The National Environmental Management Authority (NEMA) has outlined a range of anticipated environmental and social risks expected in the construction of the Naivasha–Kisumu Standard Gauge Railway.
In a notice published on April 14, KeNHA shared a report of its risk assessment of the proposed project by the Kenya Railways Corporation (KRC), which aims to construct the Standard Gauge Railway (SGR) Phase 2B, a railway line of approximately 262.4 km from Naivasha to Kisumu.
“Pursuant to Section 59 of the Environmental Management and Coordination Act, CAP 387, the National Environmental Management Authority (NEMA) has reviewed an Environmental Impact Assessment Study Report for the above proposed project,” read part of the NEMA statement.
In addition to listing the risks, the authority also provided proposed mitigation measures to guide implementation.
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Among the key social risks identified is the loss of pasture for livestock and wildlife due to land-use changes along the railway corridor, with mitigation measures including the development of wildlife corridors and livestock crossings, as well as early communication with affected communities.
NEMA Lists Social Risks and Mitigation Measures
In the notice, NEMA highlighted the following risks and control measures;
| Impacts | Mitigation Measures / Controls |
| Vegetation Clearance / Clearance of urban and farm trees | • Equipment and tools brought in for reuse from other project sites should be screened and cleaned of alien/invasive propagules to avoid introduction in the project area. • Borrow sites should be inspected for invasive and colonizer propagules. • Restrict vegetation clearing to demarcated project site boundaries. • Establishment of woodlots on affected farms to help restore tree cover. • Limiting clearing to the smallest area necessary for the project to reduce habitat loss and soil exposure. • Implement tree planting programs to replace cleared trees. • Work with farmers to promote agroforestry initiatives. |
| Disturbance of indigenous forests | • Align project elements (e.g. access roads, utility corridors) along disturbed or degraded areas. • Establish and maintain buffer zones around high‑value conservation areas, riparian zones, and wetlands. • Safely relocate fauna from the project area in coordination with wildlife authorities, especially for species with limited mobility or breeding grounds. • Involve local communities in forest protection, replanting, and monitoring initiatives. • Provide support for non‑forest‑based income activities (e.g. beekeeping, agroforestry, eco‑tourism) to reduce pressure on forest resources. |
| Loss of pasture for livestock and wildlife | • Incorporate wildlife corridors and livestock crossings (underpasses and overpasses) to ensure safe and uninterrupted movement to pasture areas. • Ensure transparent and timely disclosure of all relevant project information, particularly concerning activities that may affect local communities’ rights, land use, and livelihoods. • Provide advance notice to local farmers, allowing sufficient time for the harvesting of grass. |
| Oil Spillage | • Develop a site‑specific SPCC plan. • Store oil and fuel in tanks or containers with bunds or drip trays capable. • Regularly inspect construction machinery for leaks in hydraulic systems, fuel tanks, and lubrication lines. • Ensure that all construction equipment is well‑maintained to prevent accidental leaks. |
| Blasting and rock excavation | • Blasting should be carried out in accordance with a site‑specific Blast Management Plan (BMP). • Establishment of blast exclusion zones with proper signage and fencing to restrict access during detonation. • Implementing dust suppression strategies, such as water spraying and wind barriers, should be implemented before and after blasting. |
| Poor disposal of excavated materials and equipment | • Separate excavated materials into reusable and non‑reusable/spoiled materials. • Use inert excavated materials for backfilling, slope stabilization, or forming embankments. • Transport non‑usable materials to approved dumping sites. • Salvage metals, rubber parts, and electronics for recycling through licensed waste handlers. |
| Soil Erosion | • Conduct geotechnical and hydrological assessments to identify erosion‑prone zones. • Develop erosion susceptibility maps to inform alignment design, cut‑and‑fill balances, and drainage planning. • Schedule earthworks during dry seasons to minimize rainfall‑induced erosion. • Replant native grasses, shrubs, or fast‑growing groundcover species as soon as construction is complete in each section. |
| Slope Destabilization | • Minimize the number of cut‑and‑fill earthworks by optimizing rail alignment and grading plans. • Install subsurface and surface drainage (e.g. French drains, interceptor ditches, and weep holes in retaining walls) to prevent water accumulation that weakens soil. |
| Climate change (construction phase) | • Minimize vegetation clearance by optimizing the construction corridor and integrating natural landscape features into the design where possible. • Implement carbon offset measures, such as reforestation or afforestation programs. • Incorporate climate resilience and low‑carbon strategies into regional development planning to ensure that induced growth does not exacerbate environmental degradation. |
