy Nyokabi Mathenege eia_1027 Dec-12 Mr Christopher Chika eia_1030 Undated Penko Refillers Ltd eia_1031 Aug-13 Musipe Oil Resellers Ltd eia_1033 Jan-13 Astrol Petroleum Company Ltd eia_1037 Sep-13 Shibuli Filling Station eia_1038 Aug-13 Mrs Ann Nyambura Maina eia_1039 Aug-13 Wajibu Ventures Ltd eia_1045 Oct-13 Mr Moses Parantai Shukuru eia_1047 Sep-13 Mr Joseph Ngotiek eia_1053 Oct-13 Kings Petroleum Filling Station eia_1054 Sep-13 Mr Lawrence Mwagangi Mwania eia_1056 Oct-13 Mr Thomas Mutugi Karunji eia_1057 Nov-13 Mr Farah Mowlid Khalif eia_1060 Nov-13 Mahadi Oil Kenya Limited eia_1067 2013 Gulf Energy Ltd eia_1068 Nov-13 Gulf Energy Ltd eia_1087 Oct-13 Mr Wambua Kinyao eia_1091 Jan-14 Mrs Beatrice Chelangat Biegon eia_1099 Undated Mrs Agnes Mdunge Mutuku and Mr Reuben Mutuki Munguti eia_1103 Feb-14 National Oil Corporation of Kenya Ltd eia_1117 Mar-14 Gulf Energy Ltd eia_1129 Mar-14 Kings Sent Petroleum Kenya Ltd eia_1135 Feb-14 Astrol Petroleum Company Ltd eia_1136 Feb-14 Astrol Petroleum Company Ltd eia_1151 Apr-14 Tesa Holdings Company Ltd eia_1152 May-14 Mr Peter Ndungu Mucuku Munga eia_1155 May-13 Shajanand Hardwares Ltd eia_1158 Jun-14 National Oil Corporation of Kenya Ltd eia_1159 Feb-14 Mr Johnson Gakuru Gachoki eia_1161 May-14 Mr Abdi Abdirahman Muhumed eia_1173 Jun-14 Inego Investment Company Ltd eia_1175 Jun-14 National Oil Corporation of Kenya Ltd No code Undated Wolfenberg International Ltd No code Nov-13 Naivasha Health Park Ltd
  • 11. 7 NEMA code Date IA Consultant eia_1005 Jul-13 Sustainability Kenya Ltd Consultants eia_1006 Jul-13 Justin Kabuiku Miano eia_1007 Jul-13 Sustainability Kenya Ltd Consultants eia_1010 Jul-13 Peman Consultants eia_1026 Jul-13 Mr Maurice O Mbgera eia_1027 Dec-12 Dayton Consultants eia_1030 Undated Mr Francis K Mwaura eia_1031 Aug-13 Purified Consultants Ltd eia_1033 Jan-13 Mr Njogu Barua eia_1037 Sep-13 Mr Walter Naroge Nyatwang'a eia_1038 Aug-13 Messrs Fred Moniki Omosa & James Mithanga eia_1039 Aug-13 Messrs Fred Moniki Omosa & James Mithanga eia_1045 Oct-13 Ecohealth Co. Ltd eia_1047 Sep-13 Geosmart Consultants Ltd eia_1053 Oct-13 Mr Joseph Mahindo Manyako eia_1054 Sep-13 Mr Lawrence Mwangangi Mwania eia_1056 Oct-13 Mr Tom Kimanzi and company eia_1057 Nov-13 Tehilla Company Ltd eia_1060 Nov-13 Envassess Environmental Consultants eia_1067 2013 Petrochem Associates Ltd eia_1068 Nov-13 Messrs Joseph Mwaniki Kiaharo and Mugambi Alex eia_1087 Oct-13 Mrs Faith Mozes and Mr Kenneth Bii Ng’eny eia_1091 Jan-14 Mr Wesley Langat and company eia_1099 Undated Mr James K Njeru eia_1103 Feb-14 Earth Services Ltd eia_1117 Mar-14 Pestavic EHS Services eia_1129 Mar-14 Pestavic EHS Services eia_1135 Feb-14 Mr Njogu Barua eia_1136 Feb-14 Mr Njogu Barua eia_1151 Apr-14 Mr Maurice O Mbgera eia_1152 May-14 Tehilla Company Ltd eia_1155 May-13 Not stated eia_1158 Jun-14 Kurrent Technologies Ltd eia_1159 Feb-14 Mr Anthony Njogu and Mrs Jane Ngonge eia_1161 May-14 Green Globe Foundation eia_1173 Jun-14 Prof. Vincent Sudoi (PhD) eia_1175 Jun-14 Grinenvironment Consultants No code Undated Mr Ngugi Muigai No code Nov-13 Grinenvironment Consultants A comprehensive listing of the (environmental) impact assessment reports can be found in the Appendix.
