Modogashe - Wajir Road Section ESIA Report PDF

Review and Update of the Environmental
and Social Impact Assessment for the

Proposed Upgrading to Bitumen Standards
of Modogashe - Samatar - Wajir Road
Section 157Km (A13)
North Eastern Transport Improvement Project (NETIP)
Final ESIA Study Report

November 2019
Proponent
Kenya National Highways Authority (KeNHA)
Barabara Plaza, Jomo Kenyatta International Airport (JKIA),
Off Mazao Road (Opp KCAA HQs)
P.O. Box 49712-0010
NAIROBI
Tel:+254-20-8013842
KeNHA
CONTENTS PAGE
1 INTRODUCTION 1
1.1 Project Background 1
1.2 Need for ESIA Study Review and Update 4
1.3 Project Justification 4
2 PROJECT DESCRIPTION 6
2.1 Location of the Road Project 6
2.1.1 Other Roads in the Project Area 6
2.1.2 Existing Road Reserve 6
2.1.3 Present Condition of the Road 6
2.2 Project Design Features 8
2.2.1 Terrain of the alignment 8
2.2.2 Cross section 8
2.2.3 Horizontal Alignment Design 12
2.2.4 Vertical Alignment 12
2.2.5 Truck Parking areas 13
2.2.6 Design Criteria for Main Carriageway Pavement 13
2.2.6.1 Climbing lanes 13
2.3 Drainage Structures along the Road Corridor 13
2.4 Construction Material Sources (Gravel, Hard stone, Sand and Water) 17
2.4.1 Gravel Sources 17
2.4.2 Hard Stone Sources 19
2.4.3 Sand Sources 20
2.4.4 Water Source for Construction 21
2.5 Traffic Forecasts 22
2.5.1 Traffic Forecast Samatar-Wajir Section 22
2.5.2 Traffic Forecast Modogashe-Samatar Section 23
2.6 Project Construction and Operational Activities 24
2.6.1 Outline of the Construction of the Road 24
2.6.1.1 Construction Overview 24
2.6.1.2 Ground Investigations 24
2.6.1.3 Demolition and Site Clearance 24
2.6.2 Concrete Works 24
2.6.3 Earthworks 24
2.6.4 Road pavement 25
2.6.5 Steel works 25
2.7 Wildlife/Livestock Crossing 25
2.8 Commissioning: Operation and Maintenance 26
2.8.1 Structural and Civil Engineering Works 26
2.8.2 Site Reinstatement 26
2.8.3 Reinstatement Philosophy 26
2.8.4 Timing of Reinstatement 26
2.8.5 Site Clean up 26
2.8.6 Permanent Reinstatement 26
2.9 Decommissioning and Abandonment Plans 27
2.9.1 Decommissioning of Existing Facilities 27
2.9.2 Legal Basis 27
2.9.3 Technical Solutions for Abandonment 27
2.9.4 Products, By–products and Waste 27
2.10 Project Waste Management Strategy 28
2.10.1 Project Waste Management Principles 28
KeNHA/Revised and Updated ESIA for the Upgrading of Modogashe-Samatar-Wajir 157Km (A13) Road October 2019
Pan-19-003 -i-
KeNHA
2.10.2 Hierarchy of Waste Management Practices 29

2.10.3 Transfer of Waste to Third Parties 29
2.10.4 Construction Waste and Emission Inventories 30
2.10.4.1 Construction and Commissioning Waste Management 30
2.10.5 Release to the atmosphere 31
2.10.6 General wastewater disposal 31
2.11 Project Cost 31
2.11.1 The Cost of Resettlement Action Plan (RAP) 31
2.11.2 Construction Cost 31
3 POLICY, LEGALATIVE AND INSTITUTIONAL FRAMEWORK 34
3.1 The Constitution of Kenya 34
3.2 The National Policy Framework 34
3.2.1 Sessional Paper No. 10 of 2012 on Kenya Vision 2030 35
3.2.2 Environment and Development (Sessional Paper No. 6 of 1999) 35
3.2.3 Sessional Paper No. 10 of 2014 on the National Environment Policy 35
3.2.4 National Environmental Action Plan (NEAP) of 2009-2013 36
3.2.5 The National Poverty Eradication Plan (NPEP) of 1999 36
3.2.6 The Poverty Reduction Strategy Paper (PRSP) of 2000 36
3.2.7 The National Biodiversity Strategy of 2000 36
3.2.8 Sessional Paper No. 3 of 2009 on National Land Policy 37
3.2.9 Sessional Paper No. 8 of 2012 on National Policy for the Sustainable 37
3.2.10 Wildlife Policy of 2011 38
3.2.11 Wetlands Policy of 2013 38
3.2.12 Physical Planning Policy 38
3.2.13 Public Health Policy of 2014 38
3.2.14 Occupational Health and Safety Policy of 2012 39
3.2.15 HIV/AIDS Policy of 2009 39
3.2.16 Kenya National Policy on Gender and Development (NPGD), 2000 39
3.2.17 The Kenya National Climate Change Response Strategy of 2010 39
3.2.18 National Environment Policy, 2013 39
3.2.19 The National Poverty Eradication Plan (NPEP) of 1999 40
3.2.20 Gender Policy of 2011 40
3.2.21 The Education Gender Policy (2007) 40
3.2.22 Sexual and Gender Based Violence (SGBV) Policy 2017 40
3.2.23 Kenya Rural Development Strategy (KRDS) 2002-2017 41
3.2.24 KeNHA’s Environment and Social Safeguards Policy, 2018 41
3.3 Environmental Guidelines 41
3.3.1 National Solid Waste Management Strategy, NEMA, 2014. 41
3.3.2 Technical guidelines on the management of used oil and oil sludge in Kenya 42
3.3.3 National sand harvesting guidelines, 2007 42
3.3.4 The Integrated Land Use Guidelines 42
3.4 National environmental legal framework 42
3.4.1 Environmental Management and Coordination Act (EMCA, Cap 387) 42
3.4.1.1 EMCA (Environmental Impact Assessment and Audit) Regulations,
2003 43
3.4.1.2 EMCA (Water Quality) Regulations, 2006 43
3.4.1.3 EMCA (Fossil Fuel Emission Control) Regulations, 2006 44
3.4.1.4 EMCA (Conservation of Biological Diversity and Resources, Access to
Genetic Resources and Benefit Sharing) Regulations, 2006 44
3.4.1.5 EMCA (Waste Management Regulations, 2006) 44
Pan-19-003 - ii -
KeNHA
3.4.1.6 EMCA (Wetlands, River Banks, Lake Shores and Sea Shore
Management) Regulations, 2009 44
3.4.1.7 EMCA (Noise and Excessive Vibration Pollution Control) Regulations,
2009 45
3.4.1.8 EMCA (Air Quality) Regulations, 2014 46
3.4.2 The Kenya Roads Act, 2007 46
3.4.3 The Kenya Roads Board Act, 1999 46
3.4.4 Public Roads and Roads of Access Act Cap 399 47
3.4.5 The Traffic Act Cap 403 47
3.4.6 The Wildlife Management and Conservation Act 2013 47
3.4.7 The Water Act 2016 47
3.4.8 The County Governments Act 2012 48
3.4.9 The Valuers Act (Cap 532), 1985 48
3.4.10 Physical Planning Act (Cap. 286) 48
3.4.11 The Employment Act, 2007 48
3.4.12 Work Injury Compensation Benefit Act (WIBA) 2007 49
3.4.13 Occupational Safety and Health Act 2007 49
3.4.14 The Public Health Act (Chapter 242) of Revised Edition 2012 49
3.4.15 Urban Areas and Cities Act No 13 of 2011 49
3.4.16 The Environment and Land Court Act, 2011 50
3.4.17 Community Land Act 2016 50
3.4.18 Land Act, 2012. 50
3.4.19 The National Land Commission Act, 2012 (No. 5 of 2012) 51
3.4.20 The Penal Code (Cap. 63) 51
3.4.21 Building Code 2009 52
3.4.22 The National Museums and Heritage Act, 2006 52
3.4.23 HIV / AIDS Act, 2006 52
3.4.24 The National Gender and Equality Act, 2011 52
3.4.25 The Sexual Offences Act, 2006 and its amendment 2012 53
3.4.26 Persons with Disability Act, Chapter 133 53
3.4.27 Security Laws (Amendment) Act, 2014 53
3.4.28 Matrimonial Property Act (No. 48 of 2013) 53
3.4.29 The Children Act, 2001 54
3.4.30 Protection Against Domestic Violence Act, 2015 54
3.4.31 Prohibition of Female Genital Mutilation Act, 2011 54
3.5 World Bank Safeguards Policies 54
3.5.1 Operational Policy 4.01: Environmental Assessment 54
3.5.2 Operational Policy 4.04 Natural Habitats 55
3.5.3 Bank Operational Policy 4.10: Indigenous Peoples 55
3.5.4 Operational Policy 4.11-Physical Cultural Resources 55
3.5.5 The Bank's Operational Policy 4.12: Involuntary Resettlement 56
3.5.6 World Bank Directive on Vulnerable Groups 56
3.5.7 World Bank Policy on Access to Information, 2010 57
3.6 World Bank GROUP Environmental, Health and Safety (EHS) Guidelines 57
3.6.1 Environmental Guidelines 57
3.6.2 Occupational Health and Safety Guidelines 58
3.6.3 Community Health and Safety Guidelines 59
3.6.4 Construction and Decommissioning Guidelines 59
3.7 Gaps Between Kenyan Legislation and World Bank Safeguards with
Recommendations for Bridging the Gaps 59
3.7.1 International Conventions, Treaties and Guidelines 63
3.7.1.1 Vienna Convention on the Protection of the Ozone Layer 63
Pan-19-003 - iii -
KeNHA
3.7.1.2 United Nations Convention on Biological Diversity (UNCBD) 63

3.7.1.3 African Convention on the Conservation of Nature and Natural
Resources 63
3.7.1.4 Convention on International Trade in Endangered Species 63
3.7.1.5 The World Commission on Environment and Development (The
Brundtland Commission of 1987) 63
3.7.1.6 The Ramsar Convention for the conservation and sustainable utilization
of wetlands 64
3.7.1.7 United Nations Convention to Combat Desertification (UNCCD) 64
3.7.1.8 The 1992 United Nations Framework Convention on Climate Change
(UNFCCC) 64
3.7.1.9 The Paris Agreement 64
3.7.1.10 Rio Declaration on Environment and Development 64
3.7.1.11 Earth Summit on Sustainable Development Agenda 21 65
3.7.1.12 Convention on the Rights of the Child 65
3.7.1.13 Convention on the Elimination of all forms of Discrimination against
Women 65
3.7.1.14 International Labour Organization 66
3.7.1.15 Sustainable Development Goals (SDGs) 66
3.8 Institutional Framework 67
3.9 Environment Related Permits Required for this Project 71
4 ESIA STUDY APPROACH AND METHODOLOGY 75
4.1 Desktop Review of Project Documents 75
4.2 Field Assessment 76
4.3 Identification and Engagement of Stakeholders 77
4.3.1 Stakeholder Identification 77
4.3.2 Method used for Stakeholder Engagement 77
4.4 Impact Analysis and Development of Mitigation Measures 79
5 PROJECT ALTERNATIVES 80
5.1 Analysis of Alternatives 80
5.1.1 No Upgrading of the Existing Road (‘No Action’ Option) 80
5.1.2 Analysis of Alternative Construction Materials and Technology 80
5.1.3 Solid Waste Management Alternatives 81
5.1.4 Alternative mode of Transportation 81
5.1.5 Upgrading the Existing Road without any changes in Route Alignment 81
6 ENVIRONMENTAL AND SOCIAL BASELINE 82
6.1 Physical Environment 82
6.1.1 Location 82
6.1.2 Topography 82
6.1.3 Climate 83
6.1.4 Geology and Soils 84
6.1.5 Hydrology (Surface Water) 84
6.1.5.1 Lorian Swamp 84
6.1.5.2 Borji Swamp 88
6.1.5.3 Key Physical Sensitivities 88
6.1.6 Air Quality 91
6.1.7 Noise and Vibrations 91
6.1.8 Water Quality 91
6.2 Biological Environment (Flora and Fauna) 92
6.2.1 Flora 92
Pan-19-003 - iv -
KeNHA
6.2.2 Environmentally Sensitive Habitats 96

6.2.2.1 Source of Energy 96
6.2.2.2 Other Forest Resources 96
6.2.2.3 Laggas 96
6.2.3 Fauna 97
6.2.4 Wildlife Dispersal Areas 100
6.2.4.1 The Grevy’s Zebra 101
6.2.4.2 The Oryx 102
6.2.4.3 The Giraffe 103
6.2.5 Avifauna 103
6.3 Socio- economic Environment 105
6.3.1 Administration 105
6.3.2 Population Size and Density 108
6.3.2.1 Population Size for Isiolo County and Respective Subcounties 108
6.3.2.2 Population Size for Garissa County and Respective Subcounties 109
6.3.2.3 Population Size for Wajir County and Respective Subcounties 109
6.3.2.4 Population Sizes for Urban Centres 110
6.3.3 Public Health 111
6.3.4 Land Tenure and Land Use 112
6.3.4.1 Land tenure 112
6.3.4.2 Land use 113
6.3.5 Settlement Patterns 113
6.3.6 Education Institutions 113
6.3.7 Security 114
6.3.8 Inter/Intra Clan Conflict 115
6.3.9 Physical Cultural Resources 115
6.3.10 Local Communities/Indigenous Peoples 115
6.3.10.1 Somali Community in Wajir 116
6.3.10.2 Borana Community 116
6.3.11 Gender 117
6.3.12 Poverty Levels 119
6.3.13 Gender Based Violence 119
6.3.14 Gender and Women Empowerment 121
6.3.15 Relief Operations 122
6.3.16 Trade and Industry 123
6.3.17 Transport and Communication 123
6.3.18 Tourism 123
6.4 Socio-Economic Activities and Household Survey Results 124
6.5 Socio-Economic Activities 124
6.5.1 Socio-Economic Activities in Garissa County 124
6.5.2 Socio-Economic Activities in Isiolo County 124
6.5.3 Socio-Economic Activities in Wajir County 125
6.6 The Socio-Economic Survey Results of the Road Corridor Community 128
6.6.1 Livelihoods 129
6.6.2 Age Distribution of Modogashe - Samatar - Wajir Road Corridor Residents 129
6.6.3 Quality of Housing Structures of the Residents 130
6.6.4 Level of Education of Respondents along the Road Corridor 130
6.6.5 Religious Following 131
6.6.6 Respondents for Drinking Water Sources 132
6.6.7 Respondents on Walking Distance to Water Source 132
6.6.8 Source of Energy for Cooking 133
6.6.9 Source of Energy for Lighting 133
Pan-19-003 -v-
KeNHA
6.6.10 Distance to Health Centre/Dispensary 134

6.6.11 Sanitation Facilities along the Project Road Corridor 134
6.6.12 Common Diseases Affecting Respondents along Road Corridor 135
6.6.13 Distribution of Income for Road Corridor Respondents 135
6.7 Conclusion 136
7 PUBLIC CONSULTATION AND PARTICIPATION 137
7.1 Legal Requirements 137
7.2 Stakeholder Identification and Mapping 137
7.2.1 Stakeholder Engagement and Public Consultations during Previous Study 138
7.2.2 Stakeholder Engagement and Public Consultation Meetings in Current Study 138
7.2.2.1 Key Stakeholder Consultations 138
7.2.2.2 Public Consultation Meetings 139
7.2.2.3 Focused Group Discussions 141
7.2.2.4 Interpreters During Consultations 144
7.2.2.5 Overall Findings of the Meetings 145
7.2.3 Disclosure of the ESIA 151
7.2.4 Consultation during the Project Duration 151
8 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION
MEASURES 152
8.1 Categorization of Impacts 152
8.2 Potential Positive Impacts 161
8.3 Environmental Impacts and Mitigation Measures 162
8.3.1 Pre-Construction Phase/ Impacts 162
8.3.2 Construction Phase Impacts 163
8.3.2.1 Impacts on Flora 163
8.3.2.2 Impacts on Fauna 163
8.3.2.3 Wildlife and Livestock Crossing 164
8.3.2.4 Impacts of Camp Site Construction and Operation 165
8.3.2.5 Noise Pollution and Excessive Vibrations at the Road Construction Site
166
8.3.2.6 Air Pollution at the road construction site 167
8.3.2.7 Construction Materials Harvesting (Borrow Pits and Quarry) and
Batching Plants 167
8.3.2.8 Oil and Fuel Spills 170
8.3.2.9 Soil Degradation 171
8.3.2.10 Proliferation of Invasive Species – Juliflora Prosopis 172
8.3.2.11 Interference with existing Water Sources 172
8.3.2.12 Increased Traffic along the Project Road 172
8.3.2.13 Impacts on Physical Cultural Resources 173
8.3.2.14 Occupational and Health and Safety 175
8.3.2.15 Community Health and Safety 176
8.3.2.16 Impacts on Lorian and Borji Swamp Ecosystems 177
8.4 Social Impacts and Mitigation Measures 177
8.4.1 Construction Phase Impacts 178
8.4.1.1 Employment of Locals 178
8.4.1.2 Increase in cases of HIV and AIDS 179
8.4.1.3 Liability for Loss of Life Injury or Damage to Private Property 179
8.4.1.4 Labour Influx 180
8.4.1.5 Economic Impacts 181
8.4.1.6 GBV, Sexual Harassment and SEA 182
8.4.1.7 Project Impacts on Women 183
Pan-19-003 - vi -
KeNHA
8.4.1.8 Security Risks and Crime Management 183

8.4.1.9 Impacts on Children 184
8.4.1.10 Intra/Inter Community Conflict 185
8.4.1.11 Conflicts from Project Construction Activities 185
8.4.2 Operation Phase Impacts 186
8.4.2.1 Positive Environmental Impacts during Operation 186
8.4.2.2 Increased Traffic along the Project Road 186
8.4.2.3 Air Quality 186
8.4.2.4 Community (Public) Health and Safety 187
8.4.2.5 Risk of Truck Drivers Stopping along the Project Road 187
8.4.2.6 Impacts of newcomers to the project area 187
8.4.3 Impacts during Decommissioning 187
8.4.3.1 Decommissioning of Exhausted Material Sites 188
8.4.3.2 Decommissioning of Contractor’s Camp 188
8.5 Cumulative Impacts 188
8.5.1 Identification of Potential Cumulative Impacts 189
9 ENVIRONMENT AND SOCIAL MANAGEMENT PLAN (ESMP) 192
9.1 Objectives of the ESMP 192
9.2 Responsibilities for Environmental and Social Management Plan 192
9.3 Contractor Clause 215
9.3.1 Contractors Obligations 215
9.3.2 The Supervising Consultant 216
9.3.3 Kenya National Highways Authority (KeNHA) 216
9.3.4 KeNHA Safeguards Capacity Enhancement 217
10 GRIEVANCE REDRESS MECHANISM (GRM) 218
10.1.1 Proposed Grievance Redress Mechanism 218
10.1.2 Appointment of Grievance Redress Committee Members 218
10.1.3 Remuneration of Grievance Redress Committee Members 219
10.1.4 Capacity-Building for Grievance Committee 219
10.1.5 The Commission on Administrative Justice (CAJ) – the Ombudsman 220
10.1.6 National Land Commission 221
10.1.7 Courts of Kenya 221
10.1.8 grievance mechanism for workers 222
11 SOUND ENVIRONMENTAL AND SOCIAL MONITORING 223
11.1.1 Internal Environmental and Social Monitoring 223
12 CONCLUSIONS AND RECOMMENDATIONS 232
12.1 Conclusions 232
12.2 Recommendation 232
13 COLOPHON 238
List of Maps
Map 1: Location of the Proposed Modogashe - Wajir (A13) Road 7
Map 2: Map Showing Lorian and Borji Swamps 90
Map 3: Wildlife Conservation Areas 100
Map 4: Habitat and Dispersal Area for Grevy’s Zebra 101
Map 5: Habitat and Dispersal Area for the Oryx 102
Map 6: Habitat and Dispersal Area for the Giraffe 103
Map 7: Sub Counties in Wajir County 106
Map 8: Subcounties in Garissa County 107
Pan-19-003 - vii -
KeNHA
Map 9: Livelihood Zones of Garissa County 126

Map 10: Livelihood Zones of Isiolo County 127
Map 11: Livelihood Zones of Wajir County 128
List of Tables
Table 1: Pavement Structure for Main Carriageway 13
Table 2: Drainage Structures at Lorian Swamp 17
Table 3: Existing Drainage Structures along the Project Road 17
Table 4: Identified Potential Gravel Sources for Road Construction 18
Table 5: Identified Potential Gravel Sources for Road Construction 19
Table 6: Potential hard stone sources 19
Table 7: Sand Sources along Modogashe-Samatar Road 20
Table 8: Potential Water Sources for Construction (Modogashe-Samatar Road) 21
Table 9: Potential Water Sources for Construction (Samatar-Wajir Road) 21
Table 10: Summary of AADTs (2018) along Samatar-Wajir Road 23
Table 11: Summary of AADTs (2018) along Modogashe-Samatar Road 23
Table 12: Classification of Waste by type 28
Table 13: Waste Disposal options according to type 29
Table 14: Characteristics of Potential Project Waste 30
Table 15: Construction Cost of Modogashe-Samatar Segment 32
Table 16: Construction Cost of Samatar-Wajir Segment 32
Table 17: Quality Standards for Domestic Water (NEMA) 43
Table 18: Maximum Permissible Noise Levels – Residential and Commercial (NEMA)45
Table 19: Maximum Permissible Noise Levels for Construction Sites (NEMA) 45
Table 20: Summary of Gaps between Kenyan legislation and World Bank Safeguards
with recommendations 60
Table 21: Roles of Organizations involved in the Roads Development 68
Table 22: Environment-related Permits required for the Project 72
Table 23: The Variation in Elevation Profile from Modogashe to Wajir 82
Table 24: Summary of Road Corridor Physical Baseline Sensitivities 89
Table 25: Physical/Chemical Water Analysis Report 92
Table 26: List of Flora identified along the Road Corridor 93
Table 27: List of Fauna identified along the Road Corridor 98
Table 28: List of Avifauna identified along the Road Corridor 105
Table 29: Project Area Administration 108
Table 30: Isiolo County and Subcounty Population 108
Table 31: Garissa County and Sub County Population 109
Table 32: Wajir County and Sub County Population 109
Table 33: Centres along the Modogashe-Wajir Road 110
Table 34: Types of Health Facilities per County 112
Table 35: Pupil Enrollment in ECDE Centres 113
Table 36: Pupil Enrollment in Primary and Secondary Schools per County 113
Table 37: Schools Mapped along the Road Corridor 114
Table 38: Stakeholder Engagement and Public Consultations during Previous Studies
138
Table 39: ESIA Public Consultation Meeting (PCM) Venues and Dates 139
Table 40: Focus Group Discussion with Women during Current Study 141
Table 41: Focus Group Discussion with Youth during Current Study 142
Table 42: Focus Group Discussion with Men during Current Study 143
Table 43: Summary of Question, Issues/Concerns from Key Stakeholders/PCMs/FGDs
146
Table 44: Assessment of Potential Negative Impacts 154
Pan-19-003 - viii -
KeNHA
Table 45: Potential Positive Impacts and the Justification 161

Table 46: Summary of Potential Cumulative Impacts 189
Table 47: Responsibilities for Environmental and Social Management 192
Table 48: Environmental and Social Management Plan 194
Table 49: Roles of Safeguards Officers Engaged by the Contractor 216
Table 50: Internal Environmental and Social Monitoring of Construction Activities 224
Table 51: Environmental and Social Monitoring Plan (Monitoring Plan) 226
List of Figures
Figure 1: Typical rural road cross section 10

Figure 2: Typical urban road cross section 11
Figure 3: Typical urban road cross section 15
Figure 4: Location of Map of material sites along the Modogashe Samatar road 18
Figure 5: Location Map of material sites along the Modogashe Samatar road 19
Figure 6: Location Map of Hard Stone Quarries 20
Figure 7: Sand and Water Sources along the Samatar-Wajir Road 22
Figure 8: Livelihood Categories for Persons located next to the road 129
Figure 9: Modogashe - Wajir Road Area Respondents According to Age 130
Figure 10: Type of Housing along Modogashe - Wajir (A13) Road 130
Figure 11: Education Levels of the Respondents 131
Figure 12: Road Corridor Respondents According to Religious Following 131
Figure 13: Drinking Water Sources for Residents along Road Corridor 132
Figure 14: Walking Distances to Water Sources 132
Figure 15: Cooking Energy for Road Corridor Community 133
Figure 16: Energy Source for Lighting 133
Figure 17: Distance to nearest Health Facility for respondents 134
Figure 18: Sanitation Facilities along the Road Corridor 134
Figure 19: Common Diseases Affecting Respondents 135
Figure 20: Income Distribution for Modogashe - Wajir Road Corridor 135
List of Plates
Plate 1: Photo showing the Flat Terrain of the Project Area 83

Plate 2: Lagboghol Lagga – February 2019 96
Plate 3: Giraffes near Leheley – February 2019 98
Plate 4: Marabou Stork at KWS Office Ground – February2019 104
Plate 5: Superb Starling at Borji Centre – February2019 104
Plate 7: Aerial View of Habaswein Township along the Project Road 111
Plate 6: Aerial View of Leheley Centre 111
Plate 8: Structures along the Project Road Kanchara Centre – February 2019 117
Plate 9: Structures along the Project Road – Kanchara Centre – February 2019 117
Plate 10: One of the PCM in Progress 139
Plate 11: FGD with Women 142
Plate 12: FGD with Youth 143
Plate 13: FGD with Men 144
Annexes
Annex 1: People Contacted During the ESIA Study
Annex 2: Minutes of PCMs and Attendance Registers
Annex 3: FGD Registers
Annex 4: Biophysical Features along the Modogashe-Wajir Road
Pan-19-003 - ix -
KeNHA
Annex 5: Analysis of Key Stakeholder Questionnaires

Annex 6: Chance Find Procedures
Annex 7: Ambient Air Quality Tolerance Limit
Annex 8: Standards for Effluent Discharge to the Environment
Annex 9: KWS Letter on Wildlife Movement
Annex 10: Photographic Plates
Pan-19-003 -x-
KeNHA
DEFINITION OF KEY TERMS
Air quality: Means the composition of the air in terms of how much pollution it contains
Analysis: Means the testing or examination of any matter, substance or process for the
purpose of determining its composition or qualities or its effect (whether physical,
chemical or biological) on any segment of the environment;
Assets: Comprises land, structures or crops/trees, unless otherwise defined.
Biological Diversity: Means the variability among living organisms from all sources
including, terrestrial ecosystems, aquatic ecosystems and the ecological complexes of
which they are part; this includes diversity within species, among species and of
ecosystems;
Chainage: Distance along the proposed road from a fixed commencing point presented
in kilometers
Ecosystem: Means a dynamic complex of plant, animal, micro-organism communities

and their non-living environment interacting as a functional unit;
Effluent: Means gaseous waste, water or liquid or other fluid of domestic, agricultural,
trade or industrial origin treated or untreated and discharged directly or indirectly into the
aquatic environment;
Environment: Includes the physical factors of the surroundings of human beings

including land, water, atmosphere, climate, sound, odour, taste, the biological factors of
animals and plants and the social factor of aesthetics and includes both the natural and
the built environment;
Environmental and Social Assessment (Assessment) is a process that determines

the potential environmental and social risks and impacts (including labour, health, and
safety) of a proposed Project in its area of influence
Environmental and Social Impact Assessment (ESIA) is a comprehensive document

of a Project’s potential environmental and social risks and impacts.
Environmental and Social Management Plan (ESMP) summarizes the commitments

to address and mitigate risks and impacts identified as part of the Assessment, through
avoidance, minimization, and compensation/offset. This may range from a brief
description of routine mitigation measures to a series of more comprehensive
management plans (e.g. water management plan, waste management plan, resettlement
action plan, indigenous peoples plan, emergency preparedness and response plan,
decommissioning plan). The level of detail and complexity of the ESMP and the priority
of the identified measures and actions will be commensurate with the Project’s potential
risks and impacts.
Environmental Management includes the protection, conservation and sustainable use

of the various elements or components of the environment.
Pan-19-003 -a-
KeNHA
Environmental Monitoring means the continuous or periodic determination of actual

and potential effects of any activity or phenomenon on the environment whether short-
term or long term.
Household: Family or collection of people, which function as a single economic unit.
Income Restoration: Measures required to ensure that PAPs have the resources to at
least restore, if not improve, their livelihoods.
Indigenous Peoples: People indigenous to an area and include ethnic minorities as

defined by World Bank Operational Policy on Indigenous Peoples (OP 4.10).
Key Stakeholders: Those inhabitants of an area affected by a project who have the most
to lose and the most to gain from the completion of the project, and whose concerns must
be addressed in an environmental assessment.
Natural Resources include resources of the air, land, water, animals and plants
including their aesthetic qualities.
Noise means any undesirable sound that is intrinsically objectionable or that may cause
adverse effects on human health or the environment.
Ozone layer means the layer of the atmospheric zone above the planetary boundary
layer as defined in the Vienna Convention for the Protection of the Ozone Layer, 1985.
Pollutant includes any substance whether liquid, solid or gaseous which

1. may directly or indirectly alter the quality of any element of the receiving environment;
2. is hazardous or potentially hazardous to human health or the environment; and
includes objectionable odours, radio-activity, noise, temperature change or physical,
chemical or biological change to any segment or element of the environment;
Pollution: Means any direct or indirect alteration of the physical, thermal, chemical,
biological, or radio-active properties of any part of the environment by discharging,
emitting, or depositing wastes so as to affect any beneficial use adversely, to cause a
condition which is hazardous or potentially hazardous to public health, safety or welfare,
or to animals, birds, wildlife, fish or aquatic life, or to plants or to cause contravention of
any condition, limitation, or restriction which is subject to a licence under the EMCA, Cap
387.
Project Affected Person (PAP): Any person who, on account of the execution of the
Project, or any of its components or subprojects would regardless of land type have their:
right, title or interest in any house, titled/trust land (including residential, agricultural and
grazing land) or any other fixed or movable asset acquired or possessed, in full or in part,
permanently or temporarily; business, occupation, work, place of residence or habitat
adversely affected; or Standard of living adversely affected.
Proponent: The agency proposing and has responsibility for implementation of a project.
Pan-19-003 -b-
KeNHA
Public Consultation Meeting (PCM): Meeting convened to gain public input prior to
consideration of land use application for a proposed project. The forum is used to inform
the public about the product and discuss the potential positive and negative impacts and
proposed mitigation measures
Rehabilitation: An enhanced period of maintenance intended to restore a project to its

original condition. Structural defects are repaired without major changes to alignment and
width standards as would be implemented in a reconstruction.
Relocation: Physical moving of PAPs from their pre-project place or residence, place for
work or business premises, to an area within the same land that is not affected by the
project.
Resettlement Action Plan (RAP): Time-bound action plan, with budget, setting out
resettlement strategy, objectives, eligibility criteria, entitlements, actions, responsibilities,
monitoring and evaluation. The type of RAP can be categorized by the magnitude of the
resettlement required.
Socio-economic Survey: Census of project area persons which is prepared through a

detailed enumeration survey based on actual data collected.
Stakeholder Meeting: Meeting with Key Stakeholders to inform them about the project
and seek guidance/consensus about the project activities
Squatter: A person occupying land to which they have no claim under any tenure but is
eligible for compensation as he/she is present during the census and inventory of assets
or in occupation of private land for over 12 years in accordance with The Limitations of
Actions Act.
Suspended Particulate Matter means all particulate material which persists in the
atmosphere or in flue gas stream for lengthy periods because the particles are too small
in size to have appreciable falling velocity.
UTM (Universal Transverse Mercator): Conformal projection that uses a 2-dimensional

Cartesian coordinate system to give locations on the surface of the Earth.
Pan-19-003 -c-
KeNHA
LIST OF ACRONYMS
AADT Annual Average Daily Traffic

ACC Assistant County Commissioner
ACK Anglican Church of Kenya
ALCS Axle Load Control Station
BCM Billion Cubic Metres
BD Biological Diversity
BP Bank Procedure
CAJ Commission on Administrative Justice
CBD Central Business District
CBO Community Based Organisation
CDF Constituency Development Fund
CESMP Contractor’s Environmental and Social Management Plan
°C Degrees Celsius
CC County Commissioner
CSR Cooperate Social Responsibility
DCC Deputy County Commissioner
DOSHS Directorate of Occupational Safety and Health Services
EIA Environmental Impact Assessment
EMCA Environmental Management and Coordination Act (1999)
EMF Electromagnetic Field
EMP Environmental Management Plan
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
FM Frequency Modulation
FNU Formazin Nephelometric Units
GBV Gender Based Violence
GE Gastroenteritis
GoK Government of Kenya
GRC Grievance Redress Committee
GRM Grievance Redress Mechanism
HH Household Head
HTN Hypertension
ICNIRP International Commission on Non-Ionizing Radiation Protection
IEC Information, Education and Information
ILO International Labour Organisation
ISS Immune Suppression Syndrome
KCAA Kenya Civil Aviation Authority
KeNHA Kenya National Highways Authority
KeRRA Kenya Ruaral Roads Authority
KES Kenya Shillings
Km Kilometres
Km² Square Kilometres
KNBS Kenya National Bureau of Statistics
KNCHR Kenya National Commission on Human Rights
KURA Kenya Urban Roads Authority
kV Kilo Volts
KWS Kenya Wildlife Service
LAPSSET Lamu Port, Soith Sudan, Ethipia Transport Corridor
m Meters
M Million
Mm Millimeters
NCA National Construction Authority
Pan-19-003 -d-
KeNHA
ND Non Detect
NEMA National Environment Management Authority
NETIP North Eastern Transport Improvement Project
NIB National Irrigation Board
NLC National Land Commission
NMK National Museums of Kenya
NNS Neonatal Sepsis
NTU Nephelometric Turbidity Units
NRPB National Radiological Protection Board
OHS Occupational Health and Safety
OOP Office of the President
OP Operational Procedure
OPD Out Patient Department
OPP Organo-Phosphate Poisoning
OSHA Occupational Safety and Health Act
PAPs Project Affected Persons
PCM Public Consultation Meeting
PDP Part Development Plan
ppb Parts Per Billion
POP Persistent Organic Pollutants
PPE Personal Protective Equipment
PTB Pulmonary Tuberculosis
Q&A Questions and Answers
RAP Resettlement Action Plan
ROW Right of Way
RTA Road Traffic Accident
SEA Sexual Exploitation and Abuse
STI Sexually Transmitted Infection
TB Tuberculosis
TLV Threshold Limit Value
TOR Terms of Reference
UNEP United Nations Environment Programme
UTI Urinary Tract Infection
URTI Upper Respiratory Tract Infection
UTM Universal Transverse Mercator
VAC Violence Againt Children
VCT Voluntary Counselling and Testing
WHO World Health Organisation
WMP Waste Management Plan
WRA Water Resources Authority
µg/m³ Micro-gram per cubic metre
UTM Universal Transverse Mercator
WRMA Water Resources Management Authority
µS/cm Microsiemens per Centimetre
Pan-19-003 -e-
KeNHA
EXECUTIVE SUMMARY
INTRODUCTION
1. Kenya National Highways Authority (KeNHA) is a state corporation within the

Ministry of Transport, Infrastructure, Housing and Urban Development
(MoTIH&UD), established under the Kenya Roads Act 2007 with the responsibility
for the management, development, rehabilitation and maintenance of international
trunk roads linking centres of international importance and crossing international
boundaries or terminating at international ports(Class A road), national trunk roads
linking internationally important centres (Class B roads), and primarily roads linking
provincially important centres to each other or two higher-class roads (Class C
roads).In undertaking this mandate, the Authority propels the country to achieve its
infrastructure goals espoused in the vision 2030.
2. The Government of Kenya (GoK), through Kenya National Highways Authority

has applied for a credit from the World Bank towards the cost of the North-Eastern
Transport Improvement Project (NETIP). From these proceeds KeNHA will
undertake the design, safeguards instrument preparation and the construction
works of the road. The objectives of the proposed project are:
• To improve the movement of goods and people along Isiolo-Wajir-Mandera
road
• To enhance connectivity between Kenya and Somalia
• To improve connectivity between Kenya andEthiopia.
3. The project will be implemented by Kenya National Highways Authority as part

of meeting its mandate of developing, rehabilitating and maintaining trunk roads.
KeNHA intends to use a portion of the credit proceeds in upgrading the Isiolo-
Mandera road to bitumen standard. This includes the Modogashe – Wajir section.
The Proposed road starts from Modogashe town and passes through Habaswein,
Samatar and Wajir town covering a total distance of 157km. The NETIP is aimed at
meeting the above outlined objectives and comprises of the following three
components:
• Component 1: Upgrading Selected Critical Road Infrastructure and

associated roadside amenities (US$455.50 million).
• Component 2: Institutional Development and Project Monitoring and
Management (US$12.50 million)
• Component 3: Enhancing Internet Connectivity (US$34.00 million). Support
to Information and Communication Technology Authority (ICTA).
4. Need for ESIA Study Review and Update. KeNHA engaged Intercontinental
Consultants and Technocrats Pvt. Ltd.in association with ITEC Engineering Ltd to
carry out review and update of project designs and preparation of ESIA Reports in
2017/8. During the preparation of the ESIA Report 2018, the project was assigned
Environmental Assessment Category B since the anticipated impacts were not
expected be sensitive, irreversible and unprecedented. However, in the course of
project preparation, new information emerged, and the World Bank and KeNHA
have recategorized the Environmental Assessment Category to 'A', because it is
anticipated that the potential impacts will be significant and adverse.
Pan-19-003 -f-
KeNHA
It is also forseen that the direct and indirect environmental and social impacts are
likely to be diverse, sensitive or unprecendented.
5. The proposed road project will have major impacts along the road corridor
including loss of grazing land along the road, change in the landscape not just along
the quarry and borrow sites (loss of materials), impacts to wetlands like Lorian and
Borji Swamps, dry river beds which act as source of water for domestic use,
livestock and wildlife drinking points. There will also be establishment of larger
market centres and towns, labour influx due to people moving into the area in
search of new job and business opportunities, interference with existing ways of
life, Gender Based Violence (GBV), increased conflicts, pressure on existing
resources, increase in traffic during the operation phase leading to increase of
foreign members to the community. All these impacts will have a significant change
to the existing status quo hence, this review and update of the ESIA study provided
in this report.
6. Project description. The Modogashe-Wajir Road project traverses Garissa,

Isiolo and Wajir Counties in the North Eastern part of Kenya. It covers a total
distance of 157km. The road traverses eight (8) other centres in between namely
Skanska, Habaswein, Lagdima, Kanchara, Samatar/Guticha, Lagbogol Borji,
Leheley and Wajir Town with few sensitive receptors along the road corridor i.e.
Lorian and Borji Swamps, learning institutions, religious facilities and health
centres. The road reserve is 60m and most of the areas traversed by this road is
community Land. The road is in poor state with a lot of corrugations.
7. Location of the Project Road. This ESIA covers the section from Modogashe
– Wajir which will be covered in component 1 of NETIP. The project road is located
in the North Eastern part of Kenya traversing through Isiolo County, Garissa County
and Wajir County. The road starts at Modogashe (UTM 0518923, 00800801) and
terminates in Wajir town (UTM 0617643, 0193885 covering a total distance of
157km. The road runs from Modogashe through Habaswein, Samatar and ends in
Wajir town as shown on the map below.
8. The North Eastern counties of Isiolo, Wajir, and Garissa covering a total area
of approximately 152,694km2 or 26 percent of Kenya’s land mass has a road
network of only 9,386km or 6 percent of the total road network in the country which
is predominately unpaved and in poor state.
9. Due to the poor road condition, during the rainy season the region is cut-off
from the rest of the country while in the dry season it takes on average three days
to reach Mandera via Isiolo from Nairobi a distance of about 983km. According to
the KIHBS 2005/06 Basic Report, 84 percent of the population in Wajir, 63 percent
for Isiolo, 55 percent for Garissa, live below the absolute poverty line as compared
to 47 percent nationally. Similar figures are exhibited for literacy with an average
rate of only 28 percent for the region compared to 79 percent of the national average
10. The Government of Kenya (GoK) has applied for a credit from the World Bank
towards the cost of the North-Eastern Transport Improvement Project (NETIP). The
proposed project development objectives are to improve the movement of goods
and people along Isiolo-Wajir-Mandera road corridor and to enhance connectivity
between Kenya and Somalia and Ethiopia.
Pan-19-003 -g-
KeNHA
Map Showing the Project Road
Pan-19-003 -h-
KeNHA
11. Legal framework. The main legislation that governs environmental

management in Kenya is the Environmental Management & Coordination
(Amended) Act of 2015 typically referred to as EMCA. EMCA calls for
Environmental Impact assessment (EIA) (under Section 58) to guide the
implementation of environmentally sound decisions and empowers stakeholders to
participate in sustainable management of the natural resources. Part V from
Sections 42 – 57 deals with Protection and Conservation of the Environment while
Part VI deals with Integrated Environmental Impact Assessment. Projects likely to
cause environmental impacts require that an environmental and social impact
assessment study to be carried out. It is under this provision that the current study
has been undertaken because Legal Notice No, 150 of August 19, 2016 places this
proposed road project under the High-Risk Category.
12. The other relevant legislation applied during this study are the regulations
borne of EMCA Cap 387 namely the Environmental Impact Assessment and Audit
Regulations 2003, the Environmental Management and Co-ordination (Water
Quality) Regulations 2006,; the Environmental Management Co-ordination Act
(Wetlands, River Banks, Lake Shore and Sea Shoe Management) Regulations
2009; the Environmental Management Coordination (Noise and Excessive
Vibration Pollution Control) Regulations 2009; and the Environmental Management
and Co-ordination (Conservation of Biological Diversity Resource Access to
Genetic Resource and Benefit Sharing l) Regulations2006, (Legal Notice 61), Air
quality Regulations 2013,. the Environmental Management and Co-ordination
(Controlled Substances) Regulations, 2007 among others.
13. The other sectorial legislation applicable to this project include The Kenya
Roads Act (2007), the Constitution of Kenya 2010, the Public Health Act (CAP 242),
the Wildlife Conservation and Management Act No 47 of 2013 Revised in 2014, the
Occupational Safety and Health Act 2007 Revised in 2012, the Community Land
Act No 27 Revised in 2016, the Children Act No 8 of 2001 Revised in 2018 and the
Water Act No 43 of 2016 Revised in 2017.
14. Given the vulnerable nature of the women and children in the project area due
to being subjected to GBV and other forms of violence, policies and legislation
governing these have been cited. They include among others Gender Policy of
2011, Sexual and Gender Based Violence (SGBV) of 2017, The Education Gender
Policy, National Gender and Equality Act, Protection Agains’t Domestic Violence
Act and Children Act among others.
15. In addition to the legislation, the World Bank Operational Safeguards policies
that were triggered for the project include:
• OP/BP 4.01 Environmental Assessment

• OP/BP 4.04 Natural Habitats
• OP/BP 4.10 Indigenous People
• OP/BP 4.11 Physical Cultural Resources
• OP/BP 4.12 Involuntary Resettlement
• World Bank Policy on Access to Information 2010
• World Bank Group Environmental, Health and Safety (EHS) General
Guidelines
Pan-19-003 -i-
KeNHA
16. Study Methodology. The approach and methodology used to carry out the
study included desktop review of the project documents (Designs, ESIA and RAP
Study Reports) carried out in 2017/8 to establish the biophysical, social and
environmental status of the road corridor at that time. The study was carried out
through the use of multi-faceted public consultation process which included public
consultation meetings, Focused Group Discussions and Key stakeholder meetings
to verify the previous ESIA’s stakeholder consultation findings. A field assessment
along the road corridor was also carried out to establish the environmental and
socio-economic status of the project corridor community members.
17. A questionnaire survey was conducted along the project road corridor that
yielded the data presented in the socio-economic baseline chapter of this report.
Similarly, a field assessment form was used to collect data and information on
biophysical features along the project road corridor.
18. Based on these findings and expert judgement, the consultant compiled the
projected social and environmental impacts (positive and negative) likely to
emanate from proposed project activities and the Environmental and Social
Management Plan (ESMP) which elaborates how potential adverse impacts will be
addressed and by whom and the cost of the mitigation. A monitoring Plan to check
the progress the implementation of mitigation measures has also been prepared.
19. Socio-Economic Baseline Situation. In order to bring out the character of

the economy that the road project will support with a view to locating possible
cultural and socio-economic impacts on local communities and thus understanding
the context of their mitigation of enhancement, a socio-economic survey was
carried out to collect primary socio-economic data along the road corridor. This
entailed interviewing project area community members where information data and
information on their socio-economic variables were collected. The study managed
to gather information on livelihood, quality of housing, level of education, religious
following, energy sources, sanitation facilities, common diseases and income levels
among others.
20. Primary Socio-economic Data. The outcome of this survey revealed that the
project area has a large population that has not gone to school. This is likely to
contribute to labour influx that will impact on the community. Majority of the
community members along the corridor are involved in commercial enterprises
(46%). The road will bring immediate benefit to the project area population. Given
that the survey was done in centres along the road including upcoming towns like
Modogashe, Habaswein and Wajir Town (Wajir County headquarters), for 47% to
be having an income of KShs 15,000 or less means the population is generally poor
since this amount cannot sustain a family of 5 or more members. It is also surprising
that although majority (73%) have pit latrines, 24% still undertake open defecation.
It was noted that 100% of the population along the road corridor use wood fuel
(charcoal or firewood or both). This requires intervention from the county and
national government to protect the environment. Majority (99%) of the project area
community members are Muslims. This will have a profound impact on the project
given their conservative nature and strict culture. The expected large labour influx
in the project is expected to generate conflicts due to difference in religion and
culture and must therefore be managed through implementation of code of conduct
for workers, sensitization and inculcation of tolerance.
Pan-19-003 -j-
KeNHA
Secondary Socio-economic Data
21. Population.The population data for the 3 counties traversed by the project are
given in accordance to the 2009 census and projections made for 2018. Isiolo
County had a population of 143,294 in 2009 and the projection for 2018 was
158,716. Garissa had a population of 623,060 in 2009 and the projection for 2018
was 872,284 while Wajir County had a population of 661,941 in 2009 and the
projection for 2018 was 852,963
22. Health. Majority of the population in the 3 counties live in the rural area (Wajir-
75%, Garissa-76% and Isiolo -58%) where health facilities are scarce and far
between. Challenges being experienced in the health sector include inadequate
health workers, long distance of travel to health facilities and low prevalence of
contraceptive use. According to KNBS (2014), the region has a total of 37 hospitals
with a great proportion being public. There are 62 health centres 153 dispensaries
and 111 clinics distributed across the three counties. However, most of the facilities
are found in urban centres, with the average distance to the nearest health facility
being 30 - 35km. The doctor: population ratio is 1:41,538, and nurse: population
ratio being 1:2,453.
23. Land use and Land Tenure

• The dominant livelihood in the project area is nomadic pastoralism which
contributes 75% of household incomes. This is supplemented by a limited amount
of agriculture that is carried out along the rivers and wetland areas where maize,
sorghum, some fruits and vegetables are grown using small scale irrigation.
• Much of the land (80%) is communally owned and is under the trusteeship of the
county government. Government land constitutes 10% of total land and includes
land for schools, administration, army barracks, and health facilities. The remaining
10% of the land is under private ownership and was alienated for private investment
in housing, industrial and commercial purposes.
24. Settlement Patterns. The settlements along the road corridor are few and far
apart, this is due to the nomadic pastoralism nature of the community members.
The towns and trading centres from Modogashe-Wajir include Skanska,
Habaswein, Lagdima, Kanchara, Samatar/Guticha, Lagbogol, Borji and Leheley.
25. Transport and Communication

• The main form of transportation used in the three counties of Garissa, Isiolo and
Wajir is road transport that makes use of poorly maintained unpaved roads apart
from a few paved streets in Wajir Town.
• Since the main road corridors traversing this region are in poor condition, even
distribution of local produce is difficult or impossible due to the time factor and
breakage. This has contributed to the slow economic growth in the region and
the high poverty level.
• There are three mobile service providers namely Safaricom, Airtel and Orange,
though the mobile network connection is 20 per cent which is mainly limited to
main settlement areas. Along The whole stretch from the Modogashe-Wajir
Safaricom mobile network provides good network coverage.
Pan-19-003 -k-
KeNHA
26. Commerce and Industry

• The main type of business carried out in the region is retail trade followed by
wholesale trade and hotels which are located in major towns and urban centres
like Wajir Town, Habaswein and Modogashe
• The project road Counties have no manufacturing establishments /industries
despite a huge potential in livestock product-based industries.
27. Local Communities

• The Borana inhabit the Isiolo side while the Somali are on the Garissa side. The
next Centre is Skanska which is in Garissa and partly in Wajir and inhabited by
Somalis. Other immigrant communities such as Turkana, Samburu and Meru
are found mainly around Modogashe.
• The population is predominately Somali, with three major clans, the Degodia,
(mainly in in Wajir East and West), the Ogadenis and related clans (who occupy
Wajir South), and the Ajuran in Wajir North. All clans have sub-sub clans. For
the Degodia, the Jibrail Degodia are mainly in Eldas, the Fay Degodia are in
Tarbaj and Wajir East, and the Rer Aw Mahamud in Wajir West
28. Water and Sanitation Services

• The project area is considered as a water scarce region. Water is obtained from
the seasonal rivers, boreholes, wells, dams and pans. Issues relating to access
to water often lead to conflicts between communities. Apart from Modogashe,
Habaswein and Wajir towns, the rest of the settlements do not have access to
piped water supply. Along the project road corridor majority of the residents
obtain their water from the shallow wells and boreholes.
• Along the project corridor majority (73%) own pit latrines, however the study
noted that there is still a significant number (24%) who undertake open
defecation.
29. Energy Source

• Cooking – The main source of energy used for cooking along the project corridor
is wood fuel. Over 84 percent of the households in the three counties rely on
fire wood and charcoal as their main source of energy for cooking. This has led
to over-harvesting of trees primarily for wood fuel and charcoal causing
extensive land degradation.
• Lighting – Along the project road corridor, the main source of energy for lighting
is electricity (45%) followed by kerosene lamps (35%). The towns along the
project road corridor connected to the national grid include Modogashe,
Habaswein and Wajir.
30. Gender. The Vulnerable and Marginalized Groups (VMGs) in the project area
(Somali and Borana communities are patriarchal, where women’s position is viewed
as subservient, marginalized and disempowered. Women spend most of their time
searching for water, firewood and in general taking care of the family. They do not
own any assets and do not take part in decision making and are also not accorded
the same opportunity for formal education as men, hence girls remain at home to
help their mothers with household chores. Women spend most of their time
searching for water, firewood and in general taking care of the family. Women have
therefore not been developed their skills. However, the changing socio-economic
environment in the project area has had an impact on the assigned gender roles.
Women in VMGs communities are increasingly taking up more roles that used to
be the preserve of men.
Pan-19-003 -l-
KeNHA
31. Gender based violence is rampant in the project corridor and in some cases
normalized. It’s drivers are multiple and overlapping. Socio-economic conditions,
cultural factors, as well as unequal power relations and acceptability of the use of
violence in society significantly contribute to GBV cases. Normalization of GBV and
stigma influenced by religious and cultural norms prevents GBV survivors from
speaking openly about their experiences and often keeps them from reporting their
cases to the local administration or the police.
32. To address GBV in Kenya, the GoK has enacted key instruments that include
the Constitution of Kenya that accords each individual with the Bill of rights for
protection against any form of violence and abuse. Furthermore, the constitution of
Kenya 2010, The penal code, the sexual offences Act, the Employment Act and the
children’s Act 2001 provide secure a framework for cases of Sexual and Gender
Based Violence. The Sexual Offenses Act specifically provides for the prevention
and protection of all persons from harm from sexual acts including sexual assault,
rape, defilement, sexual harassment and child prostitution. It also provides for
access to justice and psychosocial support while the Employment Act 2007
prohibits work place sexual harassment.
33. The Social Assessment (SA) carried for this project established that violence
is the default reaction when the subject of potential idolatry and sexual deviance is
discussed. This indicates that culturally there is very serious actions on the
perpetrators for which the project must be aware about with respect to contractors
and project workers. In light of the fact that the road corridor will be implemented
in marginalized, poor and remote communities, with some involving significant labor
influx in a county characterized by high rates of GBV, the risk of the project
contributing to or exacerbating risks of SEA are high. There is therefore critical need
to establish an effective GBV prevention, risk mitigation and response strategy for
the project.
34. Education. Due to the nomadic lifestyle of the project area community, uptake
of education is limited. The assessment on the level of education of the project area
community indicated that majority (48%) have not attended school while 25% have
only attained primary education. 17% have attained secondary level of education
while 10% have attained post-secondary level of education. The Somali and Borana
communities consider herding as a priority hence boys drop out to tend to livestock.
35. Security. The project in coordination with the relavant national and county
security agencies have carried out Security Risk Assessment and Security
Management Plan, potential security issues include: conflicts over boundaries at
Modogashe between the Borana and Somali communities; water and grazing
access; inter-clan political tension; and frequent Al Shabaab attacks makes. The
Security Management Plan (SMP) has adopted the WB Good Practice Note-
Assessing and Managing the Risks and Impacts of the Use of Security Personnel;
and the IFC Good Practice Handbook-Use of Security Forces: Assessing and
Managing Risks and Impacts.
Pan-19-003 -m-
KeNHA
36. Inter/Intra Clan Conflict