| Dust Emission | • Clear only the areas required for immediate work to reduce the amount of exposed, dust‑prone soil. • Apply water to loose soil prior to and during earthworks (excavation, grading, backfilling) to suppress dust at the source. |
| Disruption of Public Utilities | • Coordinate with utility service providers and local authorities to map existing underground and overhead infrastructure accurately. • Integrate comprehensive surveys and utility mapping, coupled with robust monitoring frameworks. • Prepare detailed relocation plans approved by utility providers and schedule work during off‑peak hours or planned outages. • Install protective barriers, sleeves, or enclosures around utilities that are close to excavation or piling activities. |
| Poor site management and control leading to accidents and incidents | • Nominate persons with defined responsibility for EHS. • Through relevant training, ensure everyone on site is aware of their responsibilities and liabilities with respect to the environment. • Through site induction, make staff and visitors aware of the project’s environmental issues and environmental standards. |
| Road Accidents | • Any abnormal loads for the project must be transported in line with the traffic rules, including public notification and the use of escort cars. • Sensitize project staff on risks of over‑speeding on-site. • Erect warning signs for approaching drivers at the points of entry to the project site. |
| Disputes over employment | • Develop a grievance management system to manage grievances arising from the local labor force. • Develop local labor recruitment plans, including disclosure of opportunities and partnership building with local support agencies/institutions. |
| Air Emissions | • Employ advanced engine technologies with Diesel Particulate Filters (DPFs), and selective catalytic reduction (SCR) systems to reduce NOx and PM emissions. • Application of water sprays, chemical suppressants, and use of covered conveyors or enclosed handling facilities to reduce particulate matter generation during transport and material operations. • Continuous ambient air quality monitoring near sensitive receptors and rail yard boundaries should be conducted to inform adaptive management. |
| Solid Waste Generation | • Implement a comprehensive Waste Management Plan (WMP) encompassing waste minimization, segregation, and recycling strategies. • Training of staff and public awareness campaigns to reduce littering and promote responsible waste disposal. • Engagement with licensed waste handlers for safe disposal of hazardous wastes such as oils, solvents, and batteries in compliance with local regulations and international best practices. |
| Wildlife and Livestock accidents due to breached fence | • Conduct wildlife movement and behaviour studies to identify high‑crossing zones and optimize the placement of underpasses. • Utilize fencing materials that balance strength, flexibility, and visibility to reduce damage by animals and humans. • Design underpasses with appropriate dimensions, lighting, and natural substrate to encourage regular animal use. • Engage local communities and stakeholders in awareness programs to minimize human interference with fencing infrastructure. |
| Noise and Vibration | • Use ballast mats, under‑sleeper pads, or floating slab track systems to absorb and dissipate vibration energy before it transmits to the ground. • Set speed limits in vibration‑sensitive zones to significantly reduce both the amplitude and frequency of vibration. • Maintain appropriate setback distances between the railway and residential or sensitive land uses. • Conduct noise and vibration monitoring to establish baseline levels and assess the effectiveness of mitigation measures as per EMCA (Noise and Excessive Vibration Pollution) (Control) Regulations, 2009. • Workers performing in noisy working environment shall be provided with suitable ear protectors based on the expected noise levels. |
| Climate change (operation/energy) | • Adoption of low‑emission locomotives, including electrified rail systems or hybrid alternatives to diesel engines. • Energy‑efficient station infrastructure, powered by renewable energy sources (e.g. solar PV systems). • Afforestation or reforestation programs to offset unavoidable emissions and enhance carbon sequestration. • Integration of climate risk assessments into infrastructure design to ensure climate‑resilient development. |
| Flooding/water ponding | • Integrate appropriately sized and strategically placed culverts, box drains, or small bridges along the embankment to allow unimpeded flow of water. • Ensure drainage structures are designed to handle peak flows based on historical flood data and climate change projections. • Consider vegetative stabilization techniques to improve slope integrity and absorb runoff. • Implement a maintenance schedule to inspect drainage structures for blockages or sedimentation and monitor embankment stability, especially during and after heavy rainfall. |
| Energy Consumption | • Use energy‑efficient lighting (e.g. LED) in stations, offices, and maintenance yards. • Install solar panels at strategic locations. • Promote energy‑saving practices during construction and operation phases. |
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