  • 12. 8 Evaluation criteria The project team agreed on a number (of sets) of evaluation criteria. These consisted of five general criteria: 1. readability; 2. clarity; 3. comprehensiveness; 4. appropriate use of maps, tables, figures, graphs and other illustrations; 5. readability and clarity of the non-technical summary for the general public. In addition, we used five criteria on completeness and comprehensiveness: 1. separate assessment of construction and operation; 2. assessment of normal and abnormal (maintenance, emergency situations) operations; 3. assessment of emergency control and recovery; 4. assessment of cumulative and possible future impacts of project extension; 5. assessment of abandonment and restoration. We applied four criteria on conformity with ISO14000: 1. availability of a regulatory register; 2. availability of an aspects register; 3. availability of an impacts register; 4. compatibility of the environmental management plan(s) with ISO14000. Also, we used the review criteria listed in the UNEP EIA Training Resource Manual (2002) (1). These are in Handout 9-1 (Topic 9: Review of EIA quality) pp. 375-381. They cover the description of the project, the local environment and the baseline conditions; the identification, analysis and assessment of impacts; the alternatives and mitigation measures; and communication. Of the 53 criteria 37 were used, as a number of the criteria listed turned out not to be relevant or useful for the impact assessment reports reviewed. We do not think that including these criteria, which the reviewers mainly disregarded anyway, would have had a great effect on the rating results. The Environmental (Impact Assessment and Audit) Regulations, 2003 (Kenya) (2) require information on 15 items and these formed the fifth set of evaluation criteria. Finally, we used the South African Gauteng Province’s EIA Administrative Guideline, Guideline for the Construction and Upgrade of Filling Stations and Associated Tank Installations (2001) (3) as guidance with regard to the completeness and comprehensiveness of the impact assessment reports. These address 13 items of interest, but we did not use them as formal evaluation criteria.
  • 13. 9 Review of impact assessment reports Because of the changing composition of the project team, it was not possible to have a fixed number of reviews of each of the individual reports. The number of reviews of each individual report varied from 1 to 6: No. of reviews 1 2 3 4 5 6 No. of reports 4 20 12 3 1 1 During the reviews of the impact assessment reports a rating was given for each of the 66 criteria: Rating Description 3 Satisfactory or good 2 Needs to be improved 1 Unsatisfactory 0 Not applicable; not available for review; not relevant Average ratings for the different reviews were obtained by dividing the sum of the scores given for the different criteria and rounding these (down) to the nearest integer value. We believe that this rating on a three-point scale is not only simpler than other ratings that have been applied in reviews of environmental impact assessment reports, such as the six-point scale presented in the UNEP EIA Training Resource Manual (2002), but is also more meaningful, realistic and practical, certainly from a regulatory point of view. The six-point scale from the UNEP EIA Training Resource Manual provides for the following ratings: Rating Description A Generally well performed, no important tasks left incomplete B Generally satisfactory and complete, only minor omissions and inadequacies C Just satisfactory despite omissions and inadequacies D Parts well attempted but must, on the whole, be considered just unsatisfactory because of omissions and/or inadequacies E Unsatisfactory, significant omissions or inadequacies F Very unsatisfactory, important task(s) poorly done or not attempted N/A Not applicable, the review topic is not applicable in the context of the project The reviewer must be a highly competent impact assessment practitioner to be able to make a meaningful distinction between adjacent ratings. The regulatory reviewer basically has three options for action following the review: 1. To approve the report 2. To send the report back to the project proponent for revision and resubmission 3. To reject the report as unsatisfactory. While the ratings of the UNEP EIA Training Resource Manual can of course simply be converted from letters to numerical values for easier processing, combination and integration, combined and integrated scores will be more difficult to interpret for a required follow-up because of the length of the rating scale.
  • 14. 10 Rating results General criteria The rating results for the general criteria are presented here, with the average scores rounded down and rounded conventionally. Naturally, the rounded down scores are a more severe rating. It is remarkable in itself that in both presentations not a single (environmental) impact assessment report achieved an overall score of 3 (satisfactory or good) for these very basic and general criteria. The use of maps, tables and figures is rated very low, while digital maps and images are or can be made easily available. rounded down score 1 2 3 mean general criteria readability 0 38 3 2 clarity 3 38 0 2 comprehensiveness 11 29 1 2 use of maps, tables, figures etc. 38 3 0 1 readability of non-technical summary 19 22 0 2 overall score 17 24 0 2 rounded score 1 2 3 mean general criteria readability 0 10 31 3 clarity 0 26 15 2 comprehensiveness 1 28 12 2 use of maps, tables, figures etc. 28 12 1 1 readability of non-technical summary 8 31 2 2 overall score 2 39 0 2 Completeness and comprehensiveness The rating results for the second set of criteria (on completeness and comprehensiveness) show that subjects addressed in the Kenyan Environmental Regulations are generally rated higher than those not specifically addressed in the Regulations. So, while some attention is given to emergency control and recovery (which in a large number of reports is covered by the provision to call the fire service), the more basic requirement that the impact assessment needs to cover both normal and abnormal operations is also poorly addressed. And while it should be relatively easy to assess the (environmental) impact of possible project extension, because the design of petrol stations tends to be modular, this is hardly addressed because it is not required by the Regulations. Again, it is noted that none of the impact assessment reports reviewed merited an overall score of 3 (satisfactory or good) as the overall rating result.