• The project road lies along the boundary line that separates the Somali and
Borana communities in Modogashe town. The inter clan conflicts between the
Somali and Borana occur due to disagreements on resource sharing and
disregard for established communal control in the use of water and pasture
compounded by boundary disputes.
• The intra clan conflicts are rare, however, it was observed that there was
growing intra clan animosity between the inhabitants of Samatar/Guticha Centre
where the Wajir West community did not want the inhabitants of Wajir South to
collect water from their community borehole. During project implementation
such animosity are likely to escalate if there is no comprehensive consultation
or inclusiveness in the planning and sharing of opportunities.
37. The Physical and Biological Baseline Information

• Topography. Wajir County is a featureless plain and lies between 150 m and
460 m above sea level. The plain rises gently from the south and east towards
the north rising to 200m at Buna and 460m at Bute and Gurar at the foothills of
Ethiopian highlands. The road altitude drops gently from an elevation of 268m
at Modogashe (Garissa and Isiolo counties) to 218m at Habaswein, and then
gently rises to 236m at Samatar town. The topography drops to 227 at Lagbogol
and then steadily rises to 263m at Wajir Town.
• Climate.The average minimum and maximum temperatures along Modogashe-
Wajir Road varies between 21oC – 36oC. It is cooler in Modogashe but
generally hotter in Wajir Town. The average monthly relative humidity ranges
from 56% in February to 68% in June. The region receives long rains from
March – April) and the short rains from October – December. The average
annual rainfall varies between 200 – 400mm per annum. The Isiolo/Garissa
area experiences the higher of 400mm annually. The average wind speeds
along the project road varies between 5.5-6.5 m/s at 80m height.
• Geology.The area is primarily composed of Quaternary Sediments of the
Pleistocene Age, characterized by quartzitic sandstones and limestone sands.
The deposits of recent age are largely soils and alluvial accumulations.
• Soils. Modogashe to Skanska and Habaswein to Lagdima area is characterized
by imperfectly drained, deep brown, extremely firm slightly calcareous, slightly
sodic clay loam, abruptly underlying a thick topsoil of sealing sandy loam. The
Lorian Swamp area (Skanska to Habaswein) contains imperfectly drained, very
deep, dark grey, very firm, slightly calcareous, cracking clay, with a slightly to
moderately saline and sodic deeper subsoil. The area from Lagdima to
Lagbogol is characterized by imperfectly drained, moderately deep brown,
extremely firm, moderately calcareous, moderately sodic clay loam with a top
soil of sealing sandy loam. The area from Lagbogol through Borji and Leheley
to Wajir contains well drained, very deep, dark red to dusky red, loose loamy
sand to very friable sandy loam.
• Hydrology.The project area has no permanent rivers, however, there are a
number of seasonal laggas/streams, water pans, and earth dam, sand dams.
The project road crosses the seasonal overflow of North Ewaso Ngiro River
near Habaswein. Tana River runs on the Eastern side of the Garissa –
Modogashe road. Ewaso Ngiro River has its catchments area in the Aberdare
ranges and Mount Kenya flows between October – March draining into the
Lorian swamp.
Pan-19-003 -n-
KeNHA
38. Flora and Fauna

• Flora : The three counties have sparse vegetation consisting of dry scrubland
dominated by Commiphora – Acacia woodlands which are 3.0m to 5.0m high
with little under growth. Due to the prevailing arid condition, the most dominant
tree species are Acacia spp. Which are common along the road. Other species
include Balanites spp. And commiphora spp, panicum spp and Eragrostis spp.
The mature acacia trees serve as habitat for birds.
• Fauna: The project area is rich in wild life ranging from spotted hyena, Black
rhino (Dicerosbicornis), African Wild dog (Lycaonpictus), Giraffe, Elephant,
Ostrich, Monkeys, Antelopes, Impala, Giraffe, Leopard, Warthog, Lesser kudu,
Greater kudu, Hippo, Grevy zebra, Buffalo, Lion and numerous bird species.
The wildlife moves freely across the project area with majority being found at
the Lorian Swamp (from Km 26+200 to Km 48+000), which is dry season
grazing area.
• Flooding: The project area is located in a flat area which is basically a flood
plain. The area experiences periodic flash floods during the rainy seasons. The
lowest area is 218m (Habaswein) and 265m (Wajir Town) for the highest
elevation point. The Lorian swamp near Habaswein and the Borji swamp near
Lagbogol flood during the wet season rendering the road impassable.
• Air Quality: The project area is mainly an arid rural county and therefore air
quality along the project corridor is influenced by exhaust emissions from
vehicular sources and particulate matter from dust. The road is unpaved.
Currently human populations are concentrated at the urban centres which
include Modogashe, Skanska, Habaswein, Kanchara, Samatar/Guticha,
Lagbogol, Borji, Leheley and Wajir Town. The urban centres/towns that have
slightly higher concentration of vehicular emissions and particulate matter
because of the high number of vehicles include Modogashe, Habaswein and
Wajir Town.
• Some of the main streets in Wajir town are paved hence have reduced fugitive
dust emission. The rest of the project area has relatively low number of vehicles
and there is reliance on carts that are powered by animals such as camels.
• Noise Pollution. The current ambient noise and vibration conditions within the
project corridor can be described as low except for urban centres i.e.
Modogashe, Habaswein and Wajir towns, where typical urban noise is
experienced. Throughout the project area the source of noise that was evident
was from the vehicles used as means of transport.
• Water Quality. Environmental baseline water quality measurements were
carried out from Modogashe-Samatar in 2017 by AWEMAC. There were
variations although generally within the NEMA standards/guideline values and
World Health Organization standards (WHO). In particular, the pH range was
within the acceptable levels in the sampled points. Turbidity (170.2 NTU) and
total suspended solids (160 mg/l) concentrations were found to be above the
guideline values. The other parameters and water resources along the
proposed project, such as Skanska, Kanchara and Samatar depicted ranges
that were within the NEMA guideline values. The Design Consultant also carried
water analysis in 2018 and confirmed some treatment will need to be done
before the water is used for construction.
39. Physical Cultural Resources

• Physical Cultural Resources are resources of archaeological, paleontological,
historical, architectural, and religious (including graveyards and burial sites),
Pan-19-003 -o-
KeNHA
aesthetic or other cultural significance. The Consultant identified a graveyard in

Modogashe and Mosques in Kanchara and Lagbogol that that may be affected
by the proposed road alignment, it has been recommended to redesign the
section to avoid the PCRs.
• A Chance Find Procedure has been provided in Annex 6 to guide in
management of PCRs.
40. Project Alternatives. Five alternatives were considered for the proposed
Modogashe - Wajir (Al3) Road. They include:
• No upgrading of the existing road (‘no action’ option). The no project alternative
would deny the project area community many benefits including:
o Economic improvement,
o Opening up of education opportunities for both gender
o Poverty reduction,
o Women empowerment
o Improvement of social services including healthcare.
• Analysis of alternative construction materials and technology – Material and
technology alternatives have also been evaluated by the design consultant to
selected options of locally available materials.
• Solid waste management alternatives – Priority was given to reduction at
source. The second option is recycling, reuse and composting of the waste.
• Alternative mode of transportation – Only road transport option is available for
construction activities.
• Upgrading existing road without any changes in route alignment – This option
has been evaluated and the Design Consultant has considered reviewing the
RoW of the road sections passing through town centres from 60m to 30m to
minimize impacts on settlements and reduce displacement.
41. Outcome of The Public Consultations. Part of the ESIA process includes
conducting public consultation with the local community within the project area. The
consultants identified and mapped stakeholders in the project area. These included:
• Community members at the trading centres of Wajir Town, Leheley, Borji,
Lagbogol, Samatar/Guticha, Kanchara, Lagdima, Habaswein, Skanska and
Modogashe
• County officials including County Commissioners, Deputy County
Commissioners, Elected leaders and Chiefs
• KeNHA representatives in Garissa (Regional Office) and other government
departments in the counties
• Persons affected by physical and economic displacement
• Women, youth and people living with disability along the project road
Table A: ESIA Public Consultation Meeting (PCM) Venues and Dates

Total No of
# Date Location Venue Female Male Participants
1 20/02/2019 Leheley Leheley Centre 22 43 65
2 20/02/2019 Wajir Town Baraza Park 13 26 39
3 21/02/2019 Borji Centre Borji Centre 29 58 87
4 21/02/2019 Lagbogol Lagbogol 44 81 125
Centre Centre
Pan-19-003 -p-
KeNHA
Total No of
5 22/02/2019 Guticha/ Guticha/ 17 17 34
Samatar Centre Samatar
Centre
6 22/02/2019 Kanchara Kanchara 37 31 68
Centre Centre
7 23/02/2019 Lagdima Centre Lagdima 3 27 30
Centre
8 23/02/2019 Habaswein Habaswein 28 86 114
9 25/02/2019 Skanska Skanska 8 31 39
10 25/02/2019 Lagdera Leheley Centre 14 39 53
11 26/02/2019 Sericho Baraza Park 18 50 68
Total 233 489 722
42. The participants were made up of village elders, youth representatives,

religious leaders, teachers, KeNHA representatives and the local administration. In
majority of the meetings both women and men attended, and their different issues
were included in the meeting minutes. However, to address special needs, Youth,
Women and Men were met separately to allow them to articulate their concerns in
an enabling environment. This was done to mitigate against the culture in this region
that inhibits women and youth from expressing their views publicly (in the presence
of adult male members of the society).
43. The outcome of the meetings indicated that that the area currently suffers
greatly due to a poor transport network and would stand to benefit greatly from the
road upgrade. However, several issues were raised including:
• The need to ensure equal job opportunities for both female and males
• Community members to be regularly informed on the project planning and
progress through their representatives
• There is need for road safety enhancement for people, livestock and wildlife.
• The project is going to displace/resettle community members
• The project may increase the potential for community conflicts due to increased
pressure on resources
• The cultural heritage sites like Mosques and Graves are to be protected
• There should be inclusion of vulnerable community members
• There will be potential for loss of grazing land
• Construction activities may pollute air
• Procedures for rehabilitation of borrow pits and quarry sites should be put in
place
• The project will develop water sources for project and share with the community
• The project should consider implementing a CSR activity
• The project should protect wildlife from potential poaching for game meat
All the concerns raised during the consultations have been incorporated in the
Updated ESIA Report.
44. Project Impacts.The expected impacts emanate from the Planning phase,
the Construction phase, the Operation phase and Decommissioning Phase of the
project. In general, successful implementation of the project will have high
environmental and socioeconomic benefits to the people and will contribute to their
well-being. Overall, negative expected impacts are related to the planning and
construction activities of the project. The assessment has proposed appropriate
Pan-19-003 -q-
KeNHA
mitigation measures to reduce identified impacts. The severity and duration of these
impacts can be minimized by ensuring that the construction and operation activities
adhere to the proper construction and operation standards specified by the design
and supervision engineers. These positive benefits of the project include:
• Improved business opportunities
• Provision of job opportunities during construction
• Improved security
• Reduced travel time
• Improved social services
• Improved community well being
The potential negative impacts of the project will occur during the Planning,
Construction and Decommissioning Phases
a) Environmental Impacts
• Site oil and fuel spills
• Water resources pollution
• Proliferation of invasive species
• Air pollution (Fugitive dust and Exhaust emissions)
• Noise Pollution
• Generation of Solid Waste
• Impacts on wetland and wildlife
b) Social Impacts
• Impacts on settlements
• Impacts on demographics
• Influx of labour in search of opportunities
• Potential for conflicts due to limited resources and difference in culture
• Increase in potential accidents and incidences along the road
• Public Health & Safety
• Impacts of HIV and AIDS
• Potential of Gender Based Violence and Harassment
• Potential damage to private property
• Potential damage to service utilities
• Gender equity, sexual harassment
• Child rights and child labour
• Crime Management Increased Crime rates
• Impacts on economy
• Impact on livelihoods
• Cultural impacts
• Economic impacts and materials and wellbeing impacts
• Geographic impacts
• Impacts on quality of living environment
• Impacts on family and community
• Indicative gender relation impacts
• Health and social well being
• Institutional, legal, political and equity impacts
Pan-19-003 -r-
KeNHA
3. Cumulative Impacts
45. Cumulative impacts are defined as those that may result from incremental
impact, on areas or resources used or directly impacted by the project, from other
existing, planned , or reasonably defined planned developments , at the time the
risks and impacts identification process is undertaken. There are potential
cumulative impacts that will arise since there other projects or actions that are
planned for the region where this project is located. The proposed or ongoing
projects that are likely to generate cumulative impacts include:
• The proposed Isiolo-Modogashe (A13) road which joins the Modogashe -Wajir
road from the south
• The ongoing construction of the Garissa-Modogashe (A13) road that joins the
Modogashe-Wajir road from the eastern side
• The proposed planned LAPSSET road project from Lamu to Isiolo to South
Sudan and Ethiopia
• The proposed Wajir-El-Wak road that will connect with the project road from
Wajir Town on the northern side.
• The proposed 748km fibre optic cable between Isiolo and Mandera to improve
internet connectivity.
• The proposed social infrastructure projects that are part of the larger NETIP
project
• Potentail impacts on sourcing of construction materials including water, energy,
road construction materials along the corridor;
• Impacts on resources in the project area due to labour influx
• Any other initiatives in the project road corridor that may result in positive or
negative cumulative impacts that have been included in the ESIA Study
• Potential impacts on the on culture and religion, increase in crime, increase in
GBV, SEA, Sexual Harassment and abuse of Children
Summary of Potential Cumulative Impacts

Environmental Potential Cumulative Impacts
Topic Construction Phase Operation Phase
Loss of flora and Potential cumulative impacts will only During the operational phase, it is
fauna, proliferation of occur during the construction phase if expected that influx of people to
invasive species the construction of other nearby the area and change in land uses
projects coincides with that of the with increased settlements along
proposed project. During construction it the project corridor this will
is expected vegetation clearance along excaberte pressures on the fauna
the alignment, material sites, spread of and sensitive ecosystem such as
invasive species, poaching, speed kills Lorian Swamp that may result to
and disruption of animal habitats .If this reduced biodiversity and
is the case, even greater attention will degradation .
need to be paid to the outlined
mitigation measures to ensure the Cumulative impacts may become
cumulative impacts remain insignificant significant on traffic accidents
involving community members,
livestock and wildlife.
Implementation of proposed
mitigation measures will ensure
impact is moderate.
Increased Traffic Potentail cumulative impacts are Given that traffic volumes will
anticipanted with use of construction increase in the project area due
vehicles and heavy machinery during to improved road conditions. The
construction. Implemnattion of design and proposed ESMP
Pan-19-003 -s-
KeNHA

mitigations measures including mitigation measures will ensure

operationalizing traffic management the impact is low.
plans will ensure the impact is low.
Road Safety Potential cumulative impacts on road Anticipanted during operational
safety are anticpanted given the area phase is increased traffic and
remoteness and little knowledge on speed for vehicle to the project
traffic regulations. Project has proposed area. Road signages and
mitigation measures and when implementing community road
implemented will maintain impact at safety awreness initiatives will
moderate level. ensure the impact is low.
Water Resources Potential cumulative impacts are likely Potential cumulative impacts will
to occur during construction period in be negligible
relation to abstraction of water from
ground water sources due to large
demand for construction, and potential
contamination from oil spills and waste.
The proposed mitigation measures will
suffice and will require continuous
monitoring.
Air Quality Cumulative impacts will only occur Efficient vehicular movement
during the construction phase if the arising from a multiplicity of
construction of other nearby projects improvement initiatives will
coincides with that of this proposed effectively lead to a reduction in
project. emissions, especially CO2.
If this is the case, even greater attention Cumulatively, the initiatives will
should be paid to the mitigation contribute to Climate Change
measures outlined in order to ensure mitigation.
the cumulative impact will remain of
minimum
Social Impacts Implementation of the project and the The enhanced transport
including: proposed social infrastructure among improvement targeted is soon
• Labour influx, others is expected to cause influx of going to attract more settlements
• Crime, workers into the area seeking for either and commercial activities which
• Disruption of skilled or unskilled employment. This may also be accompanied by
services, may pose increased social risks with sprawl of informal settlements.
• Increased respect to among others; new cases of The situation may not get an
conflicts, HIV/AIDS contraction and subsequent immediate back up of necessary
• Impacts on spread, illegal poaching, native’s amenities including sufficient
children, cultural dilution due to influence with the housing, water supplies,
• GBV, sexual incoming workers from other areas in sanitation, drainage systems and
exploitation and the Country, Gender Based Violence, power supply. Hence the
abuse drug trafficking, insecurity issues due to available limited resources will be
presence of ‘strangers’ (project over-stretched by the increased
workers) and other social challenges. population leading to communal
conflicts over the little available
resources.
Economic Impact Positive cumulative economic Impact Travel time reduction in the area
will occur during the construction will be more efficient.
phases of the projects since there
would be increased local and regional
employment benefits. The Local
businesses would experience an
increased demand for products and
services during construction.
Pan-19-003 -t-
KeNHA

Population Increase Upon commissioning of the road,

and migration provision of other infrastructure
such as water, electricity, health
centres, learning institutions and
fibre cable internet among others
will be enabled and easily
implemented compared to when
the road is not there. Hence, the
people from within and outside
the project counties will be
attracted to move into the project
area either to settle there, set up
businesses or provide needed
services. This will cause an
increase in population numbers in
the area, also, from the rural
areas to the urban areas in
serach of opportunities hence
urbanisation.
Sourcing of Large quantities of aggregate and
construction materials quarry material will be required during
along the corridor construction, this will result on potential
cumulative impacts along the project
corridor. This situation will lead to
serious degradation of land and general
environment in the project counties
arising from over-extraction and
haulage which may take many years to
restore.
Increased demand for more

construction materials will result into
more land being excavated for material
at the expense of other sustainable land
use practices. The outlined mitigation
measures should be implemented to
ensure the potential cumulative impacts
remain of moderate
46. Environmental and Social Management Plan (ESMP). The ESMP has been
prepared to minimize or eliminate the adverse negative impacts. The ESMP
provides the responsible entities and cost estimate for the mitigations.
Pan-19-003 -u-
KeNHA
Table B: Environmental and Social Management Plan (ESMP)

Project Phase Environmental/ Mitigation Measure Responsibility Cost (KShs) Frequency Total for
Social Impact of Payment Construction
Period (3yrs)
Pre-construction Potential Undertake the following specialized studies • KeNHA 15,000,000 Lumpsum -
environmental and • Biodiversity assessment for Lorian , Borji Swamps and
ecological impacts of other section of the proposed road corridor before
commencement of works
the Project Road
• Prepare Biodiveristy Management Plan to be
incorporated to the works contract
• Consult with communities along the road corridor to
identify additional livestock and Wildlife and livestock
crossing points and recommend the best design
features
Pre-construction Potential Preparation and use of CESMPs • KeNHA Included in Lumpsum
environmental and • Waste Management Plan • Contractor Contractor’s Cost
social impacts of • Traffic Management Plan
• Social Management Plan
construction activities
• Occupational Health and Safety Plan
by contractor
Pre-construction Loss of: • Carry out fair and adequate compensation and • KeNHA As per RAP Lumpsum
• Community and resettlement as per RAP and provide livelihood • NLC
Privately-owned restoration assistance to PAPs until their livelihoods
Land are restored to pre-project levels or better.
• Loss of Structures • Implement internal and external monitoring to ensure
• Loss of Livelihood the RAP is implemented appropriately.
• A grievance redress mechanism (e.g. establishment of
PAP Committee) will be put in place to address all
emerging complaints and grievances from the PAPs
and project area community.
Pre-construction Lack of Free Prior and • Prepare a community engagement plan • KeNHA Included in - -
Informed • Carry out regular consultation with VMGs especially • Contractor Contractor’s cost
on key issue like project implementation and selection • Resident
Consultations
of sites for contractor’s camp, quarry/borrow pits and Engineer
throughout the project water sources
implementation phase
for VMGs
Pan-19-003 -v-
KeNHA
Period (3yrs)
Pre-construction Displacement of Vulnerable HH to be provided with extra assistance as • KeNHA As per RAP - -
Vulnerable persons per RAP (e.g. sourcing host land, support with • NLC
exposing them to dismantling of structures, moving and building new
resettlement related structures).
impacts
Pre-construction Potential occurrence • Prepare a Grievance Redress Mechanism (GRM) • KeNHA Included in - -
of conflicts, and • Set up a Grievance Redress Committee (GRC) • Contractor Contractor’s
• Carry out training of GRC members • Garissa, Isiolo
complaints/grievances Clause
and Wajir
that need to be County
addressed representatives
• Community
Pre-construction Loss/disruption of • Provision of compensation for loss of net income for a • KeNHA As per RAP - -
livelihood due to period of 3 months • NLC
• Provision of livelihood restoration plan
project activities
Construction Contractors Camp • Institute proper domestic and office waste collection • Contractor Included in - -
Construction and and disposal. Practice waste segregation. supervised by Contractor’s cost
• Monitor septic tanks and exhaust before overflow the Resident
operation of
• Pave waste collection area at the camp Engineer
contractors Camp • Engage NEMA registered firms for collection and
• Pollution from disposal of ordinary and hazardous wastes
garage operations • Pave fuel dispensing areas with containments
and stored • Store all materials and chemicals on paved surfaces
materials • Provide appropriate ventilation for workers house/fans
• Domestic and • Provide disaggregated toilet facilities for men and
construction Waste women considering cultural and religious differences
Management
• Contractor to ensure proper construction of roads
within the camp that minimizes dust
• Technicians working at the garage to be instructed to
service vehicles on paved areas of the garage
• Store used oil and other fluids recovered from vehicles
and machinery in drums placed on paved surfaces
with containment
Pan-19-003 -w-
KeNHA
Period (3yrs)
• Make use of chain of custody forms for handling and
disposal.
Construction Loss of Flora along • Vegetation clearance should be restricted to the • Local Included in - -
the road corridor project footprint Administration Contractor’s cost
• Discuss with the local community and relevant • Community
authorities on methods of revegetation or members
compensation for the lost vegetation • Contractor
• Monitor planted trees for 2 years supervised by
• Areas to be cleared should be demarcated Resident 100,000/= Monthly 2,400,000
beforehand Engineer
• Except to the extent necessary for establishing the •
construction site and carrying out the construction
works, vegetation shall not be removed, damaged or
disturbed - -
• The construction workers should be sensitized on the
need to use alternative sources of fuel to meet their
energy requirement
Included in
• It is practically difficult to abate the advancement of
Prosopis juliflora however control measures can be Contractor’s cost
implemented by constantly monitoring the area to
control the advancement.
• Areas with dense indigenous vegetation shall not to be
disturbed unless required for construction purposes,
• Trees shall be trimmed rather than removed wherever
possible;
• The Contractor should plant indigenous and native
trees along the project road
• Stockpile construction materials in areas that are
naturally void of vegetation.
• The proposed biodiversity assessment to identify
additional design measures on wildlife crossings and
provide for free passage during construction
• Contractors to consider strategically locating borrow
areas so that during rain season they can harvest rain
water, the ponds can act as small reservoirs to
Pan-19-003 -x-
KeNHA
Period (3yrs)
recharge groundwater, act as local watering holes for
livestock and wildlife so at to lower frequency of
crossings by some wildlife and livestock herders
Construction Disturbance/loss of • Contractor will prepare a code of conduct to ensure • Contractor Included in - -
Fauna along the that workers do not consume game meat from the • Local Contractor’s cost
area, whether supplied by the locals or killed by Administration
project road corridor themselves.
• Awareness creation amongst the local people and the • Contractor
construction workers of laws that relate to wildlife supervised by
hunting and consumption, and the importance of Resident
wildlife as a natural resource and heritage. Engineer
• Avoid night time construction when noise is loudest.
Avoid night-time construction using heavy machinery,
from 10:00pm to 6:00am near areas known to have
wild animals
• Design and provide animal crossing infrastructure at
the identified animal crossing points (Lorian and Boji
Swamps, seasonal laggas). For large animals like the
Giraffe and elephants consider tapering the road
embarkments at the swamps and lagga areas to
facilitate crossing from one side of the road to the
other.
• KWS Officers need to be stationed at the construction
site
Construction • Harvesting of • Locate Quarry and borrow pit sites as far away as • Contractor Included in - -
Construction possible from human settlements supervised by contractors’ cost
Materials (Borrow • Locate processing plants (Crushers, Asphalt Plant and the Resident
Pits and Quarry) Concrete Batching Plants etc) away from settlement Engineer
• Processing Plants areas considering dominant wind direction which
(Crusher, Asphalt should be away from away from human settlements
Plant and • Use hydraulic hammers or other mechanical methods
Concrete Batching to extract rock material instead of using explosives
Plants) • Where blasting is not avoidable prepare a robust plan
- Noise together with KWS and implement appropriate
- Air Pollution evacuation
Pan-19-003 -y-
KeNHA
Period (3yrs)
- Damage to • Maintain roads to material sites by adequately
property compacting the road to minimize fugitive dust.
• Implement speed limit controls
• Adherence to the NEMA Integrated National Land Use
guidelines
• Establish at least 10 meters buffer zone between the
quarry, burrow or batching plants and the 30-meter
riparian reserve of the river, wetland and water
catchment areas. (i.e. 40 meters buffer zone between
the quarry and the edge of the river, wetland and water
catchment area)
• Siting of material sites should be in harmony with other
land uses and Provide for defined buffer zone between
quarries and other land uses. b. Quarry operations with
controlled blasting
• A technical officer (inspector of mines/explosives) to
advice accordingly as provided for under Subsidiary
Legislation 78 of Explosives Act and MSR 90 of the
Mining Act
• Contractor should establish quarry/burrow pit
rehabilitation and/or after use plan to be approved by
the NEMA as prescribed in the EMCA
• Discourage undercutting and tunnelling in quarries and
sand mining to avoid damage to property, injury or loss
of life.
• Prohibit vertical faces exceeding 2.5 m when quarrying
on soil, sand, gravel, soft rock or debris – these shall
be worked in terraces/ benches or at a safe angle of
slope.
• Hard rock quarry faces to be benched or worked from
top to bottom.
• All quarry faces/cliffs should be securely fenced. The
fence should be at least 3 meters from the edge of the
cliff using chain link of at least 1.5meters high.
Pan-19-003 -z-
KeNHA
Period (3yrs)
• Warnings signs of appropriate font size and in the
appropriate language should be erected in all quarry
entries and in areas with high cliffs e.g. Danger Quarry
Deep Pit’ or ‘Caution Flying Stone and Debris’.
• All access roads to and from quarries and burrow pits
to be made safe and accessible and transportation of
quarried material to follow a designated route.
• Contractors to ensure provision of clean water,
sanitation and well equipped first aid kit with trained
first aiders
• Provide protective gear for persons working in quarries
as provided for in the Public Safety Regulations
• Contractors’ workers to be trained on safety, health
and environmental issues and the quarry site should
have a person in charge of safety and ensure
establishment of ‘Safety, Health and Environment
Committees’ (SHEC).
• Each quarry site (where blasting is required) should
have suitable skilled blaster to carry out safe blasting
and acquiring blasting permits.
• All blasting materials /explosives should be acquired
and conveyed legally through acquisition of relevant
permit(s) from Mines and Geological Department.
Construction Noise Pollution • Contractor shall avoid night time construction when • Contractor Included in - -
noise is loudest near residential areas or areas near supervised by contractors’ cost
wildlife. the Resident
• There shall be no discretionary use of noisy machinery Engineer
within 50m of residential areas and near institutions or
use of manual labour in these sections
• Contractor shall ensure good maintenance and proper
operation of construction machinery.
• Contractor shall ensure that where possible, non-
mechanized construction shall be applied to reduce the
use of machinery
Pan-19-003 - aa -
KeNHA
Period (3yrs)
• Ensure that all vehicles and construction machinery
are kept in good condition all the time to avoid
excessive noise generation.
• Ensure that all workers wear ear muffs and other
personal protective gear/equipment when working in
noisy sections.
• Ensure machines are switched off when not in use.
• Ensure the NEMA maximum noise level is observed
for the eight working hours i.e. 55 dB.
• Undertake loud noise and vibration level activities
during off-peak hours during the day (i.e. between 8.00
am and 5.00 pm)
• Carry out daily noise measurements
Construction Air Pollution (Fugitive • Control speed of construction vehicles and Prohibit • Contractor
Dust and Exhaust idling of vehicles; supervised by
• Water is to be sprayed during the construction phase the Resident
Emissions) Engineer Included in - -
on dusty areas to reduce dust emission;
• Regular maintenance of vehicle & equipment to Contractor’s cost
reduce smoke;
• Provision of dust masks for use by workers in dusty
conditions;
• Use of serviceable vehicles/machinery to avoid
excessive exhaust emissions;
• Operation and maintenance of contractor’s plant in
compliance with relevant vehicle emission standards
and manufacturer’s specification to minimize air
pollution.
• Install improvised screens to minimize dust at stone
crusher.
• Monitoring of daily air quality during and after
construction to ensure no major negative impacts or
come up with mitigation measures
Construction Risk of site pollution • Employee awareness on company procedures for Contractor Included in the - -
by oil and fuel spills at dealing with spills and leaks from oil storage tanks. supervised by the Contractor’s cost
• Isolation of source and containment of leaks.
camp, construction
Pan-19-003 - bb -
KeNHA
Period (3yrs)
and material sourcing • Provision of absorbent material for emergency Resident
sites cleanup in case of spill Engineer
• Maintenance of contractor’s machinery and vehicles
• Contractor to provide for oil/grease interceptors in
motor vehicle garages
• Recovered used oil will be kept in a paved store house
with containment.
• Contractor will keep records of all recovered used oil
and hydraulic fluids in a chain of custody form for
appropriate handling and disposal
• Fuel dispenser (pump) and dispensing area will be
paved with containment.
• Fuel Skid Tanks will be mounted within a leak proof
bunded wall with equivalent capacity to the tank for
containment
• Servicing of machinery and vehicles will be restricted
to the paved garage area
• Provision of relevant emergency numbers
Construction Soil Degradation • Provision of adequate drainage facilities to channel • Contractor • Included in - -
water from one side of the road to the other. supervised by Contractor’s
• Provision of temporary drainage for run-off water the Resident cost
• Restoration of the ground by allowing for natural Engineer • Restoration
revegetation or planting adequate grass and trees. cost covered in
Flora and
• Provision of a borrow pit/ quarry site rehabilitation Fauna cost
plan, including a standalone ESIA/ESMP for each new • Included in the
borrow pit/quarry site. Contractors
• Planning emergency response measures in case of clauses
accidental oil spills. • Oil spill costs
are included in
Contractor’s
cost
Pan-19-003 - cc -
KeNHA
Period (3yrs)
Construction Proliferation of • Re-use of nutrient rich top soil in the areas of origin. • Contractor Included in - -
invasive species • Making use of cut and fill road material within similar supervised by Contractor’s cost
homogeneous areas the Resident
• Minimal stockpiling periods. Engineer
• Proper storage of stockpiled material.
Construction Water Resources • Proper solid and liquid waste disposal from the • Contractor Included in the - -
construction camp and offices will be done supervised by Contractor’s
• Water will be reused where possible to reduce the Resident
Engineer clauses
demand on ground water sources
• Oil water separators and grease traps will be installed
and maintained as appropriate at fueling facilities, Included in the - -
workshops, parking areas, fuel storage and Contractor’s cost
containment to reduce potential contamination risk to
water sources
• All equipment, machinery and vehicles being used at
the Ewaso Ngiro River Bridge, Lorian and Boji Swamp
areas and River Laggas will be inspected on a daily
basis for any fuel/oil leaks before use
• During the rainy season when Ewaso Ng’iro River and
other streams crossing the road are flowing, water
samples will be collected once every two weeks for
TPH and PAH analysis during construction at each
facility to monitor impact of the construction activities
on the water sources. The water samples will be
collected
o approx. 100m upstream,
o at the crossing (where the bridge or culvert is being
constructed) and
o 100m down stream
• Ensure measures are in place to quickly recover any
spilled fuel, oils and lubricants for appropriate
disposal.
• All waste will be disposed of to appropriate NEMA
licensed facility
Pan-19-003 - dd -
KeNHA
Period (3yrs)
• Handling, storage, treatment and disposal of
hazardous substance will be in line with appropriate
standards to reduce contamination of water
resources. The procedures for all stages of
hazardous waste handling, storage, use and disposal
will be defined in the CESMP
• The Contractor will contruct/drill own water sources
for construction activities and after construction these
facilities can be given back to the communities
• The Emergency Response Plan will identify
procedures that will include measures to protect water
environment from contamination in the event
emergencies such as spills and leaks
Construction Increased Traffic • Contractor will implement the Traffic Management • Contractor Included in - -
Plan supervised by Contractor’s
• Provide traffic controllers/marshals the Resident
clauses
• Provision of retro reflective night time signage at Engineer
ongoing works and road deviations
• Effecting traffic controls to avoid congestion and Included in - -
accidents on roads. Contractor’s cost
• Choosing suitable traffic routes to reduce impact in the
neighbourhood.
• Ensuring no interference with traffic through traffic
control, designated parking, speed limits.
• Provision of a road safety analysis and campaign
including provision of temporary and permanent road
crossing facilities for domestic animals, wildlife and
people
• Maintain temporary diversion and access roads
Construction Impacts on Physical • Before construction commences, the contractor should • Contractor Included in - -
Cultural Resources carry out reconnaissance survey to establish that the supervised by Contractor’s costs
road corridor does not have any mosques or graves. the Resident
• Inform the local community on the actions being taken Engineer
to avoid such sites.
Pan-19-003 - ee -
KeNHA
Period (3yrs)
• Re-design the road routing to avoid the encountered • National
physical cultural resource Museums of
• Apply the “Chance Find Procedure” provided in Annex Kenya (NMK)
6 to protect any cultural resources that may be Officers
underground.
Construction Disruption of Service • Preparation of a stakeholder engagement plan Contractor Included in
Delivery Impacts • Provide alternative routes, traffic controllers, concrete Contractor’s costs
barriers and speed limits for motorists.
• Communication on any intended disruption of the
services. • KeNHA & 15,000 Monthly 540,000
• Repair of any affected areas in consultation with the Relevant Included in
local authorities. service
provider Contractor’s
clauses
Construction Occupational Health The Contractor is to: • Contractor Included in - -
and Safety • Prepare a detailed Occupational Safety and Health supervised by Contractor’s
Management Plan (OSHMP) that will provide all the the Resident
Engineer clauses
required health and safety measures needed for the
project activities.
• Prepare Emergency and Response Plan • Appointed
• Provide a whistle-blower policy to ensure wellbeing of Health and
whistle-blowers Safety Officer
• Trained occupational health and safety staff and fire
marshal shall be appointed on-site for the duration of
Included in
the construction work.
• Prepare a Code of Conduct that inter alia commits to Contractor’s cost
the Implementation of the OSHMP and that also
commits at individual level to compliance to OSHMP
requirements and standards.
• Carry out work assessment and identify hazardous
substances and working conditions and include safety
measures in the OSHMP
• Carry out daily tool box meetings for all workers
Pan-19-003 - ff -
KeNHA
Period (3yrs)
• Conduct a road safety analysis and campaign with
the local community, including road crossings for
domestic animals, children etc.
• Ensure that all construction machines and equipment
are in good working conditions and to manufacturer’s
specifications to prevent occupational hazards.
• Provide road signs and barriers to block off working
areas from the rest of the traffic.
• Appoint qualified health and safety advisor staff on-
site for the duration of the construction work.
• Provide workers with appropriate personal protective
equipment (PPE).
• Provide first aid kits and train first aiders
• Provide workers with adequate drinking water and
breaks.
• Provide workers training on safety procedures and
emergency response such as fire, oil and chemical
spills.
• Roads passing through population centres will be
water sprayed to suppress dust.
• Work to minimize or altogether eliminate mosquito
breeding sites.
• Project for worker’s health clinic with a nurse on -site
• Provide for an ambulance vehicle to evacuate
emergency cases
• Provide a stakeholder engagement plan
• Fence off the site with security to avoid unauthorized
access to the borrow site(s) and hence mitigate
potential injuries from accidental falls.
• Provide clean toilets for workers, these toilets will be
to World Health Organisation standards
• Carry out regular and statutory health and safety
audits
• Contractor to undertake WIBA insurance for workers
Pan-19-003 - gg -
KeNHA
Period (3yrs)
Construction Community Health The Contractor is to: • Contractor Included in - -
and Safety • Prepare and implement an occupational health and supervised by Contractor’s
safety plan. the Resident
Engineer clauses
• Carry out awareness and sensitization meetings with
community members on safety issues at the project area
• Fence off the camp site, borrow Pit sites and Quarry • Appointed Included in -
Sites with security to avoid unauthorized access and Health and Contractor’s cost
also protection of community members and their Safety Officer
livestock from accidental fall into the borrow and
Quarry excavations to mitigate potential injuries.
• Carry out regular monitoring and assessment of
community health and safety issues with a view to
improve on performance
• Conduct a road safety analysis and campaign with the
local community, including road crossings for domestic
animals, children etc.
• Barricade working areas from the rest of the traffic
Pan-19-003 - hh -
KeNHA
Period (3yrs)
Construction Employment of locals • Contractor will prepare Labour Management Plan • Contractor Included in - -
• The Contractor will prepare an employment plan to supervised by Contractor’s
manage employment of labour the Resident
clauses
• Contractor will prepare a code of conduct to ensure Engineer
that workers follow established work ethics and avoid
discrimination, Gender Discrimination, annoyance, Included in
promote tolerance of different cultures and religion Contractor’s cost
• Unskilled construction and skilled (if available) labour
to be hired from the local population as far as possible
to minimize on influx of foreigners into the community.
• Use of manual labour where possible to ensure more
employment of locals and hence ensure project
support throughout the construction process.
• The contractor will ensure that all workers’ pay
adheres to minimum wage requirements to avoid
labour unrest.
• Sensitize workers and the surrounding community on
awareness, prevention and management of HIV / AIDS
through staff training, awareness campaigns,
multimedia, and workshops or during community
Barazas.
• The Contractor will enforce and maintain a code of
conduct for his employees
• Skills transfer will be enhanced to enable some of the
local staff to gain new skills.
• In consultation with local communities come up with
suitable CSR measures for the community
• Contractor will provide Workers’ grievances redress
mechanism
• Hire qualified Human Resources Officer to manage
labour related risks
Pan-19-003 - ii -
KeNHA
Period (3yrs)
Construction Increase in • The Contractor will prepare and implement a • Contractor Included in - -
incidences of HIV and HIV/AIDS management plan • Appointed Contractor’s
• Sensitize workers and the surrounding communities Health and
AIDS clauses
on awareness, prevention and management of Safety Officer
HIV/AIDS through staff training, awareness • Public Health
campaigns, multimedia, and seminars/workshops Officer Included in
and during community Barazas. Contractor’s cost
• Provide an on-site clinic to provide VCT services to
construction crew and provision of ARVs for
vulnerable community members
• Ensure workers are regularly reminded about the
code of conduct and the potential consequences if
not adhered to
Construction Liability for loss of life, • Developing a site safety action plan. • Contractor Included in - -
injury or damage to • Prepare and implement a grievance redress supervised by Contractor’s
mechanism the Resident
private property clauses
• Workers to be provided with appropriate PPE Engineer
• Induction of workers on appropriate operation of the • Appointed
machinery and equipment Health and Included in
• Provision of adequate signage at working sites Safety Officer Contractor’s cost
• Ensuring that the prepared code of conduct for staff is
followed to prevent accidents.
• Cordoning off unsafe areas using barriers or barrier
tapes
• Provision of first Aid kit at the construction site.
• Keeping records of all injuries that occur on site in the
incident register, corrective actions for their prevention
are instigated as appropriate.
• Compliance with the Workmen's Compensation Act,
ordinance regulations and union agreements.
• Carry out baseline evaluation of property near the
project road, borrow sites and quarry to minimize
controversy on damages caused by construction.
• Repair/compensate any damage done to private
property.
Pan-19-003 - jj -
KeNHA
Period (3yrs)
Construction Labour influx • Prepare a labour influx plan to manage labour influx Contractor Included in - -
• Unskilled construction and skilled (if available) labour supervised by the Contractor’s
Resident clauses
• Use of manual labour where possible to ensure more Engineer
employment of locals and hence ensure project Included in the
support throughout the construction process. Contractor’s Cost
awareness, prevention and management of HIV /
AIDS. Included in
• The Contractor will enforce and maintain a code of Public Health Contractor’s Cost
conduct for his employees Officer
• Sensitize workers on the different cultures and
inculcate tolerance
• Enforce and maintain a code of conduct for employees
• Contractor is to monitor and report on the
implementation and effectiveness of the labour influx
related mitigation measure
• Due to the possibility of conflicts arising between
workers and the locals, the Contractor shall ensure all
key staff, receive training regarding the likelihood,
significance and management of influx-related issues.
• Through the Non-Governmental Organization that will
be handling GBVSEA issues, hold sensitize the
community on possible occurrence of GBV and how
they should respond.
• Monitor potential occurrence of annoyance, conflicts
that may arise from differences in lifestyle and culture
between community and in-migrants
• The Contractor shall ensure that the Grievance
Redress Mechanism (GRM) addresses issues related
to labour influx
• Monitor the potential occurrence of Gender Based
Violence (GBV), Sexual Harassment and Violence
Against Children (VAC)
Pan-19-003 - kk -
KeNHA
Period (3yrs)
Construction GBV, Sexual Contractor will: • Contractor Included in the - -
Harassment and • Provide and implement a gender-based violence supervised by Contractor’s
strategy, which will include: the Resident
Sexual Exploitation Engineer clauses
• Provide and implement an employee code of conduct
and Abuse (SEA) and
for workers • Local
Violence Against Administration
Children (VAC) • Ensure there is Gender mainstreaming in employment
at the worksite with opportunities provided for females
to work, in consonance with local laws and customs
• Liaise with KeNHA to ensure NGO concerned with
GBV issues to be engaged as early as possible before
construction commences since GBV and cases
Violence Against Children will arise early in the project
• Grievance redress mechanisms that incorporates non-
retaliation and specific procedures for GBV.
• The works contractor will be required, under its
contract, to prepare and enforce a No Sexual
Harassment and Non-Discrimination Policy, in
accordance with national
• Contractor to prepare and enforce a code of conduct
that will be signed by all project workers prohibiting
SEA and SH by workers and providing an
accountability and response framework including non-
retaliation against those who report.
• Ensure there is Gender sensitization of workers (this
will be done by the HIV/AIDS services provider; see
above)
• NGO engaged by KeNHA to mobilise early in order to
educate all workers and nearby communities and
stakeholders on preventing and responding to SEA,
sexual harassment and GBV ahead of any project
related works;
• Popularize /put in place safe, ethical and confidential
mechanisms and hotlines for reporting
SEA/SH/GBV/VAC cases;
Pan-19-003 - ll -
KeNHA
Period (3yrs)
• Strategies such as male involvement will be employed
in preventing and responding to GBV/SEA and sexual
harassment;
• Establish partnerships with relevant government
agencies, GBV Service Providers and NGOs to ensure
survivors of GBV and sexual offences access survivor
centred services such as medical care, psychosocial
support, legal redress, safety, etc as and when
necessary;
• Provision of gender disaggregated facilities - separate
bathing, changing, sanitation facilities for men and
women;
• Prepare grievance redress mechanisms with specific
procedures for GBV including confidential reporting
with safe, and ethical documenting of GBV cases
should be set up for the workers and community;
Construction Project Impacts on • Ensure equitable distribution of employment Contractor Included in - -
Women opportunities between men and women supervised by the Contractor’s cost
• Provide toilets and bathrooms for both male and
Resident
female workers on site
• The women will be involved in the periodic Engineer
dialogues/consultations with the contractor and host
communities during construction to enable them
handle their other roles while working with contracto r
Construction Security Risks and Contractor will: Contractor Included in the - -
Crime Management • Prepare Security Management Plan supervised by the Contractor’s
• Prepare a code of conduct for signing by all staff Resident clauses
members
Engineer
• Recruit Security Coordinator to coordinate security
issues with security agencies Included in
• Fence off the Contractor’s camp that contains plant
Contractor’s cost
and materials.
• Work with local committees in addition to the
Contractor’s own security.
Pan-19-003 - mm -
KeNHA
Period (3yrs)
• Remove any employee who persists in any
misconduct or lack of care, carries out duties
incompetently or negligently, fails to conform to any
provisions of the contract, or persists in any conduct
which is prejudicial to safety, health, or the protection
of the environment.
• Take all reasonable precautions to prevent unlawful,
riotous or disorderly conduct by or amongst the
contractor's personnel.
• Prohibit alcohol, drugs, arms, and ammunition on the
worksite among personnel.
• Log in all events of a criminal nature that occur at the
worksite or at the civil works activities.
• Report all activities of a criminal nature at the worksite
or contractor's employees to the police.
• KeNHA has carried out a Safety/Security Audit of the
project road and provided mitigation measures for the
project road
Construction Impacts on children • Provide and implement a child protection strategy • Contractor Included in the - -
• Ensure no children are employed on site in accordance supervised by Contractor’s
with national labour laws the Resident
clauses
• Ensure that any child sexual relations offenses among Engineer
contractors' workers are promptly reported to the
• Local
police
Administration
• Sensitize Community on child protection and
• County
eradication of child labour.
Governments of
Isiolo, Garissa
and Wajir
All Project Intra/Inter Community • Contractor will prepare a Security Management Plan • Contractor Included in the - -
Phases Conflicts • The Contractor will develop Resource Use supervised by Contractor’s
Management Plan. the Resident
clauses
• Contractor will prepare and implement a stakeholder Engineer
engagement plan to ensure continuous communication • Local
and discussions with all stakeholders Administration
Pan-19-003 - nn -
KeNHA
Period (3yrs)
• The Contractor will source for new water sources for • Security Agents Included in
construction e.g. Boreholes, pans and rain water • County Contractor’s cost
harvesting, after construction these facilities can be Governments of
given back to the communities. Isiolo, Garissa
• KeNHA and Contractor will convene meetings with the and Wajir
Somali and Borana communities in Modogashe to
discuss project implementation plans to avoid conflicts
arising during implementation.
• Contractor and KeNHA will convene similar meetings
in Samatar/Guticha and Lagbhogol to diffuse intra
community conflicts that may arise over resources
during construction (selection of camp sites and
selection of sites to sink boreholes)
• Contractor and KeNHA to consider providing CSR
where possible to reduce some of the pressure on
resources
• Contractor to ensure there is a working grievance
redress mechanism to address/mitigate any
community grievances early before escalation to
conflict.
• Contractor and KeNHA are to provide regular updates
on project progress and fulfill agreed actions
Construction Conflicts from project • Contractor to establish presence of any cultural • Contractor Included in the - -
construction activities resources near sites of construction and avoid them. supervised by Contractor’s cost
• Contractor to consult with local/religious leaders to the Resident
ensure Cultural Sites are identified and measures put Engineer
in place to avoid disturbance.
• Contractor to ensure access is provided to all cultural
resources near the road.
Construction Project • Contractor will appoint a Liaison Officer to facilitate • Contractor Included in the - -
Communication smooth communication between the project and the • KeNHA Contractor’s
community
clauses
• Contractor will prepare and implement a
communication and community/stakeholder
engagement plan that addresses all project issues
Pan-19-003 - oo -
KeNHA
Period (3yrs)
Construction Complaints from the • Contractor will prepare an effective and strong • Contractor Included in the - -
communities and Grievance Redress Mechanisms (GRM) that is • KeNHA Contractor’s
responsive to GBV reporting and other issues that may
other stakeholders arise. clauses
Construction and Flooding in Lorian To minimize the impact, the design has incorporated • Contractor Included in the - -
operation and Borji due to climate resilience measures which include: • KeNHA Contractor’s cost
• Increasing of capacity and frequency of drainage
Climate Change structures
• Raising of road surface level above expected flood
levels
• Strengthen Lorian swamp embankments
• Provide bank protection for culverts and bridges
• Provide road overtopping protection
• Reduce Sedimentation Rates from Sand – ensure
culverts are free of sedimentation to ensure design
capacity
Operation Increased Traffic • Provision and maintenance of safety signage along the KeNHA 600,000 Annually -
along the Project corridor.
Alignment • Periodical road safety audits to establish any issues
with the road and establishment of mitigation
measures
Operation Air Quality • Policing of unroadworthy vehicles to reduce air KeNHA - - -
pollution Traffic Police
• Periodical air quality monitoring along the road corridor
Operation Community (Public) • Provision and maintenance of safety signage along the KeNHA Included in Traffic - -
Health and Safety corridor. Cost
• Periodical road safety audits to establish any issues
measures.
• Carry continuous Public Health and Safety awareness
Operation Risk of truck drivers • Provision of visible signage. KeNHA - - -
stopping along the • Working with the police to ensure drivers make use of
truck stops.
project area
Pan-19-003 - pp -
KeNHA
Period (3yrs)
• Encouraging the establishment of businesses near the
truck stops to service the truck stops.
Operation Impacts of KeNHA to work with the County Governments of the KeNHA, County 1,000,000.00 Annually
newcomers to the three counties on integration between newcomers and Governments and
project area. along host communities. Administration
the project area
Decommissioning Decommissioning • Prepare a Decommissioning Plan and submit to NEMA Contractor Included in the - -
Plan of exhausted and the County Governments of Garissa, Isiolo and Contractor’s cost
Wajir and obtain approval for implementation.
material sites and
• Obtain approval of decommissioning plan from NEMA
camp
Decommissioning Decommissioning of • Implement the decommissioning plan including Contractor Included in the - -
the Contractor’s camp backfilling, revegetation, disposal of waste material, Contractor’s cost
recycling of recyclable material
• Obtain Clearance Certificate for successful
rehabilitation/restoration for each facility (Camp,
Borrow Pit or Quarry Site)
Pan-19-003 - qq -
KeNHA
47. Table C: Environmental and Social Monitoring
Environmental/ Monitoring Requirements Frequency of Responsibility

Location Performance Indicators
Social Component monitoring/ Duration
1. Construction
Contractor’s Public health and • Reports from Community • Provision of condoms, contraceptives and Monthly • RE’s
Camp safety • Physical inspection mosquito nets. Environmental
• EHS records • No of campaign meetings on transmission of Supervisor
• Incident logs maintained by diseases like HIV/AIDS and other STDs. • Contractor’s
Contractor • Availability of adequate solid waste bins and Environmental
waste disposal procedures Supervisor
• Availability of first aid facilities.
• Outpatient attendance registers.
• Prevalence rates of common diseases.
• Compliance with the Occupational Safety and
Health
• Compliance with Public Health Act.
• Provision of condoms, contraceptives and
mosquito nets
Solid and liquid • Physical inspection of Camp • Presence of scattered litter. Monthly • RE’s Environmental
wastes from Offices • Physical inspection of • Confirm records of waste disposal Supervisor
and Residential sewage system • Signs of obstruction of water courses. • Contractor’s
areas • Number of complaints • Evidence of engaging a NEMA registered waste Environmental
disposal firm Supervisor
Hazardous/Chemical • Physical inspection • Presence of oil spillage Weekly • RE’s Environmental

waste (Used Oil, Oil of Garage and workshops • Chain of custody forms for handling, storage Supervisor
filters, hydraulic fluids • Records of hazardous waste and transportation for disposal by NEMA • Contractor’s
and Lubricants) handling and disposal registered firm Environmental
• Contract of NEMA Registered Firm Supervisor
Pan-19-003 - rr -
KeNHA

HIV&AIDS • Inspection of HIV/AIDS • Number campaign meetings on transmission of Quarterly • RE’s Social Supervisor
prevention services in the diseases like HIV/AIDS and other STDs. • Contractor’s Social
project • Number of condom dispensers within the site. Supervisor
• Number of condoms, ARVs • Number of ARVs provided to vulnerable • Community
provided. persons Representative
Material Sites Solid and liquid • Physical inspection • Scattered litter Monthly • RE’s Environmental
(Quarry, wastes • Number of complaints • Signs of obstruction of water ways. Supervisor
Borrow Pits) • Flow of wastewater on the ground surface. • Contractor’s
and Crusher • Provision of sanitary facilities to the Environmental
Plant construction crews. Supervisor
Noise • Documentation on • Level of noise generated.by quarry • Use of portable • RE’s Environmental
complaints about noise • Provision of PPE. equipment to monitor and EHS Supervisors
• Carry out noise • Compliance with existing noise standard issued noise levels on • Contractor’s
measurements by NEMA. regular and adhoc Environmental and
• Zone out elevated noise a) Health, Educational facility basis EHS Supervisors
areas for mandatory use of 109 dB(C) Max • Monitor daily during
PPE (ear muffs) b) Residential, Commercial Facilities active operation
114dB(C)
Air Pollution • Physical inspection • Level of dust generated. • Use of portable • RE’s Environmental
• Exhaust emissions • Interview residents including • Provision of PPE. equipment to monitor Supervisor
• Fugitive dust workers • Compliance with existing air quality standards air pollution on • Contractor’s
• Liaise with other issued by NEMA regular and adhoc Environmental and EHS
stakeholders - Sulphur Oxides (SOx) - 60µg/m3 basis Supervisors
• Carry out air quality - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor daily during
measurements (SOx, NOx, - Respirable Particulate Matter (RPM) - active operation
PM10 and HC) 50µg/m3
- Total Volatile Organic Compound (VOC) -
600µg/m3
Pan-19-003 - ss -
KeNHA