  • 15. 11 rounded down score 1 2 3 mean completeness and comprehensiveness construction and operation separately 8 23 10 2 normal and abnormal operations 33 8 0 1 emergency control and recovery assessed 31 10 0 1 possible project extension assessed 39 1 1 1 abandonment and restoration assessed 3 30 8 2 overall score 29 12 0 1 rounded score 1 2 3 mean completeness and comprehensiveness construction and operation separately 4 18 19 2 normal and abnormal operations 20 21 0 2 emergency control and recovery assessed 16 25 0 2 possible project extension assessed 28 12 1 1 abandonment and restoration assessed 0 26 15 2 overall score 5 36 0 2 ISO14000 conformity ISO14000 (environmental management system standard) has been on the market since 1996. While the Kenyan Environmental Regulations do not refer to ISO14000, it would make sense for environmental impact assessment consultants to include the essential ISO14000 elements in the (environmental) impact assessment reports that they prepare. These include three registers: the regulations register, the aspects register and the impacts register. The rating results for these criteria are pretty forgiving because none of the (environmental) impact assessment reports actually features formal environmental regulations, aspects and impacts registers. The reviewers clearly have considered that the regulatory information provided and the description of environmental, social and cultural effects of the project go some way to meet the ISO14000 requirements. At the same time, it is pointed out that a systematic description of the environmental aspects of the projects, i.e. elements of an organisation's activities, products, or services that have or may have an impact on the environment, is generally lacking in the impact assessment reports. There is little doubt that compatibility of the environmental management plans presented in the impact assessment reports with ISO14000 would be of considerable value to the client company (the project proponent) and to NEMA. However, not one of the environmental management plans presented is really ISO14000 compatible. rounded down score 1 2 3 mean ISO14000 conformity regulations register 24 17 0 1 aspects register 36 5 0 1 impacts register 19 22 0 2 management plan ISO14000 compatible 37 4 0 1 overall score 36 5 0 1
  • 16. 12 rounded score 1 2 3 mean ISO14000 conformity regulations register 5 32 4 2 aspects register 19 21 1 2 impacts register 4 34 3 2 management plan ISO14000 compatible 24 17 0 1 overall score 10 31 0 2 UNEP EIA Training Resource Manual (2002) Project team members chose to use the criteria included in the UNEP EIA Training Resource Manual as an external, comprehensive checklist for the quality of the impact assessment reports. Rather than giving the scores for all 37 criteria, against which the reviewers scored the reports, we decided just to present the overall score. This is really a summary appraisal of comprehensiveness and quality of the (environmental) impact assessment reports. Again, it is remarkable that none of the (environmental) impact assessment reports achieved a satisfactory overall score using the UNEP EIA Training Resource Manual review criteria. rounded down score 1 2 3 mean UNEP EIA Training Resource Manual overall score (for 37 criteria) 26 15 0 1 rounded score 1 2 3 mean UNEP EIA Training Resource Manual overall score (for 37 criteria) 1 40 0 2 Environmental (Impact Assessment and Audit) Regulations, 2003 Arguably, the ratings given for compliance with the Environmental (Impact Assessment and Audit) Regulations are the most important for this review and evaluation, as these demonstrate compliance with the Kenyan Laws and Regulations on impact assessment. The rating results show (both for the friendlier rounded scores and the more severe rounded down scores) that NEMA should not have approved any of the (environmental) impact assessment reports, as they all fall short of complying with the requirements of the Environmental Regulations. Markedly, the (environmental) impact assessment reports fail to set out the environmental, social and cultural effects of the petrol station project satisfactorily, which is a central plank of impact assessment. Admittedly, for petrol stations there are no realistic alternative technologies and processes, while project proponents were not normally in a position to offer an alternative site for the project. So, low scores here may be considered to be reasonable.
  • 17. 13 The Environmental Regulations require an assessment of (occupational) health hazards and security (for staff), but many environmental impact assessment consultants may not be qualified to perform this task. As will be discussed below, a proper and systematic review and appraisal of submitted (environmental) impact assessment reports by the regulatory authority i.e. NEMA, is required. It may be useful to use checklists, such as lists of rating criteria, for this purpose. While participating in the review and appraisal process will be useful for internees and junior graduate staff, experienced senior staff will be needed to direct and oversee the process. rounded down score 1 2 3 mean Environmental Regulations Kenya project location 0 21 20 2 regulatory and baseline information 1 26 14 2 objectives of the project 0 22 19 2 technology, procedures and processes 4 25 12 2 materials to be used for the project 6 34 1 2 products, by-products and wastes 4 36 1 2 description of affected environment 2 34 5 2 environmental, social and cultural effects 7 33 1 2 alternative technologies and processes 37 3 0 1 alternative sites or designs for project 35 6 0 1 environmental management plan 1 40 0 2 action plan for accidents, hazards etc. 27 14 0 1 health hazards and security for staff 11 30 0 2 gaps in knowledge; uncertainties 34 7 0 1 economic and social analysis of project 28 13 0 1 overall score (for 15 criteria) 11 30 0 2 rounded score 1 2 3 mean Environmental Regulations Kenya project location 0 7 34 3 regulatory and baseline information 0 4 37 3 objectives of the project 0 7 34 3 technology, procedures and processes 1 20 20 2 materials to be used for the project 1 23 17 2 products, by-products and wastes 1 20 20 2 description of affected environment 0 27 14 2 environmental, social and cultural effects 2 36 3 2 alternative technologies and processes 28 13 0 1 alternative sites or designs for project 19 22 0 2 environmental management plan 1 22 18 2 action plan for accidents, hazards etc. 11 30 0 2 health hazards and security for staff 3 24 14 2 gaps in knowledge; uncertainties 23 17 1 1 economic and social analysis of project 14 27 0 2 overall score (for 15 criteria) 1 40 0 2