Rock Blasting • Physical inspection • Area of influence of the rock blasting After every blast • RE’s Environmental
causing damage to • Field determination of area • Baseline status of nearby structures Supervisor
structures of influence • Contractor’s
Environmental and EHS
Supervisors
Stone Crusher, Noise • Documentation on • Level of noise generated. • Use of portable • RE’s Environmental
Asphalt and complaints about noise • Provision of PPE. equipment to monitor and EHS Supervisors
Concrete regular and adhoc
measurements by NEMA. Maximum allowed for sites in Environmental and EHS
Batching • Zone out elevated noise Construction sites basis Supervisors
Plants areas for mandatory use of a) Health, Education, Residential • Monitor daily active
ear muffs Day - 60 dB(A), Night – 35 dB(A) operation
b) Place of Worship
Day – 40dB(A), Night - 35dB(A)
• Exhaust emissions • Interview residents including • Compliance with existing air quality standards equipment to monitor and EHS Supervisors
• Fugitive dust workers issued by NEMA air pollution on regular • Contractor’s
• Liaise with other - Sulphur Oxides (SOx) - 60µg/m3 and adhoc basis Environmental and EHS
stakeholders - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor daily during Supervisors
• Carry out air quality - Respirable Particulate Matter (RPM) - active operation
measurements (SOx, NOx, 50µg/m3
PM10 and HC) - Total Volatile Organic Compound (VOC) -
600µg/m3
Risk of falling into • Physical inspection of fence • Incident records Monthly • RE’s EHS Officer
excavations at line surrounding facility
borrow pits and
quarry
Road Vibration causing • Physical Inspection • Establish baseline of existing structures Monthly • RE’s Environmental
Construction damage to • Field measurement of neighboring the road and Social
neighboring vibration level and distance • Compliance with existing noise standard issued Supervisors
Activities structures of influence. by NEMA. • Contractor
Pan-19-003 - tt -
KeNHA

• Liaise with other - Sulphur Oxides (SOx) - 60µg/m3 and adhoc basis. Environmental and EHS
stakeholders - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor daily near Supervisors
• Carry out air quality - Respirable Particulate Matter (RPM) - settlement centres and
measurements (SOx, NOx, 50µg/m3 institutions like
PM10 and HC) - Total Volatile Organic Compound (VOC) - mosques, hospitals
600µg/m3 and schools
Traffic Management • Physical inspection of the • Incident records Daily • RE’s Environmental
during the day road under construction to • Minimal accidents and road kill and EHS Supervisors
ensure flagmen are active • Compliance with approved traffic management • Contractor’s
and road signs are in place plan Environmental and
• Maintaining speeds EHS Supervisors
recommended by KWS due
to presence of
livestock/wildlife
Traffic Management • Installation of retro-reflective • Incident records Daily • RE’s EHS Supervisor
at night road signs • Minimal accidents and road kill • Contractor’s Traffic
• Physical Inspection of road Management
signs Supervisor
Drainage Discharge • Physical inspection of water • Registered complaints of damages Weekly during the rainy • RE’s Environmental
causing damage drainage discharge routes • Records of damage caused season when drainages Supervisor
• Reports from Community contain water • Contractor’s
• Damage caused Environmental
Supervisor
Water Pollution at • Physical inspection of • Lab analysis results • Use of Portable • RE’s Environmental
camp (garage) and machinery, equipment and equipment to monitor Supervisor
River/Lagga vehicles for oil leaks hydrocarbon pollution • Contractor’s
crossings including • Water quality monitoring on regular and adhoc Environmental
Loorian and Boji upstream, road crossing and basis Supervisor
swamps
Pan-19-003 - uu -
KeNHA

downstream for TPH and • Monitor weekly during

PAH analysis rainy season when
rivers/laggas and
swamps contain water
Noise • Documentation on • Level of noise generated. • Use of portable • RE’s Environmental

measurements by NEMA. regular and adhoc Environmental and
• Zone out elevated noise a) Residential Outdoor basis EHS Supervisors
areas for mandatory use of Day - 50 dB(A), Night – 35 dB(A) • Monitor daily during
PPE (ear muffs) b) Place of Worship active operation
Flora and Fauna • Records of uprooted trees • Amount of vegetation removed Quarterly • Environmental
• Physical observation • Change in animal behavioral pattern Supervisor
• Discussions with KWS
Gender • Review of company staff • Number of female employees Quarterly RE’s Social Supervisor
Empowerment records. • Number of male and female toilets
• Physical Inspection
Crime Management • Review of records • Number of reported crimes Monthly RE’s Social Supervisor
and security • Interviews with staff and • Number of complaints
local community
Impacts on Children • Review of records • Record of employees including IDs Monthly RE’s Social Supervisor
• Interviews with staff and
local community
GBV, Sexual • Review of grievance redress • Number of complaints Monthly • RE’s Social Supervisor
Exploitation and forms. • NGO Handling GBV
Abuse • Interviews with local issues
community
Pan-19-003 - vv -
KeNHA

Loss of Life, Injury • Interviews with staff and • Record of accidents and damages done Monthly • RE’s Environmental
and Damage to local community. and Social
Private property • Review of records Supervisors
• Contractor
Labour Influx • Interviews with local • Number of grievances Monthly RE’s Social Supervisor
administration on influx and • Incidences of conflicts
conflicts
• Complaints log
• Interviews with grievance
committee members
Increased Conflicts • Police incidence reports • Records of conflicts with local administration Monthly RE’s Social Supervisor
• Information from Local • Number of grievances
Administration • Complaints logs
• Grievance/Complaints logs
Operation
Completed Road Safety – • Inventory of signages • Missing road signage Replacement of signage KeNHA
Road missing road signage especially at settlement
areas and wildlife crossing
Completed Traffic Accidents • Number of accidents • Police accident reports Monthly KeNHA
Road • Cause of accidents
Completed Wildlife movement • Road Kill records • No of wildlife able to across the road Monthly KeNHA
Road across the road • Ease of movement of KWS
livestock and wildlife across
the road
Completed Noise pollution from • Complains from community • Level of noise generated. Monthly KeNHA
Road traffic at settlement • Noise measurements • Compliance with existing noise standard issued KWS
centres and Lorian • Wildlife behavioral change by NEMA.
Swamp where a) Residential Outdoor
Pan-19-003 - ww -
KeNHA

significant wildlife is Day - 50 dB(A), Night – 35 dB(A)

found b) Place of Worship
Completed Drainage • Complaints from community • Records of drainage water damages Rainy season KeNHA
Road • Route taken by drainage
water after leaving the road
infrastructure
Pan-19-003 - xx -
KeNHA
48. Table D: Provides the Institutional Framework for the Implementation of the ESIA/ESMP
No. Institution Role/Function
Ministry of Transport, Provide funding mechanisms and general guiding policies for the project.
Infrastructure, Housing and
1
Urban Development
(MoTIHUD)
2 The Kenya Roads Board (KRB) The main objective is to oversee the road network in Kenya and thereby coordinate its development, rehabilitation and
maintenance and to be the principal adviser to the Government on all matters related thereto.
3 Kenya National Highways KeNHA
Authority (KeNHA) • Will engage the following dedicated Engineer, Environmental and Social staff to support the project
✓ Project Engineer (Team Leader and Employer Representative)
✓ Deputy Director – Environment and Social Safeguards (Overseeing Safeguards Implementation)
✓ Environmental Safeguards Specialist
✓ Social Safeguards Specialist
✓ Registered Land Valuer
• Will conduct induction and trainings for contractors and supervision staff on ESMP implementation, WB safeguards
requirements, national environmental and social legislative framework requirements
• Will carry out monthly supervision and monitoring of the ESMP implementation
• Will review and approve CESMPs and other plans
• Submit CESMPs and other plans to the World Bank for review and clearance
4 The County and Sub-County The Environment Committee swill:

Environment Committees • Approve applications for Contractors site camps
• Provide permits for quarries and borrow pit sites
• Audit the Contractors camps and construction sites for safeguards compliance
5 The National Environment NEMA will:
Management Authority (NEMA • Approve the ESIA Report
• Issue EIA License for project implementation
• Carry out independent Audit to determine compliance with ESMP
7 Kenya Wildlife Service (KWS) KWS will
Guide and monitor road construction throughout the project area since it is a wildlife dispersal area
8 Water Resources Authority WRA will:
(WRA) Will issue water abstraction permits to enable Contractor use water from boreholes, pans, wells and rivers
Pan-19-003 - yy -
KeNHA
9 Kenya Forest Service (KFS) KFS

• Will provide guidance on which tree species should be planted
• Will provide support in ensuring the trees grow
10 The National Museums of NMK will:
Kenya (NMK) • Carry out recovery of any physical, cultural or archaeological artefacts encountered during construction
• Guide the Contractor’s team on the protection of physical cultural resources
11 National Land Commission NLC will:
(NLC) • Verify the affected land and assets for purposes of compensation and resettlement
• Carry out land acquisition on behalf of KeNHA
• Carry out compensation and resettlement
12 County Governments of Wajir, County Governments will:
Garissa and Isiolo • Provide approval for the project
• Provide Approval for camp sites, borrow pit and quarry sites.
• Provide support
13 County Government - County Department will:
Department of Education, • Provide support to any group at higher risk of being subjected to discriminatory practices, violence, natural or
Gender, Youth, and Social environmental disasters, or economic hardship than other groups within the state
Services • Provide support to any group or sector of society (such as women, children or the elderly) that is at higher risk in
periods of conflict and crisis
14 The Ministry of Public Service, To coordinate gender mainstreaming in national development planning and promote equitable political and socio-economic
Youth and Gender Affairs development for women, men, girls and boys.
15 National Construction Authority NCA
(NCA) • Registers contractors carrying out construction activities in Kenya
• Inspects constructions for compliance
16 Kenya National Commission on KNCHR:
Human Rights (KNCHR), • Investigates and provides redress for human rights violations
• Carries out research and monitor the compliance of human rights norms and standards,
• Conducts human rights education,
17 Commission on Administrative CAJ
Justice (CAJ) also known as • Investigates any conduct in state affairs or any act or omission in public administration in any sphere of Government
the "Office of the Ombudsman" • investigate complaints of abuse of power, unfair treatment, manifest injustice or unlawful, oppressive, unfair, or
unresponsive official conduct.
Pan-19-003 - zz -
KeNHA
18 National Gender and Equality The Commission:

Commission Ensures that there is gender equality and equity throughout the implementation of the project.
Representatives will monitor and evaluate gender quality and equity with regards to job provision and harassment cases on
site to ensure compliance with the law.
19 Department of Community Work with poor, marginalized, vulnerable and disadvantaged communities as its primary target group will ensure that this
Development group is supported and is not left out of the project implementation
20 Directorate of Occupational DOSHS:
Safety and Health Services • Provides OSH permits for workplaces of the project including campsites and quarries
(DOSHS) • Conduct inspections to ensure conformance to OSHA
21 Water Resources Authority WRA
(WRA) • Provides necessary water abstraction permits for boreholes and surface water sources (rivers, streams etc)
• Monitor water use in the region and provide guidance water use
22 Supervision Consultant Supervising Consultant:
• Will engage the following dedicated full-time safeguards staff to support risk management
✓ Supervising Engineer (RE)
• Review and approval of the CESMPs and other plans
• Day to day supervision of Contractor implementation of the CESMPs and other plans
• Regular reporting on the ESMP implementation
• Has full time Environmental, Health and Safety and Social Specialists
23 Contractor Contractor
• Will engage the following dedicated full-time safeguards staff
✓ Registered Occupational Health and Safety (OHS) Expert
• Will Prepare the CESMPs and other plans before commencing construction
• Will Operationalize and implement the CESMPs
• Carries out day to day management of ES, H& S risks
• Reports on incidents and accidents to the Resident Engineer and regulators
Pan-19-003 - aaa -
KeNHA
49. Contractor’s Clauses. The Contractor will be expected to address all
aspects of the construction activities in compliance with all laws and regulations,
approvals, licenses and permits which are applicable to the proposed road
project. The Contractor will ensure that he is familiar with the ESMP for this
project. He shall prepare his work plan and strategy taking into account the
relevant provisions of the ESMP. The required safeguards documents include
the following:
• Construction Environmental and social management plan

• Waste management plan
• HIV AIDS and other Sexually Transmitted Diseases (STDs) plan,
• Child protection plan,
• Plan for prevention and protection against GBV, SEA and Sexual
Harassment,
• Labour rights and the employment of community members.
• Grievance redress mechanism for workers and project area community
• Occupational Safety and Health Management Plan
• Traffic management plan
• Workers code of conduct
• Labour influx management plan
• Stakeholder engagement plan
• Whistleblower plan
It will be required that the plans are elaborate enough to address all the emerging
safeguard issues associated with the project of this magnitude. The Contractor will
be expected to bring on board staff that will be able to address all the safeguards
issues that are likely to arise. These include:
• Environmental Safeguards Specialist
• Social Safeguards Specialist
• Registered OHS Expert
50. Conclusions. Arising from the analysis the proposed project is unlikely to
generate irreversible or permanent negative impacts if the proposed mitigation
measures are implemented . The project area community and key stakeholders
support the project and would like that it is implemented as soon as possible so
that they can start enjoying its benefits. The ESIA has identified potential negative
environmental and social impacts that are likely to arise and proposed appropriate
mitigation measures that require implementation. The impacts include temporary;
permanent, short term, long term and cumulative impacts. Some of the issues
that have been noted by the consultant regarding the project include the following:
o The Modogashe-Wajir Road serves as the administrative boundary of

Garissa and Isiolo Counties for the segment between Modogashe and
Habaswein
o Wajir West and Wajir South Sub-Counties from Habaswein to very
close to Wajir Town.
• There is potential for communal conflicts over competition for natural

resources and other benefits accrued from the project even for residents of
the same centre where the road act as the boundary.
Pan-19-003 - bbb
-
KeNHA
o It was observed that inclusive stakeholder consultations have to be
done on every aspect throughout the life of the project to avoid
potential conflicts arising. KeNHA and the contractor have to ensure
that thorough consultations are done with the community committee
that will be set up before the following is implemented:
▪ Identification and location for Camps
▪ Selection of the sites where the water boreholes are sunk.
▪ Local workers are engaged
▪ The Community is regularly informed about the progress on
issues that are affecting them
▪ ESMP is implemented according to recommendations
provided.
51. Recommendations. Arising from the findings of the study, the following
recommendations are made:
• Contractor is to make robust environmental and social management plans to

address the potential environmental and social risks and impacts that likely
to arise during construction phase of the project. The list of required
management plans is provided in Section 9.3 of this report.
•
• Due to the significant labour influx expected at the project area GBV issues
and Violence against Children (VAC), crime, conflict over job opportunities
and cultural issues are likely to increase. The Contractor shall ensure the
following plans are ready for implementation before commencement of
construction activities:
o CESMP
o Stakeholder engagement plan
o Security Management Plan
o Labour Influx Management Plan
o Workers sign the Code of Conduct
o CSO handling GBV issues is ready to mobilize
o Grievance Redress Mechanism (GRM)
o Contractor and the local CSO who will be managing the GBV/SEA
issues to ensure sensitization and training plans are in place.
Pan-19-003 - ccc
-
KeNHA
1 INTRODUCTION
1.1 Project Background
52. The Ministry of Transport and Infrastructure is the overall government body
charged with ensuring transportation and accessibility of all areas within the
country. It does this through Kenya National Highway Authority (KeNHA). Kenya
Urban Roads Authority (KURA) and Kenya Rural Roads Authority (KERRA) within
the country in meeting its mandate.
53. Kenya National Highways Authority (KeNHA) is a state corporation,
established under the Kenya Roads Act 2007 with the responsibility for the
management, development, rehabilitation and maintenance of international trunk
roads linking centres of international importance and crossing international
boundaries or terminating at international ports (Class A road), national trunk roads
linking internationally important centres (Class B roads), and primarily roads linking
provincially important centres to each other or two higher-class roads (Class C
roads).In undertaking this mandate, the Authority propels the country to achieve its
infrastructure goals espoused in the vision 2030.
54. Road transport is the predominant mode of transport in Kenya, carrying
approximately 93% of all cargo and passenger traffic in the country. The road
network in Kenya has been established to be approximately 160,886 km long,
comprising of approximately 11,189km of paved roads and 149,689km of unpaved
roads. The bulk of the road network in Kenya lies within the highly populated parts
of the country, providing some level of access to the rest of the country. In sparsely
populated areas of the North-Eastern counties of Isiolo, Wajir, Mandera and
Garissa covering a total area of approximately 152,694km2 or 26% of Kenya's land
mass has a road network of only 9,386km or 6% of the total road network in the
country which is predominately unpaved. The poor condition of road network in
these areas has contributed to uneven distribution of local produce due to time
factor and breakage. The effect of this is that recovery and development costs in
all sectors are adversely affected, hindering a rapid development of the region. In
addition, failure to improve the road conditions of the transport corridors in this
region that provide access to the sea and productive centres hinders the realization
of full benefits from devolution.
55. It is against this background that the Government of Kenya (GoK) through
KeNHA has received funding from the World Bank towards the cost of the North-
Eastern Transport Improvement Project (NETIP). KeNHA intends to use a portion
of the credit proceeds to undertake the design and safeguards instrument
preparation for the road project; while GoK is to finance the construction works of
the road. The project will involve upgrading of the Isiolo-Mandera road to bitumen
standard. This includes the Modogashe – Wajir section that is the focus of this
report. The Proposed road starts from Modogashe town and passes through
Habaswein, Samatar and Wajir town covering a total distance of 157km. The
project road has been placed as Category A under the World Bank Operational
Policy requiring Environmental and Social Assessment. In this regard an
Environmental and Social Impact Assessment (ESIA) has been prepared to
address the potential environmental and social impacts that could arise from the
road upgrading activities.
56. The exercise was carried out in accordance with the National Environment
Management Authority (NEMA) of Kenya Environmental Impact Assessment and
Audit Regulations of 2003 and EMCA, Cap 387 and World Bank Safeguards
Policies and Procedures. The policies that were triggered include:
• OP/BP 4.01 Environmental Assessment
Pan-19-003 -1-
KeNHA
• OP/BP 4.04 Natural Habitats

• OP/BP 4.10 Indigenous People
• OP/BP 4.11 Physical Cultural Resources
• OP/BP 4.12 Involuntary Resettlement
• World Bank Group Environmental, Health and Safety (EHS) General
Guidelines
52. The other safeguards documents for the project that are under preparation include:
• ESIA update for Isiolo-Kulamawe-Modogashe road section
• ESIA update fpr Wajir-Elwak road section
• RAP update for Isiolo-Modogashe road section
• RAP update for Modogashe -Wajir road section
• RAP update for Wajir-Elwak road section
• Environmental and Social Management Framework (ESMF)
• Resettlement Policy Framework (RPF)
• Social Assessment (SA)
53. The NETIP is aimed at enhancing connectivity between Kenya and its neighbouring
countries to the north that is Somalia and Ethiopia and also to improve inter County
connection. within the North Eastern region of Kenya. The proposed design intends
to improve the road section from its existing state to bitumen standards. In addition,
the new road corridor will provide an emergency runway for light aircrafts in addition
to other road furniture. This would be achieved through increasing transport
efficiency which would spur trade and development along the Isiolo-Wajir-Mandera
road corridor and also make it easy to connect the area with information and
communication technologies.
54. The road reserve for the proposed project is 60 meters. Most of the area traversed
by the road is on community land vested on Isiolo, Garissa and Wajir County
Governments.
55. Potential beneficiaries of the proposed road project include motorists , traders,
transport companies, communities living along the road corridor, investors in the
agriculture, tourism and mining sectors of the economy and consumers of goods
and services from these sectors. The communities along the project road are
VMGs. Improvement of the road will no doubt stimulate development, integrate, and
contribute to improved security and bringing about sharing the prosperity of the
country with this region. At the national level, this project is expected to contribute
significantly towards the attainment of Kenya’s Vision 2030, economic growth,
employment creation and poverty
56. Prior to this study, KeNHA engaged Intercontinental Consultants and Technocrats
Pvt. Ltd.in association with ITEC Engineering Ltd to carry out review and update of
project designs and preparation of ESIA Reports in 2017, at time the project was
classified as Category B which has since been reclassified to Category A.
necessitating another update to comply with the OP/BP 4.01 Environmental
Assessment for Category A projects . Therefore, this updated project report covers
the road section between Modogashe -Wajir.
57. The Wajir-Modogashe road section falls under component 1 of NETIP which
includes the following:
58. Component 1: Upgrading Selected Critical Road Infrastructure and associated
roadside amenities (US$455.50 million). This component includes:
Pan-19-003 -2-
KeNHA
• Support to KeNHA to carry out design review and feasibility and detailed design
studies for upgrading 344km of the Isiolo-Wajir-Mandera comprising the
following road sections: (i) Isiolo-Kula Mawe (77km); (ii) Kulamawe-Modogashe
(113 km); (iii) Modogashe- Habaswein (51km); (iii) Habaswein-Samatar (41km);
and (iv) Wajir-Elwak (175km);
• Provisions for roadside social amenities and Human Immunodeficiency Virus
Infection/Acquired Immune Deficiency Syndrome (HIV/AIDS) prevention
measures to help raise awareness and provide mitigation interventions to
support efforts to protect the local community, drivers and contractors’
personnel;
• Carry out a program of activities designed to implement transport, trade and
development facilitation measures, for instance, a program to cover activities
such as carrying out a study to enhance social infrastructure and social services
delivery along the corridor;
• Designing and establishing facilities and marketing system for pilot pastoralist
roadside markets;
• Provision of market shades, milk cooler, slaughter houses, veterinary posts,
livestock holding area in selected locations;
• Designing and implementing activities to support key Project stakeholders such
as county governments, communities, and households on management and
operational modalities of these facilities;
• Strengthening the capacity of KeNHA in enhancing the road design manuals
and specifications as well as contract management, value engineering, road
maintenance, safeguards and procurement management and training; and
Preparation of future projects
59. Component 2: Institutional Development and Project Monitoring and Management

(US$12.50 million). This component includes
• Support to the State Department of Infrastructure on enhancing project
management and oversight capacity, maintenance management and
engineering capabilities in the transport sector;
• Support to Materials department in mapping road construction material sites;
• Supporting the State Departments of Infrastructure and Transport in the
monitoring and evaluation of the projects;
• Support to strengthen the National Transport and Safety Authority to:
• Conduct needs assessment, vehicle safety inspection and safety audits;
• Strengthening enforcement capability of the Authority and post-impact care; and
• Assessing road safety on the Isiolo-Mandera Corridor;
• Strengthening the capacity of the National Construction Authority in overseeing
and developing the local construction industry; and
• Training and coordination of Project implementation activities, including audits,
and the monitoring and evaluation of progress achieved in the execution of the
Project.
60. Component 3: Enhancing Internet Connectivity (US$34.00 million). Support to
Technology Authority for: Carrying out feasibility and detailed design and the
construction of a fiber optic cable network, alongside the part of the Isiolo-Mandera
Corridor; Construction of fiber spurs and rings and provision made for connecting
selected schools, hospitals and other strategic locations including pastoralist
roadside markets, rest stops and community and service Centres along the corridor;
Connecting community information Centres with fiber optic connection and advisory
Pan-19-003 -3-
KeNHA
services in the management of these facilities and services; and Institutional

strengthening of ICTA and training.
1.2 Need for ESIA Study Review and Update
61. KeNHA engaged Intercontinental Consultants and Technocrats Pvt. Ltd.in

association with ITEC Engineering Ltd to carry out review and update of project
designs and preparation of ESIA Reports in 2017/8. During the preparation of the
ESIA Report 2018, the project was assigned Environmental Assessment Category
B since the anticipated impacts were not expected be sensitive, irreversible and
unprecedented. However, in the course of project preparation, new information
emerged, and the World Bank and KeNHA have reclassified the Environmental
Assessment Category to 'A', because it is anticipated that the potential impacts will
be significant and adverse, and the direct and indirect environmental and social
impacts are likely to be diverse, sensitive or unprecedented.
62. The proposed road from Modogashe-Wajir will have significant impacts along the
road corridor including loss of grazing land along the road, change in the landscape
not just along the quarry and borrow sites (loss of materials), impacts to wetlands
like Lorian and Borji Swamps, dry river beds which act as source of water for
domestic use, livestock and wildlife drinking points. establishment of larger market
centres and towns, influx of new populations in search of new job and business
opportunities, interference with existing ways of life, Gender Based Violence (GBV),
increased conflicts, pressure on existing resources, increase in traffic during the
operation phase leading to increase of foreign members to the community. The
Review and Update of the Modogashe-Samatar-Wajir road which will be financed
by using GoK funds is being done under Category A
63. The proposed project Component 1 c, d and e will provide for social infrastructure
that include market shades, milk cooler, slaughterhouses, veterinary posts,
livestock holding area, whose exact locations and designs are unknown at this
stage of project preparation. Thus, the Borrower has prepared the Environmental
and Social Management Framework (ESMF), the ESMF sets out the principles,
rules, guidelines and procedures to assess the environmental and social impacts of
the subprojects prepared during Project implementation i.e. ESIAs/ESMPs, ARAP
and RAPs. It includes guidelines to prepare measures and plans to reduce, mitigate
and/or offset adverse impacts and enhance positive impacts of subprojects,
provisions for estimating and budgeting the costs of such measures, and
information on the agencies responsible for addressing project impacts. The
supplementary safeguard instruments for the social infrastructure will be prepared
by KeNHA, reviewed and approved by the Bank during implementation.
1.3Project Justification
64. The North-Eastern region has very poor road network, most of the roads are
currently earth/gravel roads and the road in the project area is no exception. The
project is located in an area where the Government of Kenya considers as
vulnerable and marginalized. The condition of the road has been a serious
hinderance to socio-economic development of the region. Some of the
consequences include high travel costs, time wasted in travelling, high cost of
goods, insecurity, difficulties in accessing social services.
65. Upgrading of the road will result in reduced vehicle operating costs (fuel saving,
reduced repair and maintenance costs) including time saving for existing and
generated traffic.
Pan-19-003 -4-
KeNHA
Additionally, the road is traversing pastoralist communities who stand to benefit

through efficient transportation of livestock and livestock products to markets
outside the project area. Further the upgraded road will increase the potential for
institutional development and increased attraction for commercial development. In
addition, the improvement of the road is critical in promoting and facilitating traffic
movement within and around Wajir, Garissa, Isiolo and the greater North-Eastern
region.
66. In summary the project will lead to overall improvement of the communities’
standards of living and facilitate economic development of the region thus
contributing towards attaining the Kenya Vision 2030 objectives.
67. The Proposed Road Project is expected to meet the following objectives and service
needs both during construction and operation phases:
• Improve the region’s road network;
• Reduce travel time along and across the roads;
• Enhance the operational efficiency of the road;
• Promote economic growth within the region;
• Improve safety and reliability for all road users;
• Provide employment opportunities to local inhabitants, among other
benefits.
Pan-19-003 -5-
KeNHA
2 PROJECT DESCRIPTION
2.1 Location of the Road Project
68. Modogashe – Wajir section of the NETIP project road is in the North Eastern part of
Kenya traversing through Isiolo County, Garissa County and Wajir County. The road
starts at Modogashe (UTM 0518923, 00800801) at its intersection with A13 (formerly
(C81) road and B84 (formerly B9) road and terminates in Wajir town (UTM 0617643,
0193885). The road covers a total distance of 157km. The Road runs from Modogashe
through Habaswein, Samatar and ends in Wajir Town. From Modogashe to Wajir, the
road runs in the north-east direction. The project road is shown in Map 1 of this report.
69. The first 42 km of the road runs along the boundary between Garissa and Isiolo Counties
while the other 115km is in Wajir County.
70. Town Centres within the road corridor are Modogashe in Garissa and Isiolo Counties
(where the project road commences and Wajir Town where the road ends (Wajir County
Headquarters). Large Trading Centres within the project area are Habaswein, Kanchara,
Samatar/Guticha and Lagbogol in Wajir County. Smaller Trading Centres – Skanska
(Garissa County), Lagdima, Borji and Leheley (Wajir County).
2.1.1 Other Roads in the Project Area
71. The roads under construction in the project area include:

• The LAPSSET road project from Lamu to Isiolo to South Sudan and Ethiopia. Within
Isiolo, the LAPSSET is currently undergoing RAP implementation before
commencement of construction works. The LAPSSET project road will intersect the
project road near Kulamawe.
• The Garissa – Modogashe A13 road is currently undergoing upgrading to bitumen
standards and will intersect the Project Road at Modogashe
2.1.2 Existing Road Reserve
72. The ROW for this road is 60m within the rural sections and varies between 30 to 40m
within the small towns and 10 to 20m within the more densely populated Wajir town.
2.1.3 Present Condition of the Road
Road Status
73. Murram - Presently, the existing road is gravel surfaced and in a poor condition. It has
heavy corrugations that make driving difficult. Motorists have now made several
alternative roads away from the main road. Currently, over 90% of the road that is used
by motorists from Modogashe-Wajir is outside the main road. In some sections of the
route, motorists have created as many as six (6) parallel roads outside the main road.
Seeking better smoother earth roads.
Pan-19-003 -6-
KeNHA
Map 1: Location of the Proposed Modogashe - Wajir (A13) Road
Pan-19-003 -7-
KeNHA
74. Tarmac – Approximately 5km of the last section of the project road into Wajir Town is
made of tarmac. The tarmac roads in Wajir town CBD were facilitated by the County
Government of Wajir. The road is in fair condition but some section having developed
potholes. The presence of tarmac road in Wajir town has made the CBD vibrant and
improved businesses.
75. Terrain. The geometrics of the existing road is pre-dominantly flat with gently rolling
sections thereby presenting drainage challenges. The ride quality of the project road is
quite low with numerous washouts and flooded areas during rainy season. The project
area has a gentle rolling terrain slightly sloping to the south east as manifested by the
drainage of seasonal (Ewaso Ng’iro, Laga Bogal and Laga Bar Rivers)
76. Drainage. The current road alignment has pipe culverts, box culverts, concrete drifts
where storm-water in the seasonal rivers cross the alignment. There is one narrow
bridge built across Ewaso Ng’iro River near Habaswein Trading Centre. Only one vehicle
can pass the bridge at a time. The drainage of the project area is largely from the north-
west to south east direction.
77. Road Signage. The road does not have any signage even in areas where there is a
bridge or drifts.
2.2 Project Design Features
78. The design report indicates that the Modogashe – Wajir (B9, now, A13) road was
designed in accordance with the Road Design Manual Part 1; Geometric Design Manual
of Rural Roads by Ministry of Works, Roads Department, January 1979. The geometric
design review will also be based on the same manual. The road has been designed in
two lots namely;
a. Modogashe – Samatar (88.7Km) and
b. Samatar Wajir (67.5KM)
The project also includes service roads and loop roads within the main towns along the
road including Modogashe, Habaswein, Laghbogol, Lahley and Wanjir.
2.2.1 Terrain of the alignment
79. The road mostly traverses a flat terrain with no existing embankment except for the last
5km approaching Wajir town, where the road is paved and constructed on 1m high
embankment fill. The rest of the road sections are unpaved and in poor condition. The
average road width for the unpaved sections is 10m. The available ROW is 60m within
the rural sections, and varies between 30 to 40m within the small towns and 10 to 20m
within the more densely populated Wajir town. The biophysical features encountered
along the Modogashe-Wajir Road are elaborated in Annex 4 Sample photos of the
features have also been included.
2.2.2 Cross section
Modogashe-Wajir Road
80. The road is proposed to be upgraded into a 7m wide carriageway with a 2m shoulder on
either side making the total road width of 11m. Since the topography is low lying/flat
which is susceptible to flooding, the proposed road is entirely on a fill of approximately
1.5 to 2m, that height of the embankment will require an embankment slope of at least
1:2 (vertical: Horizontal) this will result with a total embankment width of approximately
20m which is the minimum construction width excluding any need to construct bus bays,
lorry parking areas, deviations, toe drains and cut off drains. It is however noted that
some sections of the road will have a much higher fill especially the section through the
Pan-19-003 -8-
KeNHA
Lorian swamp where the height of the embankment is between 2- 4m which will result
in a wider construction width.
Pan-19-003 -9-
KeNHA
Figure 1: Typical rural road cross section
The design has also proposed the cross section to be adopted in the main towns along the road incorporating a service road.
Pan-19-003 - 10 -
KeNHA
Figure 2: Typical urban road cross section
Pan-19-003 - 11 -
KeNHA
81. The World Bank and KeNHA recently carried out a climate change vulnerability
assessment on the NETIP road corridor which includes the Modogashe – Wajir road
section. Among the objectives was to inform the detailed design of the proposed
improvements along Isiolo- Mandera road corridor to address natural hazards and
projected climate related risk. The report identifies the section between Km 26+200 to
Km 48+000 (Lorian Swamp) as high risk to flooding. High embankment in this section
has been designed, and dry-stone pitching has been proposed for slope protection
where there is a risk of flooding and erosion.
Proposed Measures
• Provision of sufficient cross drainage structures to allow passage of water across the
embankment fill.
• It is proposed that in this section the embankment be of such height as to ensure
that the bottom of subgrade remains at least 1.0m above the highest water table/
flood water level (IRC: SP:73 - 2015) During construction, the existing gravel road
surface shall be scarified to a depth of 50mm before the new embankment is
constructed over the existing road surface (where the new and old road alignments
are coincident).
• Fill material that meets the criterion for subgrade materials of at least S3 quality used
in this road shall apply for this specific flood prone section.
• At critical locations where ground treatment is required as per the site condition
especially in the swampy area the ground shall be stabilised with rock fill. According
to Clause 507 of The Standard Specifications for Road and Bridge Construction, the
maximum dimension of rock fill shall be 250 mm, reasonably well graded and with
less than or equal to 5% finer than 10mm material.
• The embankment slopes shall be protected against erosion by top soiling and
grassing. Efforts should be made to encourage the growth of the indigenous plants
with a mix of annual and perennial vegetation. Grouted stone pitching is also
recommended at culvert inlets and outlets and at bridges or where there is possibility
of damage to the embankment by water.
2.2.3 Horizontal Alignment Design
82. In the previous design, horizontal alignment was generally designed for a design speed
of 100 km/hr. In the present design review, the horizontal alignment has been re-
designed following the existing alignment to minimize land acquisition, while at the same
time ensuring that the design standards are adhered to. The design speed at the built-
up areas has been relaxed to 50kmph, mainly to minimize land acquisition, particularly
in built up areas.
2.2.4 Vertical Alignment
Modogashe-Samatar
83. The terrain of this road section is largely flat. The vertical geometry has been Designed
as per the guidelines given in the RDM-I. The gradients achieved are very gentle with a
maximum vertical slope achieved being 1%.
Samatar-Wajir
84. From the site visit, it was observed that about 5km of the road to Wajir has been
improved to bituminous standards. Consequently, the vertical alignment has been re-
designed taking into consideration the existing road levels.
Pan-19-003 - 12 -
KeNHA
2.2.5 Truck Parking areas
85. Parking for Lorries has been proposed for the area immediately after Modogashe town,
on either side of the road and also one before and after Habaswein town for each
direction. These are indicated in the book of drawings. The Terms of Reference require
that lorry parking facilities be provided approximately every 30 – 50Km. The parking
should be paved and able to accommodate at least 10 HGVs facing each direction. As
for the stretch of the road from Samatar to Wajir, one set of lorry parking has been
proposed at Laghbogal town on either side of the road and one for Wajir town on left
side before the entry of the town.
2.2.6 Design Criteria for Main Carriageway Pavement
86. The pavement design is based on the Kenya RDM Part III. Based on the traffic class
(T2) and the improved subgrade class of S3, Standard Pavement Structure Type 5 is
considered the most suitable. The structure consists of layers as given in Table 1 below.
Table 1: Pavement Structure for Main Carriageway

Design
No Design Details
Parameters
1 Surfacing 75mm (0/20mm) thick binder course asphalt concrete
(SUPERPAVE) to cover both the carriageway and shoulders.
The AC shall be covered with 10/14mm single seal surface
Dressing. Chippings for surface dressing shall be class 3 and
above.
2 Base 150mm thick 2% cement stabilised gravel
Type of cement is CEM II, 32.5N
3 Subbase 175mm thick 2% cement improved material (base quality)
Type of cement is CEM II, 32.5N
4 Subgrade Lower subgrade layer - At least 300mm thick S3 quality gravel
Upper subgrade layer – At least 350mm thick S5 quality gravel
For both layers, the maximum swell shall be 2% and compaction
shall be 100% MDD (AASHTO T99)
Source: Design Report 2018
This is the same pavement recommended by the previous design.
2.2.6.1 Climbing lanes
87. Climbing lanes are provided in accordance with Road Design Manual Part 1. Where
longitudinal gradients are long and/or steep enough to cause significant increase in the
speed difference between cars and heavy vehicles, both traffic safety and road capacity
may be adversely affected. As the project road traffic in design year 10 is in between
2,000 and 6,000 pcu, climbing lanes are proposed at 21+490 to 21+985 for 495 m.
2.3 Drainage Structures along the Road Corridor
88. The drainage proposed along the road comprises of numerous pipe culverts and box
culverts of varying sizes, the former consist mainly of 900mm-1200mm diameter pre
cast concrete pipe culvert either as a single line or a several of them while the box
culverts consist of either a single cell or multiple cell of varying sizes ranging from
3mx1.2m to 4.2mx 2m, there is also a 24m span bridge proposed at km45+835.
The numerous cross drainage structures are a pointer to the topography of the area and
the drainage characteristics that is fairly flat with few defined channels, the dominating
drainage feature is the Lorian and Borji swamps.
Pan-19-003 - 13 -
KeNHA
89. There are numerous culverts proposed within the swamps to allow passage of water,
the structures are mainly expected to act as relieve. The culverts are appropriately sized
with adequate capacity to pass the expected flows, the sizing has included a factor of
safety to cater for abnormal flood than the design discharge. The factor of safety is of
the order between 10% to 30% depending on catchment size. Thus, no choking is
expected occur.
90. The alignment crosses the North Ewaso Ngiro (Lorian Swamp) at coordinates
(551402N, 110024E) near Habaswein and several laggas which are critical sources of
water for domestic use; livestock and wildlife drinking points. Spread of flood water from
the Ewaso Ngiro shall necessitate provision of battery of culverts for cross drainage
spread over road length starting from km 26 to km 48 (Lorian Swamp). The road design
has provided sufficient design measures to ensure the flood waters do not affect the
road and cause safety risks. The streams in the project area carry substantial silt
charges that settle cross drainage structures. The culverts built in areas where the
project road crosses the Lorian Swamp overflow and become heavily silted and clogged.
Pan-19-003 - 14 -
KeNHA
A typical plan and profile of the road section through the Lorian swamp is presented below
Figure 3: Typical urban road cross section
Pan-19-003 - 15 -
KeNHA
Pan-19-003 - 16 -
KeNHA
The section through Lorian swamp comprises of numerous drainage structures as included
in the table below;
Table 2: Drainage Structures at Lorian Swamp

Structure No Remarks
Bridges 1 A 24m span across the ewaso Ng’iro river at Km 45+857
Box culverts 65 Single and multiple cell structures ranging from 2.5X1.3 to
4.2X2
91. The Borji swamp (0593740, 0142632) which is a seasonal swamp is located
approximately 10km north east of Lagbogol centre along the the road to Wajir Town.
The swamp serves as dry season grazing zone though it impedes road transport during
the wet season as most sections on the swamp become impassable. The swamp
stretches 0.44km across where the road passes. The construction activities will interfere
with 0.44km by 60m of the swamp area. This translates to approx. 6.5acres of swamp
land. The culvert for the seasonal river (at km 100+500, River Laghbogol) poses danger
to the motorists when the river has flowing water. These drainage structures are
distributed as shown in Table 3 below.
Table 3: Existing Drainage Structures along the Project Road

Modogashe - Samatar -
No. Structure Type Total
Samatar Wajir
1 Bridges 1 0 1
2 Fully Chocked 14 0 14
Structure
No of RC Box 5 0 5
3 No of Drift 22 3 25
4 Pipe Culverts 80 21 101
2.4 Construction Material Sources (Gravel, Hard stone, Sand and Water)
92. The potential sources for gravel and hardstone were identified during the design stage.
These are existing sites that still have the potential to provide the required materials.
The sites were visited, and the baseline environmental and social settings were
assessed. However, the contractor will have the responsibility of sourcing for suitable
sources of materials. It is recommended that the contractor endeavors to establish
quarries within the proximity of the project road to avoid the long haulage distances and
the associated impacts on the existing roads.
2.4.1 Gravel Sources
Modogashe-Samatar
Four (4) potential gravel material sites (MS) were identified as shown in Table 4.
Pan-19-003 - 17 -
KeNHA
Table 4: Identified Potential Gravel Sources for Road Construction

S/No. Chainage Remarks Approximate Northing Easting
(km) 3 (37N) (UTM)
Yield (m )
Material 50+000 RHS at 6.7 km from the 139,500 0561550 0114587
Site 1 Habaswein Samatar Road
(Turnoff from Alignment Section
at 37N 0555515, UTM
0112685) Contains coral gravel
with quartz.
Material 60+000 Along the existing Habaswein- 148,400 0562859 0118404
Site 2 Samatar gravel road at 10 km
from Habaswein Town
Contains whitish coral gravel with
reddish brown quartz.
Material (-) 4+600 Along the Nuno- Modogashe 189,000 0521334 0076858
Site 3 Section dirt road, 4.6 km from
km 0+000 of the project road
Contains reddish quartz with
greyish
brown coral gravel
Material 1+900 LHS along Modogashe- 160,000 0519110 0082389
Site 4 Habaswein Section (Turnoff from
Alignment Section at 37N
0519064, UTM 0082068)
Contains whitish grey gravelly tuff
with
quartz.
Figure 4: Location of Map of material sites along the Modogashe Samatar road
Samatar-Wajir
93. Four (4) potential gravel material sites (MS) were identified, sampled and tested for
suitability for use as pavement materials on the project road. The locations of the
material sites are given in the Table 5.
Pan-19-003 - 18 -
KeNHA
Table 5: Identified Potential Gravel Sources for Road Construction

S/No. Chainage Remarks Approximate Northing Easting
(km) 3
Yield (m )
Material 15+300 Both LHS and RHS along 150,000 595567 146965
Site 1 Samatar – Wajir road
Material LHS along Samatar –
Site 2 15+600 Wajir road section 110,000 595741 146869
Material Both LHS and RHS along
Site 3 51+300 Samatar – Wajir road 141,120 611260 178587
Material Both LHS and RHS along
Site 4 56+100 Samatar – Wajir road 78,000 613618 182805
Source: Design Study 2018
Figure 5: Location Map of material sites along the Modogashe Samatar road
2.4.2 Hard Stone Sources
94. Five (5) existing hard stone sources were identified during the design stage and
assessed. They still have the potential to provide the required materials.
95. Table 6 below provides details of the location of the five sites. Most of the quarry sites
are within the Isiolo area, with the Kibiru Quarry being the furthest at approximately
340km from Wajir town which is the end point of the project road. There were no
suitable stone quarry sites found within the project road vicinity.
Table 6: Potential hard stone sources

No Location Northing (36N) Easting (UTM)
1 Kibiru quarry 0346973 0034060 Near Isiolo Town
2 Babitho quarry 0425930 0059160 Near Garbatula along Isiolo
Modogashe Road
3 Mtaiboto quarry 0355640 0070128 Near Archers post along A2
(Isiolo – Moyale Road)
Pan-19-003 - 19 -
KeNHA
No Location Northing (36N) Easting (UTM)

4 Ndamuru quarry 0370080 0039532 Off the Isiolo – Modogashe
Road towards Meru
5 Kula Mawe 0410751 0062256 At Kulamwe Township along
quarry Isiolo Modogashe Road
Figure 6: Location Map of Hard Stone Quarries
2.4.3 Sand Sources
Modogashe-Samatar
Three (3) sand sources have been identified as shown in Table 7 below.
Table 7: Sand Sources along Modogashe-Samatar Road

Easting
S/No. Remarks Northing (37N) Elevation
(UTM)
(m)
Lagdima S1 RHS at 2.3 km from the 0557387 0113117 225
Habaswein Samatar Road
River Sand (Turnoff from Alignment at
37N 0555515, UTM 0112685)
Lagtarjan S2 LHS at 1.2 km from the 0555293 0113505 219
Habaswein Samatar Road
River Sand (Turnoff from Alignment at
37N 0555515, UTM 0112685)
Habaswein S3 RHS at 1.8 km from the 0521880 0082998 258
Modogashe -Habaswein Road
River Sand (Turnoff from Alignment at 37N
0520669, UTM 0085241)- at
Tarjan Laga
Pan-19-003 - 20 -
KeNHA
Samatar-Wajir Road
Three (3) sand sources have been identified along Samar-Wajir Road:
• Site S1 – Along River Laghbogol
• Site S2 – Near Leheley Town
• Site S3 – Beyond Wajir Town
96. Sand to be utilized in the project will be of specified standard and as per Engineer’s
approval. Where the contractor opts for direct harvesting then he will be required to
seek Engineer’s approval. In addition, other permits that are required from County
Government. include use sustainable sand harvesting guidelines and any other County
regulations.
2.4.4 Water Source for Construction
97. Water for construction of the Modogashe-Wajir Road will mainly be obtained from
boreholes and Wells along the project road. Water is an extremely precious resource in
this area. Issues relating to access to water often lead to conflicts between whole
communities. Other potential negative impacts include livestock-wildlife-human conflict,
disease, salinity and water quality. It is in this regard that any permanent water sources,
to be handed to the communities upon decommissioning, should be carefully selected.
Table 8 & 9 provide the lists of water sources identified for construction by the Design
Consultant.
Table 8: Potential Water Sources for Construction (Modogashe-Samatar Road)

S/No. B/H Depth Rate Remarks Northing Easting Elevation
(m) (m3/hr) (37N) (UTM) (m)
1 Habaswein Water 160 9 Operational 0554727 0111807 214
Supply
2 Bulla Juu 250 12 Operational 0555205 0110571 211
3 Asal Borehole II 200 12 Operational 0556801 0112095 220
4 Ademasajida 200 12 Operational 0553059 0113567 207
5 Lagdima 200 24 Operational 0533662 0100828 216
6 Kanchara 250 7 Operational 0537743 0103744 214
7 Guticha 250 9 Operational 0542127 0106157 207
8 Skanska - 0546927 0107988 209
9 Ewaso Ng‟iro River Operational
Table 9: Potential Water Sources for Construction (Samatar-Wajir Road)

S/No. Source Name Depth Rate Remarks Pump
(m) (m3/hr)
W1 Leheley Shallow Well -- -- Operational --
W2 Lagh Bogol South Borehole No. 1 at km 210 15 Operational --
10+300
W3 Lagh Bogol South Water Pan at km -- -- Operational --
11+000
W4 Lagh Bogol North- Borehole No. 2 -- -- Operational --
Pan-19-003 - 21 -
KeNHA
W5 Lagh Bogol North- Water Pan- No. 2 -- -- Operational --

W6 Wajir Shallow Well 50 -- Operational --
W7 Al Fatah Borehole (Privately owned) 144 3 Operational 2.2 kW
W8 Chines B/H 250 10 Operational 9.2 kW
W9 Samatar B/H 250 10 Operational 7.5 kW
Figure 7: Sand and Water Sources along the Samatar-Wajir Road
2.5 Traffic Forecasts
2.5.1 Traffic Forecast Samatar-Wajir Section
98. Traffic surveys were carried out between 30th January and 12th February 2018 by the
Design Consultants in Wajir Town, Leheley and Lagbogol Centres. The preliminary
Annual Average Daily Traffic (AADT) flows for the various stations along the project road
are as summarized in Table 10.
Pan-19-003 - 22 -
KeNHA
Table 10: Summary of AADTs (2018) along Samatar-Wajir Road
Large Bus
Small Bus
M/Cycles
Matatus
Saloon
Others
Large
HGV1
HGV2
Location Direction
Vans
Total
Pick-
MGV
Cars
Cars
LGV
ups/
Northbound 39 26 21 22 3 0 12 0 11 30 10 0 175
Southbound 45 25 18 17 3 1 10 0 9 23 10 0 160
Lagbogol
Both Directions 84 52 38 38 6 1 22 0 20 52 20 0 335
Northbound 25 50 22 7 6 0 14 0 25 24 16 0 189
Southbound 23 29 21 9 7 0 12 1 21 25 13 0 161
Leheley
Both Directions 48 80 43 16 13 0 26 1 46 49 29 0 350
Northbound 356 186 83 53 15 2 16 1 27 25 12 2 780
Southbound 367 203 93 70 13 1 12 0 29 29 16 2 834
Wajir
Both Directions 723 390 176 124 29 3 28 1 56 54 28 4 1,614
Source: Final Design Study 2018
2.5.2 Traffic Forecast Modogashe-Samatar Section
99. Traffic surveys were carried out at strategic locations along the project road between 8th
September and 21st September 2017 at the locations shown in Table 11. The Average
Daily Traffic (ADT) was calculated as the average flow for the 14 days in which traffic
counts were carried out. Since no historical traffic data was available for analysis of
seasonal variation factors, a seasonal variation factor of 1.0 was adopted. The base
year was therefore t ken as 2017.
Table 11: Summary of AADTs (2018) along Modogashe-Samatar Road

Pick-ups/
Location
M/Cycles
Matatus
Census
Saloon
Others
HGV1
HGV2
Large
Large
Small
Total
Vans
MGV
Cars
Cars
LGV
Bus
Bus
Direction
Modogashe
Northbound 83 20 12 13 2 2 1 1 8 15 2 0 159
Southbound 82 19 11 12 1 2 2 0 5 13 2 0 150
Both 165 39 23 25 3 4 3 1 13 29 4 0 308
Directions
Habaswein
Northbound 50 45 23 12 1 0 5 1 15 34 15 0 201
Southbound 50 50 24 17 0 0 8 4 13 36 16 0 217
Both 100 94 47 29 1 0 13 5 28 70 31 0 418
Directions
Northbound 11 7 13 7 0 0 7 1 12 16 9 0 82
road junction
Southbound 9 5 11 10 0 0 8 2 9 14 9 0 77
Samatar
Both 20 12 24 16 0 0 15 3 20 30 18 0 159
Directions
Source: Design Study 2018
Pan-19-003 - 23 -
KeNHA
2.6 Project Construction and Operational Activities
2.6.1 Outline of the Construction of the Road
2.6.1.1 Construction Overview
100. A pre-qualified Contractor capable of carrying out road construction will undertake
construction of the road and associated works. The construction will require a number
of temporary facilities such as equipment and workshop yard, labour camp and site
offices. The construction contract will be based on FIDIC (International Federation of
Consulting Engineers) conditions, which stipulate that the Contractor must provide a
performance bond as well as the following insurances:
• Insurance of works and contractor’s equipment
• Third party insurance
2.6.1.2 Ground Investigations
101. Prior to actual construction work, the Contractor will undertake additional ground
investigations over and above the one done by the Consultant. These additional ground
investigations will be more elaborate. Samples from test pits will be subjected to both
visual observations and laboratory tests.
2.6.1.3 Demolition and Site Clearance
102. This will include general clearance of vegetation including their disposal. Where
necessary, trees will be cut, their stumps removed and resulting holes backfilled. Where
the road requires slight realignment, or there is need to clear the entire width of the road
reserve, existing structures, which are in the way of the construction, will be demolished
and disposed. This is likely to be intense in Modogashe, Habaswein and Wajir where
there is substantial encroachment into the existing road reserve. The demolished
elements will include brickwork, concrete, masonry blocks, metal (largely steel) and
timber.
2.6.2 Concrete Works
103. There will be concrete works at certain sections of the road that require
reinforcement. In addition, new culverts and other drainage structures will be required.
2.6.3 Earthworks
104. Earthwork operations will be carried out in preparation of road sub-grade and
drainage, in addition to auxiliary works within the road corridor. Earthworks will include:
105. Site survey and setting out
• Excavation by cutting into topsoil, normal soil, rock or artificial material
• Trimming some excavated surfaces and disposing of excavated material(s)
• Filling to embankment and general filling with imported natural material other than
topsoil. Natural materials include rock; sand and other approved naturally occurring
materials
• Scarifying, watering and compaction of fill layers or in situ road formation level.
• Providing, placing and lapping geo-textile materials
Pan-19-003 - 24 -
KeNHA
2.6.4 Road pavement
106. The road pavement comprises of the following: -