  • 18. 14 Comparison of impact assessment reports As can be seen from the list of Environmental impact assessment reports, there are a limited number of project proponents, which commissioned impact assessments for more than one project. These are: Report Proponent IA Consultant eia_1033 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1135 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1136 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1068 Gulf Energy Ltd Messrs Joseph Mwaniki Kiaharo & Alex Mugambi eia_1117 Gulf Energy Ltd Pestavic EHS Services eia_1067 Gulf Energy Ltd Petrochem Associates Ltd eia_1103 National Oil Corporation of Kenya Ltd Earth Services Ltd eia_1175 National Oil Corporation of Kenya Ltd Grinenvironment Consultants eia_1006 National Oil Corporation of Kenya Ltd Mr Justin Kabuiku Miano eia_1158 National Oil Corporation of Kenya Ltd Kurrent Technologies Ltd eia_1005 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants eia_1007 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants Similarly, a limited number of impact assessment consultants worked on multiple projects, sometimes for different project proponents: Report Proponent IA Consultant No code Naivasha Health Park Ltd Grinenvironment Consultants eia_1175 National Oil Corporation of Kenya Ltd Grinenvironment Consultants eia_1038 Mrs Ann Nyambura Maina Messrs Fred Moniki Omosa & James Mithanga eia_1039 Wajibu Ventures Ltd Messrs Fred Moniki Omosa & James Mithanga eia_1026 Mrs Lucy Nyokabi Mathenege Mr Maurice O Mbgera eia_1151 Tesa Holdings Company Ltd Mr Maurice O Mbgera eia_1033 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1135 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1136 Astrol Petroleum Company Ltd Mr Njogu Barua eia_1117 Gulf Energy Ltd Pestavic EHS Services eia_1129 Kings Sent Petroleum Kenya Ltd Pestavic EHS Services eia_1005 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants eia_1007 National Oil Corporation of Kenya Ltd Sustainability Kenya Ltd Consultants eia_1057 Mr Farah Mowlid Khalif Tehilla Company Ltd eia_1152 Mr Peter Ndungu Mucuku Munga Tehilla Company Ltd While we do not think it useful to compare these reports in depth, we present a number of examples that demonstrate that there is extensive copying and pasting of text between a number of these reports. This is partly a demonstration of the lack of business ethics and of quality control by the impact assessment consultants and the project proponents. However, it also shows that the review, appraisal and approval process of NEMA is failing.
  • 19. 15 Astrol Petroleum Company Ltd – Mr Njogu Barua All three (environmental) impact assessment reports submitted by Astrol Petroleum Company had been prepared by Mr Njogu Barua. The tables of contents of the three impact assessment reports (eia_1033, eia_1135 and eia_1136) are identical, even though the actual number of pages of the three reports are different. In addition, the actual contents of report eia_1136 are in part very different and very differently organised than indicated in the table of contents. Reports eia_1033 and eia_1135 cover projects in Nairobi and in Kikuyu respectively. The site descriptions characterise both sites as: ‘Soil cover is shallow overlaid by volcanic rocks. The neighbouring developments are of varying sizes and topography’. In the baseline information the descriptions of Topography and drainage, of Geology and soils, of Hydrology, of Vegetation, of Water resources and of Energy resources are identical for both projects. The texts of Chapter 4 Impacts and Chapter 5 Potential environmental impacts and mitigation measures are identical for all three reports and this includes the contents of the Environmental Management Plans presented for the three projects. National Oil Corporation of Kenya The National Oil Corporation of Kenya is represented in our project by six (environmental) impact assessment reports. Of these we compared four (eia_1005, eia_1006, eia_1007 and eia_1175). Three impact assessment consultants prepared these reports: Sustainability Kenya Ltd Consultants (eia_1005 and eia_1007), Mr Justin Kabuiku Miano (eia_1006) and Grinenvironment Consultants (eia_1175). The Exective summaries for reports eia_1005, eia_1006 and eia_1007 are identical. Large parts of the text of Chapter1 Introduction are identical for the four reports. Large parts of the text of Chapter 2 Project description, design and construction are identical for reports eia_1005, eia_1006 and eia_1007. The texts of Chapter 5 Environmental impacts and mitigation, Chapter 6 Project alternatives, Chapter 7 Environmental management and monitoring plan, Chapter 8 Public consultation, Chapter 9 Environment, health and safety issues and Chapter 10 Conclusions and recommendations are essentially identical in reports eia_1005, eia_1006 and eia_1007. Many of these texts can also be found in report eia_1175, but in this report they may be placed in differently organised chapters. Mr Maurice O Mbgera Mr Maurice O Mbgera prepared (environmental) impact assessment reports (reports eia_1026 and eia_1151) for petrol station development projects proposed by Mrs Lucy Nyokabi Mathenege and by Tesa Holdings Company Ltd respectively. The texts of Chapter 5.0 Analysis of project alternatives, Chapter 6.0 Environmental impacts and mitigation measures, Chapter 7.0 Recommended mitigation measures, Chapter 8.0 Consultation and public participation, Chapter 9.0 Environmental Management Plan, Chapter 10.0 Environment, health and safety (EHS) and Chapter 11.0 Recommendations and conclusion of these two reports are essentially identical.
  • 20. 16 Messrs Fred Moniki Omosa and James Mithanga Messrs Fred Moniki Omosa and James Mithanga prepared (environmental) impact assessment reports (eia_1038 and eia_1039) for petrol station development projects proposed by Mrs Ann Nyambura Maina and by Wajibu Ventures Ltd. While from the dates of these two reports and their NEMA webcodes it appears that these two reports were produced side-by-side and while there is considerable overlap of texts between the two reports, it is also amazing how poorly these two reports appear to have been coordinated. The chapters on the Environment and social management plan and on the Conclusion (and recommendations) of the two reports have widely different contents. Pestavic EHS Services Pestavic EHS Services prepared (environmental) impact assessment reports (eia_1117 and eia_1129) for petrol station development projects proposed by Gulf Energy Ltd and Kings Sent Petroleum Kenya Ltd. These reports are both dated March 2014. The Chapter Project overview and baseline information shows essentially the same texts in both reports for many sections. The Chapters on Construction safety, Public consultation, Description of the existing and anticipated impacts, Issues of concern and mitigation measures, Project completion and decommissioning, Alternatives including the proposed action, Environmental and monitoring plans and Conclusion and recommendations are essentially identical. This includes the analysis of the public consultation and it includes mitigation measures in relation to above-ground storage tanks (for both projects), while such tanks do not feature in the design of any of the two projects.
  • 21. 17 Discussion Rating results Generally, the quality of the (environmental) impact assessment reports reviewed is poor as shown by the rating results. This is for relatively simple projects, so there are two possibilities: (1) because of the simplicity of the projects the importance of the (environmental) impact assessment is rated low (and the quality of EIAs for more complex projects is probably better); (2) if EIAs of these simple projects are so poor, one may expect that EIAs for more complex projects will also be poor and that will present a much bigger problem. NEMA approves poor quality, non-compliant (environmental) impact assessments of projects and does issue environmental impact assessment licenses to project proponents regardless. Comparison of impact assessment reports Comparison of impact assessment reports shows massive duplication of text between reports and poor business ethics and quality control by impact assessment consultants and project proponents. (Environmental) impact assessment is obviously one of the boxes to be ‘ticked’ on the list of required actions, not an exercise to inform project development. NEMA’s review and approval process appears not be designed to pick this up, even though some of the reports concerned were submitted for approval almost simultaneously, as indicated by the NEMA code and report date. Environmental Impact Assessment for petrol stations (EIA or checklist ?) The results of this project beg the question whether a full (environmental) impact assessment is the best tool to assess and approve the (environmental) impact of petrol station development projects. A checklist with clear pass/fail criteria may be more appropriate (see also the Gauteng EIA Administrative Guideline (3)). Improvements of NEMA review and approval procedure Review, appraisal and approval (or rejection) of impact assessment reports is a very important regulatory activity, as it determines the quality of development projects that are carried out. Review, appraisal and approval (or rejection) must be centralised (or be carried out/overseen by members of a dedicated task force of senior graduate staff with a solid experience in and knowledge of the EIA process and EIA reports). Checks must be built in to be able to spot poor quality and duplication of text between reports. Templates may be made available for regulatory, aspects and impacts registers for different categories of projects. Templates for ISO14000 compatible management plans may be useful. Guidance should be provided on the integration of ISO14000 elements in environmental impact assessment work. Learning value of the project Project members were advised to read the ‘Overview of IOGP’s Environmental-Social-Health Risk and Impact Management Process’ (4) as a brief and clear introduction to (environmental) impact assessment.
  • 22. 18 Project members commented on the sets of review criteria to be used. Individual project members were asked to review and rate four (environmental) impact assessment reports. Combined scores for the different reviewers of all the reports were returned to the project members. Towards the completion of the project it became clear that at least one project team member should cover the work of all the other project team members. As four EIA reports were assigned for review and appraisal to each individual project member, the entire issue of widespread duplication of texts would not have been picked up without the project lead having read and rated all the 41 reports. Projects members were able to comment on the draft project report. This report provides more learning to project members, as it is covering all the 41 (environmental) impact assessment reports and after publication will provide learning to all interested YoungProfsNet members. Organisation of the project as a learning experience Originally the project was started as an autonomous exercise carried out independently by the project team. There was a project proposal with a number of appendices, including the proposed evaluation criteria. The project was relaunched twice. A large number of YoungProfsNet members (about 90) committed to contribute but in the end only 16 members contributed in practice. For the re- launch a more detailed project proposal and appendices were distributed and in the course of the process early scoring results were evaluated and feedback provided to participants. A flow chart for the completion of the project was provided. So, generally the preparation for projects as these must not be underestimated. This may appear to be unexpected in view of the fact that most YoungProfsNet members are university graduates. There appears to be a fine balance between under- and over-documentation and guidance for these projects. For this project we used Slack (www.slack.com) to make the (environmental) impact assessment reports and the worksheets with the appraisal criteria available to the project team members. While this worked well, we did not make more extensive use of Slack for team communications. Probably, it would have been easier to use an application such as Dropbox or Google Drive to have all relevant project documents available in the cloud.