• Construction of the carriageway
• Precast concrete kerbs and channels to act as restraint to road edges
• Non illuminated traffic signs
• Reflective road studs along the centre line of carriageway
• Road markings to designate carriageway from shoulders
2.6.5 Steel works
107. The steel works in the project are in the viaduct bridge guardrails and related
subsidiary works of site bolts.
2.7 Wildlife/Livestock Crossing
108. The provided cross structures along the swampy sections will only act as drainage
structures during the wet seasons. They will be utilised as animal crossing during the
dry season when both livestock and wildlife use the Lorian swamp as dry season grazing
area. However, it is noted that large animals such as giraffes can not use the box
culverts. Therefore, it is recommended that the embarkment slopes along the sections
where the livestock and wildlife cross the road will be made mild for ease usage by the
animals to cross the road.
109. The design has proposed traffic signage along the road including clear wildlife
crossing signs at measured distance. However, study recommends that biodiversity
assessment is carried out for the Lorian, Borji swamps and other sections of the road
corridor before commencing works, the study will among other outputs identify additional
crossing locations other than those near the Lorian and Borji Swamps, so as not to
restrict wildlife movement, minimize the chances of few crossing points from becoming
“death traps” from predators and illegal hunters and minimize the potential of accidents.
The Study will recommend the best design features, i.e. ramp slope, crossing surface,
visibility provision, road signage, traffic calming features, etc. and incorporate those
features in the design. The study will also provide guidance to the Contractor to minimize
wildlife conflict during construction and provide free passage during construction. For
example, at Lorian swamp where it’s most likely to have frequent animal crossing during
the dry season, it is recommended to have the road embankment slopes along the
section at 1:4 (vertical :horizontal) as opposed to the current 1:2. It should however be
noted that this will have a significant cost implication due to additional earth works
required to achieve this mild slopes. In additional to the warning signs and ramp slope
for animal crossings, the design shall consider lower speed limits along the sections
expected to have frequent animal crossing, generally 70km/h or as may be advised by
KWS, as opposed to the design speed of 100km/h.
110. The study recommends that a design engineer evaluates various livestock and
wildlife crossing design options for their environmental and social impacts and discusses
them with the KWS local communities and relevant wildlife NGOs
111. The number of wildlife crossing the road were mostly individual animals as
observed during the survey, except for antelopes which moved in herds of less than ten.
Little movement of livestock was experienced across the road since the road acts as a
boundary between different communities hence not much cross boundary movements
were noticed.
Pan-19-003 - 25 -
KeNHA
2.8 Commissioning: Operation and Maintenance
2.8.1 Structural and Civil Engineering Works
112. These types of works are usually ready for use after construction and construction
testing. These works will be commissioned if and when, their functionality can be
substantially achieved. As a part of the commissioning activity, the Consultant will
prepare and finalize built drawings for the entire structural and civil engineering works.
2.8.2 Site Reinstatement
113. Prior to the commencement of the reinstatement program for any affected
construction, quarry and borrow pit sites, the contractor will be required to develop a
project specific reinstatement plan.
2.8.3 Reinstatement Philosophy
114. The reinstatement of the project will be based on the following principles:
• Disturbed areas which are not permanent works, will be reinstated to pre-
construction conditions to the greatest practicable extent
• Disturbed areas will be stabilized to protect the integrity of permanent works
• Disturbed areas will be re-vegetated to achieve good and natural landscape
ambience
• Regular monitoring of reinstated areas will be undertaken until environmental
requirements and goals have been achieved.
2.8.4 Timing of Reinstatement
115. Reinstatement of the project area will be undertaken on a sequential basis

dependent on the completion of construction and testing in each area. The site will be
cleared of residual construction debris, construction signs and equipment as part of
activities associated with reinstatement.
2.8.5 Site Clean up
116. Prior to de-mobilization of construction personnel and equipment, clean-up

activities will be carried out in accordance with environmental and social standards and
industry best practice.
117. Clean-up activities will consist of the removal and/or disposal of temporary
structures, equipment, tools and excess material brought on site or generated during the
construction and commissioning program.
2.8.6 Permanent Reinstatement
118. Permanent reinstatement will be undertaken in all the areas that have been
subjected to disturbance by the road and viaduct bridge construction. To facilitate natural
re-vegetation of disturbed areas, the separately stockpiled excavated material and
topsoil will be spread back in the reverse order in which they were excavated.
119. The key reinstatement principles are summarized below:

• Minimize reduction in soil quality and structure during construction
• Reinstate all third-party assets affected by project activities in accordance with the
construction contract documents and other pre-entry agreements
Pan-19-003 - 26 -
KeNHA
• Carry out restoration activities on the basis of a landscape plan prepared by a

landscape professional
• A target minimum cover of pre-existing ground vegetation should be established
within one year of final reinstatement
• An aftercare monitoring and corrective action program will be developed and
implemented based on examining the bio-restoration process periodically after
reinstatement.
• Any fences, services, structures or other facility affected by the construction works
will be repaired or replaced to a condition that is at least as good as that found prior
to construction.
2.9 Decommissioning and Abandonment Plans
2.9.1 Decommissioning of Existing Facilities
120. Decommissioning of the road is not foreseen, however, decommissioning of

related facilities, especially contractor’s camps and workshops are inevitable. Further,
decommissioning of quarries and borrow sites will be done upon completion of
construction work.
2.9.2 Legal Basis
121. For the components that will require decommissioning, the proponent will prepare
a written abandonment plan within 30 days of determining decommissioning. The plan
will detail how decommissioning will be carried out. The decommissioning Plan will be
prepared following the World Bank safeguards policies.
122. The reinstatement and decommissioning of material sites (borrow pits, quarries
and ancillary facilities) will comply with the approved ESIA/ESMP and follow Good
International Industry Practice, in addition to the National Environmental Framework
(EMCA. An Environment Project Report (EPR) will be prepared prior to implementation
of this plan, to assess and minimize potential environmental and social impacts arising
from the abandonment operations. This abandonment EPR study will be submitted to
NEMA for consideration.
2.9.3 Technical Solutions for Abandonment
123. The reinstatement, abandonment and decommissioning of material sites (borrow

pits, quarries and ancillary facilities) must comply with the approved ESIA/ESMP and
follow Good International Industry Practice, in addition to the National Environmental
Framework (EMCA).
2.9.4 Products, By–products and Waste
124. The construction of the project will generate inert, non-hazardous and hazardous
waste over the period of construction. Operation of the road will result in relatively small
volumes of routine waste generation for the life of the project. Maintenance and repair
activities conducted during the operational lifetime of the project may generate limited
volume of waste.
Pan-19-003 - 27 -
KeNHA
2.10 Project Waste Management Strategy
125. Prior to the commencement of construction work, the contractor(s) will prepare a
Waste Management Plan (WMP). The WMP will:
• Propose a minimization, collection, storage, treatment, re-use and disposal route for
each waste stream
• Identify potential third-party re-users
• Propose incinerator types if required
• Propose location of waste storage and duties of site personnel with regard to waste
management
• Identify and describe possible locations of disposal sites or long-term storage sites.
• State the methods for properly managing wastes (i.e. training, storing, and
containerizing, labelling, transporting and disposing waste).
• Describe the transition of control from the contractors to the Proponent, including
arrangements for wastes associated with commissioning.
2.10.1 Project Waste Management Principles
Standards
126. The waste management standards to be used for the construction, operation and
decommissioning of the roads should be based on the legal notice 121: Waste
Management Regulations 2006.
If these regulations do not cover certain aspects of the project, then the Contractor and
Proponent shall comply with Good International Industry Practices on environmentally
sound management of waste.
Duty of care
127. The principles of ‘duty of care’ (i.e. the responsibility of a generator or owner of
waste to ensure that it is handled, transported and disposed of in an appropriate manner)
for waste and waste ownership by the waste generator will be adopted by the proposed
project throughout the construction, commissioning and operation of the project. During
construction and commissioning, the contractor will be responsible for duty of care
whereas during operations, the Proponent will be the duty holder.
Waste inventories and classification

128. Waste inventories will be created to quantify and characterize waste streams at
each stage of the project. Separate inventories will be developed for construction wastes
and for commissioning / operational wastes. Table 12 gives classification of waste.
Table 12: Classification of Waste by type

# Waste type Waste Standard & Description
1. Inert Waste as defined by EMCA Act - Waste Management Regulations.

2. Hazardous Waste classified as hazardous according to EMCA Act - Waste Management
Waste Regulations
3. Non- Waste that is neither inert, nor hazardous nor wastewater. It includes
hazardous ‘municipal waste’ as defined in the EMCA Act - Waste Management
Waste Regulations
4. Wastewater Fresh water that is contaminated as a result of project activity.
Pan-19-003 - 28 -
KeNHA
129. Further subdivisions of these classifications may be developed and adopted on the
basis of the treatment requirements (e.g. incineration) and ultimate disposal point (e.g.,
reuse, recycling and landfill) for each individual waste material. The principal waste
disposal options for each waste stream will be as indicated in Table 13 below.
Table 13: Waste Disposal options according to type

# Waste Stream Principal Disposal Option
1. Inert Waste Transfer to a third party for recycling or reuse

Processed and used for construction and reinstatement purposes
Disposal to a recognized disposal site.
2. Non-Hazardous Transfer to a third party for recycling or reuse. A special case of this
Waste is to spread it on land for agricultural purposes. Disposal to a
recognized disposal site.
3. Hazardous Waste Transfer to a third party for re-use
Disposal as prescribed in the EMCA Waste Management
Regulations of 2006.
130. The volumes of waste requiring ultimate disposal will be minimized both through
the control of waste generation and through incineration. Inert and non-hazardous
wastes that cannot be reused or recycled may be incinerated in an incinerator designed
and operated in general accordance with Kenya’s regulations on Municipal Incinerators.
2.10.2 Hierarchy of Waste Management Practices
131. Each waste stream will be managed according to the following hierarchy of
techniques, in which the technique chosen should be the first in the hierarchy that is safe
and practicable:
• Eliminate or minimize the waste stream by choice of procedure or technology
• Re-use as a material
• Re-use as a fuel
• Process and re-use as a material
• Process and re-use as a fuel
• Incinerator or re-use or landfill the ash.
• Designated disposal site (Landfill)
• Landscape- Landfill with appropriate vegetation planted
• Discharge to a receiving water course (applicable only to wastewater)
2.10.3 Transfer of Waste to Third Parties
132. It is expected that there will be a variety of potential third parties that may receive
wastes generated during the road’s construction. These third parties will include
commercial waste disposal contractors and entities (corporate or individual) that have
the capacity to reuse or recycle individual waste materials.
133. In general, transfer to third parties for ultimate disposal will only be permitted if the
part of their operation that is used for the proposed project waste is licensed. However,
items such as timber wastes and other re-useable project wastes may be disposed to
local population on the basis of case by case review by the contractor.
Pan-19-003 - 29 -
KeNHA
2.10.4 Construction Waste and Emission Inventories
2.10.4.1 Construction and Commissioning Waste Management

Table 14 below presents indicative characteristics of wastes that will be generated by the
proposed project.
Table 14: Characteristics of Potential Project Waste

Solids Metals
Bituminous material Welding rods
Cement (dust) Isolated steel siles wasted lengths
Paper and cards Copper (Electrical Wires etc.)
Plastic bottles, cans, drums & packaging bags Reinforcement steel
(both polythene and biodegradable)
Aggregates Sludges
Vehicle parts Grease
Glass Paint
Rags and oil adsorbents Oil
Light bulbs and tubes Liquids
Paint cans and brushes Wash down water and drum water
Stone and rocks Oily water
Tyres Domestic
Cleared trees & branches Food
Cleared undergrowth, shrubs etc.
Waste timber
Concrete shuttering
134. It is expected that the special specifications will obligate the contractor to dispose
of different categories of waste appropriately. For example, steel wasted lengths may
easily be taken by the Jua Kali (informal) Industry.
135. In general, the contractor will be required to develop construction specific Waste
Management Plans prior to the start of construction work. At the start of the construction
contract, the contractor will undertake a waste minimization/treatment/disposal study,
guided by the project waste management strategy.
136. The study will identify and quantify the expected wastes and describe:
• Proposals for reduction, treatment processing
• Third parties to whom waste will be transferred for re-use
• Liaisons with the County Government and NEMA to identify and document suitable
disposal sites ground, landfill and incineration facilities
• Other locations of landfills or waste storage sites to be adopted if local County
facilities are inadequate
• On site incineration facilities to be adopted if facilities by the County Government are
inadequate
137. The findings of the study will be used in the development of the construction waste
management plans which must adhere to the EMCA - Waste Management Regulations
of 2006. At a minimum, these plans will include:
• A consolidated summary of the applicable regulations and restrictions governing the
generation, handling, treatment and disposal of wastes generated during the
construction/commissioning phases of the project.
• Any permitting requirements for waste treatment or disposal.
Pan-19-003 - 30 -
KeNHA
• Detailed method statement for each element of the waste management handling,
treatment and disposal process
• Any third-party agreements for waste handling, transfer or disposal
138. After construction of the road, the waste handling/disposal facilities established by
the contractor under the construction program will be closed. If a waste
handling/disposal facility procured by the contractor is closed, the contractors will be
required to ensure that it is appropriately de-commissioned (i.e. including capping of any
disposal sites) and the surface will be re-instated according to the project reinstatement
strategy. If the facility is retained, it will be transferred to the proponent.
2.10.5 Release to the atmosphere
139. Atmospheric emissions will be generated by the proposed roads project activities
principally during construction of road works. It is anticipated that the most significant
components of such emissions will be combustion gases, specifically:
• Nitrogen oxides (NOx)
• Carbon monoxide (CO)
• Sulphur dioxide (SO2)
• Particulate matter (PM)
• Volatile organic compounds
• Aldehydes
• Secondary pollutants
2.10.6 General wastewater disposal
140. Wastewater includes all water flows from the temporary site office, work sites and
subsidiary operations such as vehicle and equipment washing. Wastewater from the
temporary site office should be treated in a septic tank and related soak-aways.
Wastewater from the works will generally be from the roadside drains and during curing
of concrete works. Such wastewater is not hazardous, but should be monitored to ensure
that they do not cause adverse effects.
2.11 Project Cost
141. The cost of cost of implementing Resettlement Action Plan (RAP) and the cost of
constructing the Modogashe-Wajir Road have been determined and given below.
2.11.1 The Cost of Resettlement Action Plan (RAP)
142. An Updated RAP Study for the Modogashe-Wajir Road was carried in 2019. The
cost of paying compensation to the project affected persons for loss of Land, Structures,
Trees and Business disruption during the upgrading of the Modogashe-Wajir Road to
Bitumen standard is KShs 448,504,717.15.
2.11.2 Construction Cost
143. The construction of the proposed road project is estimated to cost KES
9,645,183,966 for the Modogashe-Samatar Segment while the Samatar-Wajir Segment
is estimated to Cost KES 8,188,311,912.
144. The estimated total cost for Modogashe-Wajir Road is KES 17,833, 495, 878. Not
including the cost of ESMP implementation. A summary of the Bill of Quantities (BoQs)
is provided in the tables below.
Pan-19-003 - 31 -
KeNHA
Table 15: Construction Cost of Modogashe-Samatar Segment

Bill No. Description Amount (KShs)
1 Preliminary and Supervisory/Support Services 1,597,806,598
4 Site Clearance and Topsoil Stripping 228,819,255
5 Earthworks 1,173,909,361
7 Excavation and Filling for Structures 271,042,668
8 Culverts and Drainage Works 52,509,500
9 Passage of Traffic 119,735,000
12 Natural Material Subbase and Base 364,273,816
14 Cement and Lime Treatment 446,547,166
15 Bituminous Surface Treatment and Surface Dressing 525,340,662
16 Bituminous Mixes 1,535,385,600
17 Concrete Works 368,808,280
20 Road Furniture 123,274,656
21 Miscellaneous Bridgeworks 2,398,314
22 Dayworks 33,805,000
23 Piling 24,151,594
24 Street Lighting 61,204,000
1 SUB TOTAL (1) 6,929,011,470

Add 10% of Sub-Total 1 of Bills as Provisional Sums for
Contingencies to be Expended in the whole or part as
directed by the Engineer in accordance with sub-clause
52(4) and clause 58 of the Conditions of Contract (2) 692,901,147

Variation of Price in accordance to Clause 70 of the
Conditions of Contract. 692,901,147
2 SUB-TOTAL (2) 8,314,813,764

3 Add 16% of Sub-Total (2) for V.A.T. - (3) 1,330,370,202
GRAND TOTAL CARRIED FORWARD TO FORM OF
BID (SUB-TOTAL 2+3) 9,645,183,966
Total Cost per Km 108,739,391
Table 16: Construction Cost of Samatar-Wajir Segment

Preliminary and Supervisory/Support Services 1,294,183,796

1
4 Site Clearance and Topsoil Stripping 126,744,160
5 Earthworks 701,680,909
7 Excavation and Filling for Structures 50,931,970
Pan-19-003 - 32 -
KeNHA
8 Culverts and Drainage Works 77,923,000

9 Passage of Traffic 93,230,000
12 Natural Material Subbase and Base 300,889,181
14 Cement and Lime Treatment 384,947,608
15 Bituminous Surface Treatment and Surface Dressing 488,242,726
16 Bituminous Mixes 1,437,278,715
17 Concrete Works 595,643,723
20 Road Furniture 117,300,685
21 Miscellaneous Bridgeworks 6,282,818
22 Dayworks 33,805,000
23 Piling 29,475,692
24 Electrical Installations 143,848,000
1 SUB TOTAL (1) 5,882,407,983
Contingencies to be Expended in the whole or part as
directed by the Engineer in accordance with Sub-Clause
13.5 and Sub-Clause 13.6 of the Conditions of Contract. 588,240,798

Variation of Price in accordance with Sub-Clause 13.7
and Sub-Clause 13.8 of the Conditions of Contract. 588,240,798
2 SUB-TOTAL (2) 7,058,889,580

3 Add 16% of Sub-Total (2) for V.A.T. (3) 1,129,422,333
GRAND TOTAL CARRIED FORWARD TO FORM OF
BID (SUB-TOTAL 2+3) 8,188,311,912
Total Cost per Km 112,786,665
Pan-19-003 - 33 -
KeNHA
3 POLICY, LEGALATIVE AND INSTITUTIONAL FRAMEWORK
145. Several laws and regulations that govern environmental and social issues have
been developed. The main legislation is the Environmental Management & Coordination
(Amended) Act (EMCA) of 2015. The Act emphases that every person in Kenya is
entitled to a clean and healthy environment in accordance with the Constitution and
relevant laws and has the duty to safeguard and enhance the environment. It also
empowers stakeholders to participate in sustainable management of the natural
resources. It calls for Environmental and Social Impact Assessment (ESIA) to guide the
implementation of environmentally and socially sound decisions. There are other
relevant local laws and regulations that have been looked into. They include but not
limited to, the Constitution, the Water Act of 2016, The County Government Act 2012
among others.
146. The World Bank Safeguards Policies and Procedures that were triggered for this
project were also evaluated.
147. An outline of the legislative, policy and regulatory framework that the proponent
will need to observe when implementing this project in order to comply with the
environmental and social requirements.
3.1 The Constitution of Kenya
148. The Constitution of Kenya has taken onboard various issues that are related to
environmental management. Article 42 of the Bill of Rights contained in the Constitution
provides that ‘every Kenyan has the right to a clean and healthy environment, which
includes the right to have the environment protected for the benefit of present and future
generations through legislative and other measures.
149. Article 54 provides for the rights of persons with disability while Article 56 highlights
the rights of marginalized communities, in the decision-making process with regards to
development and their input. Thus, highlighting the need for consultation during the ESIA
process and the implementation of the project. Land classification is provided in Articles
61 and 62 including public land for roads and thoroughfares. The need to establish
systems of environmental impact assessment, environmental audit and monitoring of
the environment and public participation is provided in Article 69.
3.2 The National Policy Framework
150. The Republic of Kenya has a policy, legal and administrative framework for
environmental and social management. The broad objectives of the policy are: -
• To ensure optimal use of natural resources while improving environmental quality.
• To conserve natural resources such that the resources meet the needs of the present
without jeopardizing future generations in enjoying the same.
• To develop awareness that inculcates environmental stewardship among the
citizenship of the country.
• To integrate environmental conservation and socio-economic aspects in the
development process.
• To ensure that national environmental and social goals contribute to international
obligations on environmental management and social integrity.
Pan-19-003 - 34 -
KeNHA
151. To achieve the above policy objectives, it is a policy directive that appropriate
reviews and evaluations of all forms of developmental project plans and operations are
carried out to ensure compliance with the environmental policy and legal frameworks.
The following section provides details on the relevant policies in the country.
3.2.1 Sessional Paper No. 10 of 2012 on Kenya Vision 2030
152. The Kenya Vision 2030 is a comprehensive national development plan for the
period 2008 to 2030. The plan was developed following successful implementation of
the Economic Recovery Strategy for Wealth and Employment Creation which ensured
the country’s economy was back on the path for realization of rapid economic growth
since 2002. The country’s GDP growth rose from 0.6% to 7% in 2007, but declined to
1.7% and 1.8% in 2008 and 2009, respectively. The objective of the Vision 2030 is to
transform Kenya into a middle-income country with a consistent annual economic growth
of 10 % by the year 2030. The 2030 goal for urban areas is to achieve “a well-housed
population living in an environmentally-secure urban environment.” This goal is expected
to be achieved by developing basic infrastructure services such as roads, street lights,
water and sanitation facilities, storm water drains, footpaths, and others while ensuring
that the country has a clean, secure and sustainable environment by 2030 through
reduction of pollution and improvement of waste management. The proposed road
project will contribute to the realization of the goals of Vision 2030 through improvement
of a reliable and efficient road infrastructure facility, provision of employment
opportunities, and provision of faster and efficient mode of transport among other
benefits.
3.2.2 Environment and Development (Sessional Paper No. 6 of 1999)
153. Kenya’s policy paper on the Environment and Development was formulated in
1999. The policy defined approaches that will be pursued by the Government in
mainstreaming environment into development. The policy harmonized environmental
and developmental objectives with the broad goal of achieving sustainable development.
The policy paper also provided guidelines and strategies for government action
regarding environment and development. In regard to wildlife, the policy reemphasized
government’s commitment towards involving local communities and other stakeholders
in wildlife conservation and management, as well as developing mechanisms that allow
them to benefit from the natural resources occurring in their areas. The policy also
advocated for the establishment of zones that allow for the multiple use and
management of wildlife. This policy is relevant to the proposed development project in
view of the potential impacts on the environment and involvement of the public in project
planning.
3.2.3 Sessional Paper No. 10 of 2014 on the National Environment Policy
154. The policy seeks to provide the framework for an integrated approach to planning
and sustainablemanagement of natural resources in the country. It recognizes the
various vulnerable ecosystems and proposes various policy measures not only to
mainstream sound environmental management practices in all sectors of society
throughout the country but also recommends strong institutional and governance
measures to support achievement of desired objectives and goals.
Pan-19-003 - 35 -
KeNHA
3.2.4 National Environmental Action Plan (NEAP) of 2009-2013
155. The 1992 Earth Summit held in Rio de Janeiro came up with various
recommendations, among them Agenda 21, a Global Environmental Action Plan. The
theme of the Summit focused on how nations could attain sustainable development. The
Government of Kenya embraced this idea by developing the first National Environment
Action Plan (NEAP) in 1994. The NEAP report addresses environmental issues from
various sectors in an integrated manner and their significance in development planning.
It proposed a strategy for achieving sustainable development in line with Kenya’s quest
to meet the Millennium Development Goals (MDGs), Vision 2030 and Medium-Term
Plan (MTP). The report brings out several proposed interventions, legal and institutional
framework to be incorporated into sectoral development plans and programmes. Its
implementation is monitored through the Annual State of the Environment Reporting.
3.2.5 The National Poverty Eradication Plan (NPEP) of 1999
156. The National Poverty Eradication Plan (NPEP) was formulated with an objective of
reducing the high levels of poverty in Kenya by 50 percent by the year 2015, as well as
to strengthen the capabilities of the poor and vulnerable groups to earn income. The
plan also aimed at reducing gender and geographical disparities in order to create a
healthy, better-educated and more productive population. The formulation of the plan
was guided by the goals and commitments agreed during the World Summit for
Sustainable Development (WSSD) of 1995. The plan therefore focuses on the delivery
of four WSSD themes of poverty eradication; reduction of unemployment; social
integration of the disadvantaged people and creation of an enabling economic, political,
and cultural environment through development of transport and communication sector.
The plan is implemented by the Poverty Eradication Commission (PEC) that was
established in collaboration with various Government Ministries, bilateral and multilateral
donors, the private sector, Community Based Organizations (CBOs) and Non-
Governmental Organizations (NGOs). The NPEP is relevant since the proposed road
will create an enabling environment that will contribute immensely in the enhancement
of economic growth in Kenya. The proposed project would also impact businesses,
agricultural and tourism related activities that have great relevancy to poverty eradication
in the country.
3.2.6 The Poverty Reduction Strategy Paper (PRSP) of 2000
157. The Poverty Reduction Strategy Paper (PRSP) for Kenya has the broad objective
of reducing poverty and promoting economic growth. This policy articulates Kenya’s
commitment and approach to tackling endemic poverty through involvement of the poor
communities in both rural and urban areas in various socio-economic development
activities. The proposed project, during and after implementation will offer various
employment opportunities to Kenyans and will therefore contribute directly towards the
realization of the broad national goal of reducing poverty in the country. In addition, the
project would stimulate economic development by creating an enabling environment for
other key sectors of the economy to thrive.
3.2.7 The National Biodiversity Strategy of 2000
158. The National Biodiversity Strategy and Action Plan (NBSAP) was formulated to
enable Kenya address national and international commitments defined in Article 6 of the
Convention on Biological Diversity (CBD). The strategy is a national framework of action
for ensuring that the present rate of biodiversity loss is reversed, and present levels of
biological resources are maintained at sustainable levels for posterity.
Pan-19-003 - 36 -
KeNHA
159. The general objectives of the strategy are to conserve Kenya’s biodiversity; to
sustainably use its components; to fairly and equitably share the benefits arising from
the utilization of biological resources among the stakeholders; and to enhance technical
and scientific cooperation nationally and internationally, including the exchange of
information in support of biological conservation. The proposed road project will need to
comply with the requirements of this strategy since the project may lead to loss of
biodiversity in some sections along the proposed route e.g. the Lorian and Borji swamps.
Before works commence an indepth biodiversity assessment will be carried out on the
Lorian and Borji swamps to understand their current status, wildlife sustainability and
productivity (wildlife, agriculture, livestock, avifauna, water quality, soil, etc.), to identify
potential impact of construction and operation of the road on the wetland productivity
and to identify mitigation / enhancement measures. Based on the assessment a
Biodiversity Management Plan will be prepared and incorporated to the works contract
to meet the commitment under NBSAP and to satisfy critical habitat requirement under
OP 4.04.
3.2.8 Sessional Paper No. 3 of 2009 on National Land Policy
160. The Land Policy in Kenya is guided by the environmental management principles
which are aimed at restoring the environmental integrity through introduction of
incentives and encouragement of use of technology and scientific methods for soil
conservation, among others. The policy further requires fragile ecosystems to be
managed and protected by developing a comprehensive land use policy bearing in mind
the needs of the surrounding communities. The policy also requires zoning of catchment
areas to protect them from degradation and establishment of participatory mechanisms
for sustainable management of fragile ecosystems. The policy also called for
development of procedures for co-management and rehabilitation of forest resources
while recognizing traditional management systems and sharing of benefits with
contiguous communities and individuals. Lastly, all national parks, game reserves,
islands, front row beaches and all areas hosting fragile biodiversity are declared as
fragile ecosystems under the policy.
161. The policy recognizes that sustainable management of land based natural
resources depends largely on the governance system that defines the relationships
between people, and between people and resources. To achieve an integrated
approach to management of land-based natural resources, all policies, regulations and
laws dealing with these resources need to be harmonized with the framework
established by the Environmental Management and Coordination Act (EMCA Cap 387).
162. The policy also addresses land management on ecosystem protection (including
wetlands). Measures for protection are required for fragile ecosystems. The policy also
calls for the protection of watersheds, lakes, drainage basins and wetlands. The policy
prohibits settlement and agricultural activities in water catchment areas and calls for
identification, delineation and gazettement of all water courses and wetlands.
3.2.9 Sessional Paper No. 8 of 2012 on National Policy for the Sustainable
Development of Northern Kenya and other Arid Lands
163. In Kenya, the ASAL occupy 89% of the country and are home to about 36% of the
population, 70% of the national livestock herd and 90% of the wild game that supports
the country’s tourism industry. Arid lands of Northern Kenya cover close to 400,000 km2
of land but have less than 700 km of tarmac road, most of which is in disrepair. This has
an impact on the attraction of investment and communication in the region. Since 2003
the Government has demonstrated renewed commitment to the ASALs, for example
Pan-19-003 - 37 -
KeNHA
through the Economic Recovery Strategy launched in 2003, which recognized ‘the
important contribution the ASALs can make to national development’. The Government
of Kenya is committed to putting in place a holistic policy framework that facilitates and
fast-tracks sustainable development in the region, reducing levels of inequality with the
rest of Kenya and releasing its potential for the benefit of the nation. The Government
recognizes that Kenya will not achieve sustained growth in her economy and progress
as a nation if the ASALs are not appropriately factored into national planning and
development.
164. Trickledown benefits from areas which already have more favourable investment
climates have not worked across the country; moreover, the potential for significant
growth in these areas is now limited. The Government also recognizes that Kenya will
not achieve the goals of Vision 2030 or meet international commitments such as the
Sustainable Development Goals (SDGs) if regional inequalities are not addressed.
165. Poverty, inequality and insecurity in one part of the country negatively affects the
country as whole. Accelerated investment in ASALs is necessary if all Kenyans are to
have an equal chance of sharing in the promise and benefits of Vision 2030. Through
appropriate financing, the Government will provide leadership in mobilizing and
allocating resources necessary for strengthening the foundations for development,
including roads, energy, ICTs, water, education, health and security in ASAL areas.
3.2.10 Wildlife Policy of 2011
166. The wildlife policy is aimed at promoting protection and conservation of wildlife in
Kenya, both in protected and non-protected areas. The policy is implemented by the
Kenya Wildlife Service (KWS). The proposed road project will need to be consistent with
this policy. Where wild animals will be disturbed during the construction and operation
of the road, appropriate mitigation measures must be implemented to minimize
disturbance to wildlife.
3.2.11 Wetlands Policy of 2013
167. The wetlands policy is intended to promote protection of wetlands in Kenya. The
policy sets out strategic measures for the protection of existing wetlands in Kenya. The
proposed road has potential of impacting Lorian and Borji swamps. It would be important
to undertake appropriate mitigation measures to minimize or avoid degradation of
wetlands.
3.2.12 Physical Planning Policy
168. The current policy governs the development and approval all building plans as
provided for in the Physical Planning Act (Cap 286). The proposed project will be
subjected to the provisions of this policy and legislation.
3.2.13 Public Health Policy of 2014
169. The public health policy calls upon the project proponents to ensure that buildings
are adequately provided with utilities so that they are fit for human habitation. The
workers camps must be provided with all amenities/utilities that are essential for
safeguarding public health for all people using the facilities.
Pan-19-003 - 38 -
KeNHA
3.2.14 Occupational Health and Safety Policy of 2012
170. This policy is intended to protect safety and health of workers in work places. The
proposed road project will provide employment opportunities to many workers in various
categories. The contractor will be expected to comply with the requirements of this policy
when engaging workers in various construction activities. The environmental
management provides mitigation measures that can be undertaken to ensure
compliance with the requirements of this policy.
3.2.15 HIV/AIDS Policy of 2009
171. The policy identifies HIV/AIDS as a global crisis that constitutes one of the most
formidable challenges to development and social progress. The Pandemic heavily
affects the Kenyan economy through loss of skilled and experienced manpower due to
deaths, loss of man hours due to prolonged illnesses, absenteeism, reduced
performance, increased stress, stigma, discrimination and loss of institutional memories,
among others.
172. Due to the large number of workers who will be involved in the project and the
associated social issues with projects of such as scale, HIV/AIDS has been considered
as one of the potential impacts, but adequate mitigation measures have also been
proposed to that effect.
3.2.16 Kenya National Policy on Gender and Development (NPGD), 2000
173. The purpose of the Gender Policy is to institutionalize The Kenya National Policy
on Gender and Development (NPGD), within Gender, Children and Social Development.
It articulates the policy approach of gender mainstreaming and empowerment of women
at the ministry level. The policy seeks a society where women, men, children and
persons with disabilities enjoy equal rights, opportunities and a high quality of life. This
report has addressed in depth matters to do with gender and development. The project
shall be governed under this principle during the entire project period.
3.2.17 The Kenya National Climate Change Response Strategy of 2010
174. This strategy provides measures that the Government of Kenya is taking to
address issues related to the impact of climate change on various sectors of the
economy. The proposed road will need to take onboard the effects of changing climate
in the country and apply applied climate change mitigation measures.
175. This is important because climate change will in future affect the operation of the
road. Climate vulnerability and risk assessment for this NETIP project was carried out in
2018, and climate resilience measures have been mainstreamed to this project
3.2.18 National Environment Policy, 2013
176. This policy aims to protect the environment. Section 5.6 on Infrastructural
Development and Environment 5.6.1 states that Infrastructural development includes
among others buildings, roads, ports, railways, ICT, pipelines, irrigation systems,
airports and electricity transmission. This section also emphasizes that the environment
aspects of such infrastructural developments are distinct and unique such as effects on
flora and fauna, social and psychological disruption, vegetation clearance, excavation
works and spillages during construction. This policy states that the government will:
Pan-19-003 - 39 -
KeNHA
• Ensure Strategic Environmental Assessment (SEA), Environmental Impact

Assessment, Social Impact Assessment and Public participation in the planning and
approval of infrastructural projects
• Develop and implement environmentally-friendly national infrastructural
development strategy and action plan
• Ensure that periodic Environmental Audits are carried out for all infrastructural
projects
3.2.19 The National Poverty Eradication Plan (NPEP) of 1999
177. The National Poverty Eradication Plan (NPEP) was formulated with an objective of
reducing the high levels of poverty in Kenya by 50 percent by the year 2015, as well as
to strengthen the capabilities of the poor and vulnerable groups to earn income. The
plan also aimed at reducing gender and geographical disparities in order to create a
healthy, better-educated and more productive population. The formulation of the plan
was guided by the goals and commitments agreed during the World Summit for
Sustainable Development (WSSD) of 1995.
178. The plan therefore focuses on the delivery of four WSSD themes of poverty
eradication; reduction of unemployment; social integration of the disadvantaged people
and creation of an enabling economic, political, and cultural environment through
development of transport and communication sector. The plan is implemented by the
Poverty Eradication Commission (PEC) that was established in collaboration with
various Government Ministries, bilateral and multilateral donors, the private sector,
Community Based Organizations (CBOs) and Non-Governmental Organizations
(NGOs). The NPEP is relevant since the proposed road will create an enabling
environment that will contribute immensely in the enhancement of economic growth in
Kenya. The proposed project would also impact businesses, agricultural and tourism
related activities that have great relevancy to poverty eradication in the country.
3.2.20 Gender Policy of 2011
179. The purpose of the Gender Policy is to institutionalize The Kenya National Policy
on Gender and Development (NPGD), within Gender, Children and Social Development.
It articulates the policy approach of gender mainstreaming and empowerment of women
at the ministry level. The policy seeks to have a society where women, men, children
and persons with disabilities enjoy equal rights, opportunities and a high quality of life.
This report has in depth addressed matters to do with gender and development and in
the concession period the entire project period the project shall be governed under this
principle.
3.2.21 The Education Gender Policy (2007)
180. This policy addresses prevention and response to school related gender-based
violence. It recommends mainstreaming of policies that address GBV at all education
levels; establishing modalities for dealing with SGBV including harassment; and
developing and implementing clear anti-sexual harassment and anti-gender-based
violence policies at all levels in the Ministry of Education and all educational institutions.
3.2.22 Sexual and Gender Based Violence (SGBV) Policy 2017
181. The purpose of this policy is to put in place a framework to accelerate

implementation of laws, policies and programmes for prevention and response to SGBV.
Pan-19-003 - 40 -
KeNHA
The overall objective of the policy is to progressively eliminate sexual and gender-based
violence through the development of a preventive, protective, supportive and
transformative environment.
3.2.23 Kenya Rural Development Strategy (KRDS) 2002-2017
182. This was a long-term framework outline, with a broad range of strategies for the
improvement of rural Kenya over the next 15 years.
• It emphasized food security as the initial step towards poverty alleviation/reduction
and rural development. Kenya adopted the policy of rural decentralization as a
fundamental policy for rural development.
• The thrust of the policy was to achieve balanced development in rural areas as well
as improvement and sustenance of the livelihood of the rural household. The
intention of this policy was to use rural development as a vehicle that would enhance
transformation of Kenya’s rural economy enabling the rural society, among other
things, to achieve better living conditions from increased productivity, improved
transportation facilities and new market opportunities, to promote social system close
to the people based on their perceived needs and requirements as well as to
stimulate growth of the national economy and ensure sustainable development
3.2.24 KeNHA’s Environment and Social Safeguards Policy, 2018
183. The revised policy is set within KeNHA Vision of quality, safe and adequate
National Trunk Roads network. It contains the actions KeNHA will take so as to ensure
that the Authority activities do not negatively harm the environment and adversely affect
the social fabric in communities where it works. Working in an environmentally and
socially responsible and safe manner are conditions of employment of contractors for
various projects. This policy is therefore targeting all it’s staff, contractors and other
service providers. The Policy will be mainstreamed to all bidding and contract documents
for the civil works.
3.3 Environmental Guidelines
184. In line with the Kenyan Constitution, NEMA has developed a number of guidelines
which are part of a series of environmental management tools for environmental
management under the Environmental Management and Coordination Act, CAP 387 of
the Laws of Kenya. Below is a highlight of the key project relevant guidelines;
3.3.1 National Solid Waste Management Strategy, NEMA, 2014.
185. NEMA developed the National Solid Waste Management Strategy in 2014 as a
framework for implementing the Vision 2030 flagship project. The Strategy establishes
a common platform for action between stakeholders to systematically improve waste
management. It introduces a new approach for improved waste management in Kenya
to create wealth, employment and reduce pollution of the environment. The proposed
road project is anticipated to produce waste; the proponent will be required to manage
waste as guided by this strategy but in line with Waste Management regulations of 2006
and other relevant legislative frameworks. In general, the project proponent should
ensure waste management activities are 7R oriented, by Reducing; Rethinking;
Refusing; Recycling; Reusing; Repairing and Refilling waste.
Pan-19-003 - 41 -
KeNHA
3.3.2 Technical guidelines on the management of used oil and oil sludge in Kenya
(NEMA, 2014)
186. The main objective of the guidelines is to ensure effective and efficient collection
and transportation systems for used oil. These guidelines target government agencies
(responsible for decision making, formulating policies and enforcing health and safety
aspects of used oil and oil sludge management in the country), small generators, bulk
generators of used oil and oil sludge, garages, used oil treatment plants, recycling and
disposal facilities, and other interested stakeholders. The Proponent is envisioned to use
heavy machinery which will require servicing hence producing used oil. These guidelines
provide direction on safe management of used oil and oil sludge in Kenya and are a
main regulatory reference material for management of used oil in Kenya and hence will
be used as a key reference point to create awareness on hazards associated with
handling used oil and to provide guidance on infrastructure for management of used oil.
3.3.3 National sand harvesting guidelines, 2007
187. These Guidelines apply to all sand harvesting activities in Kenya. This is deemed
key to ensure sustainable utilization of the sand resource and proper management of
the environment. Since the road project will require use of sand, it is expected that the
contractor’s sand harvesting activities will be conducted in line with respective legal
requirements and guided by these sand harvesting guidelines.
3.3.4 The Integrated Land Use Guidelines
188. Land in Kenya is a key factor of production, making its proper management a
requirement for sustainable development. The demand for arable land, grazing, forestry,
wildlife, tourism and urban development are greater than the land resources available.
These demands become more pressing every year with continued population growth.
To address the identified key issues in land use management within a development-
oriented approach poses challenges to all stakeholders and requires integrative
solutions across the policy, socio-economic, and environment sectors.
189. the Integrated National Land Use Guideline is aimed at the prevention and
mitigation of land degradation, addressing land use conflicts and managing both natural
and anthropogenic disasters through the promotion of sustainable land management. It
takes into account the provisions of the New Constitution of Kenya 2010 (specifically
Chapter Five – Sections 60 - 72 which deal with “Land and Environment” as well as the
various other laws, regulations, policies and guidelines in the different land sectors.
3.4 National environmental legal framework
190. The Republic of Kenya has numerous statutes that guide environmental
management and conservation in the country. Most of these statutes are sector specific
and cover a wide range of issues including public health, soil conservation, protected
areas conservation, endangered species, public participation, water rights, water quality,
air quality, excessive noise control, vibration control, land use, among others. The
relevant legislations are described in the following sections.
3.4.1 Environmental Management and Coordination Act (EMCA, Cap 387)
191. Part II Article 3 of EMCA, Cap 387 states that every person is entitled to a clean
and healthy environment and has the duty to safeguard the same. To achieve this goal,
the projects listed under the Schedule No. 2 of EMCA must be subjected to
Pan-19-003 - 42 -
KeNHA
Environmental Impact Assessment (EIA). The aim of EIA is to reduce negative

environmental outcomes of the listed projects by implementing mitigation measures. The
proposed project falls within the Second schedule and must therefore comply with
EMCA requirements in as far as EIA is required. There are several other regulations that
have been formulated within the framework of EMCA, that are applicable to the proposed
project.
192. Under EMCA, NEMA has gazetted legal tools that govern conduct of EIAs and
general environmental protection. The Proposed Road project has been screened
against these tools with results outlined below.
3.4.1.1 EMCA (Environmental Impact Assessment and Audit) Regulations, 2003

193. The Environmental (Impact Assessment and Audit) Regulations provides ESIA
process for preparation of the EIA Project or Study Reports that have to be submitted
NEMA for review and issuance of EIA License. The regulations provide details on the
aspects to be evaluated and ESMPs and Monitoring plans to be prepared. The proposed
project must comply with the requirements of the regulations that also include
conducting regular monitoring and annual audits. The project requires an EIA license
from NEMA before commencement of any activity
3.4.1.2 EMCA (Water Quality) Regulations, 2006

194. The EMCA (Water Quality) Regulations, 2006 apply to water used for domestic
consumption, industrial, recreation, fisheries, wildlife and irrigation, among others. The
Contractor will be expected to provide water for consumption that meets the water quality
standards as provided in the First Schedule of these regulationsand provided in Table
17.. The proposed project will need to comply with the requirements of this regulation to
ensure water sources along the route are protected from pollution and over abstraction.
The project will also need to comply with the regulations that prohibit undertaking of
development within a minimum of 6m from the highest ever recorded flood level of a
river system. The regulation prohibits pollution of water bodies and requires that all
substances discharged into the water bodies should meet the effluent discharge
standards set under the Third Schedule of the regulations and prvided in Annex 8.
Table 17: Quality Standards for Domestic Water (NEMA)

No Parameter Guide Value (max allowable)
1 pH 6.5 – 8.5
2 Suspended solids 30 (mg/L)
3 Nitrate-NO3 10 (mg/L)
4 Ammonia –NH3 0.5 (mg/L)
5 Nitrite –NO2 3 (mg/L)
6 Total Dissolved Solids 1200 (mg/L)
7 Scientific name (E.coli) Nil/100 ml
8 Fluoride 1.5 (mg/L)
9 Phenols Nil (mg/L)
10 Arsenic 0.01 (mg/L)
11 Cadmium 0.01 (mg/L)
12 Lead 0.05 (mg/L)
13 Selenium 0.01 (mg/L)
Pan-19-003 - 43 -
KeNHA
14 Copper 0.05 (mg/L)

15 Zinc 1.5 (mg/L)
16 Alkyl benzyl sulphonates 0.5 (mg/L)
17 Permanganate value (PV) 1.0 (mg/L)
Source: Water Quality Regulations - 2006 (NEMA)
3.4.1.3 EMCA (Fossil Fuel Emission Control) Regulations, 2006

195. The EMCA (Fossil Fuel Emission Control) Regulations, 2006 aims at eliminating
or reducing emissions emitted from internal combustion engines to acceptable levels.
The regulation provides guidelines on use of clean fuels, use of catalysts and inspection
procedures for engines and generators. This regulation is applicable to the proposed
project since there would be use of vehicles, machinery and equipment that depend on
fossil fuel as their source of energy. The requirements of the regulation must be
implemented to eliminate or reduce air quality degradation. Sections of the regulation
citing the standards of recommended emission levels will be given to the contractor and
or pinned at strategic points in the contractor’s field offices
3.4.1.4 EMCA (Conservation of Biological Diversity and Resources, Access to Genetic

Resources and Benefit Sharing) Regulations, 2006
196. The EMCA (Conservation of Biological Diversity and Resources, Access to
Genetic Resources and Benefit Sharing) Regulations, 2006 provides that no person
shall engage in any activity that may have an adverse impact on any ecosystem; may
lead to the introduction of any exotic species or to unsustainable use of natural
resources, without an Environmental Impact Assessment License issued by the
Authority under the Act. The regulation requires NEMA in consultation with the relevant
lead agencies, to impose bans, restrictions or similar measures on the access and use
of any threatened species to ensure its regeneration and maximum sustainable yield.
The proposed road traverses’ areas with diverse ecosystems which will need to be
protected as per the requirements of this regulation
3.4.1.5 EMCA (Waste Management Regulations, 2006)

197. The Waste Management Regulations are basically aimed at streamlining the
handling, transportation and disposal of various types of wastes. The broad goal of the
regulations is to protect human health, wildlife and the environment. The regulations will
be critical during the construction phase of the project when various wastes will be
generated. Since there will be both ordinary and hazardous (used oil and hydraulic fluid)
wastes generated, the Contractor will be expected to engage a NEMA
registered/approved waste collection firm to manage the transportation and disposal of
waste.
198. The Contractor will follow the Waste Management Plan to carry out segregation,
storage, transportation and disposal of waste at all the operational areas (Camp,
Workshop area and Construction site)
3.4.1.6 EMCA (Wetlands, River Banks, Lake Shores and Sea Shore Management)
Regulations, 2009
199. The Environmental Management and Co-ordination (Wetlands, River Banks, Lake
Shores and Sea Shore Management) Regulations, 2009 applies to all wetlands in Kenya
whether occurring in private or public land.
200. The objectives of the regulations are to provide for the conservation and
sustainable use of wetlands and their resources.
Pan-19-003 - 44 -
KeNHA
The road crosses the Lorian and Borji swamps and dry river beds (laggas) which hold
water during the rains. These are considered valuable wetlands and water resources
along the route that need to be protected.
201. Due to the fact that the road project traverses several river courses and areas
prone to flooding. The road construction shall ensure that there is adequate
infrastructure to ensure the natural flow of these water bodies is maintained and not
impeded.
3.4.1.7 EMCA (Noise and Excessive Vibration Pollution Control) Regulations, 2009
202. This regulation prohibits generation of excessive noise and vibration in habited
areas. These Regulations determine the level of noise that will permissible in particular
during the construction of the improvements, the following factors will be considered:
• Time of the day;
• Proximity to residential area;
• Whether the noise is recurrent, intermittent or constant;
• The level and intensity of the noise;
• Whether the noise has been enhanced in level or range by any type of electronic or
mechanical means; and,
• Whether the noise is subject to be controlled without unreasonable effort or expense to
the person making the noise.
203. The Contractor will be expected to meet the noise level requirements as provided
in the following schedules of the regulations and also carry out noise level monitoring:
• Schedule 1 – Noise levels at residential and commercial sites – Table 18
• Schedule 2 – Noise levels at Construction sites – Table 19
• Schedule 3 – Noise Levels at quarry sites
Noise permits may be required in blasting areas given that the project area is habited and
wildlife is also present.
Table 18: Maximum Permissible Noise Levels – Residential and Commercial (NEMA)
Zone Sound Level Limits Noise Rating Level (NR)
dB(A) (Leq,14 h)
(Leq,14 h) Night
Day Day Night
A. Silent Zone 40 35 30 25
B Places of worship 40 35 30 25
C. Residential: Indoor 45 35 35 25
Outdoor 50 35 40 25
D. Mixed residential (with some 55 35 50 25
Commercial and places of
entertainment)
E. Commercial 60 35 55 25
Source: Noise and Excessive Vibration Pollution Control) Regulations, 2009
Table 19: Maximum Permissible Noise Levels for Construction Sites (NEMA)
Facility Maximum Noise Level Permitted (Leq) in dB(A)
Day Night
(i) Health facilities, educational 60 35
institutions, homes for disabled
etc.
Pan-19-003 - 45 -
KeNHA
Facility Maximum Noise Level Permitted (Leq) in dB(A)

(ii) Residential 60 35
(iii) Areas other than 75 65
those prescribed in (i)
Source: and (ii)and Excessive Vibration Pollution Control) Regulations, 2009
Noise
3.4.1.8 EMCA (Air Quality) Regulations, 2014