  • 23. 19 References (1) United Nations Environment Programme Division of Technology, Industry and Economics; Economics and Trade Branch Environmental Impact Assessment Training Resource Manual Second edition 2002 Geneva https://www.sprep.org/att/IRC/eCOPIES/Global/217.pdf (2) Republic of Kenya Environmental (Impact Assessment and Audit) Regulations, 2003 Kenya Gazette Supplement No. 56 of 13th June 2003 2003 http://faolex.fao.org/docs/pdf/ken53040.pdf (3) Gauteng Provincial Government Department of Agriculture, Conservation, Environment and Land Affairs EIA Administrative Guideline Guideline for the Construction and Upgrade of Filling Stations and Associated Tank Installations March 2001 http://home.intekom.com/salbu/a_R21/FillingStationsGuidelines.html (4) International Association of Oil and Gas Producers Overview of IOGP’s Environmental-Social-Health Risk and Impact Management Process IOGP Report 529 London, November 2014 https://www.iogp.org/bookstore/product/overview-of-iogps-environmental-social-health- risk-and-impact-management-process/
  • 24. 20 Appendix List of (environmental) impact assessment reports reviewed by this project Code Date Location eia_1005 Jul-13 King’ong’o, Nyeri County eia_1006 Jul-13 Kisauni, Mobassa County eia_1007 Jul-13 Kamulu, Nairobi County eia_1010 Jul-13 Thika-Garissa highway eia_1026 Jul-13 Embakasi Ranching –P-6966, Nairobi County eia_1027 Dec-12 Chianda Uyoma along Ndori-Luanda Kotieno road eia_1030 Undated Kiambu-Githunguri Road, Kiambu County eia_1031 Aug-13 Stanley Mathenge Road, Nakuru Town (Industrial Zone) eia_1033 Jan-13 Eastern Bypass, Nairobi eia_1037 Sep-13 Kakamega Mumias Highway, Shibuli eia_1038 Aug-13 Mugaga Shopping Centre, Thika-Garissa Highway, Thika, Kiambu County eia_1039 Aug-13 White Sisters Road, Thika, Kiambu County eia_1045 Oct-13 Kiserian-Isinya highway eia_1047 Sep-13 Plot L.R No. Kjd/Kaputiei North/57039 at Isinya eia_1053 Oct-13 Jomvu Raod, Jomvu eia_1054 Sep-13 Nairobi – Mombasa road, Kiboko, Makueni County eia_1056 Oct-13 Embu-Kiritiri Road, Muraru shopping centre, Mbeere South County eia_1057 Nov-13 Eldoret Jua kali road, Eldoret West District, Uasin Gishu County eia_1060 Nov-13 Plot L.R No. 209/11827 along Mombasa Road, Nairobi County eia_1067 2013 Nairobi – Nakuru Highway, within Limuru Municipality, Rironi eia_1068 Nov-13 Off Kangudo Road, 600m along the Eastern By-pass towards Thika Road eia_1087 Oct-13 Kibwezi-Kitui Road in Kalamba market Kibwezi, Makueni County eia_1091 Jan-14 Plot No. Ker/Sil/2128 Bomet Township, Bomet County eia_1099 Undated Garrissa highway between Kithimani market and Matuu market eia_1103 Feb-14 Nairobi-Nakuru Highway, Gilgil, Nakuru County eia_1117 Mar-14 Namanga-Nairobi road, Namanga, Kajiado County eia_1129 Mar-14 Matiliku Market, Emali-Matiliku Road, Matiliku, Makueni County eia_1135 Feb-14 Plot L.R No. 4885/124 AND 4885/125 Rironi, Kikuyu, Kiambu County eia_1136 Feb-14 Plot L.R No. 1/168 Lenana Road, Kilimani, Nairobi County eia_1151 Apr-14 Plot L. R. No.899, Maseki, Mutulu, Matinyani District, Kitui County eia_1152 May-14 Eldoret-Ziwa road, Eldoret East District, Uasin Gishu County eia_1155 May-13 Kericho-Nakuru road and Kimungu Road, Kericho, Kericho County eia_1158 Jun-14 Mombasa-Nairobi Highway, Mtito Andei eia_1159 Feb-14 Samson Corner-Mwea –Nairobi highway, Nyangati, Kirinyaga County eia_1161 May-14 Pumwani Petrol Station, Plot L. R. No. 209/14652, Nairobi eia_1173 Jun-14 Kamwasor trading centre, Keiyo south district, Elgeiyo Marakwet County eia_1175 Jun-14 Naivas supermarket off Nakuru -Nairobi highway, Nakuru, Nakuru Cty No code Undated Kisumu-Ahero road, Buoye No code Nov-13 Moi South Lake Road, Karagita market, Naivasha,Nakuru County
  • 25. 21 NEMA Webcode: eia_1005 Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol Station on Plot Title No. 753, King’ong’o, Nyeri County, July 2013 Proponent: National Oil Corporation of Kenya Ltd Consultant: Sustainability Kenya Ltd Consultants NEMA Webcode: eia_1006 Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol Station on Plot Title No. MN/II/12385, Kisauni, Mombasa County, July 2013 Proponent: National Oil Corporation of Kenya Ltd Consultant: Mr Justin Kabuiku Miano NEMA Webcode: eia_1007 Environmental Impact Assessment Full Study Report for the Proposed Model Standard Petrol Station on Plot Title No. 11594, Kamulu, Nairobi County, July 2013 Proponent: National Oil Corporation of Kenya Ltd Consultant: Sustainability Kenya Ltd Consultants NEMA Webcode: eia_1010 Environmental Impact Assessment Study Report for the Proposed Petrol Service Station on L.R Thika Municipality Block 8/181 along the Garissa Highway, [July 2013] Proponent: Mr Vishal Shah Nemchand Consultant: Peman Consultants NEMA Webcode: eia_1026 Environmental Impact Assessment Study Report for the Proposed Filling Station cum Commercial Services, on Plot L.R. No. Embakasa Ranching, -P-6966, Nairobi County, July 2013 Proponent: Mrs Lucy Mathenge Consultant: Mr Maurice O Mbgera NEMA Webcode: eia_1027 Environmental Impact Assessment Project Report: Proposed Filling Station and a Hotel at Chianda in Uyoma Along Ndori-Luanda K’otieno Road on Plot No. Siaya/Kobong/2893, December 2012 Proponent: Mr Christopher Chika Consultant: Dayton Consultants NEMA Webcode: eia_1030 Environmental Impact Assessment Study Report for the Proposed Petrol Station on 0.25 acres excised from L.R. No. Githunguri/Githunguri Township/422 along Kiambi-Githunguri Road, Kiambu County, Not Dated Proponent: Penko Refillers Ltd Consultant: Mr Francis K Mwaura NEMA Webcode: eia_1031 Environmental Impact Assessment (EIA) Project Report for the Proposed Musipe Oil Resellers Ltd’s Oil Storage Facility and Filling Station on Plot L.R. No. Nakuru Municipality/Block 8/6 in Industrial Zone, Nakuru, August 2013 Proponent: Musipe Oil Resellers Ltd Consultant: Purified Consultants Ltd
  • 26. 22 NEMA Webcode: eia_1033 Environmental Impact Assessment Project Report on Plot L.R No. Nairobi Block 115/14 and 115/15, Eastern Bypass, Nairobi; Project: the Proposed Construction of Fuel Station, January 2013 Proponent: Astrol Petroleum Company Ltd Consultant: Mr Njogu Barua NEMA Webcode: eia_1037 Environmental Impact Assessment for Proposed Shibuli Filling Station Plot No. Butsotso/ Shibeye/ 5034 in Shibuli on Kakamega Mumias Highway, September 2013 Proponent: Shibuli Filling Station Consultant: Mr Walter Naroge Nyatwang'a NEMA Webcode: eia_1038 Environmental Impact Assessment Study Report Petrol Station Development-Muguga Shopping Centre; Title: the Proposed Petrol Station, Restaurant, Swimming Pool and Convenience Store on Plot LR No. Kiambu/Gatuanyaga/446 off Thika-Garissa Road, Thika West District. within Kiambu County, August 2013 Proponent: Mrs Ann Nyambura Maina Consultant: Messrs Fred Moniki Omosa & James Mithanga NEMA Webcode: eia_1039 Environmental Impact Assessment Study Report Petrol Station Development-Ngoingwa Shopping Centre; Title: the Proposed Service Station Development on Plot LR No. Thika Municipality Block 2/404 off White Sisters Road, Thika West District. within Kiambu County, August 2013 Proponent: Wajibu Ventures Ltd Consultant: Messrs Fred Moniki Omosa & James Mithanga NEMA Webcode: eia_1045 Environmental Impact Assessment Study Report for the Proposed Petrol Service Station on L.R Nos. KJD/Kipeto/6613 & 6614 along the Kiserian – Isinya Highway, October 2013 Proponent: Mr Moses Parantai Shukuru Consultant: Ecohealth Co. Ltd NEMA Webcode: eia_1047 Environmental Impact Study Report for Proposed Development of a Petrol Station on L.R. No. KJD/Kaputei North/57039, at Isinya – Kajiado County for Mr. Joseph Ngotiek, September 2013 Proponent: Mr Joseph Ngotiek Consultant: Geosmart Consultants Ltd NEMA Webcode: eia_1053 Environmental Impact Assessment for Proposed Kings Petroleum Petrol Station Jomvu Mikindani Area, Mombasa County Railways Land Plot No.697, October 2013 Proponent: Kings Petroleum Filling Station Consultant: Mr Joseph Mahindo Manyako NEMA Webcode: eia_1054 Environmental Impact Assessment Study Report: Proposed Construction of a Filling Station on Plot No. Makindu/Kiboko B/687 Makindu. Makueni County, September 2013 Proponent: Mr Lawrence Mwagangi Mwania Consultant: Mr Malachi O. Okello
  • 27. 23 NEMA Webcode: eia_1056 Environmental Impact Assessment Study Report for Proposed Petrol Filling Station on Parcel No. Mbeti/Gachoka/3295, Mbeere County Council, October 2013 Proponent: Mr Thomas Mutugi Karunji Consultant: Mr Tom Kimanzi and company NEMA Webcode: eia_1057 Environmental Impact Assessment Study Report for Proposed Development of Petroleum Filling Station on Plot 64, Baharini,along Eldoret Jua Kali Road, Eldoret West District, Uasin Gishu County, November 2013 Proponent: Mr Farah Mowlid Khalif Consultant: Tehilla Company Ltd NEMA Webcode: eia_1060 Environmental Impact Assessment (EIA) Study Report for the Proposed Development of a Petrol Station and Commercial Building on Plot L.R No. 209/11827 along Mombasa Road, Nairobi County, November 2013 Proponent: Mahadi Oil Kenya Ltd Consultant: Envassess Environmental Consultants NEMA Webcode: eia_1067 Environmental Impact Assessment Study Report: Proposed Service Station for Gulf Energy Ltd, Rironi, Plot No. Limuru/Rironi/233, [2013] Proponent: Gulf Energy Ltd Consultant: Petrochem Associates Ltd NEMA Webcode: eia_1068 Environmental Impact Assessment Study Report for the Proposed Gulf Energy Ruai Junction Service Station on Plt L.R. No. V. 13106 & V. 13101 off Kangudo Road, 600 m along the Eastern By-pass towards Thika Road, November 2013 Proponent: Gulf Energy Ltd Consultant: Messrs Joseph Mwaniki Kiaharo and Mugambi Alex NEMA Webcode: eia_1087 Environmental Impact Assessment Study Report: Proposed Filling Station Land Parcel No. 143 along Kibwezi-Kitui Road, Kalamba in Kibwezi, Makueni County, October 2013 Proponent: Mr Wambua Kinyao Consultant: Mrs Faith Moses and Mr Kenneth Bii Ng’eny NEMA Webcode: eia_1091 Environmental Impact Assessment Study Report for the Proposed Filling Station Project on Plot No.KER/SIL/2128 Bomet Township, Bomet County, January 2014 Proponent: Mrs Beatrice Chelangat Biegon Consultant: Mr Wesley Langat and company NEMA Webcode: eia_1093 Environmental Impact Assessment Full Study Report for the Proposed Waste Oil Facility and Petrol Station on Plot No. LR. 17/Kaliang’ombe/Jimba Adjudication Section, Kilifi County, January 2014 Proponent: Patkey Energy Ltd Consultant: Messrs Justin Kabuiku and George Morara