204. The objective of this regulation is to provide for prevention, control and abatement
of air pollution to ensure clean and healthy ambient air. It provides for the establishment
of emission standards for various sources, including as mobile sources (e.g. motor
vehicles). The Contractor will be required to observe the limits for Air Quality as provided
in:
Schedule 1 – Ambient Air Quality Tolerance Limits – Annex 7
205. The Proponent for the road project shall observe policy and regulatory
requirements and implement the mitigation measures proposed in this document to
comply with the provisions of these regulations on abatement of air pollution and also
carry out air quality monitoring.
3.4.2 The Kenya Roads Act, 2007
206. This is the Act of Parliament that provided for the establishment of Kenya Road
Agencies i.e. Kenya National Highway Authority (KeNHA), the Kenya Urban Roads
Authority (KURA) and the Kenya Rural Roads Authority (KeRRA), and provided powers
and functions of the authorities.
207. KeNHA is mandated to manage, develop, rehabilitate and maintain all national
roads. Other function invested on this authority relevant to the proposed project are:
controlling national roads and road reserves and access to roadside developments;
implementing road policies in relation to national roads; ensuring adherence to the rules
and guidelines on axle load control prescribed under the Traffic Act (Cap. 403) and under
any regulations under this Act; ensuring that the quality of road works is in accordance
with such standards; in collaboration with the Ministry responsible for Transport and the
Police Department. They are also responsible for overseeing the management of traffic
and road safety on national roads; collecting and collating all such data related to the
use of national roads as may be necessary for efficient forward planning under this Act;
monitoring and evaluating the use of national roads; planning the development and
maintenance of national roads and liaising and coordinating with other road authorities
in planning and on operations.
3.4.3 The Kenya Roads Board Act, 1999
208. The Act was assented in January 2000. Establishing a board to oversee the road
network in Kenya and thereby coordinate its development, rehabilitation and
maintenance and to be the principal advisor to the Government on all matters related to
Road Development. The Standard Specifications for Road and Bridge construction has
guidelines on environmental protection and mitigation.
209. Standard Specification Clauses 116,117,125,135,137 specifically address

protection of the environment, with regard to water, health, safety and accidents, water
supply, maintenance of the engineers’ staff houses, offices, laboratories, and
attendance upon the engineer and his staff. The provisions of these standards and
codes must not be contravened during project implementation.
Pan-19-003 - 46 -
KeNHA
These provisions are largely supportive of EMCA, Cap 387 and forms part of the legal
basis for environmental mitigation, avoidance, prevention, compensation, restoration
and enhancement.
3.4.4 Public Roads and Roads of Access Act Cap 399
210. The Public Roads and Roads of Access Act Cap.399 Act states that a public road
is any road which the public has a right to use immediately before the commencement
of this Act, or all proclaimed or reserved roads and thoroughfares being or existing on
any land sold or leased or otherwise held under the East Africa Land Regulations, 1897,
the Crown Lands Ordinance,1902, or the Government Lands Act at any time before the
commencement of this Act and all roads and thoroughfares hereafter reserved for public
use. The construction of the proposed road will need to take note of the provisions of
this Act.
3.4.5 The Traffic Act Cap 403
211. The Traffic Act reserves the use of the road corridor for road facilities only. Any
vegetation grown to protect the road edges should not cause problems during
maintenance. Encroachment along the road corridor will have to be checked especially
during the operational phase of the project. The Act also spells out conditions for use of
roads by motorists, among others. The contractor’s vehicles shall comply to all traffic
rules in Kenya.
3.4.6 The Wildlife Management and Conservation Act 2013
212. The Wildlife and Conservation Act deals with the conservation and management
of wildlife in Kenya. The Act provides that wildlife should be conserved to yield optimum
returns in terms of cultural, aesthetic, scientific and economic benefits. The Act requires
that full account be taken of the interrelationship between wildlife conservation and land
use. The Act controls activities within the national parks, which may lead to the
disturbance of wild animals. Unauthorized entry, residence, burning, damage to objects
of scientific interest, introduction of plants and animals and damage to structure are
prohibited under this law.
213. The proposed road traverse’s wildlife dispersal areas. The road construction will
need to make provisions for the free passage of wildlife. Passage provisions will need
to be integrated into the design of the road. The contractor will also need to provide free
wildlife passages such as culverts so that the road project does not affect wildlife
negatively. KWS have indicated that there are no distinct wildlife migration corridors
however majority of the wildlife are located within the Lorian swamp ecosystem
3.4.7 The Water Act 2016
214. The Water Act No. 43 of 2016 was assented to on 20th September 2016. The new
Act repealed the water Act 2002. The Act provides for the establishment of the Water
Resources Authority (WRA) who have the responsibility to regulate the management
and use of water resources. The Act provides for the regulation, management and
development of water resources and water and sewerage services in line with the
Constitution. The enactment of this law aimed at aligning national water management
and water services provision with the requirements of the Constitution of Kenya 2010
particularly on the devolving of water and sanitation services to the county governments.
Pan-19-003 - 47 -
KeNHA
215. The Act stipulates that a permit shall be required in all cases of proposed diversion,
abstraction, obstruction, storage or use of water, with minor exceptions relating to use
for domestic purposes (Section.36). A person shall not throw, convey, cause or permit
to be thrown or conveyed, any rubbish, dirt, refuse, effluent, trade waste or other
offensive matter or thing into or near to any water resource in such manner as to cause,
or be likely to cause, pollution of the water resource
216. The Contractor shall be expected to make applications for a water abstraction
permit subject of public consultation and, where applicable, of environmental impact
assessment in accordance with the requirements of the Environmental Management
and Coordination Act, 1999 (No. 8 of 1999).
3.4.8 The County Governments Act 2012
217. The promulgation of the 2010 Constitution brought about devolution and the setting
up of County Governments. This Act provides for the roles and functions of the County
Government. The County Government will be in charge of all development activities
within the County, as such will be a major stakeholder for the proposed project. The
Contractor will be expected to carry out implementation of the project in consultation
with the County Government of the respective counties of Wajir, Garissa and Isiolo.
3.4.9 The Valuers Act (Cap 532), 1985
218. The revised edition 1985 of the Valuers Act Cap 532 makes provisions for the
relevant charges and conducts of valuers in relation to valuation of assets. The Act also
provides the relevant regulations and guidelines in the undertaking of the valuation
works. The Act requires that adequate valuation is carried out to help meet the actual
compensation measures and the market rates and reduce any acts of malice in the
exercise. A competent valuer will have to be deployed to site to carry out the professional
valuation of project affected assets for compensation.
3.4.10 Physical Planning Act (Cap. 286)
219. This Physical Planning Act, Cap. 286 provides for the preparation and
implementation of physical development plans. Section 36 of the Act provides for
environmental impact assessments and states that if in connection with a development
application a local authority is of the opinion that proposals for industrial location,
dumping sites, sewerage treatment, quarries or any other development activity will have
injurious impact on the environment, the applicant shall be required to submit together
with the application an environmental impact assessment report’. The proponent and
contractors of the proposed road will need to comply with the requirements of this Act
3.4.11 The Employment Act, 2007
220. The Employment Act, 2007 defines the fundamental rights of employees including
the basic conditions of employment of workers. It also regulates employment of children.
The contractor on site will have to employ casual labourers probably from the
communities where the road traverses during construction.
221. The basic conditions of employees should be observed to avoid unnecessary

conflicts during the construction works. The Contractor shall pay the entire amount of
the wages earned by or payable to the workers. Payment of such wages shall be done
at the end of a working day at or near the place of work.
Pan-19-003 - 48 -
KeNHA
The Contractor shall also ensure that all statutory deductions are submitted without
delay to appropriate government agencies e.g. Kenya Revenue Authority, NSSF, NHIF,
among others.
222. This Act provides for the prevention and protection of all persons from sexual
harassment at the work place. Sexual harassment is described as happening between
workers in an organization and involves sex or any other sexual favors with direct or
implied promises for preferential treatment, threat of detrimental treatment at work,
present or future threats to employment, use of language or visual material of a sexual
nature or shows physical behaviour of a sexual nature that is unwelcome or offensive to
that employee. The World Bank is endeavoring to help infrastructure projects more
effectively prevent and respond to this work related GBV occurring between
personnel/staff working on a given project
3.4.12 Work Injury Compensation Benefit Act (WIBA) 2007
223. The Work Injury Compensation Benefit Act 2007 provides guideline for
compensating employees on work-related injuries and diseases contacted during
employment. The Act also requires provision of compulsory insurance for all employees.
The Act defines an employee as any worker on contract of service with employer will be
important for the Contractor of the proposed project to ensure that all workers contracted
during the project implementation phase are provided with appropriate insurance covers
so that they can be compensated in case they get injured while at work.
3.4.13 Occupational Safety and Health Act 2007
224. The Act provides for protection of workers during construction and operation
phases of the project. This Act will provide some of the mitigation measures for any
negative impacts in particular those concerning the workers within the site. Section 17
of the Act further highlights the importance of an employer or in this case Contractor to
ensure the health and safety of persons other than his/her employees. As such this Act
also ensures the inclusion of community health and safety in this ESIA
3.4.14 The Public Health Act (Chapter 242) of Revised Edition 2012
225. The Public Health Act (Chapter 242) is an Act of Parliament that provides for
securing and maintaining good health of citizens. The Act contains directives that are
focused on ensuring protection of human health. There are provisions within the Act that
deal with water, air and noise quality as they pertain to human health.
226. An environmental nuisance includes the emission from premises of waste waters,
gases and smoke which could be regarded as injurious to health. The owner and/or
occupier of premises responsible for such nuisances are liable to prosecution under the
Act. The construction of the proposed road has potential pollution risks related to water
and air. The contractor will need to ensure that air and water pollution is controlled and
does not affect people living along the road and even workers residing in various
construction camps established all along the route.
3.4.15 Urban Areas and Cities Act No 13 of 2011
227. This is an Act of Parliament to give effect to Article 184 of the Constitution, to
provide for the classification, governance and management of urban areas and cities
and to provide for the criteria of establishing urban areas.
Pan-19-003 - 49 -
KeNHA
The Act also provide for the principle of governance and participation of residents of
towns and cities. Under the Act a town is an urban area with a population of at least ten
thousand residents. Also, under the Act the management of a city and municipality is
vested in the county governments. The County Governments may impose such fees,
levies and charges for delivery of services by the municipality or the city.
3.4.16 The Environment and Land Court Act, 2011
228. This is an Act of Parliament to give effect to Article 162(2) (b) of the Constitution to
establish a superior court to hear and determine disputes relating to the environment
and the use and occupation of land. The Environment and Land Court is one of the
Courts contemplated by article 162(2). It is a Superior Court and has the same status as
the High Court. The court is established under section 4 of the Environment and Land
Court Act No. 19 of 2011. It has jurisdiction to hear any other dispute relating to
environment and land.
229. The jurisdiction of the court is provided under section 13 of the Act. The Court has
original and appellate jurisdiction to hear and determine all disputes in accordance with
Article162(2) (b) of the Constitution and with the provisions of the Act or any other written
law relating to environment and land. The court has powers to deal with disputes relating
to land administration and management. The court is also empowered to hear cases
relating to public, private and community land and contracts or other instruments
granting any enforceable interests in land. The court also exercises appellate jurisdiction
over the decisions of subordinate courts or local tribunals in respect of matters falling
within the jurisdiction of the Court. The court further exercises supervisory jurisdiction
over the subordinate courts, local tribunals, persons or authorities in accordance with
Article 165(6) of the Constitution.
3.4.17 Community Land Act 2016
230. The Community Land Act, No. 27 of 2016 came into force on 21 September 2016.
The Act aims at: 1. Giving effect to Article 63 of the Constitution of Kenya, 2010 which
provides for a classification of land known as community land. To this end, the
Constitution provides that community land shall vest in and be held by communities. 2.
Providing for;
• The recognition, protection and registration of community land rights.
• The management and administration of community land.
• The role of county governments in relation to unregistered community land and related
matters.
231. The Act repeals the Land (Group Representatives) Act (Chapter 287 of the Laws
of Kenya) and the Trust Lands Act (Chapter 288 of the Laws of Kenya). This project
shall uphold the requirement of all the relevant land legislations, involving key
administrative stakeholders and the affected parties (i.e. the community) facilitating in
coexistence with the surrounding community. Most of the land within the project corridor
is community land. Community consultations and consent will be critical during project
construction period.
232.
3.4.18 Land Act, 2012.
233. The Land Act was enacted by Parliament to give effect to Article 68 of the
Constitution, to revise, consolidate and rationalize land laws; to provide for the
sustainable administration and management of land and land-based resources, and for
Pan-19-003 - 50 -
KeNHA
connected purposes. The Act applies to all land declared as (a) public land under Article
62 of the Constitution; (b) private land under Article 64 of the Constitution; and (c)
community land under Article 63 of the Constitution and any other written law relating to
community land.
234. The Land Act guarantees security of tenure for land under (a) freehold; (b)
leasehold; (c) such forms of partial interest as may be defined under the Act and other
law, including but not limited to easements; and (d) customary land rights, where
consistent with the Constitution and guarantees equal recognition and enforcement of
land rights arising under all tenure systems and non-discrimination in ownership of, and
access to land under all tenure systems. Under the Lands Act 2012, The Wayleaves
Act, Cap 292 and The Land Acquisition Act, Cap. 295 have been revoked but Sections
8 and 9 allow for Compulsory Acquisition as an option in acquiring land for public utility.
The corridor traversed by the road project is largely community grazing land hence this
Act will be important when establishing the road reserve for this project.
3.4.19 The National Land Commission Act, 2012 (No. 5 of 2012)
235. The National Land Commission of Kenya is an independent government

commission whose establishment was provided for by the Constitution of Kenya to,
amongst other duties, manage public land on behalf of the national and county
governments, initiate investigations into present or historical land injustices, recommend
appropriate redress, monitor and have oversight responsibilities over land use planning
throughout the country. It was officially established under The National Land
Commission Act, 2012.
236. The mandate of the National Land Commission is drawn from the National Land
Policy of 2009, Constitution of Kenya 2010, National Land Commission Act, 2012, the
Land Act 2012 and the Land Registration Act of 2012. Under the National Land
Commission Act, the Commission shall among other duties monitor the registration of
all rights and interests in land and ensure that public land and land under the
management of designated state agencies are sustainably managed for their intended
purpose and for future generations. Also, the commission is required to manage and
administer all unregistered trust land and unregistered community land on behalf of the
county government and develop and encourage alternative dispute resolution
mechanisms in land dispute handling and management. The Commission is also
required in consultation and cooperation with the national and county governments, to
establish county land management boards for the purposes of managing public land.
This Act is extremely important due to the need for acquisition of community land along
the project road alignment
3.4.20 The Penal Code (Cap. 63)
237. The Penal Code (Cap. 63) chapter on “Offences against Health and
Conveniences” strictly prohibits the release of foul air into the environment, which affects
the health of other persons.
238. Any person who voluntarily violates the atmosphere at any place, to make it
noxious to health of persons in general dwelling or carrying out business in the
neighborhood or passing along public ways is guilty of misdemeanor and shall be
subjected to imprisonment not exceeding two years with no option of fine. Under this
code, any person who for trade or otherwise makes loud noise or offensive awful smell
in such places and circumstances as to annoy any considerable number of persons in
Pan-19-003 - 51 -
KeNHA
the exercise of their rights, commits an offence, and is liable to be punished for a
common nuisance, i.e. imprisonment not exceeding one year with no option of fine.
239. The contractor of the proposed road will therefore need to ensure that all emissions
are controlled during the construction phase of the project to avoid interference on health
of the local communities and the workers
3.4.21 Building Code 2009
240. This by-law recognizes the County Governments as the leading planning agencies.
It compels potential developers to submit development applications for approval. The
county governments are hence empowered to approve or disapprove any plans if they
do or do not comply with the law, respectively. Any developer who intends to erect a
building must give the respective local authority a notice of inspection before the erection
of the structure.
241. Section 214 of the by law requires that any public building where the floor is more
than 20 feet above the ground level should be provided with firefighting equipment that
may include one or more of the following; hydrants, hose reels and fire appliances,
external conations portable fire appliances, water storage tanks, dry risers, sprinkler,
drencher and water spray spring protector system.
242. The Contractor will need to comply with these requirements when constructing the
camps and offices for the project.
3.4.22 The National Museums and Heritage Act, 2006
243. This Act provides for the establishment of the National Museums of Kenya (NMK)
to serve as the national repositories for things of scientific, cultural, technological and
human interest. The Act provides for the control, management and development of
national museums and the identification, protection, conservation and transmission of
the cultural and natural heritage of Kenya.
244. Due to the project area’s rich and diverse history and background, there might be
historical and cultural sites which may be affected. The Chance Find Procedures
presented in Annex 6 of this report has taken into consideration the requirements of this
Act for its implementation.
3.4.23 HIV / AIDS Act, 2006
245. The Act provides for measures of prevention, management and control of HIV and
AIDS. It Promotes public health, counseling, support and care for those affected or living
with HIV. This Act will ensure that the Contractor makes provision for Voluntary
Counseling and Testing (VCT) for the workers. This greatly contribute to management
of HIV and AIDS and also bringing down stigmatization.
3.4.24 The National Gender and Equality Act, 2011
246. National Gender Equality Commission is a constitutional Commission established

by an Act of Parliament in August 2011, as a successor commission to the Kenya
National Human Rights and Equality Commission pursuant to Article 59 of the
Constitution. NGEC derives its mandate from Articles 27, 43, and Chapter Fifteen of the
Constitution; and section 8 of NGEC Act (Cap. 15) of 2011, with the objectives of
promoting gender equality and freedom from discrimination.
Pan-19-003 - 52 -
KeNHA
247. Gender mainstreaming in road projects ensures that the concerns of women and
men form an integral dimension of the project design, implementation, operation and the
monitoring and evaluation ensures that women and men benefit equally, and that
inequality is not perpetuated.
3.4.25 The Sexual Offences Act, 2006 and its amendment 2012
248. This Act protects people and employees from any unwarranted sexual attention or
advances by staff members. This act ensures the safety of women, children and men
from any sexual offences which include: rape, defilement, indecent acts. This law will
govern the code of conduct of the Contractor’s staff and provide repercussions of any
wrong doing by an offender.
3.4.26 Persons with Disability Act, Chapter 133
249. This act protects the rights of people with disabilities ensuring they are not
marginalized and that they enjoy all the necessities of life without discrimination. The act
guarantees that (1) No person shall deny a person with a disability access to
opportunities for suitable employment. (2) A qualified employee with a disability shall be
subject to the same terms and conditions of employment and the same compensation,
privileges, benefits, fringe benefits, incentives or allowances as qualified able-bodied
employees. (3) An employee with a disability shall be entitled to exemption from tax on
all income accruing from his employment.
250. The Act will ensure that persons with disability are included in all decision making
that affects their lives and also provided with extra support to minimize impact of the
project.
3.4.27 Security Laws (Amendment) Act, 2014
251. This act entails a legal framework and jurisdiction on security matters. It is a
constitutional entitlement to live and feel secure from agents that may compromise ones’
life and safety. Security measures are vital in this project following past terrorist
experiences reported in the area; the contractor shall embark on a community policing
program to be executed by a competent security firm.
252. It is recommended that the government takes keen interest in providing adequate
support to enhance the security of persons involved in this project and the community
at large, which will translate to provision of critical intelligence that will trigger a review
of the existing security measures and tactics, among other advantages such as security
expertise and artillery.
3.4.28 Matrimonial Property Act (No. 48 of 2013)
253. Matrimonial property is property owned or obtained by either or both married

spouses before or during their marriage. It is sometimes called 'matrimonial assets.'
Matrimonial property includes the matrimonial home; the home that the couple lived in
during their marriage. It also includes many other things, not just physical property like
land or houses but also things like the contents of the home, furniture and appliances,
vehicles that a couple owns while married, and sometimes other things as well. It may
include work pensions that either spouse may have, and certain debts that the parties
have. The law that deals with matrimonial property in Kenya is called the Matrimonial
Property Act.
Pan-19-003 - 53 -
KeNHA
254. This act only applies to married couples, or couples who are in a Registered
Domestic Partnership. This act does not apply to common law couples. When a married
couple separates, either person can apply to the court to divide property, pensions, or
debts.
These issues, though, are usually dealt with during a divorce. It is important to speak to
a lawyer for advice before dividing property, pensions, or debts. Once a couple is
divorced, these issues are usually finished. You usually can't re-open them in the future
if you’ve made a mistake. Compensation during resettlement needs to follows the legal
provisions.
3.4.29 The Children Act, 2001
255. This Act protects the welfare of children within the Country. The Act identifies
Children as a person below the age of 18 years old and protects them from exploitation.
Of particular importance to this project, is section 10, which protects the child from:
• Sexual exploitation
• Physical and psychological abuse
• Economic exploitation.
• Any work that interferes with his/ her education, or is harmful to the child’s health or
physical, mental, spiritual, moral or social development.
256. Project area community are poor and marginalized and may easily be exploited.
The Contractor will need to sensitize workers against abuse and exploitation of children.
3.4.30 Protection Against Domestic Violence Act, 2015
257. This Act provides for the protection of persons against domestic violence including
women and Children against abuse. As reported in the SA Report, Gender Based
Violence is high in the project area and it is likely to increase during project
implementation considering the high poverty levels and lack of education for the girl child
exposing them to manipulation and abuse. It will be important for the Contractor to
sensitize workers and firmly implement the workers code of conduct
3.4.31 Prohibition of Female Genital Mutilation Act, 2011
258. This Act prohibits the practice of Female Genital Mutilation and safeguards against
violation of a person’s mental or physical integrity. The Act makes such acts punishable
by law.
3.5 World Bank Safeguards Policies
3.5.1 Operational Policy 4.01: Environmental Assessment
259. The Operational Policy on Environmental Assessment (OP 4.01) is applied by the
World Bank to identify, avoid, and mitigate the potential negative environmental and
social impacts associated with Bank lending operations. The purpose of Environmental
Assessment is to provide guidance for environmental and social assessment of the WB
financed projects, improve decision making, to ensure that project options under
consideration are sound and sustainable, and that potentially affected people have been
properly consulted. The proposed road project will have significant impacts along the
road corridor in all phases including loss of grazing land along the road corridor, change
in the landscape not just at the quarry or borrow sites (loss of materials), establishment
Pan-19-003 - 54 -
KeNHA
of larger market centres and towns, influx of new populations in search of new
opportunities, interference with existing ways of life, GBV, increased conflicts, pressure
for increased demand on existing resources, increase in traffic during the operation
phase leading to an increase of foreign members to the community. Full Environmental
and Social Impact Assessment (ESIA) and environmental and social management plan
(ESMP) has been carried out to fulfill the requirements of this policy.
In addition, at least two consultation cycles have been carried out with project affected
people and other stakeholders (during the design engineer ESIA preparation and
Independent Consultant), and the disclosure requirements.
3.5.2 Operational Policy 4.04 Natural Habitats
260. This operational policy requires that the ESIA study applies the precautionary
principle approach to natural resource management to ensure environmental
sustainability. The policy requires conservation of critical habitat during project
development. To ensure conservation and project sustainability, the policy requires
project alternatives to be sought when working in fragile environment areas and key
stakeholders to be engaged in project design, implementation, monitoring and
evaluation including mitigation planning.
261. This policy is important because some sections of the proposed project road
directly passes through Lorian swamp that act as a host for majority of the wildlife and
livestock during the dry season found in the area because of availability of drinking water
and forage.
3.5.3 Bank Operational Policy 4.10: Indigenous Peoples
262. This policy contributes to the World Bank's mission of poverty reduction and
sustainable development by ensuring that the development process fully respects the
dignity, human rights, economies, and cultures of Indigenous people. The project area
community are indigenous peoples because they have been geographically and
historically marginalized and underserved
263. The project planning therefore must involve Free, Prior, Information Consultation
with the community, all the key stakeholders in ensuring the objectives of this policy are
attained by (a) avoiding potentially adverse effects on the Indigenous Peoples’
communities; or (b) when avoidance is not feasible, minimize, mitigate, or compensate
for such effects.
264. The project should also be designed to ensure that the indigenous people receive
social and economic benefits that are culturally appropriate and gender and inter-
generationally inclusive. The predominant communities identified along the project road
corridor are: the Somali and Borana communities. A Social Assessment has been carried
out for the project to determine how the communities will benefit from the project benefits
and to obtain Free, Prior, Information Consultation for the project .
3.5.4 Operational Policy 4.11-Physical Cultural Resources
265. This policy guides in preserving physical cultural resources and helps reduce
chances of their destruction or damage. The policy considers Physical Cultural
Resources (PCR) to be resources of archaeological, paleontological, historical,
architectural, and religious (including graveyards and burial sites), aesthetic or other
cultural significance. This policy applies to all projects requiring a Category A or B
Environmental Assessment under OP 4.01, projects located in, or in the vicinity of,
Pan-19-003 - 55 -
KeNHA
recognized cultural heritage sites. There is a potential of the project road affecting some
of these sites, whose exact location is unknown as such a “Chance Find Procedures”,
has been presented in Annex 6 of this report.
3.5.5 The Bank's Operational Policy 4.12: Involuntary Resettlement
266. The objective of this policy to avoid where feasible, or minimize, exploring all viable
alternative project designs to avoid resettlement. This policy is triggered in situations
involving involuntary taking of land and involuntary restrictions of access to legally
designated parks and protected areas. The policy aims to avoid involuntary resettlement
to the extent feasible, or to minimize and mitigate its adverse social and economic
impacts.
267. The policy advocates for the participation of displaced/affected persons in the
resettlement planning and implementation process with the objective of ensuring that
the livelihoods of affected persons are restored to levels that are better than or equal to
their former living standards
268. The policy prescribes compensation and other resettlement measures to achieve
its objectives and requires that borrowers prepare adequate resettlement planning
instruments prior to project appraisal of proposed projects. The proposed road project
will affect several people living and conducting businesses along the road, in addition
there will be the loss of grazing land along the road corridor for which a Resettlement
Action Plan (RAP) was conducted and report prepared.
269. The policy provides for the preparation of appropriate and accessible grievance
mechanisms for such affected persons so as to offer an avenue where they can register
their complains and solutions provided. A Grievance Redress Mechanism (GRM) for this
project has been prepared and included in Section 9.4 of this report.
3.5.6 World Bank Directive on Vulnerable Groups
270. The project area is home to the Borana and Somali communities as elaborated in
Section 6.3.10 of this report. They are considered as marginalized and vulnerable. The
term “vulnerability” refers to those individuals or groups who, by virtue of, for example,
their age, gender, ethnicity, religion, physical, mental or other disability, social, civic or
health status, sexual orientation, gender identity, economic disadvantages or indigenous
status, and/or dependence on unique natural resources, may be more likely to be
adversely affected by the project impacts and/or more limited than others in their ability
to take advantage of project benefits.
271. Such an individual/group is also more likely to be excluded from/unable to

participate fully in the mainstream consultation process and as such may require specific
measures and/or assistance to do so. This will take into account considerations relating
to age, including the elderly and minors, and including in circumstances where they may
be separated from their family, the community or other individuals upon whom they
depend.
272. This ESIA Study has taken into account the vulnerable community members along
the project road, engage them in various consultations in order to include them and their
various vulnerabilities in the ESIA with a means of adequately providing mitigation
measures to their various disadvantages for all phases of the project.
Pan-19-003 - 56 -
KeNHA
3.5.7 World Bank Policy on Access to Information, 2010
273. The World Bank policy on access to information sets out the policy on public
access to information in its possession. This Policy supersedes the World Bank Policy
on Disclosure of Information, and took effect on July 1, 2010.
274. This Policy is based on five principles:
• Maximizing access to information.
• Setting out a clear list of exceptions.
• Safeguarding the deliberative process.
• Providing clear procedures for making information available.
• Recognizing requesters’ right to an appeals process.
275. In disclosing information related to member countries/borrower in the case of

documents prepared or commissioned by a member country/borrower (in this instance,
safeguards assessments and plans related to environment, resettlement, and
indigenous peoples, OP/BP 4.01, Environmental Assessments, OP/BP 4.10 and OP/BP
4.12 Involuntary Resettlement); the bank takes the approach that the country/borrower
provides such documents to the Bank with the understanding that the Bank will make
them available to the public.
3.6 World Bank GROUP Environmental, Health and Safety (EHS) Guidelines
276. The Environmental, Health and Safety (EHS) Guidelines are technical reference
documents with general and industry-specific examples of Good International Industry
Practice (GIIP). When one or more members of the World Bank Group are involved in a
project, these EHS Guidelines are applied as required by their respective policies and
standards. These General EHS Guidelines are used in addition to the local guidelines
in order to provide mitigation measures for the various environmental and social impacts
that will be identified in this report. The main EHS guidelines that will be used alongside
local policies include:
• Environmental Guidelines
• Occupational Health and Safety Guidelines
• Community Health and Safety Guidelines
• Construction and Decommissioning Guidelines
3.6.1 Environmental Guidelines
277. These guidelines will govern the Contractor’s activities during the construction of
the road and the construction works impacts on the physical environment.
278. The guidelines include:
a) Air Emissions and Ambient Air Quality – which provide the air quality standards,
limits and monitoring requirements for construction works. The guidelines incorporate
WHO air quality guidelines on the major air pollutants expected from the Contractor’s
machinery and equipment.
b) Wastewater and Ambient Water Quality – These guidelines will be key particularly
in the Contractor’s camp and the impacts of wastewater generation and treatment
before release into the environment, in order to prevent pollution of the surrounding
physical environment. Due to the fact that the project area is not sewered, the
Contractor will have to establish onsite treatment of waste water, proper channeling of
stormwater to prevent contamination of the physical and social environment. The
guidelines call for monitoring of wastewater from the site through testing and
Pan-19-003 - 57 -
KeNHA
inspections for which the Contractor will have to establish a plan for management and
monitoring.
c) Waste Management – All construction works are expected to produce one or more
forms of waste. The construction of the road will be no exception. Construction wastes
and Domestic wastes are expected from the Contractor’s site as well as the camp.
The Contractor will have to prepare a waste management plan using these guidelines
that conform to the local legal framework provided in this chapter.
d) Noise – Use of several equipment and plant is bound to generate some level of noise,
which are bound to have a negative impact on the surrounding environment and in
particular sensitive receptors (human settlements and wildlife). These impacts will be
short-lived during the construction phase of the project. The guidelines also provide the
maximum noise levels, provided in the Noise and Excessive Vibration Pollution Control
Regulations – Schedule 1-3, which the Contractor should strive to adhere to. The
guidelines also call for baseline and annual monitoring of noise generation within the
Contractor’s site to establish compliance to the guidelines and local regulation.
3.6.2 Occupational Health and Safety Guidelines
272. These guidelines are geared towards ensuring the safety of the staff on site and
within the Contractor’s camp. The guidelines with regards to occupational health
and safety include:
a) General Facility Design and Operation – These guidelines will guide the
Contractor’s workspace. Being that the project area is in the Northern Region of the
Country, characterized by high temperatures the Contractor will have to provide
suitable potable water supply for the staff, a clean eating area, suitable lavatories and
showers, fire precaution measures (extinguishers and safety drills) and first aid
services.
b) Communication and Training – This will provide for communication and training of
staff and visitors to the site, to govern behavior within the site. This is necessary to
ensure safety while operating within the site. The Contractor will need to employ a
health and safety officer fulltime on site who will be in charge of ensuring safety and
communication of safety within the site.
c) Physical Hazards – These guidelines will govern the exposure of the workers to
physical dangers including excavation sites, bridge sites, noise, dust, welding, manual
handling, work environment temperatures. The guidelines provide fall protection when
working at height and work hour limits (8 hours maximum).
d) Personal Protective Equipment (PPE) - Personal Protective Equipment (PPE)
provides additional protection to workers exposed to workplace hazards in conjunction
with other facility controls and safety systems. PPE is considered to be a last resort
that is above and beyond the other facility controls and provides the worker with an
extra level of personal protection. The Contractor will have to provide the relevant PPE
for staff on site for the different job descriptions. In addition, visitors to site will have to
be provided with some minimal form of PPE during their visits.
e) Monitoring - Occupational health and safety monitoring programs should verify the
effectiveness of prevention and control strategies. The selected indicators should be
representative of the most significant occupational, health, and safety hazards, and
the implementation of prevention and control strategies. The Contractor will have to
employ a health and safety officer who will come up with an occupational health and
safety monitoring program for implementation by the Contractor. In addition, the
Contractor will provide a clinic and log of accidents and incidences on site as a control
measure for ensuring health and safety
Pan-19-003 - 58 -
KeNHA
3.6.3 Community Health and Safety Guidelines
273. These guidelines complement the environmental, social and occupational health
and safety guidelines. The guidelines specifically address the impact of the project
activities on the surrounding community. They involve the following aspects:
a) Structural Safety of Project Infrastructure – Construction works, works on

borrow/quarry sites may pose a risk to the surrounding communities. As such safety
measures have to be taken into account. The Contractor will have to provide physical
buffers such as cordons to prevent falls into the pits, road signage, establishment of
speed limits, water spraying to ensure the safety of the community.
b) Traffic Safety – The project road will still be under use during construction. As such
the Contractor will have to provide a traffic management plan in order to ensure safety
of motorists and other road users. The traffic management plan will include alternative
diversion routes and a traffic controller to divert traffic and road signage.
c) Emergency Preparedness and Response – These are designed to deal with events
and acts that are unplanned when a project operation loses control, or could lose
control, of a situation that may result in risks to human health, property, or the
environment, either within the facility or in the local community. Emergencies do not
normally include safe work practices for frequent upsets or events that are covered by
occupational health and safety. The Contractor will prepare an emergency
preparedness and response plan, including training of staff, drills to gauge responses
to preparedness, and communication with the local community in case of rinse.
d) Disease Prevention – Workers will be coming in from other parts of Kenya. There is
potential that communicable diseases may be spread among the workers and
community members. Communicable diseases of most concern during the construction
phase due to labour mobility are sexually-transmitted diseases (STDs), such as
IV/AIDS. Contractor is to facilitate screening and treatment of workers and undertaking
health awareness and education initiatives. Promoting individual protection, and
protecting others from infection, by encouraging condom use.
3.6.4 Construction and Decommissioning Guidelines
274. These guidelines govern the project components that require decommissioning
including the material sites and camp. The Contractor will prepare a decommissioning
plan for all these features taking into account the EHS guidelines as mentioned above
3.7 Gaps Between Kenyan Legislation and World Bank Safeguards with
Recommendations for Bridging the Gaps
275. Table 20 below summarizes a comparison between Kenyan legislation and the
World Bank Safeguards with recommendations of bridging the gaps between the two
policies
Pan-19-003 - 59 -
KeNHA
Table 20: Summary of Gaps between Kenyan legislation and World Bank Safeguards with recommendations
World Bank OP 4.01 EMCA Comparison Recommendation
O.P 4.01 requires screening of sub EMCA requires screening of project Both the Kenyan and World Bank safeguards Preparation of the ESIA
project investments in order to investments in order to determine if further require screening to establish the level of to meet both NEMA and
determine if further environmental and environmental and social assessments ESIA prepared. World Bank Standards.
social assessments (ESIAs) are required (ESIAs) are required
The ESIA will be prepared with mitigation
After screening and determination of
An ESIA of a project will be prepared in measures for any negative environmental and
required ESIA category, an ESIA is
accordance to EMCA guidelines and the social impacts.
prepared before project design and
report submitted to NEMA for licensing. Use of Kenyan
implementation (which includes an
regulations in
assessment of social impacts). EMCA is also equipped with regulations on The various limits set out in the regulations
accordance to EMCA.
air, noise, water, waste management, are close to World Bank and IFC policies with
Also gives guidelines on air, noise,
emissions and wetlands management. minimal differences in the actual figures.
water, waste management, emissions
and wetlands management.
The prepared ESIA Study should take The EMCA (Conservation of Biological Both require an ESIA to establish the Preparation of the ESIA
into account natural resources and the Diversity and Resources, Access to Genetic potential impact of a development on to meet both NEMA and
principle approach to natural resource Resources and Benefit Sharing) Regulations, biodiversity and ensuring environmental World Bank Standards.
management to ensure environmental 2006 provides that no person shall engage in sustainability.
sustainability. any activity that may have an adverse impact
on the ecosystem, lead to the introduction of
any exotic species or to unsustainable use of
natural resources.
The Wildlife Management and Conservation
Act also ensures consideration of wildlife and
their conservation in project implementation.
This policy guides in preserving physical The National Museums and Heritage Act The World Bank policy offers more detail on Use of the World Bank
cultural resources and helps reduce identifies the need for the protection, the physical and cultural resources other than policy in handling any
chances of their destruction or damage. conservation and transmission of the cultural archaeological finds identified in the Kenyan physical and cultural
and natural heritage of Kenya Policy. site, while making use of
Pan-19-003 - 60 -
KeNHA
the Kenyan institutional

framework.
Involuntary resettlement should be Involuntary resettlement may occur as a The Kenyan Policy does not stipulate that Resettlement issues are
avoided wherever possible, or result of projects implemented in public resettlement should be avoided wherever to be considered at the
minimized, exploring all alternatives. interest. possible; on the contrary, as long as a project design stage of the
is for public interest, involuntary resettlement project in order to avoid/
is considered to be inevitable. minimize resettlement.
Inclusion of persons considered Article 56 of the constitution highlights the Both the Kenyan and World Bank Safeguards Preparation of an ESIA
indigenous, who without proper rights of marginalized communities, in the requires the inclusion of communities that are in accordance to
consultation may suffer as a result of the decision-making process with regards to marginalized and inclusion of the vulnerable Kenyan and World Bank
project leading to further marginalization. development and their input in project planning, implementation and Standards in addition a
operation phases of the project. In order to separate social
Similarly, the bank has a directive on The National Gender and Equality Act,
ensure these communities, reap the benefits assessment in
vulnerable groups, who may be left out Children Act and Persons with Disabilities Act
of the project without suffering accordance to the World
of the benefits of the project or suffer promote the inclusion of these persons, who
disproportionately in comparison to the rest of Bank Safeguards.
more as a result of the negative impacts in society are often looked over, in the
the communities.
of the project. implementation of projects.
However, if the World Bank OP 4.10 is
These safeguards are in place to ensure
triggered, the proponent will be required to
the vulnerable and often marginalized
conduct a social assessment in order to have
are adequately consulted and their
an in-depth analysis of the impact of the
issues addressed in the ESIA.
project on marginalized and vulnerable
groups, in a bid to mitigate the negative
impacts. Kenyan legislation only requires an
ESIA.
Pan-19-003 - 61 -
KeNHA
Displaced persons should be EMCA requirements for project proponent to Both Policies are similar Consultation of
meaningfully consulted and should have seek the views of persons/communities that stakeholders in the
opportunities to participate in planning may be affected by the project to be ESIA in accordance to
and implementing resettlement consulted, at least explain project potential both Kenyan legislation
programs impacts and obtain oral/written comments and World Bank
Safeguards.
In addition to the operational policies, The Occupational Health and Safety Act is Both provide guidelines which should be Incorporation of the
the World Bank has guidelines to the main act ensuring the health and safety of adhered to, during all phases of the project, World Bank Guidelines
ensure, environmental, occupational and the Contractor’s employees and the with the Kenyan legislation providing an while ensuring
community health, and decommissioning surrounding community institutional framework for the implementation conformance to the
guidelines. These guidelines will provide of the Act. The World Bank guidelines Kenyan Legislation and
the Contractor with best working provides best international practices for institutional framework.
procedures. construction works.
Pan-19-003 - 62 -
KeNHA
3.7.1 International Conventions, Treaties and Guidelines
276. There are number Multi-Lateral Environmental Agreements (MEAs) that are relevant to
the proposed project. These are described in the following section.
3.7.1.1Vienna Convention on the Protection of the Ozone Layer
277. This was an Intergovernmental negotiation for an international agreement to phase out
ozone depleting substances concluded in March 1985 which saw the adoption of the Vienna
Convention for the Protection of the Ozone Layer. This Convention encourages
intergovernmental cooperation on research, systematic observation of the ozone layer,
monitoring of CFC production, and the exchange of information.
3.7.1.2United Nations Convention on Biological Diversity (UNCBD)
278. The purpose of this convention is to ensure the conservation and sustainable use of
biodiversity. Kenya signed the convention on 5th June 1992 and ratified the same on 26th July
1992. The National Environment Management Authority (NEMA) is the National Focal Point
to this Convention. The provisions of this Convention have been integrated in many laws of
Kenya.
3.7.1.3African Convention on the Conservation of Nature and Natural Resources
279. This convention reaffirms the importance of natural resources both renewable and non-
renewable, particularly the soil, water, flora and fauna. The main objective is to facilitate
sustainable use of the above resources. The convention was adopted in Algiers on 15th
September 1968 and came into force on 16th June 1969.
3.7.1.4Convention on International Trade in Endangered Species
280. This Convention was adopted on 3rd March 1973 and came into force on 1st July 1975.
The purpose of the Convention is to regulate the international trade in wild plants and animals
that are at risk of extinction because of trade. The Convention seeks to control trade not only
in live species but also in dead specimen and their derivatives. The Kenya Government ratified
CITES on 13th December 1978. The lead agency for the CITES in Kenya is the Kenya Wildlife
Service (KWS).
3.7.1.5The World Commission on Environment and Development (The Brundtland

Commission of 1987)
281. The Commission in its 1987 report dubbed “Our Common Future” focused on the
environmental aspects of development, the emphasis on sustainable development that
produces no lasting damage to the biosphere and to ecosystems. In addition to environmental
sustainability is economic and social sustainability. Economic sustainable development is
development for which progress towards environmental and social sustainability occurs within
available financial resources. While social sustainable development is development that
maintains the cohesion of a society and its ability to help its members work together to achieve
common goals, while at the same time meeting individual needs for health and well-being,
Pan-19-003 - 63 -
KeNHA
adequate nutrition, and shelter, cultural expression and political involvement. The key aspect
of sustainability is the interdependence of generations.
3.7.1.6The Ramsar Convention for the conservation and sustainable utilization of wetlands
282. The Ramsar Convention (formally known as the Convention on Wetlands of International
Importance, especially as Waterfowl Habitat) is an international treaty for the conservation and
sustainable utilization of wetlands, recognizing the fundamental ecological functions of
wetlands and their economic, cultural, scientific, and recreational value. The proposed road
has potential of impacting several wetlands. Appropriate mitigation measures will need to be
implemented as detailed in the Environmental Management Plan.
3.7.1.7United Nations Convention to Combat Desertification (UNCCD)
283. The above Convention was adopted on 17th June 1994 in Paris and came into force on
26th December 1996.Kenya ratified the Convention in 24th June 1997. The purpose of the
UNCCD is to address the problem of the degradation of land by desertification and the impact
of drought particularly in arid and dry semi-humid areas. NEMA is the focal point for the
Convention.
3.7.1.8The 1992 United Nations Framework Convention on Climate Change (UNFCCC)
284. The primary purpose of the convention is to establish methods to minimize global
warming and the emission of the greenhouse gases. The UNFCCC was adopted on 9th May
1992 and came into force on 21st March 1994. The Convention has been ratified by 189
states. Kenya ratified the Convention on 30th August1994. NEMA is the focal point for the
Convention.
3.7.1.9The Paris Agreement
285. This agreement was adopted on 12th December 2015 at the 21st session of the
Conference of the Parties to the United Nations Framework Convention on Climate Change
in Paris, it then came into force on 4th November 2016 after meeting the ratification threshold.
The Agreement provides the framework to address climate change for a safer and sustainable
future, it has an objective of preventing a global temperature increase above 1.5 degrees
Celsius relative to pre-industrial levels by reduction of Greenhouse gas emissions. Kenya
ratified the Paris Agreement and welcomed it into force on 28th December 2016. As at now a
total of 171 parties out of 197 have ratified the agreement.
3.7.1.10Rio Declaration on Environment and Development
286. The Rio Declaration on Environment and Development, often shortened to Rio
Declaration, was a short document produced at the 1992 United Nations "Conference on
Environment and Development" (UNCED), informally known as the Earth Summit. The
declaration aimed at establishing a new and equitable global partnership through the creation
of new levels of co-operation among States, key sectors of societies and people, working
towards international agreements which respect the interests of all and protect the integrity of
the global environmental and developmental system, recognizing the integral and
interdependent nature of the Earth, our home.
Pan-19-003 - 64 -
KeNHA
The Rio Declaration consisted of 27 principles intended to guide countries in future sustainable
development. It was signed by over 170 countries.
287. Principle 17 of the Rio Declaration provides key relevance to the proposed project; the
principle denotes that environmental impact assessment as a national instrument shall be
undertaken for proposed activities that are likely to have a significant impact on the
environment and are subject to a decision of a competent national authority.
3.7.1.11Earth Summit on Sustainable Development Agenda 21
288. Agenda 21 is a non-binding, voluntarily implemented action plan of the United Nations
regarding sustainable development. It is a product of the Earth Summit (UN Conference on
Environment and Development) held in Rio de Janeiro, Brazil, in 1992. It is also regarded as
an action agenda for the UN, other multilateral organizations, and individual governments
around the world that can be executed at local, national, and global levels. The "21" in Agenda
21 refers to the 21st Century. Agenda 21 Section I on Social and Economic Dimensions is
directed toward combating poverty, especially in developing countries, changing consumption
patterns, promoting health, achieving a more sustainable population, and sustainable
settlement in decision making.
289. Section II on Conservation and Management of Resources for Development Includes

atmospheric protection, combating deforestation, protecting fragile environments,
conservation of biological diversity (biodiversity), control of pollution and the management of
biotechnology, and radioactive wastes.
290. Section III focuses on strengthening the Role of Major Groups including the roles of
children and youth, women, NGOs, local authorities, business and industry, and workers; and
strengthening the role of indigenous peoples, their communities, and farmers. Kenya
continues to implement Agenda 21 to support sustainable development through the integration
of environmental concerns into the national development policies, plans, and programmes.
Also relevant is the implementation of Agenda 17. The proposed project would need to be
consistent with the objectives of Agenda 21.
3.7.1.12Convention on the Rights of the Child
291. The Convention on the Rights of the Child (CRC), 1989 is the most comprehensive
compilation of international legal standards for the protection of the human rights of children.
The CRC is also the most widely ratified international human rights treaty, ratified by all
countries in the world, apart from two.
292. The Convention acknowledges children as individuals with rights and responsibilities
according to their age and development (rather than the property of their parents or as victims),
as well as members of a family and community. Underlying the Convention are four main
principles: non-discrimination, the best interests of the child, the right to life, survival and
development and the right to participation.
3.7.1.13Convention on the Elimination of all forms of Discrimination against Women
293. The Convention on the Elimination of all forms of Discrimination against Women
(CEDAW) places explicit obligations on states to protect women and girls from sexual
Pan-19-003 - 65 -
KeNHA
exploitation and abuse. Universal Declaration of Human Rights (Article 7), the UN Charter
(Articles 1, 13, 55, and 76) and the International Covenant on Civil and Political Rights (Article
24) reaffirm the freedoms and rights of all children, including internally displaced children.
3.7.1.14International Labour Organization
294. The International Labour Organization (ILO) is built on the constitutional principle that
universal and lasting peace can be established only if it is based upon social justice. The ILO
has generated such hallmarks of industrial society as the eight-hour working day, maternity
protection, child-labour laws, and a range of policies which promote workplace safety and
peaceful industrial relations.
295. The ILO has four principal strategic objectives:
• To promote and realize standards, and fundamental principles and rights at work.
• To create greater opportunities for women and men to secure decent employment.
• To enhance the coverage and effectiveness of social protection for all.
• To strengthen tri-parties and social dialogue.
274. The key ILO Conventions applicable to the proposed road project include:
• Equal Remuneration Convention (1951) (No. 100) - Calls for equal pay and benefits for
men and women for work of equal value.
• Discrimination (Employment and Occupation) Convention (1958) (No. 111) - Calls for
a national policy to eliminate discrimination in access to employment, training, and
working conditions, on grounds of race, colour, sex, religion, political opinion, national
extraction or social origin, and to promote equality of opportunity and treatment.
• Minimum Age Convention (1973) (No. 138) - Aims at the abolition of child labour,
stipulating that the minimum age for admission to employment shall not be less than
the age of completion of compulsory schooling.
• Worst Forms of Child Labour Convention (1999) (No. 182) - Calls for immediate and
effective measures to secure the prohibition and elimination of the worst forms of child
labour which include slavery and similar practices, forced recruitment for use in armed
conflict, use in prostitution and pornography, any illicit activity, as well as work which is
likely to harm the health, safety, and morals of children.
3.7.1.15Sustainable Development Goals (SDGs)
275. The Sustainable Development Goals (SDGs) are a new, universal set of goals, targets
and indicators that UN member states will be expected to use to frame their agendas and
political policies over the next 15 years. The SDGs include 17 Sustainable Development Goals
and 169 targets. Considering the current status of the project area being arid, receiving
minimal rainfall and the inhabitants being considered poor and marginalized the proposed
upgrading of the road to bitumen standards will positively contribute to the achievement of the
13 sustainable development goals (SDGs) listed below.
276. GOAL 1: No Poverty, GOAL 2: Zero Hunger, GOAL 3: Good Health and Well-being,
GOAL 4: Quality Education, GOAL 5: Gender Equality, GOAL 6: Clean Water and Sanitation,
GOAL 7: Affordable and Clean Energy, GOAL 8: Decent Work and Economic Growth, GOAL
9: Industry, Innovation and Infrastructure, GOAL 10: Reduced Inequality, GOAL, GOAL,
Pan-19-003 - 66 -
KeNHA
GOAL 13: Climate Action, GOAL 15: Life on Land, GOAL 16: Peace and Justice Strong
Institutions,
277. The GOALs seek to build on the Millennium Development Goals that expired in 2015.
Most notably SDGs are integrated, indivisible and balance the three dimensions of sustainable
development: the economic, social and environmental. This road project is expected to cut-
across the three dimensions of sustainable development hence making SDGs a key reference
point. The SDGs are also linked to several Kenyan legal frameworks such as Water Act,
Forestry Act, and EMCA Cap 387.
3.8 Institutional Framework
278. There are various national institutions that are important in road project matters related
to environmental management in Kenya. These are described in Table 21.
Pan-19-003 - 67 -
KeNHA
Table 21: Roles of Organizations involved in the Roads Development

Ministry of Transport, Provide funding mechanisms and general guiding policies for the project.
Infrastructure, Housing and
1
Urban Development
(MoTIHUD)
2 The Kenya Roads Board (KRB) The main objective is to oversee the road network in Kenya and thereby coordinate its development, rehabilitation and
maintenance and to be the principal adviser to the Government on all matters related thereto.
3 Kenya National Highways KeNHA
Authority (KeNHA) • Will assign dedicated Engineer, Environmental and Social staff to support the project
✓ Project Engineer (Team Leader and Employer Representative)
✓ Deputy Director – Environment and Social Safeguards (Overseeing Safeguards Implementation)
✓ Registered Land Valuer
• Will conduct induction and trainings for contractors and supervision staff on ESMP implementation, WB safeguards
requirements and WBG EHS guidelines , national environmental and social legislative framework requirements
• Will carry out monthly supervision and monitoring of the ESMP implementation
• Will review and approve CESMPs and other plans
Full Term Safeguards Consultants
4 The County and Sub-County The Environment Committee swill:
Environment Committees • Approve applications for Contractors site camps
• Provide permits for quarries and borrow pit sites
• Audit the Contractors camps and construction sites for safeguards compliance
5 The National Environment NEMA will:
Management Authority (NEMA • Approve the ESIA Report
• Issue EIA License for project implementation
• Carry out independent Audit to determine compliance with ESMP
7 Kenya Wildlife Service (KWS) KWS will
Guide and monitor road construction throughout the project area since it is a wildlife dispersal area
8 Water Resources Authority WRA will:
(WRA) Will issue water abstraction permits to enable Contractor use water from boreholes, pans, wells and rivers
9 Kenya Forest Service (KFS) KFS
Pan-19-003 - 68 -
KeNHA
• Will provide guidance on which tree species should be planted

• Will provide support in ensuring the trees grow
10 The National Museums of NMK will:
Kenya (NMK) • Carry out recovery of any physical, cultural or archaeological artefacts encountered during construction
• Guide the Contractor’s team on the protection of physical cultural resources
11 National Land Commission NLC will:
(NLC) • Verify the affected land and assets for purposes of compensation and resettlement
• Carry out land acquisition on behalf of KeNHA
• Carry out compensation and resettlement
12 County Governments of Wajir, County Governments will:
Garissa and Isiolo • Provide approval for the project
• Provide Approval for camp sites, borrow pit and quarry sites.
• Provide support
13 County Government - County Department will:
Department of Education, • Provide support to any group at higher risk of being subjected to discriminatory practices, violence, natural or
Gender, Youth, and Social environmental disasters, or economic hardship than other groups within the state
Services • Provide support to any group or sector of society (such as women, children or the elderly) that is at higher risk in
periods of conflict and crisis
14 The Ministry of Public Service, To coordinate gender mainstreaming in national development planning and promote equitable political and socio-economic
Youth and Gender Affairs development for women, men, girls and boys.
15 National Construction Authority NCA
(NCA) • Registers contractors carrying out construction activities in Kenya
• Inspects constructions for compliance
16 Kenya National Commission on KNCHR:
Human Rights (KNCHR), • Investigates and provides redress for human rights violations
• Carries out research and monitor the compliance of human rights norms and standards,
• Conducts human rights education,
17 Commission on Administrative CAJ
Justice (CAJ) also known as • Investigates any conduct in state affairs or any act or omission in public administration in any sphere of Government
the "Office of the Ombudsman" • investigate complaints of abuse of power, unfair treatment, manifest injustice or unlawful, oppressive, unfair, or
unresponsive official conduct.
18 National Gender and Equality The Commission:
Commission Ensures that there is gender equality and equity throughout the implementation of the project.
Pan-19-003 - 69 -
KeNHA
Representatives will monitor and evaluate gender quality and equity with regards to job provision and harassment cases on
site to ensure compliance with the law.
19 Department of Community Work with poor, marginalized, vulnerable and disadvantaged communities as its primary target group will ensure that this
Development group is supported and is not left out of the project implementation
20 Directorate of Occcupational DOSHS:
Safety and Health Services • Provides OSH permits for workplaces of the project including campsites and quarries
(DOSHS) • Conduct inspections to ensure conformance to OSHA
21 Water Resources Authority WRA
(WRA) • Provides necessary water abstraction permits for boreholes and surface water sources (rivers, streams etc)
• Monitor water use in the region and provide guidance water use
22 Supervision Consultant Supervising Consultant:
• Will engage the following dedicated full-time safeguards staff to support risk management
✓ Supervising Engineer (RE)
• Review and approval of the CESMPs and other plans
• Day to day supervision of Contractor implementation of the CESMPs and other plans
• Regular reporting on the ESMP implementation
23 Contractor Contractor
• Will engage the following dedicated full-time safeguards staff
✓ Registered Occupational Health and Safety (OHS) Expert
• Will Prepare the CESMPs and other plans before construction begins
• Will operationalize and implement the CESMPs
• Carries out day to day management of ES, H& S risks
• Reports on incidents and accidents to the Resident Engineer and regulators
24 Development Partners – World • Provision of Project Development Funds
Bank • Provision of Environmental and Social Safeguard Policies that will govern the project implementation
Pan-19-003 - 70 -
KeNHA
3.9 Environment Related Permits Required for this Project
279. Before the contractor mobilizes to the site, there certain permits that he will need to put
in place. Some permits may be obtained during construction since they will be determined as
need arises. Table 22 lists the environment-related permits required for this project.
Pan-19-003 - 71 -
KeNHA
Table 22: Environment-related Permits required for the Project

No. Relevant activity Statute Requirement Competent Responsible Date of Duration
Authority Agency for Acquisition
Obtaining
Clearance
Pre-Construction Stage
1 Construction and Environmental Need to submit ESIA NEMA KeNHA Upon approval Max 90 Days from
operation of the Management and report to obtain EIA of ESIA report date of submission
road Coordination Act (EMCA) license of ESIA Study
Cap 387, Rev 2018 Report
2 Cutting of trees Forest Management and Need to obtain Kenya Forest KeNHA Before road Indefinite
Conservation Act, 2016 permission to cut Service (KFS) clearance
down trees works
3 Construction Occupational Safety and Need to apply Directorate of Contractor Before 1 – 4 weeks
activities Health Act (OSHA), 2007 registration of Occupational commencemen
premises Safety and Health t of
Services (DOSHS) construction
works
4 Construction and County Governments Act Need to obtain County KeNHA Upon approval Indefinite
Use of the No. 17 of 2012 revised in clearance of ESIA Governments of of ESIA report
Modogashe-Wajir 2017 report Wajir, Garissa and
Road Isiolo Counties
5 Setting up of Environmental Need to submit Project NEMA Contractor Before 1 – 1.5 months
construction camp Management and report for the Camp commencemen
sites Coordination Act (EMCA) Sites to obtain EIA t of
Cap 387, Rev 2018 License construction
6 Water abstraction Water Act, 2012 Need to obtain Water Resources Contractor Before 1 – 1.5 months
from Surfacewater permission to abstract Authority (WRA) commencemen
sources in the area water t of
(Rivers etc.) construction
7 Drilling of Environmental Need to submit Project NEMA Contractor Before 1 – 1.5 months
boreholes to supply Management and report to obtain EIA commencemen
water to the Coordination Act (EMCA) license t of
contractor Cap 387, Rev 2018 construction
Pan-19-003 - 72 -
KeNHA

Obtaining
Clearance
Water Act 2012 Need to obtain Water Resources Contractor Before 1 – 1.5 months
permission to abstract Authority (WRA) commencemen
water t of
construction
8 Storage, transport Environmental Need to obtain waste NEMA Contractor Before 1 – 1.5 months
and disposal of Management and license through commencemen
ordinary domestic Coordination Act (EMCA) submission of Waste t of
and office waste Cap 387, Rev 2018 Management Plan construction
9 Storage, transport Environmental Need to obtain NEMA Contractor Before 1 – 1.5 months
and disposal of Management and hazardous waste commencemen
hazardous waste Coordination Act (EMCA) license through t of
Cap 387, Rev 2018 submission of Waste construction
Management Plan
Construction Stage
1 Extraction of rock Environmental Need to obtain NEMA Contractor Before Max 1 month
aggregates and Management and material extraction extraction
murram from Coordination Act (EMCA) permit works
quarry Cap 387, Rev 2018
- Need to purchase Local Authority on Contractor Before Max 1 month
material extraction behalf of extraction
rights community works
2 Blasting of Explosives Act, 2016 Need to obtain to Mines and Geology Contractor Before blasting Max 1 month
construction site blasting permit Department in works
bedrocks (if Ministry of
required) Environment and
Forestry
3 Emission of Environmental Need to obtain permit NEMA Contractor Before 2 days
excessive Management and to emit excess excessive
noise/vibration (if Coordination (Noise and noise/vibration noise/vibration
required) Excessive Vibration works
Pan-19-003 - 73 -
KeNHA

Obtaining
Clearance
Pollution) (Control)
Regulations 2009
Pan-19-003 - 74 -
KeNHA
4 ESIA STUDY APPROACH AND METHODOLOGY
280. To commence the works the Consultant had an initial meeting with the Client to kick
off the ESIA process, agree on the terms of reference for conducting the ESIA and establish
a working relationship.
281. The next step included screening and a site reconnaissance and preparation of an
inception report which included an updated methodology for conducting the ESIA. Following
the screening process, a reconnaissance survey was done along the project road and
impacts were seen to affect not only the road corridor but also the plants and animals
outside the corridor. The presence of sensitive receptors including human settlements,
Lorian and Borji Swamps and wildlife necessitated the project to be identified as Category
A with high risks and warrants the controls that come with a typical Category A project.
282. A proposed project is classified as Category A if it is likely to have adverse

environmental impacts that are significant, generally large-scale, irreversible, sensitive,
diverse, cumulative or precedent setting and may affect an area broader than the sites or
facilities financed by the project. The proposed road project will have significant impact
along the road corridor in all phases and some of the impacts include loss of grazing land
along the road, establishment of larger market centres and towns, increase in traffic during
the operation phase leading to an increase of foreign members to the community. All these
impacts will have a permanent change to the existing status quo, thus requiring an in depth
ESIA study provided in this report.
283. A questionnaire survey was conducted along the project road corridor that yielded the
data presented in the socio-economic baseline chapter of this report. Similarly, a field
assessment form was used to collect data and information on biophysical features along
the project road corridor.
284. The outcome of the documents reviewed, reconnaissance survey and the study
results of the consultations have been used to prepare the Environmental and Social
Management Plan that elaborates how the negative impacts will be addressed, the cost of
mitigation and the responsible entities. A Monitoring Plan to check the progress of mitigation
measures has also been prepared.
285. The Study to review and update the ESIA Report for this project involved various
components as mentioned below:
4.1 Desktop Review of Project Documents
286. The desk review involved the following:
• Review of the Design Review, ESIA reports, RAP reports, gender analysis and design
review documents for the proposed road, including subsequent annexes to the
reports. In order to establish the project scope, background, potential impacts and
gaps within the reports to provide an update on the same.
Pan-19-003 - 75 -
KeNHA
• Review of available baseline data, maps and any relevant information on the existing
environmental and social conditions of the area of influence of the project considering
environmental changes and social dynamics that will take place as a result of the
project.
Review of existing National Legislation, Regulation, World Bank Safeguards Policies
and Procedures, relevant to the proposed Project and the World Bank Group
Environmental, Health and Safety Guidelines
Preparation of checklists consisting of a simple catalogue of environmental and social
factors which were compared to the activities to be developed.
4.2 Field Assessment
286 Several visits to the project area were made to carry out an assessment of the project
road corridor. The field investigation was conducted using a checklist of physical,
biological, socio-economic features of the project area.
287 The activities implemented during field investigations involved:
• Field assessment of the road corridor from Modogashe to Wajir to evaluate the bio-
physical and socio-economic environment.
• Site visits to the Project Area and the neighbouring areas within the zone of influence
of the project.
• Photographing the significant aspects to aid in describing baseline environmental and
social conditions of the Project area and its influence zone.
• Identifying potential sensitive environmental and social receptors within the project
area of influence including vulnerable and marginalized communities and vulnerable
animal and plant species, in order to establish the people or environments that may
suffer disproportionately due to the project and find solutions to mitigating the
measures.
• Recording the coordinates of the environmental and social features
• Update the collected baseline environmental and social data that will be used for
establishing project impacts and preparation of monitoring program
288 The physical characteristics evaluated include project location, topography, geology,
soils and water resources. The biological features include flora and fauna. Socio-
economic aspects include land use and economic activities, employment
opportunities, settlement patterns, demographic features, availability of and access to
social amenities such as education, health facilities and cultural heritage.
289 The main purpose of the field investigation was to verify information and data collected
during the desktop study and collection of any new information that may assist in the
assessment of impacts and design mitigation measures.
Pan-19-003 - 76 -
KeNHA
4.3 Identification and Engagement of Stakeholders
4.3.1 Stakeholder Identification
290 The consultant conducted additional stakeholder identification and engagement based
on the desktop review in order to fill any potential gaps. The stakeholder identification
and engagement included; identifying the various road authorities, county officials,
KWS officials, local leaders as well as the public in the project area
291 The stakeholders identified include:
• The Road Authorities (County and National)

• County Officials (Roads, Water, Public Health, Gender, Land and Physical Planning,
Environment, Livestock, education and Administrators)
• National Government (Interior and Coordination, KWS, KFS, Ecosystem
Conservator)
• Transportation (Bus Companies)
• Religious Leaders
Following the identification of the different stakeholders, different methods of engaging
with these stakeholders based on their roles and positions were devised.
4.3.2 Method used for Stakeholder Engagement
292 The methods applied to engage the stakeholders included key stakeholder interviews,
Questionnaire administration, Focus Group Discussions (FGDs) and Public
Consultation meetings (PCMs). The FGDs and PCMs were carried in all the
centres/towns along the project corridor. Eleven PCMs were convened from February
20-26, 2019 as given in Table 35 under Chapter 8.
293 One set of questionnaires was used to gauge the perception of key stakeholders, such
as staff from Kenya Wildlife Service, County Government, National Environmental
Management Authority, Kenya Forest Service, selected NGOs and CBOs about the
proposed road project. Another set of questionnaires was used obtain the opinion of
households, which were located in areas / settlements that were likely to be affected
by the project.
294 Public consultation meetings and Free Prior and Informed Consultations were held in
all towns and market centres that were likely to be affected by the project. The intention
was to obtain the opinion of local communities, community leaders, political leaders,
religious community and business owners about the project. These meetings were
used to provide an overview of the road project, potential benefits, potential adverse
impacts and the likelihood of disturbance and the need for alternatives or
compensation. Feedback forms/questionnaires were distributed towards the end of
PCM to get feedback from the meeting participants.
Pan-19-003 - 77 -
KeNHA
295 The process of consultations was carried out as follows:
a) Carrying out key informant interviews by using key informant guide;

b) Administration of ESIA questionnaires to key stakeholders including local
administration officers, service providers and lead agencies;
c) Holding a question and answer session with PCM participants;
d) Administration of ESIA feedback forms/questionnaires to PCM participants;
e) Administration of socio-economic questionnaires to the community.
a) Key Informant Interviews

296. Key informant interviews were carried out with the local administration
including Chiefs and Assistant Chiefs and other local leaders to obtain information
regarding the local community, their candid views of the local community’s perception
on the project.
b) ESIA Questionnaires
297. To obtain views of stakeholders, service providers and lead agencies the
consultant administered ESIA questionnaires. These questionnaires were
administered during consultation visits to the offices of key stakeholders including the
local administration, service providers and lead agencies. This is intended to obtain
stakeholder views regarding the proposed resettlement site project and the potential
environmental impacts of the project that require mitigation. The questionnaire
provides the opinion on whether they support the project or not.
c) Question and Answer Session with PCM Participants

298. In order to be able to interact with the community to get their views regarding
the proposed project, a question and answer session after conducting a presentation
during the PCM. The participants were given a chance to exhaustively ask any
questions regarding the resettlement site project, its positive and negative impacts
and the proposed mitigation measures.
d) Administration of ESIA Feedback Forms/Questionnaires

299. At the end of each PCM the study team administered ESIA feedback
form/questionnaire to all participants to obtain their views regarding the project.
300. The feedback forms were administered after conducting presentation on the
proposed project to ensure that participants are well informed about all aspects of the
proposed project including positive impacts, potential negative impacts and proposed
mitigation measures.
e) Administration of Socio-economic Questionnaires

301. In order to be able to evaluate baseline socio-economic aspects of the project
area community, socio-economic questionnaires were administered. The socio-
economic information collected includes:
Pan-19-003 - 78 -
KeNHA
• Characteristics of household members;

• Household income;
• Household expenditures;
• Housing characteristics
• Water and sanitation;
• Health facilities;
• Education institutions;
• Energy sources for cooking and lighting; and
• Social amenities
4.4 Impact Analysis and Development of Mitigation Measures
302. During the field assessment and consultations, potential environmental and
social impacts of the project were identified and appropriate mitigation measures
proposed. The evaluation considered:
• The nature of impact (whether it is positive or negative)

• The magnitude of the impact (whether it is localized or widespread)
• Whether the impacts are direct or indirect
• The significance of the impact (whether it can easily be mitigated or not)
• Whether the impact is reversible or not
• Duration of impact (short term, medium term or long term)
303. Project benefits and mitigation measures for the project impacts have been
provided following using the guidelines provided by the relevant laws and regulations.
Pan-19-003 - 79 -
KeNHA
5 PROJECT ALTERNATIVES
304. During the course of formulating the proposed project, several project alternatives
were considered to ensure that the best option of project development is adopted. The
consideration of alternatives is one of the more proactive approaches of environmental
assessment. This process serves to enhance the project design through an examination
of other feasible options instead of only focusing on the more defensive task of reducing
adverse impacts of a single design.
5.1 Analysis of Alternatives
305. Five alternatives were considered for the proposed Modogashe - Wajir (Al3) Road.
They include:
a) No upgrading of the existing road (‘no action’ option)

b) Analysis of alternative construction materials and technology
c) Solid waste management alternatives
d) Alternative mode of transportation
e) Upgrading existing road without any changes in route alignment
5.1.1 No Upgrading of the Existing Road (‘No Action’ Option)
306.
• In the analysis of ‘‘no action’ option” scenario, the following criteria is used; past, current
and future effect/ impacts of the road as currently existing, anticipated benefits of
proposed upgrading plus any other considerations are analysed. The selection of “no
action’ option” alternative would mean that no upgrade of the road is carried out and the
road is retained in its existing form. As such, this alternative is likely to have the greatest
implications on the socioeconomic environment of the area and surrounding
communities.
• Due to the proposed size of the NETIP development it is anticipated that it will open up
the North Eastern part of Kenya, improve connectivity to these areas, provide
opportunities for employment, benefits associated with the construction industry and
potentially significant business opportunities to spring up as a result of Upgrading of
Modogashe-Samatar-Wajir 157Km (A13) Road.
• The marginalised communities of the project area who face harsh weather, insecurity
and poverty would continue enduring the current living conditions.
• The low literacy levels would continue to persist since the area community would
continue with their current livelihood style without any incentive to promote education as
one way of improving livelihood.
• The community would miss the potential to open up the area for economic activities
including marketing of their livestock products.
• The community would miss improved service delivery. including access to proper health
care.
• The cost of travel and transportation of goods would remain unaffordable high
The above-mentioned benefits would be foregone if the proposed project is not undertaken.
5.1.2 Analysis of Alternative Construction Materials and Technology
307.
• The proposed road project will be constructed using modern, locally and internationally
accepted materials to achieve public health, safety, security and environmental
Pan-19-003 - 80 -
KeNHA
aesthetic requirements. Equipment that saves energy and water will be given priority
without compromising on cost or availability factors.
• The road surfaces sub-structure and road infrastructure will be made using locally
sourced materials that meet the Kenya Bureau of Standards requirements.
• On the alternative construction materials and technology; rainwater should be harvested
and be used in construction activities and supply to labour camps for flushing toilets and
other non-domestic activities.
• Asphalt mixers, crushers and other construction equipment and machinery will be
incorporated with pollution control devices like dust arrestors/precipitators, emission
control, noise abatement devices and desulfurization devices. The equipment and
vehicles should have highest levels of combustion efficiency, capability to use cleaner
fuels like biofuels and should have enhanced safety features.
5.1.3 Solid Waste Management Alternatives
308.
• A lot of solid waste will be generated from the proposed development. An integrated
solid waste management system is recommended.
• The proponent will give priority to reduction at source of the waste materials. This option
will demand a solid waste management awareness programme in the management and
the workers. Notices for proper waste management/handling should be posted at
strategic places for the sake of visitors to the workers’ camps. The contractor will be
required to engage a NEMA licensed waste management firm to collect both hazardous
and non-hazardous waste.
• Recycling, Reuse and compositing of the waste will be the second alternative in priority.
This will call for a source separation programme to be put in place especially in the
kitchen section. The recyclables will be sold to waste buyers within County.
5.1.4 Alternative mode of Transportation
309.
• There are no viable alternatives to this road that fulfils the functions of providing
relatively fast, cheap land transportation. Air, rail, and water transport are unlikely to
either complement or to substitute for roads or highways in this region. There is no
railway transport system close to the project area connecting the project area and no
water body that can be used as a mode of transportation in the project area. The only
possible means is air transport but, the cost is prohibitive and therefore cannot be used
as an alternative to road transport in this region.
5.1.5 Upgrading the Existing Road without any changes in Route Alignment
310.
• This option was highly favoured by property owners and business persons who are likely
to be affected by the proposed road either as a result of loss of property or loss of
business due to demolition of buildings along the road corridor or shift of business
activities to the new road corridor. The final road design has reduced the RoW from 60m
to 30m to reduce impact hence very few if any of the businesses will be relocated.
• However, it has two major disadvantages: (i) the cost and level of maintenance
commitment would not ensure that the entire corridor is always in good motorable
condition (ii) the cost of vehicle maintenance would limit usage and hence affect other
sectors of the economy.
Pan-19-003 - 81 -
KeNHA
6 ENVIRONMENTAL AND SOCIAL BASELINE
311. The baseline status of the project area with regards to the physical, biological and
social environment have been evaluated. The aspects assessed include topography,
climate, air quality, noise, soil, geology, hydrology, ecological features (including Flora
and Fauna), cultural heritage, socio-economic structures and social amenities (water,
sanitation, transportation, and communication)
6.1 Physical Environment
6.1.1 Location
312. The Modogashe – Wajir section of the NETIP project road is located in the North
Eastern part of Kenya traversing through Isiolo County, Garissa County and Wajir
County. The road starts at Modogashe (UTM 0518923, 00800801) and traverses the
market centres/Towns of Skanska, Habaswein, Lagdima, Kanchara, Samatar/Guticha,
Lagbogol, Borji, Leheley and terminates in Wajir town (UTM 0617643, 0193885
covering a total distance of 157km. It runs in the north east direction from Modogashe.
6.1.2 Topography
313. The project area is a featureless plain and lies between 150m and 460m above sea
level and along latitude 10 45’N and longitude 40o 4’E. Its altitude is 244m (801ft).
The plain rises gently from the south and east towards the north rising to 200m at
Buna and 460m at Bute and Gurar at the foothills of Ethiopian highlands. No
mountains or valleys were observed within the project environment. The project
area is prone to flooding during the rainy seasons which makes roads impassable.
There are seasonal swamps (Lorian near Habaswein and Borji near Lagbogol)
which together with drainage lines serve as grazing zones during dry seasons.
314. The elevation profile of the road varies from Modogashe-Wajir. Table 23 provides
an indication of how the topography changes.
Table 23: The Variation in Elevation Profile from Modogashe to Wajir

No Location Elevation (m) Change in Distance in Km
Elevation from
Modogashe
1 Modogashe-Skanska 268 to 219 Drop by 49m 24km
2 Skanska-Ewaso Ngiro River 219 to 206 Drop by 13m 20.2km
(Bridge)
3 Ewaso Ngiro River - 206 to 217 Rise by 11m 4.1km
Habaswein
4 Habaswein - Lagdima 217 - 243 Rise by 26m 7.8km
5 Lagdima to Kanchara 243 - 265 Rise by 22m 14.4km
6 Kanchara – 265 - 236 Drop by 29m 8.7km
Samatar/Guticha
7 Samatar/Guticha - Lagbogol 236 - 227 Drop by 9m 9.7km
8 Lagbogol - Borji 227 - 235 Rise by 8m 19.9km
9 Borji-Leheley 235 - 247 Rise by 12m 12.7km
10 Leheley - Wajir 247 - 263 Rise by 16m 14.5km
Pan-19-003 - 82 -
KeNHA
Plate 1: Photo showing the Flat Terrain of the Project Area
6.1.3 Climate
315. The three counties of Isiolo, Garissa and Wajir are considered as arid receiving
annual rainfall of between 150mm and 550mm.
Temperature
316. The first 42 km of the Modogashe-Wajir Road lies along the boundary of Isiolo and
Garissa Counties. The average minimum and maximum temperatures vary
between 27oC - 31oC.
317. The rest of the remaining segment of the road covering 115km lies within Wajir
County. The Maximum temperatures range between 31oC in July and 36oC in March
while minimum temperatures range between 21oC in July and 24oC in April.
Humidity
318. The relative humidity averages 60% in the morning and 55% in the afternoon. An
average of 9.5 hours of sunshine is received per day. The average monthly relative
humidity ranges from 56% in February to 68% in June.
Rainfall
319. The region has bimodal type of rainfall, the long rains (March – April) and the short
rains (October – December). The average annual rainfall varies between 200 –
400mm per annum. The Isiolo/Garissa area that covers the first 42km experiences
the higher range from 300-400mm of rainfall annually. However, this rainfall
reduces as you move Modogashe -Wajir where Wajir receives the least rainfall of
approx. 200mm per annum.
Pan-19-003 - 83 -
KeNHA
The erratic and unreliable rainfall cannot support crop farming which partly explains
the high food insecurity and food poverty levels. This is also the reason why the
communities in this region have adapted to nomadic pastoralism as their main
economic activity.
Winds
320. Strong winds are also experienced between April and August with the rest of the
months getting calm winds. The strong winds provide a huge potential for wind
generated energy. The average wind speeds along the project road varies between
5.5-6.5 m/s at 80m height. The wind speed increases minimally as one moves from
Modogashe-Wajir.
6.1.4 Geology and Soils
Geology
321. The area is primarily composed of Quaternary Sediments of the Pleistocene Age,
characterized by quartzitic sandstones and limestone sands. The deposits of recent
age are largely soils and alluvial accumulations.
Soils
322. Modogashe to Skanska and Habaswein to Lagdima area is characterized by
imperfectly drained, deep, brown, extremely firm slightly calcareous, slightly sodic
clay loam, abruptly underlying a thick topsoil of sealing sandy loam. The Lorian
Swamp area (Skanska to Habaswein) contains imperfectly drained, very deep, dark
grey, very firm, slightly calcareous, cracking clay, with a slightly to moderately saline
and sodic deeper subsoil. The area from Lagdima to Lagbogol is characterized by
imperfectly drained, moderately deep, brown, extremely firm, moderately
calcareous, moderately sodic clay loam with a top soil of sealing sandy loam. The
area from Lagbogol through Borji and Leheley to Wajir contains well drained, very
deep, dark red to dusky red, loose loamy sand to very friable sandy loam
6.1.5 Hydrology (Surface Water)
323. The project area has no permanent rivers however, there are a number of seasonal
laggas/streams, water pans, and earth dam, sand dams and which are the main
sources of water. These sources are replenished during the rainy season from
various tributaries. The project road crosses the seasonal overflow of North Ewaso
Ngiro River near Habaswein. Tana River runs on the Eastern side of the Garissa –
Modogashe road. Ewaso Ngiro River has its catchments area in the Aberdare
ranges and Mount Kenya flows between October – March draining into the Lorian
swamp.
6.1.5.1 Lorian Swamp
324. The Modogashe-Wajir Road crosses the Lorian swamp starting at Km 24 and ends
at Km 49 from Modogashe (coordinates 0545612, 0107476 - start point to
coordinates 0550600, 0109355 - end point) as one approaches Habaswein. The
project road covers an area of 25km by 60m. During construction a larger area may
be impacted by the project. This is equivalent to approx. 370 acres (including the
Pan-19-003 - 84 -
KeNHA
existing road carriage). The swamp receives water mainly from the North Ewaso
Ngiro River that originates from the Aberdare ranges. The river carries a lot of silt
which are deposited into the Lorian Swamp. The Swamp covers Isiolo, Garissa and
Wajir Counties.
Figure 8: Map of Ewaso Ng’iro River Basin and Lorian Swamp
325. The Lorian Swamp (~300m above the sea level) is located in between Isiolo,
Garissa and Wajir counties, spanning areas in the north of Garissa and the southern
reaches of Wajir. About 200 kilometers long and 25 kilometers at its widest point,
and mainly dependent on the subterranean feed from the Ewaso Ngiro river, the
Swamp covers an area of 2,310 km2. The Swamp is unprotected. As a result, due
to encroachment from different land uses and pressure from human settlements,
the area with permanent swamp moisture has shrunk from 150 km2 (in 1913) to
just 8 km2 in 1990. Located in an arid region, the Swamp and its contiguous areas
receive rainfall of between 200 and 300 mm annually. Potential evaporation rates
in the Swamp are as much as 2,600 mm per year, meaning that precipitation is
minimally effective in recharging the Swamp. As a result, the Swamp also benefits
from incoming recharge from ephemeral streams and wadis located towards the
southwest and the northeast.
326. The swamp is fed by the Ewaso Ng’iro North River and to a lesser degree by
seasonal streams or wadis from the southwest and northeast. The river drains a
considerable area in the eastern slopes of the Aberdares while other tributaries (the
Naro Moru, Burguret, the Liki, Nanyuki, and the Sirimon) drain some of the slopes
of Mount Kenya. Stream gauge data shows the river’s flow to be highly seasonal
with dry season flows accounting for a negligible portion of the annual flow (Mati
and others 2005). The highly variable rainfall also makes the inundation of the area
Pan-19-003 - 85 -
KeNHA
largely unpredictable as well (Hughes and Hughes 1992). In addition, high rates of
abstraction for upstream irrigation considerably reduce the amount of water flowing
within the river and reaching Lorian Swamp during the dry season (Gichuki and
others 1998).
327. After the Ewaso Ng’iro River becomes ephemeral, it is referred to as the Lagh Dera.
The ephemeral river floods irregularly. In the 1950’s the Lagh Dera was known to
flood the Lorian Swamps near Habaswein regularly. However, increased water
subtractions and changes in climate have caused a now irregular and less frequent
flooding of this area. Currently, the swamps have retreated many kilometers
upstream, decreasing the perennial swamp size from 150km2 to 39km2 (De Leeuw,
Said, Kifugo, Musyimi, Mutiga, & Peden, 2012). These flood-areas are commonly
referred to as the Lorian Swamps, even though the location has shifted. In most
years, the perennial Ewaso Ng’iro becomes ephemeral near the town of Merti.
When the rains are poor, the cessation of flow occurs even further upstream. This
leaves the downstream inhabitants and livestock largely dependent on groundwater
328. Acacia (Acacia elatior) woodlands line the course of the Ewaso Ng’iro River through
much of the floodplain (Hughes and Hughes 1992). Sedge and grass species
populate the swamped floodplains, providing grazing for the large faunal species
such as the buffalo (Syncerus caffer). The African elephant (Loxodonta africana),
Vervet monkey (Cercopithecus aethiops) and Nile crocodile (Crocodylus niloticus)
are also found in the wetland (Hughes and Hughes 1992). It is home to elands (Oryx
beisa), zebra, lions, crocodiles and is visited by many of the large savannah
mammals. Because of the dangers, cattle are not grazed far into the Swamp, but
they do make extensive use of the shallow waters, particularly in the dry season.
329. The vegetation of the swamp has three different zones; the upper cynodont
dactylon zone in briefly flooded areas, a zone with Echnochloa and setaria spp. On
more regularly inundated flood plains, and the third zone with aquatic grass and
sedge species in the lowest parts of the swamp. The perennial swamp has today
been replaced by the seasonal swamp vegetation. Surface water results in the
production of wetland vegetation characterized by tall and stiff perennial grasses
and reed beds at lower sites.
330. Highest wildlife densities occur in Laikipia and Matthews range (50 to 100km north
of Isiolo and about 200km from Lorian swamp), where protected areas and wildlife
conservancies are concentrated(see figure 9. Less wildlife occur in the eastern part
of the catchment, particulary in Lorian swamp and area directly surrounding it. No
elephants occur in the eastern part but Grevy’s zebra, Oryx and giraffe occur near
the swamp. The wildlife attracts tourists to the swamp and surrounding areas. The
tourism activity promotes local economy
331. The availability of water and vegetation on the swamp attaracts people and
livestock particularly in the dry season when swamp provides drinking water and
forage. Higher livestock (camel, cattle, sheeps and goats) densities prevail in the
upper and middle parts of the catchment. Herd composition varies from cattle
dominated herds in the upper and middle parts to camel dominated herds in the
lower catchment.
Pan-19-003 - 86 -
KeNHA
332. Livestock is not grazed far into the wetland but makes extensive use of the shallow
waters, particularly during the dry season. The wetland is infested with malaria
carrying mosquitoes as well as snails that carry the Schistosomiasis (bilharzia)
causing parasite (Hughes and Hughes 1992). Nonetheless, the wetland is not well
studied due to an inhospitable and inaccessible terrain as well as widespread
insecurity that is frequently manifested through ferocious inter-ethnic clashes (Boye
2011).
333. Population densities of 100 people per km2 and above prevail in the upper parts of
the catchment, while densities of less than 10 people per km2 occur in the arid zone
surrounding the swamp.
Figure 9: Average observed wildlife numbers 1990-2010 (there are no recent

data observations)
Pan-19-003 - 87 -
KeNHA
334. The Mean annual rainfall over the swamp area fluctuates between 180 – 250mm.
Several ephemeral rivers (Wadis) from the SW and NW supply the swamp with
additional water. The swamp is located in a 2310km2 depression, 196km long and
25km wide, yet the inundated area is smaller and expands and contracts with river
discharge and rainfall over the swamp. The vegetation of the swamp has three
different zones; the upper Cynodon dactylon zone in briefly flooded areas, a zone
with Echinochloa spp and Setaria spp on more regularly inundated flood plains and
the third zone with aquatic grass and sedge species in the lowest parts of the
swamp. The swamp acts as a source of water for humans, livestock and wildlife.
335. The vegetation also serves as an important range resource for the livestock and
wildlife within the area. The swamp serves as dry season grazing zone though these
impede road transport during the wet season as most sections on the swamp
become impassable.
336. The design Engineer has proposed the following measures:
• Provision of sufficient cross drainage structures to allow passage of water

across the embankment fill.
• It is proposed that in this section the embankment be of such height as to ensure
that the bottom of subgrade remains at least 1.0m above the highest water
table/ flood water level
337. The streams in the project area carries substantial silt charges that settle cross
drainage structures. The culverts built in areas where the project road crosses
the Lorian Swamp overflow and become heavily silted and clogged. The culvert
for the seasonal river (at km 100+500, River Laghbogol) poses danger to the
motorists when the river has flowing water. Water pans in Wajir are rain-fed
twice per year during the months of April and October. Pans around Laghbogol
are filled by flood waters from the Ethiopian highlands.
6.1.5.2 Borji Swamp
338. Borji swamp which is a seasonal swamp exist in the South at Laghbogol area.
The swamp stretches 0.44km across where the road passes. The project road
covers an area of 0.44km by 60m of the swamp area. This translates to approx.
6.5acres of swamp land. However, the project will impact a larger area during
construction.
The swamp is seasonal and little literature exist about it. The Biodivesiry
assessement to be done before civil works will develop a A Biodiversity
Management Plan
339. Refer to Map 2 below Showing location of Lorian and Borji Swamps.
6.1.5.3 Key Physical Sensitivities
340. The project road from Modogashe-Wajir has some key physical sensitivities that
will need to be safeguarded during project implementation. Table 24 gives a list
of the sensitive physical features along the Modogashe-Wajir Road
Pan-19-003 - 88 -
KeNHA
Table 24: Summary of Road Corridor Physical Baseline Sensitivities

No Site Location Distance from Sensitive Features
Modogashe
Town (Km)
1 Modogashe 0 a) Active Town centre with significant human
Township population going about their livelihood activities
b) Galana River passes next to Modogashe Town
(eastern side) – Dry river bed with wet sand
2 Skanska 24 Centre with human settlement – sparsely populated
3 Lorian Swamp 26.5 – 46.5 a) Lorian Swamp – Dry during assessment but
(Flood Plain) floods during wet season which occurs
between March-May for long rains and
October-December during short rains
b) Holds a variety of wildlife due better vegetation
cover during the dry season. These include
Giraffes, Hyenas, Antelopes, Gazelles,
Gerenuks, Ostriches, Lions, Lesser kudus,
Cheetahs, Warthogs, Dik diks, zebras and
Guinea Fowls among others
4 Ewaso Ngiro 44.7 Bridge with dry Ewaso Ngiro river bed but carries
River water during wet the season which occurs between
March-May for long rains and October-December
during short rains
5 Habaswein 48 Active Township with modern commercial and
Township residential houses occupying both sides of the toad
6 Lagdima Centre 55.5 Small Centre with few residential houses
7 Lagdima River 57.1 Dry river bed but with large Acacia Trees
providing shade to travelers
8 Lagdima Flood 66.9 Lagdima flood plain – dry during the assessment
Plain
9 Kanchara Centre 70 Settlement Centre with residential and commercial
houses
10 Samatar/Guticha 79 Settlement Centre with residential and commercial
Centre houses
11 Lagbhogal Drift 90.6 Eroded drift adjacent to Mathenge tree. Soils
appear loamy clay. Area has scattered vegetation
12 Lagbhogal 95.3 Settlement Centre with residential and commercial
Centre houses
13 Lagbhogal River 96.6 River bed with drift, River wetland area is 350m
and Drift wide
14 Borji Swamp 101 Was dry at the time of the assessment, however
becomes swampy during the rainy season which
occurs between March-May for long rains and
October-December during short rains
15 Borji Centre 115.2 Settlement Centre with residential and commercial
houses
16 Leheley Centre 132 Settlement Centre with residential and commercial
houses
17 Wajir Town Wajir County headquarters with a population of
approx. 45,700 people. Has modern commercial
and residential houses.
Pan-19-003 - 89 -
KeNHA
The biophysical features are provided in Annex 4.
Map 2: Map Showing Lorian and Borji Swamps
Pan-19-003 - 90 -
KeNHA
6.1.6 Air Quality
315. The Design Engineer carried out baseline evaluation of the air quality and
reported in the Draft ESIA Reports that the project area is mainly a rural country
and therefore air quality along the project corridor is influenced by emissions from
vehicular sources and particulate matter from dust. The proposed alignment covers
unpaved section which are made of all weather and dry weather roads. Currently
the populations are concentrated at the urban centres which include Modogashe,
Skanska, Habaswein, Kanchara, Guticha, Samatar Laghbogol, Borji, Leheley and
Wajir. The centres also have a slightly higher concentration of vehicular emissions
and particulate matter because of the high number of vehicles.
316. This is especially more pronounced in Habaswein, Modogashe and Wajir. The
rest of the project area has a relatively low concentration of both vehicles and there
is reliance on carts that are powered by animals such as camels. The main air
quality pollutants are components of emissions, principally carbon dioxide (CO2),
carbon monoxide (CO), Nitrogen Oxides (NOx), Sulphur Oxides (SOx) and
Particulate Matter (PM2.5, PM5 and PM10). There are also hydrocarbons (HxCx),
fuel aerosols and soot. The most important air quality receptors are sensitive
institutions along the project road. These institutions include learning centres,
health facilities and urban centres, the latter being sites of concentrated
settlements. No measurements for baseline air quality have been carried out but it
is recommended that the contractor carries out these measurements before
commencement of the construction activities.
6.1.7 Noise and Vibrations
317. The Design Engineer also carried out noise and vibration evaluation and
reported in the Draft ESIA Reports that the current ambient noise and vibration
conditions within the project corridor can be described as low except for urban
centres where typical urban noise is experienced and the paved sections where
vehicular noise is dominant. Throughout the project area the source of noise that
was evident was from the vehicles used as means of transport.
318. The current ambient noise and vibration conditions within the project corridor
can be described as low except for urban centre i.e. Wajir town where typical urban
noise is experienced and the paved sections where vehicular noise is dominant.
Throughout the project area the source of noise that was evident was from the
vehicles used as means of transport. No measurements for noise and vibration
have been carried out but it is recommended that the contractor carries out these
baseline measurements before commencement of the construction activities.
6.1.8 Water Quality
319. The project area is water scarce and it was envisaged that construction water
will have to be obtained from subterranean sources, specifically boreholes.
Therefore, eight (8) samples were obtained from the existing boreholes and
relevant lab tests carried out to determine their suitability for use in construction.
The results of the laboratory analysis are presented in Table 25 below.
Pan-19-003 - 91 -
KeNHA
Table 25: Physical/Chemical Water Analysis Report
Shallow
Wajir Shallow Well

3rd
Lagh Bogol South

Borehole No. 1 at
Bogol
Bogol
Water
Borehole No. 2
Fatah
South Water
Edition (2007)
Lagh Bogol
km 10+300
Pan at km
Requirements
11+000
Pan- No. 2
(Privately
Borehole
Parameters Unit
North-
North-
Leheley
KEBS
Lagh
Lagh
Well
Al
pH pH scale 6.5-8.5 9.48 8.48 8.73 8.84 8.95 8.07 8.59
Colour Hazen <15 20 ND 25 5.0 5.0 ND ND
Turbidity N.T.U. <5.0 961 0.46 625 0.38 1.11 0.07 0.18
mg/L
Alkalinity CaCO <500 182 350 290 262 620 260 230
Conductivity 3 713.
(250C) uS/cm <2000 537 12,066 00 19,526 2,098 3,941 1,666
Iron mg/L Fe <0.3 9.0 ND 6.8 0.05 0.25 0.15 0.05
Calcium mg/L CO3 <150 22 620 40 1040 284 460 320
mg/L <100
Magnesium 18 600 38 840 26 260 80
MgCO
3mg/L 1,220. 78.0
Total hardness <300 40 0 0 1,880.00 310.00 720.00 400
CaCO
3 11.9 3,169. 27.9
Chloride mg/L Cl- <250 96 02 9 3,948.78 329.90 899.72 309.90
Fluoride mg/L F- <1.5 0.3 2.00 1.25 4.00 2.75 1.40 1.00
mg/ 0.20 1.45
Nitrates <50 68 8.36 2 14.30 2.33 44.00 63.36
L
NO3
mg/L 2,297. 321.
Sulphate - <400 ND 01 40 1771.32 209.97 258.55 108.23
SO4-
2 0.64
Manganese mg/L Mn <0.5 8 0.72 0.46 1.20 1.14 1.15 0.048
Total 332. 7,480. 442. 1,210,612. 1,300. 2,443. 1,032.

mg/L Ions <1000 94 92 06 00 76 42 42
dissolved
solids 19.3
Carbon dioxide mg/L CO2 N/S ND 42.24 6 31.68 ND 49.28 8.8
320. Although the water sources above are all operational, the test results show
that they require to be treated to make them suitable for use in construction.
6.2 Biological Environment (Flora and Fauna)
6.2.1 Flora
321. In any given area the natural and cultivated vegetation depends on physical
factors such as climate, soil and topography, as well as human activities. The
project area does not have gazetted forests. Generally, the project environment has
scanty vegetation which is characterized by drought resistant shrubs and
grasslands. However, due to the prevailing arid condition, the most dominant tree
species are Acacia spp. which were common along the road and are important for
shade both to humans, livestock and wildlife and should therefore be jealously
Pan-19-003 - 92 -
KeNHA
protected. Other species include Balanites spp. and Commiphora spp, Panicum
spp, Cordia sinensis, Cordia ovalis (shrubs which bear fruits and large leaves which
animals browse on during rainy season and in dry season goats feed on fallen
leaves), Azadiracta indica (neem) and Eragrostis spp. Concentration of vegetation
appears around the dry river beds.
322. Certain areas of the project around Leheley and towards Wajir town have high
canopy trees which also act as habitat for avifauna within the project area. There is
evidence of desertification in some areas located close to settlements along the
road corridor where overgrazing has occurred. The invasive species Prosopis
Juliflora (Mathenge) was noted to occur in the laggas along the road from
Modogashe town to Habaswein. It also occurs in River Lagbogol area.
323. The main uses of the vegetation besides grazing is production of gum and
resin, charcoal, firewood, building posts, barks, honey, wood carvings and wild
fruits. Firewood is harvested for individual household use and for sale to households
living around settlements and food kiosks. According to Wajir Ecosystem
Conservator, endangered trees in the area include: Acacia spp for burning of
charcoal; Delonix elata used as paint and binding properties seen in cement;
Cormiphora holsiana and C. myrrh; Cordia sinensis and C. ovalis. Table 26
provides a list of flora identified along the project road.
Table 26: List of Flora identified along the Road Corridor

No Road Common/local Scientific Status as per IUCN Status as per
Corridor name name Red List Wildlife
Conservation
and
Management
Act (Sixth
Schedule)
1 Lehley, • English Parkinsoni This taxon has not Not listed
Borji area “Jerusalem a Aculeata yet been assessed
Thorn” for the IUCN Red
List, but is in the
Catalogue of Life.
2 Lehley, Somali Prosopis This taxon has not Listed as invasive
Borji area “Mathenge” juliflora yet been assessed species
for the IUCN Red
List, but is in the
Catalogue of Life.
3 Samatar • Somali “Bebeh” Boswellia This taxon has not Not listed
area • Boran “Bebek” Microphylla yet been assessed
for the IUCN Red
List, but is in the
Catalogue of Life.
4 Lehley, • Gum Myrr Tree Commiphor This taxon has not Not listed
Borji area • Boran “Khumbi” a Myrrha yet been assessed
• Somali “Mamal” for the IUCN Red
List, but is in the
Catalogue of Life.
5 Modogas • Boran “Kumude” Lannea This taxon has not Not listed
he area • Somali Alata yet been assessed
“Kumudhe” for the IUCN Red
Pan-19-003 - 93 -
KeNHA

Conservation
and
Management
Act (Sixth
Schedule)
List, but is in the
Catalogue of Life.
6 Habaswe Acacia Acacia This taxon has not Not listed

in area • Somali paolii yet been assessed
“Gammur” for the IUCN Red
• Boran” List, and also is not in
Chachane” the Catalogue of Life.
7 Habaswe • Somali “Dainjo” Commiphor This taxon has not Not listed
in area • Boran “Diraa a Roatrata yet been assessed
for the IUCN Red
List, but is in the
Catalogue of Life
8 Habaswe • Swahili Grewia Status: Data Deficient Not listed
in area “Mkamasi” Tenax ver 2.3(needs
• Somali updating)
“Amasha”
• Boran “Deeka”
9 Samatar • Swahili Grewia This taxon has not Not listed
area “Mkorobosho” Villosa yet been assessed
• Boran “Ogumdi” for the IUCN Red
• Somali List, but is in the
“Kobbish” Catalogue of Life:
10 Kanchara • English “White Acacia This taxon has not Not listed
, Thorn Acacia” Seyal yet been assessed
Lagdima • Swahili for the IUCN Red
area “Mgunga” List, but is in the
• Boran “Waachu Catalogue of Life:
Adi”
• Somali “Fulay)
11 Lehley, • English Acacia This taxon has not Not listed
Wajir “Umbrella Thorn Tortilis yet been assessed
Town Tree” for the IUCN Red
area • Swahili List, but is in the
“Mgunga” Catalogue of Life.
• Boran “Dadach”
• Somali “Abaa”
12 Samatar • English “Long Cassia Status: Data Deficient Not listed
area Pod Cassia” Abbreviata ver 2.3 (needs
Swahili updating)
“Mbaraka”
• Somali
“Domaderi”
• Boran “Rabiya”
13 Samatar • English “Sand Cordia This taxon has not Not listed
area Paper Tree” Monoica yet been assessed
• Swahili “Msasa” for the IUCN Red
• Somali “Marer List, but is in the
Gob” Catalogue of Life
• Boran “Qotte”
Pan-19-003 - 94 -
KeNHA

Conservation
and
Management
Act (Sixth
Schedule)
15 Laghbog • Somali “Labi” Delonix Status: Least Not listed
ol area • Boran “Sukella” Elata Concern ver 3.1
Population trend:
decreasing
16 Lehley • Boran “Jirime” Dicrostach This taxon has not Not listed
Wajir • Somali “Ditar” ys Cinerea yet been assessed
Town for the IUCN Red
area List, but is in the
Catalogue of Life.
17 Modogas • Boran “Bariyub” Maerua This taxon has not Not listed
he area • Somali Decumben yet been assessed
“Abarmog” s for the IUCN Red
List, but is in the
Catalogue of Life
18 Habaswe • Swahili “Mkitaji” Omocarpu This taxon has not Not listed
in area • Boran “Butiye” m Kirkii yet been assessed
• Somali “Lebi for the IUCN Red
Sauwer” List, but is in the
Catalogue of Life
19 Habaswe • Swahili “Mtanga” Spirostach This taxon has not Not listed
in area • Somali “Haiyah ys yet been assessed
Badad” venenifera for the IUCN Red
• Boran “Siricho” List, but is in the
Catalogue of Life
20 Habaswe • English “African Sterculia This taxon has not Not listed
in area Star Chestnut” Africana yet been assessed
• Swahili “Mgoza” for the IUCN Red
• Somali “Danrab” List, but is in the
Catalogue of Life
21 Modogas • English “Jujube” Ziziphus
he area • Swahili mauritiana
“Mkunazi”
• Somali “Gup”
• Boran
“Quaqura”
Pan-19-003 - 95 -
KeNHA
6.2.2 Environmentally Sensitive Habitats
6.2.2.1 Source of Energy
324. As per the final design report (2018), 78.8 percent of the population in the
three counties use firewood as a source of energy for cooking, with 18.2 using
charcoal. There is electricity in few areas including Garissa Township, Ijara,
Dadaab, Bura East and Modogashe. Only 0.7 percent of the population has access
to electricity. Solar systems have been installed in health facilities, schools and
watering Over 70 percent of households in Isiolo County rely on firewood as the
main source of cooking fuel.
6.2.2.2 Other Forest Resources
325. The main forest products exploited by the community include gum and resin,
building and fencing posts, barks, honey, wood carvings, medicine and wild fruits.
326. Over dependency on wood as main source of energy has led to over
exploitation of indigenous trees which take long to mature. There is need to explore
the use of modern energy sources.
6.2.2.3 Laggas
327. Laggas are habitats of environmental significance in the project area. They
harbour riverine vegetation comprising diverse plant species and also serve as
habitats for various fauna species.
328. Moreover, the local community uses trees that grow on the edge of laggas as
shade, feed for livestock (tree pods) and human food (ground seed).
Plate 2: Lagboghol Lagga – February 2019
Pan-19-003 - 96 -
KeNHA
The trees that grow along the lagga assist in holding the soil on the edge of the
lagga thereby controlling the expansion of the lagga and associated soil erosion.
Thus, disturbance to a lagga lead to environmental degradation and loss of
biodiversity. It may also lead to change in river flow, which may cause damage to
an existing road.
6.2.3 Fauna
329. The project area is rich in wild life dominated by Topi (Damaliscus lunatus
jimela) and the reticulated giraffe. The wildlife densities are highest for dik
(Madoqua sp.) and Grant’s gazelle (Gazela granti). The rest of the herbivore
community comprises potential prey species for the wild dogs such as gerenuk,
warthog (Phacochoerus aethiopicus), bush pig (Potamochoerus larvatus), lesser
kudu, common duiker (Sylvicapra grimmia) and possibly species such as buffalo
(Syncerus caffer), Burchell’s zebra, hirola, eland (Taurotragus oryx) and oryx (Oryx
beisa). Common carnivores include cheetah (Acinonyx jubantus), black-backed
jackal (Canis mesomelas), caracal (Felis caracal) and spotted hyena (Crocuta
crocuta). Others include Ostrich, Monkeys and numerous bird species. The wildlife
moves freely across the project area. Most of the wildlife are resident in the project
area. The project road does not have a clearly defined migration corridor.
330. Majority of the wildlife along the road corridor are concentrated in the natural
ecosystem of Lorian swamp area (Skanska Km 25 – Habaswein km 50) due to the
more favourable vegetation cover and availability of water for a longer period. The
other areas have fewer animals due to lack of water and forage. The local
population in the project area co-exist peacefully with the wildlife. However, there
are rare reported cases of human-wildlife conflicts. Whereas the wildlife are
distributed along the road corridor, majority are found in Habaswein area where
Ewaso Ngiro River and the Lorian Swamp provide better resources due to better
water recharge. The grevy zebra (Equus Greyvi) which is the most threatened of
the three zebra species is unique to Garissa area. It is in competition for resources
with other grazers and livestock lowering their survival rate.
331. There are no identified protected areas within the county hence conservation
and management of the wildlife has been a challenge. The lack of protected wildlife
conservancies has resulted in increased cases of human wildlife conflicts exhibited
through snake bites, attacks of livestock by hyenas and lions. The project area is
also rich in avifauna visible from the heavily nested acacia trees bordering the road.
The areas noted to contain a lot of bird nests are:
• Leheley and Guticha areas in Wajir County

• Skanska area in Isiolo and Garissa Counties
315. Most of the wildlife in the area are residential. Most of the wildlife listed in
Table 27 are threatened and require concerted efforts by KWS and the community
to ensure that opening up of the area by the road project does not put the wildlife
into any more danger.
Pan-19-003 - 97 -
KeNHA
Plate 3: Giraffes near Leheley – February 2019
Table 27: List of Fauna identified along the Road Corridor

No Road Common/ Scientific name Status under Status under
Corridor local IUCN Red List Wildlife
name Conservation and
Management Act
(Sixth Schedule)
1 Throughout Topi Damaliscus lunatus Threatened Not listed
Road jimela Species 2017
Corridor
2 Throughout Reticulted Giraffa Threatened Not listed
Road Giraffe camelopardalis Species 2018
Corridor reticulata
3 Throughout Dik Dik Madoqua kirkii Threatened Not listed
Road Species 2016
Corridor
4 Throuout Grant’s Nanger granti Threatened Not listed
Road Gazelle Species 2016
Corridor
5 Throuout Gerenuk Litocranius walleri, Threatened Not listed
Road Species 2016
Corridor
6 Throuout Warthog Phacochoerus Threatened Not listed
Road aethiopicus Species 2016
Corridor
7 Throughout Bush Pig Potamochoerus Threatened Not listed
Road larvatus Species 2016
Corridor
8 Throughout Lesser Tragelaphus imberbis Threatened Listed as Vulnerable
Road Kudu Species 2016
Corridor
Pan-19-003 - 98 -
KeNHA

Corridor local IUCN Red List Wildlife
name Conservation and
Management Act
(Sixth Schedule)
9 Throughout Common Sylvicapra grimmia Threatened Not listed
Road Duiker Species 2016
Corridor
10 Throughout African Syncerus caffer Threatened Not listed
Road Buffalo Species 2008
Corridor
11 Throughout Burchell’s Equus quagga Threatened. Not listed
Road Zebra burchellii Species 2016
Corridor
12 Throughout Hirola Beatragus hunteri. Threatened Listed as critically
Road Species 2017 endangered
Corridor
13 Throughout Common Taurotragus oryx Threatened Not listed
Road Eland Species 2016
Corridor
14 Throughout Cheetah Acinonyx jubantus Threatened Listed as endangered
Road Species 2015
Corridor
15 Throughout black- Canis Mesomelas Threatened Not listed
Road backed Species 2014
Corridor jackal
16 Throughout Caracal Felis Caral Threatened Not listed
Road Species 2016
Corridor
17 Throughout Spotted Crocuta crocuta In Catalogue of Listed as vulnerable
Road Hyena Life
Corridor
18 Throughout Common Struthio camelus Threatened Listed as protected
Road Ostrich Species 2018 species
Corridor
19 Throughout Marabou Leptoptilos In the Not listed
Road Stork Crumeniferus Catalogue of
Corridor life
20 Throughout Grevy’s Equus Greyvi Threatened Listed as endangered
Road Zebra Species 2016
Corridor
21 Throughout Lions Panthera Leo Threatened Listed as endangered
Road Species 2016
Corridor
22 Throughout Avifauna Various
Road
Corridor
Pan-19-003 - 99 -
KeNHA
Map 3: Wildlife Conservation Areas
Wajir
Modogashe
Project Road
Source: KWS Strategic Plan 2012 - 2017

316. The nearest conservation area is Rahole National Park to the South of
Modogashe Township. The area where wildlife is found within the project area of
influence is not a designated conservation area.
6.2.4 Wildlife Dispersal Areas
317. Kernel densities were used by KWS to carry out studies on the wildlife habitat
and dispersal areas. The project road falls within the Greater Ewaso Ngiro Dispersal
Area. The wildlife that were studied and whose movement and dispersal areas
have been mapped in this ecosystem includes the Grevy’s zebra
Pan-19-003 - 100 -
KeNHA
6.2.4.1 The Grevy’s Zebra

Map 4: Habitat and Dispersal Area for Grevy’s Zebra
Source: Wildlife Migratory Corridors and Dispersal Areas, 2017 - KWS
315. Grevy’s zebra has undergone one of the most substantial reductions in range,
of any species, since wildlife distribution records began (DRSRS database, 1978-
2011; Kingdon, 1997). Kenya’s Grevy’s zebra population was confined largely to
the greater Ewaso ecosystem, with a small group observed near Garissa town and
another south of Lamu on the north coast. During the 1990s, the range of the
species within the Ewaso ecosystem began to shrink. The important area (green)
as can be seen on Map 4 is confined to a small radius of about 5km and the
dispersal area is a ring of a distance of approx. 3-4km from the important area.
Pan-19-003 - 101 -
KeNHA
6.2.4.2 The Oryx

316. The Oryx were widely distributed across the greater Ewaso ecosystem. Now,
core areas for oryx are in the north-eastern parts of the ecosystem and towards
Mandera. Small herds also occur in Laikipia (on the Marmar, Colcheccio, and Solio
ranches.)
Map 5: Habitat and Dispersal Area for the Oryx
Source: Wildlife Migratory Corridors and Dispersal Areas, 2017 - KWS
Similarly, the Oryx does not disperse very far from the habitat and important areas.
Pan-19-003 - 102 -
KeNHA
6.2.4.3 The Giraffe
Map 6: Habitat and Dispersal Area for the Giraffe
Source: Wildlife Migratory Corridors and Dispersal Areas, 2017 – KWS
6.2.5 Avifauna
317. Despite the harsh climatic conditions, the project area has a variety of
avifauna. These include Marabou Stork, Guinea Fowls, Ostrich, Weaver Birds,
Superb Starling, Black Headed Heron, Great Egret and Sacred Ibis. Whereas a
large number of Avifauna are found within the Lorian Swamp area where there is
Pan-19-003 - 103 -
KeNHA
abundance of vegetation, the Marabou Stork has a significant presence in Wajir

Town frequently visiting KWS Offices to drink water here. KWS Officers elaborated
that due to the harsh climatic conditions they have decided to be providing water
these birds at the office ground where they have placed special water troughs. Refer
to Table 28 for Avifauna.
Plate 4: Marabou Stork at KWS Office Ground – February2019
Plate 5: Superb Starling at Borji Centre – February2019
Pan-19-003 - 104 -
KeNHA
Table 28: List of Avifauna identified along the Road Corridor

Corridor local name IUCN Red List Wildlife
Conservation and
Management Act
(Sixth Schedule)
1 Wajir Town Marabou Leptoptilus Catalogue of Not listed
and Stork crumeniferus Life
Skanska
2 Borji Superb Lamprotornis Threatened Not listed
Starling superbus Species 2017
3 Lorian Ostrich Struthio camelus Threatened Protected
Swamp Species 2018
4 Lorian Helmeted Numida Catalogue of Not listed
Swamp Guinea Fowl meleagris Life
5 Throuot the Village Ploceus Threatened Not listed
corridor Weaver Bird cucullatus Species 2018
6 Skanska Sacred Ibis Threskiornis Threatened Not listed
aethiopicus Species 2018
7 Skanska Black- Ardea Threatened Not listed
headed melanocephala Species 2016
Heron
8 Skanska Great Egret Ardea alba Threatened Protected
Species 2016
6.3 Socio- economic Environment
318. Northern Kenya displays many of the characteristics of remote rural areas
caught in chronic poverty traps, which face multiple and interlocking forms of
disadvantage. Isolation, insecurity, weak economic integration, limited political
leverage, and a challenging natural environment combine to produce high levels of
risk and vulnerability. The highest rates of poverty are observed among those who
are no longer directly involved in pastoralism, particularly those without livestock
who depend on casual labour or petty trade in towns. Garissa, Isiolo and Wajir
Counties are classified as arid and semi-arid lands of Kenya where the rainfall
ranges between 200 – 600mm per year. Since majority of the population rely on
livestock as the main source of income, majority of the population is in the rural
areas.
319. Due to the harsh climatic conditions this scenario is slowly changing since
there is a gradual movement of people from rural to urban centres in search of
opportunities. The construction of the proposed road is expected to accelerate in
migration of people from outside the project counties and also accelerate rural
urban migration.
6.3.1 Administration
320. The project road traverses three counties of Garissa, Isiolo and Wajir, with the
largest part (115km) occurring in Wajir County. The other part of the road segment
(42km) lies at the boundary between Garissa and Isiolo Counties. The road passes
through five Sub Counties of Lagdera in Garissa, Garbatula in Isiolo and Wajir
South, West and East in Wajir County. The total number of locations are 21 as
shown in Table 29. Refer to Maps 1, 7 and 8.
Pan-19-003 - 105 -
KeNHA
Map 7: Sub Counties in Wajir County
Wajir
WajirTown
Town
Habaswein
Source: Wajir County CIDP 2018 – 2022
321. The road passes along the south eastern boundary of Isiolo County (Garbatula
Sub County) and the northern boundary of Garissa County (Lagdera Sub County)
322. The towns traversed by the road corridor are shown in Table 25 and Map 1.
Pan-19-003 - 106 -
KeNHA
Map 8: Subcounties in Garissa County
Habaswein
Modogashe
Source: Garissa County CIDP 2018 – 2022
Pan-19-003 - 107 -
KeNHA
Table 29: Project Area Administration