  • 28. 24 NEMA Webcode: eia_1099 Environmental Impact Assessment Full Study Report for the Proposed Petrol Station on Land Registration Ndalani/Ndalani Blocks 1/1705, Not Dated Proponent: Mrs Agnes Ndunge Mutuku and Mr Reuben Mutuku Munguti Consultant: Mr James K Njeru NEMA Webcode: eia_1103 Environmental Impact Assessment Study Report for the Proposed NOC Service Station along Nairobi-Nakuru Highway, Gilgil, L.R. No. Gilgil/Gilgil Block 1/18243 (Kekopey), Nakuru County, February 2014 Proponent: National Oil Corporation of Kenya Ltd Consultant: Earthcare Services Ltd NEMA Webcode: eia_1117 Environmental Impact Assessment Full Study Report for the Proposed Construction of a Petrol Station, on LR No 1499 Namanga, off Namanga – Nairobi Road, March 2014 Proponent: Gulf Energy Ltd Consultant: Pestavic EHS Services NEMA Webcode: eia_1129 Environmental Impact Assessment Full Study Report for the Proposed Construction of a Service Station, on LR No 29C Matiliku, off Emali – Matiliku Road, March 2014 Proponent: Kings Sent Petroleum Kenya Ltd Consultant: Pestavic EHS Services NEMA Webcode: eia_1135 Environmental Impact Assessment Project Report on Plot L.R No. 4885/124 and 2885/125, Rironi Kikuyu, Kiamy County; Project: the Proposed Construction of Fuel Filling Station, February 2014 Proponent: Astrol Petroleum Company Ltd Consultant: Mr Njogu Barua NEMA Webcode: eia_1136 Environmental Impact Assessment Study Report; Project: the Proposed Construction of Fuel Filling Station on Plot L.R No. 1/168 Lenana Road, Nairobi County, February 2014 Proponent: Astrol Petroleum Company Ltd Consultant: Mr Njogu Barua NEMA Webcode: eia_1151 Environmental Impact Assessment Study Report for the Proposed Maseki Filling Station on Plot L.R. No.899, Kitui County, April 2014 Proponent: Tesa Holdings Company Ltd Consultant: Mr Maurice O Mbgera NEMA Webcode: eia_1152 Environmental Impact Assessment Study Report for Proposed Development of Petrol Service Station on Plota Uasin Gishu /Kimumu/6594 & 6595, along Eldoret-Ziwa Road, Eldoret East District, Uasin Gishu County, May 2014 Proponent: Mr Peter Ndungu Mucuku Munga Consultant: Tehilla Company Ltd
  • 29. 25 NEMA Webcode: eia_1155 Environmental Impact Assesement Report: Proposed Petrol Station Development on Plot L.R.No. 631/1183, Kericho Municipality, Kericho County for Shajanand Hardwares Limited, May 2013 Proponent: Shajanand Hardwares Ltd Consultant: Not Stated NEMA Webcode: eia_1158 Environmental and Social Impact Assessment Study of the Proposed Remodeling of a Service Station on Plot L.R No. 11487/1 in Mtito Andei, June 2014 Proponent: National Oil Corporation of Kenya Ltd Consultant: Kurrent Technologies Ltd NEMA Webcode: eia_1159 Environmental Impact Assessment Study Report for the Proposed Construction and Operation of Fuel Service Station at LR Kabare/Nyangati/5735 at Kimbimbi Market, Nyangati Location, Mwea Sub County, Kirinyaga County, February 2014 Proponent: Mr Johnson Gakuru Gachoki Consultant: Mr Anthony Njogu Njurai and Mrs Jane Ngonge NEMA Webcode: eia_1161 Environmental Impact Assessment Study Report for the Proposed Patrol Station at Pumwani, May 2014 Proponent: Mr Abdi Abdirahman Muhumed Consultant: Green Globe Foundation NEMA Webcode: eia_1173 Environmental Impact Assessment Report for the Construction of Proposed Petrol Station by Inego Investment Company Limited, Located at Kamwosor Trading Center, Keiyo South District, June 2014 Proponent: Inego Investment Company Ltd Consultant: Prof. Vincent Sudoi (PhD) NEMA Webcode: eia_1175 Environmental Impact Assessment Study Report for the Proposed Petrol Station on Plot Title L.R No. Nakuru Municipality Block 16/263, Nakuru Town, June 2014 Proponent: National Oil Corporation of Kenya Ltd Consultant: Grinenvironment Consultants No NEMA Webcode Environmental Impact Assessment Study Report: Proposed Development of a Petroleum Service Station on Eldoret Municipality Block 21 (Kingongo)/91 & 92, along Eldoret Jua Kali Road, Eldoret West District, Uasin Gishu County, March 2014 Proponent: Ainu Shamshi Energy Ltd Consultant: Tehilla Company Ltd No NEMA Webcode Full Study Report for the Proposed Petrol Station on Plot L.R No. Naivasha Plot 396/71 (Previously 396/28) on Moi South Lake Road, Naivasha Municipality of Nakuru County, November 2013 Proponent: Naivasha Health Park Ltd Consultant: Grinenvironment Consultants
  • 30. 26 No NEMA Webcode Environmental Impact Assessment Report: the Proposed Wolfenberg International Service Station Project at Buoye on Kisumi-Ahero road, Kisumi, Not Dated Proponent: Wolfenberg International Ltd Consultant: Mr Ngugi Muigai