# County Sub County Location Major Towns #
1 Isiolo Garbatulla Modogashe Modogashe 1

Modogashe
2 Garissa Lagdera Ilan/Skanska Skanska 2
Garufa
Wajir West Ademasajida 3
Habaswein
Wajir South Habaswein Central
Wajir West/South Lagdima Lagdima 4
Wajir West/South Kanchara Kanchara 5
Wajir West/South Guticha Guticha 6
Wajir West/South Samatar Samatar 7
Wajir West Lagbogol West
Lagbogol 8
Wajir South Lagbogol South
3 Wajir Wajir West Borji
Borji 9
Wajir South Bus Bus
Wajir West Kukaaley
Leheley 10
Wajir South Leheley
Wajir East Furaha
Alimahu
South C WajirTown 11
Hodhan
Township
Source: ESIA Study Socio-economic Survey, 2019
6.3.2 Population Size and Density
6.3.2.1 Population Size for Isiolo County and Respective Subcounties
323. The population tally in the county according to the Kenya National Bureau of
Statistics report of 2009 is 143,294 with a population density of 6 people per km2.
51% of the population is male while 49% is female. Refer to Table 30.
324. Garbatula County where the project road passes, has a population density of
4 people per km2 which is lower than that of the whole county at 6 people per km2.
Table 30: Isiolo County and Subcounty Population

Population Population Population
Sub- County Area (Km2) 2009 Density 2018 Density 2020 Density
(Km2) Projection (Km2) Projection (Km2)
Isiolo 3,269 79,835 24 88,427 27 90,130 28
Garbatula 9,819 43,118 4 47,759 5 48,678 5
Merti 12,612 20,341 2 22,530 2 22,964 2

Total 25,700 143,294 6 158,716 6 161,773 6
Source: Isiolo County CIDP 2018 – 2022
Pan-19-003 - 108 -
KeNHA
6.3.2.2 Population Size for Garissa County and Respective Subcounties
325. According to the 2009 Kenya Population and Housing Census the population
is 623,060 with a male population of 334,939, a female population of 288,121 and
a population density of 14 people per Km2. Refer to Table 31.
326. Lagdera Subcounty has a population density of 14 people per km2 while
Garissa Township Subcounty has a population density of 173 people per km2. The
County population density stands at 14 people per km2.Modogashe Town lies in
Lagdera Subcounty, one of the 6 sub Counties in Garissa County.
Table 31: Garissa County and Sub County Population

2009 (Census) 2018 (Projections) 2020 (Projection)
Sub-county Area (Km ) 2 )Population Density Population Density ns)
Populatio Density
2
(Km ) (Km )2 n (Km2)
Garissa 2,539
116,953 173 163,734 242 178,938
265
Township
Balambala 3,049 73,109 15 102,353 34 111,857
37
Lagdera 6,519 92,636 14 129,690 20 141,733 22
Dadaab 6,781 152,487 22 213,482 31 233,305 34
Fafi 15,469 95,212 6 133,297 9 145,674 9
Ijara 6,710 92,663 9 129,728 19 141,774 21
Total 41,067 623,060 14 872,284 20 953,282 22
Source: Garissa County CIDP 2018 - 2022
6.3.2.3 Population Size for Wajir County and Respective Subcounties
327. According to the 2009 Kenya Population and Housing Census the population
was 661,941 with a population density of 12 people per Km2 and an annual growth
rate of 3.7%. Age Distribution was;0-14 years 51.8% with the economically
productive age of 15-64 years standing at 45.9% with those aged above 65 years
accounting for 2.2% of the total population. The projected population for 2018 is
852,963 with density of 15 people per km2. The main livelihood source is
pastoralism. Refer to Table 32.
328. Wajir East Sub County has the highest population density of 28 people per
Km2. Although Wajir South has a higher population than Wajir East, Wajir South
has a much larger area (about 5 times in size) Wajir Town which has a high density
of people is located within Wajir East Subcounty.
Table 32: Wajir County and Sub County Population

Area in 2009 (Census) 2018 (Projections) 2020 (Projections)
Subcounty Km2 Density Density Density
Population 2 Population 2 Population
(Km ) (Km ) (Km2)
Wajir South 21,596 130,070 6 167,605 8 184,315 9
Wajir North 8,555 135,505 16 174,609 20 192,018 22
Wajir East 4,008 112,572 28 149,729 37 164,657 41
Tarbaj 9,439 111,846 12 148,763 16 163,595 17
Wajir West 9,011 91,143 9 121,227 12 133,313 13
Pan-19-003 - 109 -
KeNHA
Area in 2009 (Census) 2018 (Projections) 2020 (Projections)

Subcounty Km2 Density Density Density
Population 2 Population 2 Population
(Km ) (Km ) (Km2)
Eldas 4,078 80,805 27 107,476 35 118,191 39
Total 56,687 661,941 12 852,963 15 937,997 17
Source: Wajir County CIDP 2018 – 2022
6.3.2.4 Population Sizes for Urban Centres
329. The project road from Modogashe-Wajir covers a total distance of 157km.
Majority of the population live in settlements located in 10 towns/centres along the
project road. These centres have a significantly higher population than the areas in
between. The areas in between are very sparsely populated with hardly any
homesteads that could be seen along the road. The main towns/centres located
along the road corridor are provided in Table 33.
330. The urban centres along the road corridor are growing rapidly. There are
also smaller centres that serve as livestock markets and watering points in
the region. The completion of the road project is likely to spur the growth of
these centres and develop them into major towns and cities.
Table 33: Centres along the Modogashe-Wajir Road

No Name of Type of Centre Approx. Chainage Population
Town/Centre Distance from (Estimates)
Modogashe
1 Modogashe Township 0 km (Start of road 30,491 (projection for
segment) 2018 from 2009
Census)
2 Skanska Small centre 24 km Less than 500
3 Habaswein Township 48 km 10,953 (projection for
2018 from 2009
Census)
4 Lagdima Small centre 55.5 km Less than 500
5 Kanchara Medium size 70 km Between 1,000-2,000
centre
6 Samatar/Guticha Medium size 79 km Between 1,000-2,000
centre
7 Laghbogol Medium size 95 km Between 1,000-2,000
centre
8 Borji Small Centre 114.5 km Less than 1,000
9 Leheley Medium size 136 km Between 1,000-2,000
centre
10 Wajir Town Major Town 157 km (End of the 106,902 (projection for
(County road segment) 2018 from 2009
Headquarters) Census)
331. It is also noted that the service institutions like schools, hospitals etc. are
located in these major centres. Since the project has the potential to generate
impacts affecting resources and human populations, a much higher threshold of
mitigations will be required to minimize impacts/inconveniences in the populated
areas of the road corridor.
Pan-19-003 - 110 -
KeNHA
332. The towns/centres mentioned in Table 33 above are also the major areas
where significant displacements and resettlement due to the road project are
expected to occur.
Plate 6: Aerial View of Habaswein Township along the Project

Road
Plate 7: Aerial View of Leheley Centre
6.3.3 Public Health
333. Majority of the population in the 3 counties live in the rural area (Wajir- 75%,
Garissa-76% and Isiolo -58%) where health facilities are scarce and far between.
Pan-19-003 - 111 -
KeNHA
Challenges being experienced in the health sector include inadequate health

workers, long distance of travel to health facilities and low prevalence of
contraceptive use. According to KNBS (2014), the region has a total of 37 hospitals
with a great proportion being public. There are 62 health centres 153 dispensaries
and 111 clinics distributed across the three counties. However, most of the facilities
are found in urban centres, with the average distance to the nearest health facility
being 30 - 35km. The doctor: population ratio is 1:41,538, and nurse: population
ratio being 1:2,453.
Table 34: Types of Health Facilities per County

County Hospitals Health Centres Dispensaries Clinic
s
Govt Priv NG FB Govt FB Priv NGO Govt FBO Priv Priv
O O O
Garissa 15 2 4 0 21 1 6 1 64 2 1 54
Wajir 8 5 0 0 28 0 0 0 50 2 0 54
Isiolo 2 1 0 1 4 1 0 0 19 8 3 3
Source: KNBS County Statistical Abstract
• There is a high morbidity rate of over 15 percent, and a high fertility rate of 6 %. Life
expectancy in the region is between 55-65years
• Five of the most prevalent diseases are; Malaria, upper respiratory diseases;
Diarrhea; Pneumonia, ear infections, Disease of the Skin, Urinary tract Infection,
Otitis Media and Gastroenteritis. The HIV prevalence rate is Wajir (0.9), Garissa
(2.7) and Isiolo (3.8)
• Along the project road, the following health facilities exist: Modogashe (Hospitals),
Habaswein (Hospitals), Lagbogol (Hospital), Borji (Health Centre) and Wajir
(Hospitals)
6.3.4 Land Tenure and Land Use
6.3.4.1 Land tenure

334. Most of the land in Wajir, Garissa and Isiolo Counties is Community Land
under trusteeship of the County Government until it is registered. In each of the
three (3) counties, Government land constitutes 10 percent of the total land,
including land for school’s administration, army barracks and health facilities. The
other 10 percent of non-communal land is owned by private investors in housing,
trade and other commercial purposes. Less than one percent of the population have
land titles in the three counties.
335. The Community Land Act, No. 27 of 2016 has made an attempt to provide
communities with a pedestal to manage land rights and land use in a manner that
is structured and sustainable in response to various economic, social,
environmental and political pressures. It provides that “Community land in Kenya
shall be owned by the Community” and that County governments shall only hold in
trust all unregistered community land on behalf of the communities for which it is
held. The law makes clear the recognition, protection and registration of community
land rights; the management and administration of community land.
Pan-19-003 - 112 -
KeNHA
336. Within the countryside away from urban centres, the land-tenure system is
similar to that of many pastoral areas. Grazing resources are open to all members
of a territorial section. In general, water in rivers and streams when they are flowing,
shallow wells are not owned by individuals but are accessible to all.
6.3.4.2 Land use
337. Nomadic pastoralism is the dominant land use in Garissa, Isiolo and Wajir
Counties (85%). The remaining 15% is used for small scale agriculture along river
banks and flood plains, scattered settlements, urban centres etc. Majority of the
people practice nomadic pastoralism where the large portion of the land is used as
grazing zones. Due to the harsh climatic conditions in the project area, the
traditional practice of pastoralism by the locals occurs during the rainy season.
Pastoralism occurs year-round, with livestock moved from dry season to wet
season grazing depending on the season.
338. Agriculture is majorly practiced in depressions and along drainage lines where
there is more moisture due to seasonal flooding. Irrigation using underground water
is limited to areas with permanent shallow wells. The major planted crops include
sorghum, drought resistant maize, beans, melons, cowpeas, green grams and
horticultural crops like kales, spinach, tomatoes, sweet and hot peppers. These
agricultural activities are undertaken in small scale.
6.3.5 Settlement Patterns
339. Being pastoral community, majority of the population in the counties (Wajir-
75%, Garissa-76% and Isiolo-68%) are found in the rural areas. Along the project
road corridor, the settlements are concentrated at the following towns/market
centres of Modogashe Town, Skanska Centre, Habaswein Town, Lagdima Centre,
Kanchara Centre, Samatar/Guticha Centre Laghbogol Centre, Borji Centre,
Leheley Centre and Wajir Town (County headquarters)
6.3.6 Education Institutions
340. The Early Childhood Development Education (ECDE) Institutions are being
developed. By 2017, the enrolment was as shown in Table 35.
Table 35: Pupil Enrollment in ECDE Centres

No of ECD
County Boys Girls Total Enrolment
Centres
Wajir - 10,642 8,158 18,800
Garissa 184 13,285 10,806 24,091
Source: Annual County Development Plans for Wajir and Garissa – 2017-2018.
341. The enrolment in Primary and Secondary Schools in Wajir, Garissa and Isiolo
Counties are provided in Table 36.
Table 36: Pupil Enrollment in Primary and Secondary Schools per County
Secondary School
No County Primary School Enrolment
Enrolment
1 Wajir 75,228 13,446
2 Garissa 133,336 20,118
3 Isiolo 37,436 5,581
Source: KNBS Statistical Abstract, 2018
Pan-19-003 - 113 -
KeNHA
342. There is very low transition from Primary to Secondary School. In 2017, it was
reported that the literacy levels of the three counties are Wajir at 23.8%, Isiolo at
15% and Garissa at 8.2%. The National average stands at 72.2%/. The low levels
of literacy is bound to expose the project affected persons even more with issues
of displacement, relocation and the management of compensation payments during
resettlement. More efforts will have to go into support structures to enable these
marginalized persons to restore their livelihoods. There are learning institutions
along the project road. There is a Technical College at Habaswein and a Secondary
Scholl at Leheley. The following learning institutions are located along the project
road corridor.
Table 37: Schools Mapped along the Road Corridor

No Institution Coordinates
1 Algal Primary School 0592905, 0141586
2 Laghbogol Dispensary 0593033, 0141730
3 Laghbogol Primary School 0593539, 0142349
4 Borji Primary School 0600890, 0160904
5 Leheley Secondary School 0611629, 0179266
6.3.7 Security
343. The project area has suffered insecurity arising from sporadic bandit attacks
on the road especially in the evening and nights. The Government has put in place
measures to improve security in the project area by establishing various road blocks
along the project road located near the various towns and sub-county boundaries
(Modogashe, Habaswein, Lagbogol, Borji and Leheley) in order to increase the
security along the road corridor.
344. The project has carried out a Security Risk Assessment and prepared
standalone Security Management Plan. The potential security issues identified
along this road section include: conflicts over boundaries at Modogashe between
the Borana and Somali communities; water and grazing access; inter-clan political
tension; and frequent Al Shabaab attacks. The Security Management Plan for the
project has adopted the WB Good Practice Note-Assessing and Managing the
Risks and Impacts of the Use of Security Personnel; and the IFC Good Practice
Handbook-Use of Security Forces: Assessing and Managing Risks and Impacts
Skanska – Samatar-Wajir Section.

345. The section between Samatar- Wajir road section is relatively peaceful with a
majority population (90%) being Somali Muslims the major clans being Ogaden,
Degodia and Ajuran. However, the following challenges exist:
• Threat of Al-shabaab crossing from Somali to Wajir County through Wajir East
along Konton, Khorof - harar and Kotulo belt to carry out attacks within the
County.
• Proliferation of small arms and light weapons. Every community has a militia for
their personal reasons.
• Entry of illegal immigrants from Somalia.
• Smuggling of contrabands goods.
• Clan Conflicts caused by Border dispute, new settlements, scarce resources
like water and pasture.
• Extremist religious teachings and Radicalization of the youth.
Pan-19-003 - 114 -
KeNHA
• Influx of Aliens from Ethiopia and Eritrea en-route to Nairobi.
6.3.8 Inter/Intra Clan Conflict
Inter Clan Conflict

346. The first 42km of the project road lies along the boundary that separates the
Somali and Borana communities in Modogashe town. The inter clan conflicts
between the two clans occur due to disagreements on resource sharing at the
disputed boundary between the two counties.
347. The two clans disregard for established communal control in the use of water
and pasture at the boundary. The Isiolo/Garissa conflict over resources is also
aggravated by the long outstanding issues in the past. The conflict situation
worsens during the dry season when the communities pursue water and pasture for
their animals.
Intra Clan Conflict

348. The intra clan conflicts are rare however it was observed that there was
growing intra clan animosity between the inhabitants of Samatar/Guticha Centre
where the Wajir West community did not want the inhabitants of Wajir South to
collect water from their borehole. During project implementation such animosity is
likely to escalate if there is no comprehensive consultation or inclusiveness in the
planning of project activities and benefits sharing.
6.3.9 Physical Cultural Resources
349. A few graveyards, water well and mosques were identified to lie within the
original RoW of 60m design of the road. The Design Review Consultant (2018/19)
has revised the RoW for the urban centres including Wajir Town to 30m (use of
existing corridor). This has been done to minimise land acquisition and impact of
the project on human settlements and sensitive cultural resources, hence the
cultural resources including graveyards/graves, mosques and water wells that could
have been impacted will be avoided.
350. An NMK Archaeologist has provided an evaluation of the potential occurrence

of Archaeological/Cultural Resources that the construction teams need to be aware
of. However, since the road construction will involve excavation of soil along the
road alignment and other resources may be underground or not identified, a
“CHANCE Find Procedures” has been provided in Annex 6
6.3.10 Local Communities/Indigenous Peoples
351. Wajir and Garissa counties where the project traverses are predominantly
occupied by the Somali Community. The Isiolo side is occupied by the Borana
Community. The Borana and Somali communities are regarded as Vulnerable and
Marginalized Groups (VGMs) as recognized in the Constitution of Kenya 2010. The
Somalis are dominantly present in all the major centres traversed by the project
apart from Modogashe town where Boranas have a significant presence.
352. The Borana and Somali communities are pastoralist communities that meets
the criteria in OP/BP 4.10. A Social Assessment was carried out in accordance to
World Bank’s O.P/BP 4.10, Free, Prior and Informed Consultations (FPIC) with
Pan-19-003 - 115 -
KeNHA
Vulnerable and Marginalized Groups (VMGs) to ensure broad community support

for the project. The SA analyzed VMGs social issues, established project impacts,
mitigation measures and FPIC that will inform the design of the project. This SA will
enable the project to be responsive to social development concerns, including
seeking to enhance benefits for vulnerable and marginalized groups, while
minimizing or mitigating risk and adverse impacts
6.3.10.1 Somali Community in Wajir
353. The Somalis are found in Garissa, Isiolo and Wajir Counties, they are
physically and culturally homogenous, speak the Somali language that belongs to
the Cushitic branch of the Afro-Asiatic language family. The Somali community in
Isiolo were originally from neighboring counties of Garissa and Wajir. They were
settled as compensation for their service after participating in World War 1. The
first settlers were originally from non-indigenous clans of Isaaq and Herti. They were
later joined by members of other Somali clans following the Shifta War. Somalis
are divided into clans, sub-clans, sub-sub-clans resulting into extended families.
The Somali from Wajir are mainly from four clans; Ogaden, Degodia, Ajuran and
Masare while those from Mandera are mainly from the Degodia, Garre and Murulle
Clans.
354. Religion - Almost all Somalis are Muslims and for those who practice, Islam
is a belief system, a culture and a way of life. Therefore, among the Somali people
attitudes, social customs and gender roles are primarily based on Islamic traditions.
6.3.10.2 Borana Community
355. The Borana concentrated in Merti and Garbatulla sub-counties are the
predominant (60%) ethnic group in Isiolo County and in the project area. They are
cushites, and are divided into three sub-groups namely, the Borana, Sakuye and
Gabra. The Borana are descendants of the Oromo Borana of Southern Ethiopia
who migrated in the 1930s to the Ewaso Nyiro river area in what is now Isiolo
County. They are traditionally a culturally homogenous society with genealogical
ties. The Borana are nomadic pastoralist whose main source of livelihood is
livestock. Livestock is kept for other uses; Donkeys are kept as beasts of burden,
though mainly by the Boran-gutu who do not keep camels. Cattle, sheep, goats and
camels all provide milk (and milk products), meat, hides and skins. In addition,
camels provide transport. Boranas speak Afaan Oromo which is an Eastern
Cushitic language belonging to the Afro-Cushitic family.
356. Religion - The Borana people have a traditional monotheistic religion with a
god called “Wak”. They communicate to their god through intermediary priests
called “Qalla” and believe that Wak sends good things to them –especially rain.
Islam was introduced to the society about a century ago, majority (50%) of the
Borana people are Muslims. Christianity was introduced through missionary work;
it is estimated that about 10% of Boranas are Christians while the rest belong to
their traditional religion.
Pan-19-003 - 116 -
KeNHA
Plate 8: Structures along the Project Road Kanchara Centre – February 2019
Plate 9: Structures along the Project Road – Kanchara Centre – February 2019
6.3.11 Gender
357. As indicated by the Social Assessment report, the VMGs (communities) in the
project area (Borana, Somali and Turkana) are patriarchal, where women’s position
Pan-19-003 - 117 -
KeNHA
is viewed as subservient, marginalized and disempowered. The Somalis for

instance consider women and children as part of a man’s property. The
responsibilities of men in these ethnic groups is livestock issues which include
herding, watering animals, selling and making other key decisions within the
household. While, women normally perform domestic duties such as tending the
home and children, milking animals, fetching water and firewood, looking after
home herds of sheep and goats while a few engage in small scale farming and
trade. The women indicated that they have a limited role limited role in decision
making.
358. The changing socio-economic environment in the project area has had an
impact on assigned gender roles. The women in VMGs communities are
increasingly taking up more roles that used to be the preserve of men. For instance,
men’s role as the household head and provider is now shifting to some women as
men migrate to take up paid work in urban areas. Women therefore have had to
take up extra load of responsibilities in addition to their normal household chores
leaving them overburdened let alone the worsening poverty levels in the area. The
project needs to consider offering jobs to women in the project area to enable them
adequately provide for their families and also uplift their economic status reducing
poverty levels.
359. In the project area, women still have limited rights of access to and ownership
of economic resources which restricts their capacity to make decisions related to
assets. However, there are slight improvements in gender relations and roles
where some women are now allowed to participate in decision making, owning and
controlling assets in some of the VMG communities. Both communities agreed that
there are few women in this category and majority are still disadvantaged making
them further vulnerable.
360. The social assessment study also established that male children are generally
given a special preference over girls and tend to benefit more from formal education
than girls who in some cases remain home to assist with domestic chores and
herding. The girls are further disadvantaged by early marriage a culture practiced
by the VMG communities. They consider the acceptable marriage age for girls to
be 14 years. This is when they are considered mature. This practice makes girls
vulnerable and can be attributed to the higher rate of school dropout among girls
than boys in the project area. This exposes women to vulnerability early in life thus
confining them to poverty and denying those opportunities that are otherwise
available to men.
361. Women in the project area are beginning to actively participate in politics by
vying for elective positions and actively participating in political campaigns to
gunner support for candidate of their choice. The road project will likely lead to
opening up opportunities for women. Their access to social amenities will be
accelerated and potential growth of urban centres will increase their business
opportunities.
Pan-19-003 - 118 -
KeNHA
It is also likely that girls will have greater chances of education due to the relaxing
of social attitudes as a result of interacting with other opportunities. Patriarchy,
though unlikely to disappear, will abate.
6.3.12 Poverty Levels
362. The people of Wajir, Garissa and Isiolo Counties fundamentally depend on the
natural systems and natural resources for existence and development. However,
due to the low literacy levels and the harsh environmental conditions prevalent in
the area, poverty levels are high.
363. The counties have a large number of poor people both in urban and rural
areas. The population living under absolute poverty level is estimated to be 84%.
This implies that the majority of the population is unable to afford their minimum
basic needs such as food, clothing and shelter. Majority are heavily dependent on
relief food from the government and other organizations.
364. The high incidence of poverty can be attributed to; unreliable rainfall, high
levels of illiteracy, poor crop and animal husbandry practices, poor infrastructure,
inaccessibility to credit facilities, poor marketing systems, natural disasters like
frequent droughts, floods, livestock and crop diseases, wildlife menace and
environmental degradation
365. The counties have many cases of malnutrition and stunting mainly for under
five children, which is because of high poverty levels leading to food insecurity and
dependence on relief food. According to the KDHS (2014), 26 per cent of children
under age, five in the county are stunted. The 26 per cent is still high and there is
need for deliberate efforts to reduce this figure.
366. Malnutrition is highly pronounced in the rural settlements where access to

nutritional food products is a challenge. Family planning and contraceptive
prevalence is very low with only 2% of married women using modern methods of
family planning. This low uptake of family planning is attributed to cultural beliefs
and practices in the community. This has led to high population growth and increase
in poverty due to unplanned families, which strain on the local resources. Total
fertility rate stands at 7.8%, which is the highest in the country with the national
average standing at 3.9%.
6.3.13 Gender Based Violence
367. Sexual violence in form of rape and defilement is prevalent in the area and
most cases are not reported due to stigma attached to the matter. Survivors of
sexual violence have less access to psychosocial support, legal assistance and
protection from further abuse as services are limited or lacking. In cases of spousal
abuse the tendency is in favor of keeping the family intact and in the case of sexual
violence involving unmarried females, they are sometimes forced to marry the
perpetrator, especially when it results to a pregnancy.
Pan-19-003 - 119 -
KeNHA
There is widespread use of maslaha - composed of traditional male elders only - to

resolve family law issues and to prosecute sexual violence cases. Therefore,
survivors access to justice is highly compromised and services including
psychosocial support and protection from further abuse.
368. Gender based violence is rampant in the project corridor and in some cases
normalized. Its drivers are multiple and overlapping. Socio-economic conditions,
cultural factors, as well as unequal power relations and acceptability of the use of
violence in society significantly contribute to GBV cases. Normalization of GBV and
stigma influenced by religious and cultural norms prevents GBV survivors from
speaking openly about their experiences and often keeps them from reporting their
cases to the local administration or the police. To address GBV in Kenya, the GoK
has enacted key instruments that include the Constitution of Kenya that accords
everyone with the Bill of rights for protection against any form of violence and abuse.
Furthermore, the constitution of Kenya 2010, The penal code, the sexual offences
Act, the Employment Act and the children’s Act 2001 provide secure a framework
for cases of Sexual and Gender Based Violence. The Sexual Offenses Act
specifically provides for the prevention and protection of all persons from harm from
sexual acts including sexual assault, rape, defilement, sexual harassment and child
prostitution. It also provides for access to justice and psychosocial support while
the Employment Act 2007 prohibits work place sexual harassment
369. Sexual violence which is one form of Gender Based Violence is widespread in
the Somali community. The perpetuation of this vice is largely due to the following:
• Cultural practices such as abduction and early child marriages;

• Gender and cultural roles that discriminate the girl child’s access to education;
• Housing arrangements that enables SGBV to occur
• The community’s interpretation of the appropriate age of marriage for a girl
• Inter-tribal conflicts where rape and acts of bestiality are committed for revenge
370. The division of roles where the men take of the Camels and mature cattle while
the women and girls have the responsibility of herding goats. This makes the girls
of the age 9-15 years become vulnerable to sexual violation when they are out alone
in the bush herding the animals. It is also reported that sexual abuse in marriage is
also occurring and one of the reasons mentioned was that female Genital Mutilation
(FGM) which is practiced by the community makes sexual intercourse both difficult
and painful hence the unwillingness to participate could be contributing the marital
rapes. What makes the situation worse is that it not viewed as a violation on women.
371. The presence of the construction in the project area where poverty levels are
high if unchecked may expose the women to sexual abuse. The influx of workers
employed by the construction company, along with those looking for jobs with the
construction company are likely to use their disposable income to sexually abuse
and assault the women and girls in the project area. There is likelihood that women
from other parts of the country may also relocate to the project area to perpetuate
sex trade which may create opportunity for local women and girls to get into the
same.
Pan-19-003 - 120 -
KeNHA
372. The increased opportunities of providing support services to the construction

team and also food vending which may extend into the late evening hours will make
these women and girls vulnerable to sexual abuse. The community generally has a
strict attitude to interactions between non related people of opposite gender.
373. In certain instances, they do not shake hands. However, the migrant
community with money may tempt the poor girls and women to break their taboos.
374. The roadside traders who are mostly girls and women who will be displaced
by the project and have not re-established themselves may find themselves being
lured into transactional sex. Considering the conservative nature of the project area
community, any reports of Sexual Exploitation and Abuse (SEA) could result in
major confrontation and revenge attacks. There should be concerted efforts to
prevent such occurrence and fight SEA by putting in place appropriate measures
before construction activities commence.
6.3.14 Gender and Women Empowerment
375. The County Governments located in Arid and Semi-Arid Lands (ASALS)
recognize that there is high Gender Inequality Indices and are therefore making
efforts to address the factors that contribute to these high inequality indices. The
county profiles indicate the empowerment of women is very low and this cannot
spur economic growth and development. Illiteracy in Garissa and Wajir at 74% and
76% respectively. These are among the highest illiteracy levels in the country.
376. The very high illiteracy levels are contributing to the low empowerment of
women. Women have traditionally played supporting roles in Somali and Borana
families, and taken lead in household duties. Women in the rural areas do not own
livestock, although in the urban area women have been able to accumulate property
in their own right. Women in the pastoral and rural sector had clearly defined gender
roles, they worked hard and had responsibility for building the nomadic huts,
tending the home and children, milking animals, looking after home herds of sheep
and goats, fetching domestic water and firewood; cleaning and cooking food for the
family.
377. Women have traditionally been ‘absent’ in pastoralist decision making

institutions, and only found voice in influencing their men sitting on the customary
tribal councils. Whenever the women had positive contribution to make, they would
usually do it through their husbands.
378. The road project is going to open up various opportunities for women. This will
enhance faster growth of the urban centres, thereby improving other sectors like
education which will improve the chances of the girl child in getting education.
Patriarchy, though unlikely to disappear, will abate. Women uptake of funds for
socio economic improvement is going to improve. This will open up women
participation in every sector and will therefore be able to assert themselves to fight
for their rights.
Pan-19-003 - 121 -
KeNHA
6.3.15 Relief Operations
379. Kenya continues to host a large number of refugees fleeing conflicts in their
countries. Dadaab is a semi-arid town in Garissa County, Kenya. It is the site of a
UNHCR base hosting 211,365 registered refugees and asylum seekers in three
camps as of the 13 May 2019, making it the third-largest such complex in the world.
The vast majority of the refugees are Somalis.
380. Islamic Relief is providing emergency food and water supplies and drilling
and rehabilitating strategic boreholes in the most critically affected areas. To try and
address the conflicts the organization is bringing conflicting parties together in the
management of a borehole project to ensure a fair and equal access to the valuable
resource of water for both people and animals. A key area of the organizations work
is in Dadaab refugee camp where they are running a hospital and six health centres
in Ifo sub camp, home to 70,000 people. They are also providing primary and early
education for 40,000 children through 10 schools in Ifo camp 1 and eight schools in
Ifo Camp 2. The services are available to both refugees and the host communities.
381. Care Kenya provides emergency and humanitarian assistance to refugees in

Dadaab Refugee Camp in Garissa. CARE has been operating in Dadaab since
1992, providing relief and development assistance in the refugee camps and
supporting the neighbouring host communities. They are currently offering the
following services among others:
• Water, Sanitation and Hygiene

• Education
• Gender and Community Development
382. ALDEF Kenya started as a small Community Based Organization before

becoming a fully-fledged NGO. Acting as both initiator and implementer, ALDEF K
has overseen several successful projects in partnership with international
institutions and funders. These include ensuring timely and adequate response to
humanitarian crises in Northern Kenya and Somalia. ALDEF K has implemented
life-saving programmes such as the resilience building programmes, cash
programmes, water tracking, and distribution of relief foods in the most vulnerable
place
383. The other NGOs operating in the project area include:
• ALDEF: Arid Lands Development Focus - Kenya

• CRS: Catholic Relief Services
• IRK: Islamic Relief Kenya
• KRCS: Kenya Red Cross Society
• PIDAD: Pastoralist’s Initiative for Development and Advocacy
• UNICEF: United Nations Children’s Fund
• WFP: World Food Program
Pan-19-003 - 122 -
KeNHA
6.3.16 Trade and Industry
Trade
384. The main type of business carried out in the region is retail trade in form of
retail shops, supermarkets and whole sale shops. The larger towns like
Modogashe, Habaswein and Wajir have bigger grocery shops with variety of goods
and also wholesale outlets.
Industry
385. Industry is poorly developed in the region. The Garissa county had only one
industry, Maua Milling. Which was closed down due to insecurity. In Wajir, there are
small scale industries in lime production, gums & resins, juice production and hides
& skins tannery. Currently the county has two bakeries. The gum and resin factory
were built in Wajir East Constituency by Ewaso Nyiro North Development Authority
(ENNDA) although it is yet to be operationalized. The county has large potential in
lime production which is yet to be explored. Livestock farming can also be done on
large scale hence the need to establish a milk and meat processing plant. Livestock
production and value addition can be increased with the participation of county
governments and third-party players as well as entrepreneurs. The main hindrance
to industrial development is the lack of electricity. Only Modogashe, Habaswein and
Wajir have supply of electricity.
6.3.17 Transport and Communication
Transport
386. The main form of transport used in the three counties general is road transport.
Along the whole stretch of the project corridor, only about 5km of the Wajir Town
road is paved. The rest of the road is unpaved and in poor condition. Most of the
road sections are impassable during rainy seasons. The county has very few
bridges found across River Tana and Ewaso Nyiro. The smaller are crossed over
concrete drifts. Most of the places in the region are rendered totally inaccessible
during heavy rains.
Telecommunication
387. The three mobile service providers in the project area are Safaricom, Airtel
and Orange. However, the mobile network connection is 20 per cent which is mainly
limited to main settlement areas. In addition, there is Wajir and community radio
station and other local community FM stations which are operational. The project
area has less than 60 percent connectivity, mainly concentrated in the urban and
settlement centres.
6.3.18 Tourism
388. The counties of Wajir, Garissa and Isiolo have rich culture, wildlife and
landscape features. The sector is also boosted by Wajir International Airport. There
are no gazetted game reserves or game parks in the county of Wajir. However,
KWS is ensuring safety and protection of the wildlife in their current habitation
outside any protected area. In addition, other tourist attraction features include Wajir
museum, Wagalla massacre site, Orahey wells, British & Italian war bunkers and
old court house. The county is also endowed with various game species like Ostrich,
Pan-19-003 - 123 -
KeNHA
Hyenas, Gazelles; Lions, Zebras, Giraffes, Warthog and Birds among others. Full
exploitation of wildlife resources is hampered by frequent human wildlife conflict.
The wildlife is found all over the vast county hence conservation and management
has been a challenge.
6.4 Socio-Economic Activities and Household Survey Results
389. This chapter delves into the socio-economic characteristics obtaining in the
project area. The aim is to bring out the character of the economy that the road
project will support with a view to locating possible cultural and socio-economic
impacts on local communities and thus understanding the context of their mitigation
of enhancement. The rest of the chapter discusses general secondary data on the
various counties that the project traverses, then turns to primary survey data, ending
with a conclusion.
6.5 Socio-Economic Activities
390. Kenya's Arid and Semi- Arid Lands (ASALs), which make up 89% of the
country’s total land surface are mainly found in the Northern, Eastern and Rift Valley
regions. The ASALs in Kenya comprise 23 counties, of which 9 are classified as
Arid, and 14 as Semi-Arid. Garissa, Isiolo and Wajir are part of the 9 arid counties
in Kenya. The defining feature of the ASALs is aridity with annual rainfall of between
150mm to 550mm per year in arid areas. The temperatures in arid areas are high
throughout the year, resulting in high rates of evapotranspiration, more than twice
the annual rainfall. These areas, which are also classified as rangelands, do not
support rain-fed cultivation due to physical limitations such as aridity, low and erratic
rainfall and poor vegetation. The harsh climatic conditions have made majority of
the inhabitants of the arid areas adopt mobile pastoralism as the major economic
activity. Garissa County appears to enjoy more agricultural potential than nomadic
pastoralism.
6.5.1 Socio-Economic Activities in Garissa County
391. The main economic activities include agriculture with the main crops being
watermelons, mangoes, vegetables, tomatoes, paw paws, bananas, cowpeas,
simsim, maize, beans and green grams. Livestock rearing is the second backbone
of the county’s economy. Main livestock breads are cattle (Boran), goats (Galla),
sheep (black headed Persian) and camel (dromedary one humped). The main
livestock products are meat, milk hides and skins. Maum milling was an important
industry, but has been closed due to security concerns within the region. Refer to
Map 9 for the livelihood zones of Garissa County.
6.5.2 Socio-Economic Activities in Isiolo County
392. A large portion of the county is arid and not appropriate for crop farming.
However, maize, beans, cowpeas, onions are produced in the areas bordering
Meru and Laikipia Counties. Mangoes, pawpaws and other horticultural crops are
produced in the existing private small-scale irrigated farm along rivers. The
backbone of the county’s economy is livestock production with over 80 percent of
the inhabitants relying on livestock for their livelihoods. The county has several
ranches. A ranch neighboring Lewa Wildlife Conservancy is used as a breeding
ground of Black Rhinos. Borana ranch is a group ranch and is a home to 50
indigenous tree species and over 300 species of bird life. Its unique geographic
situation makes the 35,000 hectares ranch a haven for a wide diversity of wildlife:
Pan-19-003 - 124 -
KeNHA
buffalo, eland, jackson's hartebeest and herds of grant's gazelle, the highly
endangered species gravy gazelle, impala and burchell zebra roam its plains. Refer
to Map 10 for the livelihood ones of Isiolo County. The livelihood activities on the
Isiolo side of the project road area is largely pastoral of all species of livestock.
6.5.3 Socio-Economic Activities in Wajir County
393. The main economic activity in the County is pastoralism with some agro-
pastoralism and rain-fed agriculture being practiced on a small-scale basis in the
northern higher altitude regions, eastern and south-western area (Habaswein). The
large tracts of land in the county provide the grazing pastures for the large camel
and cattle herds present in the county with a high dependence on groundwater.
Harvesting undertaken from numerous wells, earth pans, dams and boreholes is
made possible due to the high-water table. Along the project road, the economic
activities include:
• Pastoralism of all species in Wajir West.

• Pastoralism involving largely cattle is carried out in Wajir South Subcounty
• In Habaswein area there is agro-pastoralism where irrigation is also practised.
• Formal employment is offered in Habaswein and Wajir Town.
Refer to Map 11 for the livelihood zones for Wajir County.
Pan-19-003 - 125 -
KeNHA
Map 9: Livelihood Zones of Garissa County
Modogashe
Source: National Drought Management Authority
Pan-19-003 - 126 -
KeNHA
Map 10: Livelihood Zones of Isiolo County
Pan-19-003 - 127 -
KeNHA
Map 11: Livelihood Zones of Wajir County
Wajir Town
6.6 The Socio-Economic Survey Results of the Road Corridor Community
394. This section looks at the social terrain of the project area. It focuses on the
demographic and socio-economic characteristics of people in the project area with
a view to providing a picture of the baseline socio-economic situation. This will
support the basis for anticipating socio-economic impacts and designing
appropriate mitigation measures.
395. The population demographic data is secondary data obtained from Population
and Housing Census - Kenya National Bureau of Statistics (2009). The data used
to evaluate the project area socio-economic status is primary data obtained from
the socio-economic survey conducted by the ESIA Study team between February
7, 2019 and February 26, 2019.
Socio-economic Survey Results

396. The primary data collected during the socio-economic survey has been used
to evaluate the baseline status of the project road corridor community.
Pan-19-003 - 128 -
KeNHA
6.6.1 Livelihoods
397. The main economic activity in Wajir County is pastoralism with some agro-
pastoralism being practiced in the Northern part of the county. The large tracts of
land in the county provide the grazing pastures for the large camel and cattle herds
present in the county. Rain-fed agriculture is practiced on a small-scale basis in the
higher altitude regions of the county. These regions receive better amounts of
rainfall compared to regions lying in lowland areas which has made agriculture a
reality. The high-water table in the region has ensured that the region has an
adequate supply of water from the numerous wells, earth pans, dams and
boreholes in the area. The 2009 KHPC put the number of people in the county
above fifteen years of age that are in employment at 196,322 in rural and 14,031 in
urban areas which accounts for 32% of the total population. The livestock sector
engages 284, 265 people which accounts for 85% of the households’ income.
Livelihoods of the Community along the Road Corridor

398. The Study team carried out administration of the socio-economic
questionnaires to establish the livelihood activities along the Modogashe-Wajir
Road. The outcome is presented in Figure 8.
Figure 8: Livelihood Categories for Persons located next to the road

• Pastoralism The outlook of the county is
that Pastoralism is done by more than
80% of the population. Our sample
interviews at centres along the road
returned 15%. This still significant given
that those interviwed live in the major
centres along the road.
• Commercial Enterprises - Majority
(46%) are involved in commercial
enterprises. This implies that a significant
population will have their businesses
disrupted and there will be loss of
livelihhod.
• Employment - .17% of the respondents
are employed.
• Farming- 14% are involved in farming as
their main source of income. The harsh
weather condition and lack if irrigation
water makes them rather vulnerable
6.6.2 Age Distribution of Modogashe - Samatar - Wajir Road Corridor Residents
399. In Figure 9, majority of the respondents fall under the age bracket of 36-
60years (57%) followed by respondents under the age of 35years (28%). Those
that fall in the age bracket of 60 years and above (15%). This implies that the
population found along the road corridor area are largely economically active.
Pan-19-003 - 129 -
KeNHA
Figure 9: Modogashe - Wajir Road Area Respondents According to Age
Distribution by Age
n = 98
15%
28%
0-35
36-60
Above 60
57%
6.6.3 Quality of Housing Structures of the Residents
400. Majority of the road corridor respondents live in semi-permanent houses (57%)
while 39% live in permanent houses. This shows that the road corridor communities
are changing their livelihood status and also getting urbanized. The traditional
housing unit (Manyattas) only form 10% of the housing structures found along the
road corridor Figure 10 provides distribution by type of housing along the road
corridor.
Figure 10: Type of Housing along Modogashe - Wajir (A13) Road
Distribution by Type of Housing

n = 96
4%
39% Permanent
Semi
57% Permanent
Temporary
6.6.4 Level of Education of Respondents along the Road Corridor
401. As shown in Figure 11, majority of the respondents along the project road
corridor have not gone to school (no formal education - 59%). However, it is worth
noting that the area’s population being largely Muslim do attend religious education
at young age before being enrolled into formal education.
Pan-19-003 - 130 -
KeNHA
402. 25% of the respondents had attained primary school level of education, 17%
had attained secondary level of education and a further 10% had attained post-
secondary education. The high percentage of persons that have not attended
school is contributing to the high level of illiteracy recorded for the county. The
poverty level, harsh climate and pastoralism lifestyle could be contributing to this.
There will be need to put in place support structures during compensation and
resettlement to ensure they are able to resettle and continue with their livelihoods.
Figure 11: Education Levels of the Respondents
Distribution by Level of Education

n = 97
10% Not Educated

17% Primary
48%
Secondary
Post - Secondary
25%
6.6.5 Religious Following
403. Majority of the Road corridor respondents were Muslims (99%) while a small
number were Christians (1%). This will have a very profound effect on the way the
project is implemented and more so on the behavior and conduct of the contractor
team. During consultations with religious leaders, there was already concern that
external influence may affect their culture and religious following. The community
also strongly proposed that the religious leaders be fully involved from the beginning
to the end.
Figure 12: Road Corridor Respondents According to Religious Following
Distribution by Religion
n = 101
1%
Muslim
Christian
99%
Pan-19-003 - 131 -
KeNHA
6.6.6 Respondents for Drinking Water Sources
404. When the study turned to the respondents’ sources of drinking water along the
Modogashe - Samatar - Wajir Road corridor, the results obtained were as shown in
Figure 13. Majority of them drew their water from the shallow wells (49%) while
28% get their water from boreholes. This gives a combined total of 77% for those
using ground water sources. The 20% who use other sources largely rely on water
purchased from water vendors. Only 3% of the respondents receive piped water as
their source.
Figure 13: Drinking Water Sources for Residents along Road Corridor
Distribution by Water Source

n = 99
20%
28%
Other
3%
Piped
Well
49% Borehole
6.6.7 Respondents on Walking Distance to Water Source
405. As shown in Figure 14, the distance to the water source for majority of
respondents was found to be between 1km and 2.5km (44%), followed by less than
0.5km at 19%. Few people walk more than 5 km to access water as at 8%. This
signifies that most settlements are found near water sources along the road
corridor.
Figure 14: Walking Distances to Water Sources

Walking Distance to Water Source
n = 96
8% 19% <0.5Km
16%
0.5 - 1.0Km
13%
1.0 - 2.5Km
2.5 - 5.0Km
44%
>=5.0Km
Pan-19-003 - 132 -
KeNHA
6.6.8 Source of Energy for Cooking
406. Respondents living along the road corridor exclusively use two sources of
energy for cooking (Firewood 85%, Charcoal 9% and both 6%). This is a very
worrying trend when considering the need to conserve forest resources. See Figure
15. Firewood does not only deplete forest resources; it significantly contributes to
air pollution resulting in Upper Respiratory Tract Infection (URTI) which is also
reported as one of the most prevalent OPD diseases at almost every health facility
in the project area. Sensitization of the project area community should be carried
out and since poverty levels are high, there should be a drive to provide alternative
clean sources of energy (like Gas) at subsidized cost. High dependency on wood
fuel and charcoal is depleting the forest cover and contributing to climate change
Figure 15: Cooking Energy for Road Corridor Community

Source of Energy for Cooking
n=
6%
9%
Firewood
Charcoal
85% Firewood/Charcoal
6.6.9 Source of Energy for Lighting
407. A large number of the project area respondents use electricity (45%) since a
significant number of the respondents live in urban centres like Modogashe,
Habaswein and Wajir Town. However, we still note that a significant number still
use kerosene lamp (35%) as shown in Figure 16. Use of kerosene lamps is unsafe
health-wise and may contribute to respiratory and eye related diseases due to
smoke emission. It is pleasant to note that a good percentage of the community are
now using clean source of energy for lighting - Solar 13%.
Figure 16: Energy Source for Lighting
Distribution by Source of Lighting

n = 99
3% 10% 6%
Other
1%
Electricity
Kerosene Lamp
35% 45% Candles
Electricity/Lamp
Solar
Pan-19-003 - 133 -
KeNHA
6.6.10 Distance to Health Centre/Dispensary
408. Majority of the respondents (48%) have to walk between 1.0-2.5km to reach
a health facility. 22% have to walk between 2.5-5km to reach a health facility. A
significant 18% have to travel more than 5km. These are large distance to walk
when there are emergencies since there are no vehicles. See Figure 17.
Community members without proper facilities in their centres requested for
assistance.
Figure 17: Distance to nearest Health Facility for respondents
Walking Distance to Health Facilities

n = 71
5%
18% 7%
<0.5Km
0.5 - 1.0Km
22% 1.0 - 2.5Km
48% 2.5 - 5.0Km
>=5.0Km
6.6.11 Sanitation Facilities along the Project Road Corridor
409. Majority of the respondents (73%) use pit latrines. About 24% do not have any
developed sanitary facility (perform open defecation) to answer the call of nature.
See Figure 18. When considering that a significant population (77%) use ground
water from wells and boreholes for drinking water and given that groundwater is
relatively shallow, there is cause for concern on health and sanitation of the
community. This is because the water sources (wells) are located where community
is residing. The uptake of technology to protect water wells is still low and efforts
should be made to assist the community who are largely poor and marginalized.
Recurrence of diarrhea disease epidemic is rather frequent.
Figure 18: Sanitation Facilities along the Road Corridor
Distribution by Sanitation Type

n = 90
3%
24% Other
Pit Latrine
73%
Bush
Pan-19-003 - 134 -
KeNHA
6.6.12 Common Diseases Affecting Respondents along Road Corridor
410. The diseases the respondents reported are as shown in Figure 19. Malaria
and typhoid appear to be the biggest challenge at a combined 69%. The other
forming 21% could be the Upper Respiratory Tract Infection.
Figure 19: Common Diseases Affecting Respondents
6.6.13 Distribution of Income for Road Corridor Respondents
411. Majority of the respondents (44%) earn between 3,000/= - 15,000/= a month
as their income. See Figure 20. Those earning between 15,000/=- 30,000/= form
17%. Those earning between 30,000/= - 50,000/= form 20% of the community while
those earning above 50,000= form 16%. It is important to note that there some
community members who get 3,000/= of less. This generally shows that although
the survey was done in the urban centres, the income levels are generally low for
persons with families to feed, clothe, pay for medical care and take to school.
Figure 20: Income Distribution for Modogashe - Wajir Road Corridor
Distibution of Income
n = 100
3%
16% <= 3,000

3,001-15,000
20% 44%
15,001-30,000
30,001-50,000
17%
Above 50,000
Pan-19-003 - 135 -
KeNHA
6.7 Conclusion
412. The data analyzed and reported in this chapter shows that the project
traverses mainly through nomadic pastoralist areas. Majority of the people in the
project area were Muslims and educational achievements were generally low with
high illiteracy rates. Generally, the findings imply that there will be need for labor
influxes to cover both skilled and non-skilled positions during construction. This
calls for a lot of community work creating awareness on HIV/AIDS, child labor and
protection, gender-based violence and sexual exploitation. In particular, labor from
outside the project area will have to sensitized to the local culture and religion in
order to avoid conflict. The findings also point to the dominance of Islam and Islamic
culture and hence a basis for a contextualized grievance redress mechanism
(GRM).
Pan-19-003 - 136 -
KeNHA
7 PUBLIC CONSULTATION AND PARTICIPATION
7.1 Legal Requirements
414.
• The overall objective of the Government is to involve citizens in project formulation
and implementation at the local level. More specifically, the Community Action
Planning Programme objective is to put in place a durable system of intra-community
co-operation through collective action, which creates communal discussion forums
for the implementation of development activities.
415.
• The foregoing is particularly pertinent in the context of Article 35 of the Constitution
of Kenya which, provides that ‘every citizen has the right of access to information
held by the state; and information held by another person and required for the
exercise or protection of any right or fundamental freedom’. For instance, a question
would arise about a project such as NETIP regarding how it affects the local people’s
right to a clean and healthy environment enshrined in Article 42 of the Constitution of
Kenya. This was determined inter alia through subjecting the project to public
participation and consultation that is the subject of this chapter.
416.
• Within Kenya, EMCA requires a project proponent to seek the views of
persons/communities that may be affected by the project to be consulted, at least
explain project potential impacts and obtain oral/written comments, which will be
included in the ESIA for implementation by the proponent.
417.
• Similarly, the World Bank under the OP/BP 4.01(Environmental Assessment)
requires adequate consultation on environment and social aspects with affected
groups and local NGOs, and demonstrate to the extent to which the views of such
groups are considered
7.2 Stakeholder Identification and Mapping
418. Public Consultation and Participation were carried out at different levels and
with different key stakeholders and community members. The consultant identified
and mapped the stakeholders in the project area. These included:
• Community members at the trading centres Modogashe, Skanka, Lagdima,

Habaswein, Laghbogol, Borji, Guticha, Leheley and Wajir.
• County officials including County Commissioners, Deputy County Commissioners,
Religious Leaders, Political Leaders, Local Authority Officials, Chiefs and Village
Elders.
• KeNHA representatives in Garissa and other government departments in the
counties
• Persons affected by physical and economic displacement
• Women, youth and people living with disability along the project road.
Pan-19-003 - 137 -
KeNHA
7.2.1 Stakeholder Engagement and Public Consultations during Previous Study
419. Table 38 below provides a summary of the stakeholders and public consultation
meetings that were held during the previous ESIA Studies.
Table 38: Stakeholder Engagement and Public Consultations during Previous

Studies
Modogashe – Samatar Road

Total No of
# County Sub County Venue Female Male Participants
1 Garissa Modogashe Lagdera Social Hall 42 130 172
2 Isiolo Modogashe Sericho 56 94 150
3 Wajir Habaswein Community Library 43 57 100
4 Isiolo Garbatulla Kone (Skanska) 60 90 150
5 Wajir Kanchara 68 82 150
6 Wajir Wajir West Guticha 22 28 50
Sub-total 1 291 481 772
Samatar – Wajir Road

Total No of
# County Sub County Venue Female Male Participants
1 Wajir Laghbogol 10 36 46
2 Wajir Borji 49 63 112
3 Wajir Leheley 41 55 96
4 Wajir Wajir Town 29 83 112
Sub-total 2 129 237 366
Total 420 718 1,138
Source: ESIA Studies (Mar & Apr 2018)
7.2.2 Stakeholder Engagement and Public Consultation Meetings in Current Study
7.2.2.1 Key Stakeholder Consultations
420. In-depth interviews and discussions were held with institutional stakeholders,
such as the National Government, County Government, Government Departmental
Heads and Religious Leaders, Civil Society, NGOs and CBOs representatives. The
interviews were intended to share information on the road project with them, and
solicit their opinions and recommendations. The Key Stakeholder Consultations were
carried out from February 6 – 26, 2019.
421. The key findings from the in-depth interviews and discussions with stakeholders
were that they supported the road project because it would enhance transportation
for passengers and goods in the region. They said that the poor state of roads in
Northern Kenya had hampered economic growth and trade with the rest of the
country. In particular a civil society leader said, “the so-called marginalization of this
region is not political it is infrastructural, without infrastructure, people in the region
are really isolated and impoverished as they lose all their assets during drought
seasons’. They called for loop roads to institutions to schools and health facilities
near the main project road. Refer to Annex 5 – Analysis of Key Stakeholder
Questionnaires.
Pan-19-003 - 138 -
KeNHA
7.2.2.2 Public Consultation Meetings
422. In addition, the consultant conducted public consultation meetings along the
project road corridor in order to collect the views of the local community members
and obtain their input on the sustainable implementation of the project. The meetings
were conducted following written and verbal communication with the local
administration. The table below lists the public consultation meetings held.
Table 39: ESIA Public Consultation Meeting (PCM) Venues and Dates
Total No of
1 20/02/2019 Leheley Leheley Centre 22 43 65
2 20/02/2019 Wajir Town Baraza Park 13 26 39
3 21/02/2019 Borji Centre Borji Centre 29 58 87
4 21/02/2019 Lagbogol Lagbogol 44 81 125
Centre Centre
5 22/02/2019 Guticha/ Guticha/ 17 17 34
Samatar Centre Samatar
Centre
6 22/02/2019 Kanchara Kanchara 37 31 68
Centre Centre
7 23/02/2019 Lagdima Centre Lagdima 3 27 30
Centre
8 23/02/2019 Habaswein Habaswein 28 86 114
9 25/02/2019 Skanska Skanska 8 31 39
10 25/02/2019 Lagdera Leheley Centre 14 39 53
11 26/02/2019 Sericho Baraza Park 18 50 68
Total 233 489 722
Source: ESIA Study (Feb 2019)
Plate 10: One of the PCM in Progress
Pan-19-003 - 139 -
KeNHA
423. In all the public consultation meetings, attended by a total of 233 women and
489 men, the participants reiterated similar views on both positive and negative
impacts from the road project. The views are outlined below and further details are
contained in minutes of each meeting as presented in Annex 2:
Positive Impacts/ Attributes of the Project:

• Improved Transportation
• Increased Business Opportunities
• Increased Economic activities in Eastern Area
• Job creation
• Revitalization of large-scale livestock production
• Potential increase of export products
• Improved drainage along the road corridor
Negative Impacts/ Attributes of the Project:

• Displacement of persons
• Loss of property
• Disruption of business
• Potential impact on flora
• Potential impact on wildlife habitat and migration corridor
• Soil contamination and erosion
• Impact on culture of the local community
• Impact on cultural sites (graves/mosques/madrasa)
• Impact on water resources
• Impact on wetlands (swamps)
• Air/noise pollution
• Harvesting of construction materials
• Waste management
• Road Safety
424. However, there were specific issues encountered in some of the centres along
the road corridor as outlined below that were unique to these areas.
a) Modogashe (Sericho and Lagdera)
425. From the meetings held at both Sericho and Lagdera, the study team
established that there exists inter clan conflict over resources between the two
communities i.e. Boranas and the Somalis. In Lagdera meeting, the participants
indicated they wish for a compressive plan drawn by both community elders and the
contactor on how locally sourced construction materials would be used and paid for
by the contractor to avoid inter clan squabbles over resources. In addition, any job
opportunities should consider the two communities in an equitable for amicable and
cordial working relations.
426. In Sericho centre, the local community were concerned about the road re-
alignment which in their opinion favoured one community. However, the participants
were assured by KeNHA this particular concern is already being addressed at very
high levels in the Government.
Pan-19-003 - 140 -
KeNHA
b) Samatar/Guiticha and Laghbogol Centres
427. These centres are predominantly occupied by the Somali Community. It’s
important to note that the road separates the centres in two administrative areas
namely: - Wajir West and Wajir South Sub- Counties respectively. It was noted that
resources located in each of the administrative unit is solely used by the residents
from that particular unit. It is therefore important for the contractor to take this into
consideration when planning for mining of construction materials that are available
within these administrative units. Similarly, job opportunities should be awarded with
due consideration to each administrative area.
c) Modogashe, Habaswein and Wajir Towns
428. Where the new road requires slight realignment, or there is need to clear the
entire width of the road reserve, existing structures, which are in the way of the
construction, will be demolished and disposed.
429. This is likely to be intense in Modogashe, Habaswein and Wajir where there is
substantial encroachment into the existing road reserve. However, the local
community were concerned about the current width of the new road corridor (30m
from the centre of the road, on either side). They claimed that the width of the old
road corridor was established by the local authority as 20 feet from the centre of the
road, on either side.
430. KeNHA responded by saying that there should be further consultations

regarding road corridor in the affected centres due to lack of enforcement of the
required road wayleave in the past. This will assist in the determination of how
compensation will be handled.
7.2.2.3 Focused Group Discussions
431. Focused Group Discussions with women, youth and men were done separately
to discuss pertinent issues and any unique concerns that each group may have
regarding the road project. The meetings were conducted from February 14 – 19,
2019. Tables 40 - 42 below summarizes the different FGD meetings held.
Table 40: Focus Group Discussion with Women during Current Study
Number of
No Group Location/Place Date
Participants
1 Women Leheley February 14, 2019 27
2 Women Borji February 14, 2019 22
3 Women Guticha February 15, 2019 21
4 Women Lagbogol February 15, 2019 20
5 Women Habaswein February 16, 2019 10
6 Women Sericho February 16, 2019 18
7 Women Lagdera February 16, 2019 13
8 Women Adamasajide February 17, 2019 13
9 Women Wajir Township February 18, 2019 20
10 Women Kanchara February 18, 2019 22
Total 186
Pan-19-003 - 141 -
KeNHA
Plate 11: FGD with Women

432. A total of 186 women were engaged during the FDGs at various centres as
indicated on Table 36 above. The interviews were facilitated by women to create a
cordial atmosphere for free flow of information. The key findings from the in-depth
interviews and discussions with women groups were that they supported the road
project because it would enhance transportation for passengers and goods in the
region. This in turn will make it easy to access health facilities and market places.
They were optimistic that the project will create business/job opportunities
accompanied with other rippling effects like sinking of boreholes that would
eventually be handed over to the community after completion of the project. This will
greatly alleviate the current water shortage in the project area. However, they were
also concerned that the road project will bring with it other undesirable impacts such
as increased child fatality as a result road accidents, promiscuity by men falling prey
by fashionable women from other parts of the country which may lead to spread of
STDs, and illnesses from pollutants may also be a drawback. The documentation of
all their concerns is summarized in Table 41.
Table 41: Focus Group Discussion with Youth during Current Study
Total
No Group Location/ Place Date Women Men Participants
1 Youth Borji 14 Feb 2019 - 24 24
2 Youth Habaswein 17 Feb 2019 7 6 16
3 Youth Lagbhogol 17 Feb 2019 6 4 10
4 Youth Ali Maow/ Furaha 18 Feb 2019 4 6 10
5 Youth Leheley 19 Feb 2019 16 3 19
6 Youth Lagdera 25 Feb 2019 5 7 12
Total 38 50 88
Pan-19-003 - 142 -
KeNHA
Plate 12: FGD with Youth
433. A total of 88 youths (38 female and 50 male) participated in the youth FDGs.
The Consultant ensured that the facilitators were youthful to actively engage on
socio- economic issues that pertain to youths in general.
434. The youth supported the new road project because it will create both
employment and business opportunities for the youth as well as other senior
community members. The project will also open up the region and make
transportation for both goods and people to the rest of the Country much easier and
cheaper. They also said that the project will improve the overall livelihood of the
community through the development of other associated services e.g. better schools,
health facilities, markets, provision of electricity, water and better housing among
others. But the youth had their concerns as well. They are concerned about the safety
of their younger siblings and the aged parents. The opening up of the region will most
likely increase the poaching of the wildlife and thuggery cases might increase due
influx of people from outside the region whose character might be questionable. More
concerns are contained on Table 39.
Table 42: Focus Group Discussion with Men during Current Study
Number of
No Group Location/Place Date
Participants
1 Men Leheley February 14, 2019 31
2 Men Borji February 14, 2019 16
3 Men Guticha February 15, 2019 17
4 Men Kanchara February 15, 2019 12
5 Men Lagdera February 16, 2019 30
6 Men Habaswein February 16, 2019 8
7 Men Adamasajide February 17, 2019 22
8 Men Wajir Township February 18, 2019 13
Total 149
Pan-19-003 - 143 -
KeNHA
Plate 13: FGD with Men
428. The men focused group meetings comprised of a total of 149 men. The
meetings were conducted by senior male adults to give the elderly the confidence to
engage freely.
429. The men also supported the new road project as it will open up the region for
more business and economic growth. They expect significant improvement on
transportation of goods and people due to low cost of transport and also of time taken
to move from one point to another. The project is also expected to revitalize the
livestock industry in the region and also create job/employment opportunities.
However, the men too were concerned that the development of the new road project
will come at a cost. For example, both religious and cultural values may be eroded,
women may leave them and run away with “rich” men from upcountry, there will be
risk of STDs and poaching of wildlife will increase among others. All of the concerns
have been addressed on Table 43 below.
7.2.2.4 Interpreters During Consultations
430. To enable the consultant team to effectively communicate with the community
members during the consultations, it became necessary to engage the services of
interpreters for Somali and Borana languages. This ensured that all the participants
were able to receive the messages that were being relayed and they were also able
to effectively give their contribution during the discussions.
431. Three languages (Kiswahili, Somali and Borana) were used during the field
surveys, Focus Group Discussions and Public Consultation Meetings. The
participants were made up of village elders, youth representatives, religious leaders,
teachers, KeNHA representatives and the local administration. In majority of the
Pan-19-003 - 144 -
KeNHA
meetings both women and men attended and their different issues were included in
the meeting minutes. However, in most centres including women attended the
meetings but sat at a distance, in order to get the views of women and youth, the
Consultant conducted specialized meetings with women, youth and men separately
and their general issues were included in the report.
7.2.2.5 Overall Findings of the Meetings
432. The meetings included a presentation by the Consultant on the proposed

design, proposed works, various environmental and social impacts that may arise
from the project including resettlement along the road corridor. The consultant
however pointed out that the Designers had tried their very best to minimize
resettlement and that the proposed works would be located within the road reserves.
433. Being that these were public consultation meetings and focused group
discussions feedback from the stakeholders was obtained the analysis of which
indicated that the stakeholders approved the project so long as their concerns were
addressed. The table below provides a summary of the issues raised during the
meetings and the responses thereto.
Pan-19-003 - 145 -
KeNHA
Table 43: Summary of Question, Issues/Concerns from Key Stakeholders/PCMs/FGDs

No Questions / Issues and Concerns raised by Response
Stakeholders
1 • Our main income is from pastoralism and there is drought • All the affected property including land that has been affected by the road project
affecting us. We are now worried about the destruction of will be compensated at market rate (replacement value) before construction of the
property for the construction of the road. Give us assurance that road commences.
affected land property will be compensated.
• Secondly, there are schools bordering the road that do not have • Appropriate measures will be put in place to ensure that schools along the road are
fences and we are worried about the safety/security of our secure during construction of the road. Contractor staff will be sensitised on the
students? same to ensure that there is no interference with the school operations. Safety
measures will be put in place to safe guard against community members, domestic
animals and wild animals
2 • What will happen if the compensation is less than the value of • All the affected property including land will be valued and compensated at the
the affected property? current market rate (replacement value). This is done to ensure that that the
property owner is able to build a similar structure or purchase an equal size of land
in the area where the asset has been affected
3 • What will happen to those who have frontline businesses that are • The affected businesses within the designated road Right of Way (RoW) will be
affected by the road project? given ample notice to vacate. Those whose businesses are affected and do not lie
within the road RoW will be compensated for land, structures and disrupted
businesses
4 • Why is this road RoW 60m while other roads are much • Roads have different classes hence different RoWs. Initially the Modogashe-Wajir
narrower? Road was Class B (40m wide). It has now been upgraded to Class A (60m wide).
• All affected persons will be compensated before construction commences

• There are certain places where project affected persons have
not been compensated. How sure can we be that we will be
compensated?
5 • What will happen to graves that are affected by the road project? • If there are any graves affected by the road project, KeNHA will review the road
design to avoid such graves.
6 • Wil the community be given jobs during construction of the road • Community members will be given priority on jobs available during construction.
project. Men, women and youth will all be considered.
Pan-19-003 - 146 -
KeNHA

Stakeholders
7 • Is there a way of solving the various issues that arise on the • There will be a committee composed of local leaders, religious leaders, community
ground when the project construction is being undertaken? members and KeNHA who will be charged with the responsibility of addressing
issues as they emerge.
8 • There are persons who do not know their fate as to whether they • The Initial RAP Study for the road project has been done to identify those affected.
are affected or not. Can the status be confirmed? There will be a review of the same very soon to confirm if there is anybody that may
have been left out. Later there will be a team of surveyors that will carry out marking
of the road alignment boundaries. The team will be composed of surveyors from the
following organisations/Institutions:
• KeNHA Surveyor
• County Roads Surveyor
• County Housing and Planning Surveyors from Wajir, Isiolo and Garissa Counties
• PAPs Surveyor (if need be)
• The above road marking will be done openly and in the presence of
the PAPs representative so that every PAP will be able to know how
they are affected.
9 • We are worried that large shade trees along the road that • Only trees that must be cut down will be cut down during road construction. Those
communities use as resting places when on long journeys will be large trees that can be avoided will not be touched. As part of the reforestation,
cut down? KeNHA will facilitate planting of trees to replace those that have been cut. They will
also encourage/facilitate planting of trees along the road corridor to improve the
project area environment.
10 • There some people who were given letters indicating that they • In the next few days there will be a team that will carry out a review of the road
have been affected by the project while others have not received corridor affected persons. There will also be a team of surveyors that will demarcate
any. Could those who have not received letters proceed with the road corridor that will conform who has been affected and those that have not
their development activities? been affected. No new development should be done along the road corridor since a
cut-off date (Feb 21, 2018 for Modogashe-Samatar Road) had already been set and
if the new development falls within the corridor, no compensation will be paid out.
11 • We fear that when the contractor completes his work, the • When the contractor completes road construction activities, the boreholes will be
boreholes that are supposed to be used by the community will be handed over to the community through their representatives (committee).
hijacked by politicians and closed and therefore community
members will not be able to use them?
12 • There are mechanisms that can be used to solve issues since we • All emerging issues and conflicts will be solved locally through the committees that
have elders that can provide solutions to emerging issues. Can will be set up. Issues will only be escalated to higher offices if the local mechanisms
local mechanisms be used first before issues are escalated to fail to provide a solution
higher offices?
Pan-19-003 - 147 -
KeNHA

Stakeholders
13 • Boreholes that are drilled in Borji are never completed to the • The necessary hydrogeological assessment will be carried out to determine whether
required depth hence the boreholes never get to the water level. there is underground water at Borji
It appears there is someone against Borji getting successful
boreholes?
14 • We have attended several meetings and yet we do not know • The ESIA study are being done to get EIA license and to identify potential
when the project will commence. We are having doubts about the environmental and social impacts of the project before construction commences.
survey that was done since some people are being told they are We are not able to mention the exact date of commencement, but once the ESIA
affected while others along the same row are not being told and RAP studies are completed and the project affected persons are compensated
anything? and resettled, the road will be ready for construction.
15 • The Centre of Lagbogol was started by us even before the • If the centre was set up before the councils demarcated the area, then such
Council demarcated land to set a side road corridor. We should information should be provided to the authorities so that appropriate measures can
therefore not be penalised that we have put up structures within be put in place to safeguard land property. Such information will guide further
the road corridor? consultations on the next cause of action.
16 • Where is the contractor coming from? We hope an international • The contractor that will be constructing the Modogashe-Wajir Road is yet to be
contractor will be engaged. appointed. The road is now Class A classification. The contractor that will be
engaged will be required to show competence of being able to construct Class A
road.
17 • I was starting to construct a building but had to shift when we • Class A requires a road corridor of 60m (30m on either side from the centre of the
were informed about the road. Now considering the dimensions carriage way. Before compensation is done, a team of surveyors will come to the
of the Class A road, it wold appear that I may still be affected. ground and mark the road corridor. All persons with land and structures next to the
Can you clarify the true position? road corridor will be shown how they have been affected by the new road corridor.
18 • We had put our request to an earlier survey team that we as a • The requests were recorded and the report is with KeNHA. KeNHA has the mandate
community we need a water pan, school buildings (students are of constructing roads but they will share the requests with other relevant agencies.
learning under a tree) and a dispensary. Did our request go To a large extent, the issue of water will be addressed by the contractor since he will
without consideration or is this the same team? be sinking boreholes for construction activities. These boreholes will be handed over
to the community after completion of construction works. They will be allowed to use
he borehole water during construction but priority will be the road project during
construction.
19 • Most facilities like schools, water pan and Boreholes are located • The activities you have mentioned are being implemented by the County
in Kanchara Location Wajir West Sub-County while Samatar Government of Wajir.
Sub-location Wajir South Sub-County has none. The borehole
that was drilled 5 months ago has not been equipped?
Pan-19-003 - 148 -
KeNHA

Stakeholders
20 • We have been informed that the contractor will drill boreholes for • The contractor will target good quality water for the road construction but may not
his use and hand over to the community after completion of the guarantee that he will get good water for irrigation. The interest of the community in
road works. Can the contractor target good water that the carrying out irrigation agriculture is noted and perhaps development of water pans
community can use for irrigation? should be considered
21 • Women are the backbone of the community. They are the ones • The contractor will include ample shades at the bus stops so that women can be
providing for the families. When the road is being constructed, able to keep their commercial milk fresh as they wait for transport to other
ensure that you provide ample shades at the bus stops where centres/towns.
women can keep their milk while waiting for transport to urban
areas.
• We also request that quarries/borrow pits be converted to water

• Borrow Pits/Quarries to Water Pans: The Borrow pits/Quarries will be developed
pans so that we can have adequate water irrigation?
into water pans for use by the community if they choose to advise so.
22 • We fear that the contractor will bring a lot of money into the • KeNHA together with the project area religious and administrative leaders should
project area that will influence our girls and wives into sexual sensitize/educate community members including youth on the consequences of
activities that may result into unwanted pregnancies, sexually engaging in illicit sexual activities. The contractor will also be expected to caution
transmitted diseases and other ills? and also sensitize/educate the workers on the same. Parents will be expected to
talk to their children about the changes and influences that might be brought about
by the project and how they can guard themselves against falling prey to illicit
activities. One of the Contractor’s obligation will be HIV/AIDs awareness. This will
be carried out for both the workers and community members including Code of
conduct to ensure worker’s behaviours are managed
23 • When implementing the road project, kindly consider both sides • All sides of the road will be considered during implementation of the project. The
of the highway (Wajir West and Wajir South? contractor will work very closely with the committee that will be put in place to
oversee project activities within the area. These will include distribution of job
opportunities and businesses that will arise during road construction like provision of
materials and other services to the contractor
24 • The youth request to be given first priority when job opportunity • Equal opportunities for jobs will be provided to community members during
become available during road construction? construction. There will be jobs that can be done by skilled and unskilled workers.
Committee members that include elders and religious leaders will assist in ensuring
equitable distribution of job opportunities is done.
25 • How will you (KeNHA) ensure that the selected committee does • Committee Operations: The committee members composed of elders representing
not get influenced by the high and mighty of the society? the community will be composed of religious leaders, local leaders and
representatives from the community. We believe these persons will have the
Pan-19-003 - 149 -
KeNHA

Stakeholders
integrity to safeguard the interest of the community and guard against any influence
from outside.
26 • I am the only Borana in this community. Where I run my business • If the affected rented structure deserves compensation, the disruption of your
is rented and it has been affected by the road project. What will business will also be determined and compensated. This is done by paying the net
happen to me? monthly income for a period of 3 months. It is believed that within 3 months the
affected business can be relocated and re-established.
27 • Will there be proper documents showing affected property that • Property affected by the road project will be well documented for compensation.
will be compensated and demolished?
• As far as establishment of the true land owners is concerned, local and religious
• Land allocations have not been properly done and this may leaders and community members will be consulted. There will be further
create challenges during compensation. consultation with County Offices to establish true land owners since very few land
owners have documentation.
28 • Our fear is that there may be external influence from politicians • External Influence: KeNHA will ensure that what has been agreed on is
that may change what we have agreed on and this may result in implemented. The committee representing the community will oversee this
conflict.
• Lack of Land Documents: KeNHA and NLC will use information local offices, elders
• We do not have land documents. How will compensation be and community members and also support from the County Land offices to establish
handled? land ownership for compensation
29 • There will be increased noise and air pollution during • The contractor will sprinkle water during construction to suppress dust
construction
30 • Influx of people to the region will bring about cultural changes, • The religious leaders who are present here today together with elders are requested
and incidences such as inappropriate dressing and infidelity that to play an important role in instilling moral values to the community to mitigate
may break families against any negative influence.
31 • Medical facilities are lacking • This has been noted and requisite agencies will be notified for further action.
32 • The Religious Institutions should be involved in the project • The religious leaders are being involved and a special meeting with them have been
matters conducted in major trading centres
Pan-19-003 - 150 -
KeNHA
7.2.3 Disclosure of the ESIA
434. Disclosure involves making the ESIA available to the public, and any interested
persons. Disclosure of the ESIA report will be done within the Country at the Counties,
KeNHA website and in the World Bank external website which can be accessed by
interested parties. Since the project area is in a rural area, where majority of the
residents have limited access to the Internet, printed reports will be given to the local
administration for use by the local community.
7.2.4 Consultation during the Project Duration
435. The Consultant also proposes that continuous consultation be carried out
throughout the construction phase of the project using focus group discussions to
ensure interested stakeholders are aware of construction procedures and provide a
forum for feedback and recommendations for implementation in the construction, the
consultation will occur during the environmental and social supervision, monitoring, and
evaluation which will be carried out every four months. In addition, there is a grievance
redress procedure which is provided in Chapter 10 of this report.
Pan-19-003 - 151 -
KeNHA
8 POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES
436. The proposed upgrading of the Modogashe-Wajir Road to bituminous standards is

going to generate both positive and negative environmental and social impacts. A lot of
the positive impacts will be associated with the benefits that the improved road will bring
to the community and region at large. The anticipated negative impacts are related to the
earthworks, use of borrow pit/quarry sites, concrete and paving works, disruption of
settlements, influx of workers (Labour Influx), increased construction traffic, occupational
and community health and safety, risks associated with HIV/AIDS, impacts on women
and children, Gender Based Violence (GBV) issues, Violence against Children (VAC),
security, increased pressure on resources leading to conflicts and gender based
violence. Apart from the unavoidable displacement of persons, the identified project
impacts can be mitigated through implementation of appropriate mitigation measures.
437. In general, successful implementation of the project will have high environmental
and socio-economic benefits to the people and will contribute to the positive development
and improved economy of the project area. The magnitude of each identified impact is
described in terms of being significant, minor or negligible, temporary or permanent, long-
term or short-term, specific (localized) or widespread, reversible or irreversible. This
section of this ESIA report identifies positive and adverse impacts of the road project and
recommends measures to mitigate the identified negative impacts.
Table 44: Provides an assessment of the potential negative impact.
8.1 Categorization of Impacts
438. The assessment of the potential environmental and social impacts has been done
using the following categories:
• Low Impact (L) – Potential environmental and social impacts that are deemed to have
minimal effects on the environment and will therefore not require detailed evaluation in
the ESIA Study
• Medium Impact (M) - Potential environmental and social impacts that are deemed to be
moderately significant, and will require reasonable investigation in the ESIA
• High Impact (H) - Potential environmental and social impacts which are deemed to be
highly significant and need detailed assessment in the ESIA
439. The impact Characteristics that have been used to define impacts include the
following
The nature of Impact where:
Positive (Pos): applies to beneficial impacts

Negative (Neg): applies to impacts that have a harmful effect such as economical cost, loss
or degradation of environmental resources.
The Effect:
Direct (Dir): applies to impacts which can be clearly and directly attributed to a particular
impacting activity.
Indirect (Ind): applies to impacts which may be associated with or subsequent to a particular
impacting activity, but which cannot be directly attributed to it.
Pan-19-003 - 152 -
KeNHA
Time Range:
Short Term (ST): applies to impacts whose effects on the environment will disappear within
a 1-year period, or within the construction phase.
Medium Term (MT): applies to impacts whose effects on the environment will disappear
within a 5-year period following the construction phase.
Long Term (LT): applies to impacts whose effects on the environment will disappear in a
period greater than 5 years following the construction phase.
Reversibility:
Reversible (Rev): applies to impacts whose significance will be reduced and disappear over
time (either naturally or artificially), once the impacting activity ceases.
Irreversible (Ire): applies to impacts whose significance will not be reduced nor disappear
over time (either naturally or artificially), once the impacting activity ceases
Phases of the Project

PC – Pre-Construction
C – Construction
O - Operation
Pan-19-003 - 153 -
KeNHA
Table 44: Assessment of Potential Negative Impacts

Rating of Nature Effect Duration Reversibility
Rationale
No Aspect Impacts
PC C O Pos Neg Dir Ind ST MT LT Rev Irev
1 Air pollution L H L √ √ √ √ √ [Construction]
The main source of air pollution will be exhaust gas and fugitive dust
emission from heavy construction works at the quarry/borrow pit sites,
stone crusher plant, Asphalt plant, concrete batching plant, road
works and road deviations. This will affect the centres located next
to the project road.
2 Water pollution L H L √ √ √ √ [Construction]

Sediment-laden rainwater runoff from road excavation works may
pollute downstream surface waters. Contractors camp site where oils
and other chemicals are stored have the potential to impact surface
and shallow groundwater. Oil spill/leaks from construction
vehicles/machines and fuel tanks may cause water pollution
Uncontrolled discharge of concrete wash water may temporarily

pollute the receiving water body as concrete wash water often has
elevated pH levels. Impacts however will not be significant, as pH will
be gradually neutralized.
3 Soil pollution L H L √ √ √ √ [Construction]
Oil spill/leaks from construction vehicles/machines and fuel tanks
may cause soil pollution. Significant impacts are not expected as the
magnitude of oil spill/leaks if it occurs will be limited to a relatively
small area.
4 Solid and Liquid L M L √ √ √ √ [Pre-construction]

Waste Felled trees will be generated from site clearance. However, impacts
are not expected as these can be reused for other beneficial purposes
by the local community (e.g. fuel, building material, furniture).
[Construction]
Significant impacts are not expected as construction wastes can be
readily accommodated by the county’s waste disposal mechanism or
recycled through NEMA authorized recycling firms such as for waste
oil.
[Operation]
There will be minimal impact during road operation as far as waste
generation is concerned.
Pan-19-003 - 154 -
KeNHA

Rationale
No Aspect Impacts
5 Noise/ L H- L √ √ √ √ [Construction]
vibration Noise:
The main source of noise will be from quarry site, road construction
machinery and vehicles delivering materials to the site and pile driving
works. According to the noise impact prediction, noise from pile
driving works will attenuate to around the same level as the Kenyan
noise standard of 50 dB (residential day-time) at a distance of 300 m.
Since there are several housing structures (residential and
commercial) within this 300m zone, construction works may cause
some nuisance to the residents.
Vibration:
The main source of vibration will be from hydraulic pile driver, quarry
activities and the road compactor. According to existing literature, in
case of hydraulic pile-driver, vibration levels will in general attenuate
to below 75 dB after 25 m. minimal impacts are expected within such
distance.
6 Conservation L H H √ √ √ √ √ [Construction]
areas (Wildlife) There are no protected conservation areas within the project area.
However, presence of wildlife within the project area makes the area
sensitive and therefore a higher level of caution shall to be taken in
terms of noise control and working hours which shall be restricted to
between 8am and 5pm. Movement of wildlife will be disrupted.
[Operation]
The constructed road will be significantly elevated hence movement
of certain large wildlife like the giraffe from one side of the road to the
other will be restricted making them get stranded and may make them
become vulnerable to other predators or poachers.
Pan-19-003 - 155 -
KeNHA

Rationale
No Aspect Impacts
7 Ecosystem, M H H √ √ √ √ [Pre-construction]
flora/fauna There are different wildlife species and a few scattered trees located
along the road corridor. The Lorian and Borji Swamp areas have more
wildlife and vegetation. The contractor may have to cut down a few of
the trees. There are wild animals within the project area.
[Construction]
Construction activities of the road will disturb wildlife in the project
area especially at the Lorian and Borji Swamps where majority are
concentrated during the dry season. There will be disruption of their
free movement and generation of excess noise. The road reserve
within the swamp areas will loose some vegetation used by the
wildlife.The presence of construction labor force will also cause
distress to the animals. There will be needed to minimize activities
within the swampy areas. Noise levels and the working time will be
controlled to avoid creating significant impact.
[Operation]
There is possibility that traffic accidents with wildlife will occur. The
presence of the new road will attract socio-economic activities that
may permanently disrupt the wildlife ecosystem. They will require
access points to be able to move from one side to the other.
The presence of the elevated road may confine the wildlife to one side
of the road causing depletion of resources and impacting the
ecosystem especially during the drier periods. The elevated road may
also cause wildlife fragmentation.
8 Involuntary M L L √ √ √ √ [Pre-construction]
resettlement The Project will result in displacement of some traders carrying out
their businesses inside the road reserve
9 VMGs H L L √ √ √ √ [Pre-construction]
The project area community are classified as vulnerable and
Marginalized Groups who are largely poor.
10 Increased Traffic L H H √ √ √ √ √ [Construction]
on the project The contractor’s vehicles and trucks will be plying the project area
regularly increasing noise and air pollution. There will also be the risk
road of accidents occurring
[Operation]
There will be increase in traffic using the road hence transportation
will improve. However, on the other hand, there may be increase in
road accidents due to fast moving vehicles.
Pan-19-003 - 156 -
KeNHA

Rationale
No Aspect Impacts
11 Health and M H L √ √ √ √ √ Construction]
Safety There will be high risk occupational safety associated with the
following operations during construction:
• Operation of the various machines used during construction
• Quarry and Borrow Pit operations
• Stone Crusher, Cement Batching Plant, Concrete Batching Plant
[Operation]
There is minimal risk of occupational accidents during road operation.
12 Livelihood, living M M L √ √ √ √ [Pre-construction]
environment The Modogashe-Wajir road has been classified as a Class B road
with a corridor of 40m. It is being upgraded to a Class A road with a
corridor of 60m wide. However, at the town or market centres, the
RoW will be narrowed to 30m to minimize impact. The mobile traders
that are carrying out trading along the existing corridor are the ones
to be displaced
The illiteracy among community members is high and therefore they
will require well-coordinated support for livelihood restoration.
[Construction]
Livelihood activities such as small-scale mobile traders along the road
corridor in the bigger towns (Modogashe, Habaswein and Wajir) will
be affected.
13 Land use M M L √ √ √ √ [Pre-construction]
The road corridor is largely used by the community to run medium
and small-scale businesses like grocery shops, fruits and vegetable
vending. Pre-construction impacts will come from the displacement of
persons carrying out businesses along the road corridor.
[Construction]
Affected land parcels will be acquired for construction of the road and
owners will need to acquire new land parcels. This will disrupt the
businesses and cause loss of livelihood. Mobile businesses will also
have to relocate
Pan-19-003 - 157 -
KeNHA

Rationale
No Aspect Impacts
14 Labour Influx H H L √ √ √ √ [Pre-construction] and [Construction]
• People with different beliefs, culture and lifestyle will come to the
project area and influence the lifestyle of the community. Cases
of GBV, SEA may rise.
• Sexual Exploitation and Abuse of Children
• There will be increased pressure on resources. There will be
conflict over job opportunities and increase in crime.
15 Cultural L M L √ √ √ √ √ [Pre-construction]
Resources The only facilities of cultural importance to the local community along
the road corridor that are to be avoided include Mosques, Madrasas
and Graves.
[Construction]
To minimize impact, the Design Consultants have reduced land take
by using the available corridor. The potential cultural resources that
would have been affected have been avoided. However due to the
fact that some cultural resources may be in the subsurface, a
“Chance Find Procedure” has been provided in Annex 6 for the
contractor to use to safeguard any artefacts he may come across
during construction (excavation) of the road corridor.
16 Climate change L H H √ √ √ √ √ Climate change will have significant impact on the project especially
the Lorian and Borji Swamps where there has been increased
intensity of flooding that will cause erosion and scour damage on road
embankments
17 Gender (GBV M H L √ √ √ √ [Pre-construction] and Construction
issues including There will be increased harassment of women in and around the
project
SEA and Sexual
[Construction]
Harassment) • Harassment of women at the work place
• Discrimination of women when jobs are being given out
• Culture of women being subservient. Men refusing to take
instructions from women
• Sexual Exploitation and Abuse (SEA)
• Violence Against Children (VAC)
Pan-19-003 - 158 -
KeNHA

Rationale
No Aspect Impacts
18 Children’s right L H L √ √ √ √ [Construction]
Since child labour is relatively common in Kenya, there is a certain
possibility that underage children can be exploited for construction
works. Majority of the households in the project area have low income
levels hence there will be tendency for children to look for jobs to help
their families.
[Construction]
Due to the high poverty levels, there is high potential for children to
sexually exploit and abuse such children particularly with the influx of
people looking for jobs
19 Infectious L H L √ √ √ √ √ [Construction]
diseases The contractor will bring in a good number of construction workers
during construction. The HIV prevalence in Wajir county where three
(HIV/AIDS etc.) quarters of the project road passes is very low (0.9%). The workers
may engage in unprotected sex with community and spread HIV
among other diseases.
20 Occupational D A- H √ √ √ [Construction]
safety and There will be high risk occupational safety associated with the
following operations during construction:
accidents
• Operation of the various machines used during construction
• Quarry and Borrow Pit operations
• Stone Crusher, Cement Batching Plant, Concrete Batching Plant
[Operation]
There is minimal risk of occupational accidents during road operation.
But the potential for traffic accidents during operation is high due to
the presence of livestock and wildlife that move about in search of
pasture and water.
21 Socio-economic L H M √ √ √ [Construction]
Generation of job opportunities during construction
[Operation impacts]
Improvement of the economy of the project road counties and beyond
due to improved transport network that will boost investment in trade
and industry in the area.
22 Increased M H L √ √ √ √ Intercommunity and Intracommunity conflicts arising from competition
Conflicts over scarce resources
M H L √ √ √ √ Conflict between project workers and the local community
Pan-19-003 - 159 -
KeNHA

Rationale
No Aspect Impacts
23 Security Risk M H L √ √ √ √ √ √ √ [Construction]
and Crime • Insecurity at the project site area during construction due to
presence of Contractors Equipment and Staff
Management
• Improved security due to presence of security personnel
24 Wild life and L M H √ √ √ √ [Construction]
Livestock • The road embankment will be high hindering easy crossing for
some wildlife and livestock
crossings
25 Lorian and Borji L H H √ √ √ √ [Construction]
Swamp • Alteration of water flow in the ecosystem due to interference with
water flow patterns
Ecosystems
• Potential pollution of the surface and shallow groundwater
sources
[Operation]
• Alteration of livestock and wildlife movement by the presence of
the road will affect ecosystem resources in terms of forage and
water
• Water movement across the road may be interfered with causing
changes in the hydrology of the project area.
Pan-19-003 - 160 -
KeNHA
8.2 Potential Positive Impacts
440. Improved road connectivity in the north-eastern region, will not only open this region
economically but it will also elevate and improve the livelihoods of the marginalized
Somali and Borana communities living in the region. Some of these benefits and their
justification are outlined in Table 45 below:
Table 45: Potential Positive Impacts and the Justification

Potential Positive Justification
#
Impact
1. Improvement of Poor The poor status of the Modogashe-Wajir Road is a challenge to
Infrastructure of Wajir, truck and public transport drivers. The road is causing damage to
Garissa and Isiolo the vehicles that ply that route. The upgrading of this road will ease
Counties (Modogashe - transportation of people and goods. This in turn will boost business
Wajir (A13) Road) and increase economic growth not just for Wajir, Garissa and Isiolo
Counties alone but also for the neighbouring counties and beyond.
2. Improvement in gender It is envisaged that the upgrading of the road will improve
parity availability and accessibility to social amenities, such as schools.
Thus, women will have access to improved education facilities
thereby enabling women to compete on an equal footing with men.
The improved road will enhance service delivery including
improved health services where the women will benefit greatly
3. Enhanced economic There will be enhanced economic growth and improvement of the
growth due to improved livelihoods of the communities of this region given the harsh climate
road connectivity and the high poverty levels.
4 Improvement of socio- Investments that will be generated in the region will create job
economic status and opportunities that will in turn bring in better earnings and living
livelihoods of standards of the community. The cost of living will come down and
marginalized more people will have access to better living standards (good
communities shelter, food and health services among others).
Due to the poor road condition the cost of goods and services is
higher when compared to other parts of the country. The improved
road will bring down the cost of transportation and hence lower the
cost of goods and services which will in tun improve the economy
project area community
5. Creation of Jobs and The proposed project will provide direct and indirect employment
Employment opportunities. For instance, skilled and unskilled workers will be
Opportunities: During employed by the project during its construction. In addition, there
Construction will be opportunities for establishing shops / kiosks and other small-
scale businesses to provide some of the immediate needs of project
staff. A lot more employment opportunities will arise from
investment and economic opportunities attributable to improved
road connectivity. Some of the employment opportunities will arise
from improvement in commerce and trade, new jobs in the transport
industry, improved tourism and adventure safaris, better market
access for livestock and livestock products, market access for on-
going mining activities and irrigated agriculture.
6. There will be enhanced Travel time to destinations will be greatly reduced. This will be a
productivity, reduced relief to many motorists who have to travel from other parts of
travel times and less Kenya to the north-eastern region and vice versa.
stress to road users.
7. Reduced transport costs Truck drivers and other motorists will take much shorter time to
for transport companies reach their destination. This will result in less fuel consumption,
and other motorists that which will not only be a saving to the transporters and other motorist
would want to access but also a saving to the country on foreign exchange since fuel has
the region to be imported into the country.
Pan-19-003 -161 -
KeNHA
Potential Positive Justification

#
Impact
8. Economic and social There exists a close relationship between transport infrastructure
value addition to the and primary production (agriculture, animal husbandry, fishing,
project’s local area of forestry and mining). Without transport access, much of primary
influence production is not feasible. Availability of transport infrastructure
attracts not only traders and transporters, but also agricultural,
animal husbandry and other extension services. Equally important,
improved access also impacts on education, health and other social
services, which are essential for social and economic development
9. Appreciation of Property Development of the road network in Garissa, Wajir and Isiolo
Value Counties will create influx of would be investors resulting in high
demand for property within the project area.
10 Opportunity to improve Local communities around Habaswein area expressed concern
road drainage design during public meetings about the flooding of the area during the
rainy season. Thus, the upgrading of the proposed road offers an
opportunity to improve the existing drainage design for the area for
the benefit of the environment and local communities through the
construction of appropriate culverts and bridges to improve
drainage and protect the new road.
11. Site Area Infrastructure The project is going to enhance development of project area
infrastructure that is going to improve livelihood of the project area
residents
12 Improved response to Wajir County and adjoining areas are arid. Provision of relief food
emergencies and and other forms of humanitarian aid is therefore common. The
humanitarian aid improved road is expected to aid in rapid response to such
emergencies which will in turn save human lives and livestock.
It will be possible to quickly deploy security officers to attend to any
emergency. Banditry will reduce since the road will enhance faster
movement reducing the chances for bandits to attack.
Source: ESIA Field Survey Activity – Modogashe - Samatar - Wajir Road 2019
8.3 Environmental Impacts and Mitigation Measures
441. The proposed road project will generate impacts during the following phases
• Pre-Construction Phase (Planning Phase)

• Construction Phase
• Operation Phase (When the Road is in use)
• Decommissioning Phase)
8.3.1 Pre-Construction Phase/ Impacts
Impact
442. During this phase of the project, environmental impacts are expected to come from
acquisition of the road corridor. The road corridor is largely traversing community land
with settlements that contains trees, grazing land and other resources including
sacred/cultural sites.
Mitigation Measures
• The project road corridor has been identified and the revised road design that that
minimizes impacts at the market centres and towns has been prepared.
• The design is using the existing road corridor as much as possible and the RoW at the
town centres has been reduced from 60m to 30m to minimise impacts on settlements
that have structures and resources like trees, graves and water wells
Pan-19-003 -162 -
KeNHA
8.3.2 Construction Phase Impacts
443. Majority of the project foreseen impacts will emanate during construction. The
impacts that will be generated will come from borrow pits, quarry sites and excavations
at the construction sites. Operating trucks and other machines are also going to generate
impacts during construction. Oils and fuels that have the potential to contaminate soils
and pollute water sources will be handled at the project site. The Contractor’s camp will
be generating domestic and sanitary waste that requires appropriate management since
the project area has sensitive receptors (swamps and dry river laggas that hold water for
the community, livestock and wildlife when it rains). Most of the potential impacts
occurring during the construction phase are temporary and can be mitigated by applying
international and local environmental and social management procedures. The potential
impact of each identified activity is discussed and mitigation measures propose
8.3.2.1 Impacts on Flora
Impacts
444. During construction, vegetation clearance will occur to pave way for the project
footprint. However, the clearance is expected to be restricted to the current wayleave
hence minimal.
445. The impact on flora is anticipated to be a direct result of the energy requirement by
the construction workers who may require firewood or charcoal for cooking as opposed
to clearing of vegetation for construction works. The project area has species of Prosopis
juliflora which is an invasive species. Earth works during construction and material
extraction works may aid in dispersal and proliferation of the species.
Mitigation Measures
• Vegetation clearance should be restricted to the project footprint
• Discuss with the local community and relevant authorities on methods of revegetation or
compensation for the lost vegetation
• Areas to be cleared should be demarcated beforehand
• Except to the extent necessary for establishing the construction site and carrying out the
construction works, vegetation shall not be removed, damaged or disturbed
• The construction workers should be sensitized on the need to use alternative sources of
fuel to meet their energy requirement
• It is practically difficult to abate the advancement of Prosopis juliflora however control
measures can be implemented by constantly monitoring the area to control the
advancement.
• Spare the vegetation that must not necessarily be removed such as trees
8.3.2.2 Impacts on Fauna
Impacts
446. The project area is rich in fauna. Vegetation clearance of trees along the road and
noise and vibrations from construction activities such as excavation, blasting, crushing
and haulage may cause habitat disturbance for the avifauna and various mammalian
species within the project area. Construction workers may also engage in hunting posing
a threat to the wildlife diversity in the area. Improved access may also lead to increased
poaching and wildlife road kills. On the other hand, some wildlife may be a safety risk to
the workers.
Pan-19-003 -163 -
KeNHA
There is possibility that traffic accidents involving wildlife and livestock may occur. The
presence of the new road will attract socio-economic activities that may permanently
disrupt the wildlife ecosystem in the project area. The road may restrict the free
movement of the wildlife from one side of the road to the other. The restriction may cause
some animals to get stranded and become vulnerable to predators and poachers. The
elevated road may make wildlife or livestock group themselves on one side of the road
causing depletion of resources and impacting the ecosystem especially during the drier
periods. The elevated road may also cause habitat fragmentation.
Mitigation Measures
• A code of conduct should be developed by the contractor to ensure that their workers do
not consume game meat from the area, whether supplied by the locals or killed by
themselves.
• Awareness creation amongst the local people and the construction workers of laws that
relate to wildlife hunting and consumption, and the importance of wildlife as a natural
resource and heritage.
• Avoid night time construction when noise is loudest. Avoid night-time construction using
heavy machinery, from 22:00 to 6:00 near areas known to have wild animals
• Design and providelivestock and wildlife animal crossing infrastructure e.g. Culverts at
the selected crossing points
• The contractors camp should have a proper fence that will keep wild animals away.
• Collaborate with the KWS during construction period to discuss and resolve issues
related with wildlife conservation.
• Provide speed calming measures at areas designated as livestock or wildlife crossing
points
• Install retro-reflective signs where animals and wildlife crossings are located
• Socio-economic activities shall be encouraged away from wildlife localities and crossing
areas hence the proposed social infrastructure such as market shades, milk cooler,
slaughterhouses, veterinary posts, livestock holding area, etc. should be located away
from the Lorian , Borji Swamps and any sensitive ecosystem .
8.3.2.3 Wildlife and Livestock Crossing
447. The Lorian swamp that receives water from the Ewaso Ngiro River, Boji swamp and
the seasonal river laggas provide seasonal sources of water and forage for both wildlife
and livestock during the dry season. Wildlife and livestock therefore use these locations
as road crossing points.
448. Consultation with KWS, Wajir revealed that there are several wildlife species which
are found along Modogashe – Wajir road. This wildlife includes; giraffes, ostriches,
gazelles, hyena, lion, warthogs, and cheetah. Small games like Dikdiks, jackals and
guinea fowl are also found.
449. There is a sizeable giraffe, guinea fowl, warthogs, gazelles and elephants in ten
which crosses at Lorian swamp, Lagdima, Boji and Qumbu (Leheley area.). This wildlife
are attracted by the foliage at Ewaso Ngiro and water at the swamp. In addition, there
are individual stragglers (hyenas and jackals) which cross at no defined positions along
the road corridor. Most of this crossing takes place during the night and early mornings.
450. Several accidents involving wildlife have been witnessed and reported along the
road corridor, most affected wildlife includes giraffes, hyena and warthogs. Other small
game like dikdik and guinea fowl are also hit by speeding vehicle.
Pan-19-003 -164 -
KeNHA
451. Little movement of livestock was experienced at the time of this study across the
road since the road acts as a boundary between different communities hence not much
cross boundary movements were noticed.
452. The Giraffes are the most critical wildlife species in the context of this project since
they are likely to be affected by raised steep surfaces. The project design is expected to
raise the road by approximately 1.5m to 2m and 2m to 4m in the 25 km Lorian Swamp
section.
Mitigation measures
• The gradient of slope of the road embankment should be gentle to allow for smooth
crossing of wildlife and livestock.
• Install retro-reflective road signs and speed bumps on the known wildlife crossing points
to regulate speed and warn motorist
• Ensure all the Contractor’s camps are sited away from the wildlife corridors to prevent
conflicts.
• The study recommends that a design engineers evaluate various crossing design options
for potential environmental and social impacts and discuss them with the KWS,
communities and relevant wildlife NGOs before finalizing the design.
• Collaborate with Kenya Wildlife Service to protect wildlife during construction period
• The Contractor code of conduct should include conditions on wildlife conservation and
measures to sanction errand workers involved on hunting
• Maintain the proposed below ground livestock and wildlife infrastructure i.e. bridges and
culverts
• Signage of lower speed limit of 70km/hr or as guided by KWS should be placed at frequent
wildlife and livestock crossings.
• Avian nesting sites found along the road should be relocated before trees are cleared for
the road construction
• The assessment recommends an in-depth and focused biodiversity assessment for Lorian
and Borji swamps prior to construction works to understand their status , identify potential
impacts of construction and operational on the wetlands and to identify additional
mitigation and enhancement which may be undertaken both in the short and longterm to
meet the requirements of the OP/BP 4.04 and the National Biodiversity Strategy Action
Plan (NBSAP). The study will be carried before commencing of the construction works and
will prepare Biodiversity Management Plan (BMP) that will be incorporated to the works
contract.
• The assessment recommends Contractors to consider designing and locating borrow
areas so that during dry season, the ponds act as small reservoirs to recharge
groundwater, act as local watering holes for livestock and wildlife so as to lower frequency
of crossings by some wildlife and livestock herders.
8.3.2.4 Impacts of Camp Site Construction and Operation
453. The road construction will require central points for management offices, material
and equipment stores, machinery services and other coordination purposes. The camp
categories will include workers camp, operations camp (offices, stores and workshops)
and materials holding camps. Among the impacts anticipated would include:
• Vegetation clearing and loss of important trees;

• Firewood harvesting;
Pan-19-003 -165 -
KeNHA
• Discharge of domestic related wastes (sewage and garbage) which have potential for
environmental pollution and health risks to the affected public;
• Dumping of construction wastes including oil residuals, bitumen/asphalt, cement;
• Residuals scrape machine parts and waste water could significantly impact on
environmental resources, especially ground water;
• Emission of dust and other gases from camps may affect the health and comfort of
workers. Continued exposure to such emissions can lead to contracting respiratory
diseases and eye infections. This will relatively reduce their output as they will be
unable to perform their duties as they would when in good health. In the same way, the
neighbouring community may also have ill health due to continued exposure of dust
particles which can be transported by air to long distances;
• Noise and vibration from material preparation in camp sites and quarry excavation and
blasting could affect houses close by causing walls of structures to crack thus
weakening the structure and integrity of the buildings.
Mitigation Measures
• Prepare waste management plan
• Cut down trees that must be cut otherwise accommodate them within the camp
• Institute proper waste collection temporary storage and disposal by providing each office
and dwelling place with a waste bin
• Pave the waste collection area
• Engage a NEMA registered firms (both ordinary and hazardous waste) for collection and
disposal
• Contractor to ensure all workers are familiar with the worker’s code of conduct with
regards misuse of the camp to perpetrate sexual exploitation and abuse of women and
girl child including other house rules that promote safety and security of the camp.
• Fuel dispensing areas to be paved with containment
• All equipment and construction supplies to be stored on paved surface especially the
hazardous materials like oils, lubricants, bitumen, paints etc.
• Workers’ accommodation should have appropriate ventilation/fans since the project area
is largely arid with high temperatures experienced all year around.
• Workers to be provided with appropriate latrines and disaggregated for male and female.
Consider differences in culture and religion.
• Institute regular monitoring of septic tanks and engage a sanitary waste exhausting firm
to be emptying the septic tanks regularly before overflow occurs
• Contractor to ensure the camp site is devoid of dust either through appropriate
construction of the roads within the camp or regular spraying of water to suppress fugitive
dust
• Institute speed control within the camp
• Contractor to ensure technicians working at the garage are instructed to carry out
maintenance repairs and service of vehicles and machinery at the paved areas of the
garage
• All the recovered oils and lubricants to appropriately stored in drums placed on a paved
surface with containment for collection by a NEMA registered hazardous waste disposal
firm.
• Make use of chain of custody form for handling and disposal of used oil and other
hazardous wastes
8.3.2.5 Noise Pollution and Excessive Vibrations at the Road Construction Site
Impacts
Pan-19-003 -166 -
KeNHA
454. The project will involve use of heavy earthmoving equipment and trucks at the road
construction site which can generate excessive noise and vibrations.
• Vibrations from road compactors during constructionmay also have effect on neighboring
structures hence similar survey should be done on buildings and photo graphic images
and video recordings kept to ensure household damages are identified and
addressedContractor shall avoid night time construction when noise is loudest near
residential areas or areas near wildlife.
• There shall be no discretionary use of noisy machinery within 50m of residential areas and
near institutions or use of manual labour in these sections
• Contractor shall ensure good maintenance and proper operation of construction
machinery.
• Contractor shall ensure that where possible, non-mechanized construction shall be
applied to reduce the use of machinery
• Ensure that all vehicles and construction machinery are kept in good condition all the time
to avoid excessive noise generation.
• Ensure that all workers wear ear muffs and other personal protective gear/equipment
when working in noisy sections.
• Undertake loud noise and vibration level activities during the day (i.e. between 8.00 am
and 5.00 pm)
8.3.2.6 Air Pollution at the road construction site
Impact
455. Construction activities that will involve movement of vehicles and machinery, during
road construction will generate a lot of fugitive dust and exhaust emissions. Several
trucks will be making regular trips to the construction sites carrying away the excavated
soils and bringing in materials for road construction. The project area receives very little
rainfall hence it remains dry for the better part of the year exacerbating fugitive dust
situation.
Mitigation Measure
• Control speed of construction vehicles and Prohibit idling of vehicles;
• Water is to be sprayed during the construction phase on dusty areas to reduce dust
emission;
• Regular maintenance of vehicle & equipment to reduce smoke;
• Provision of dust masks for use by workers in dusty conditions;
• Use of serviceable vehicles/machinery to avoid excessive exhaust emissions;
• Operation and maintenance of contractor’s plant in compliance with relevant vehicle
emission standards and manufacturer’s specification to minimize air pollution.
• Monitoring of air quality during and after construction to ensure no major negative
impacts or come up with mitigation measures
• Install improvised screens to minimize dust at stone crusher.
8.3.2.7 Construction Materials Harvesting (Borrow Pits and Quarry) and Batching Plants
Impacts from material sites harvesting
456. Material harvesting activities at the quarry and borrow pit sites have the potential to
generate significant air pollution, noise and vibration risks. Site preparation and operation
Pan-19-003 -167 -
KeNHA
of Stone Crusher, Asphalt and Concrete Batching Plants also generate significant
impacts including the following:
• Removal of vegetation cover and perhaps species that might take long to re-establish;
• Land degradation by disruption of the local sub-surface geology and top soil;
• Emission (fugitive dust and hydrocarbons) into the neighbouring areas with risks to health
and comfort of residents;
• Noise and vibration from equipment and machinery, blasting activities and transportation
trucks that could affect neighboring housing structures and other installations as well as
residents’ comfort;
• Safety of the immediate residents, especially children, the aged and livestock;
• Safety of wildlife
• Surface and groundwater flow disturbance
• Rock blasting is usually done to detach rocks so as to make it accessible for quarrying.
Blasting can have impacts due to flying rocks that can cause accidents should they hit
humans, livestock and or wildlife. In addition, blasting emits dust due to fragmentation of
the rocks which can cause eye infections and respiratory diseases. It also produces
elevated noise thus disturbing residents in the neighbourhood and wildlife.
Mitigation Measures
• Undertake an ESIA for all quarry, burrow and batching sites.
• Adherence to the Noise and Excessive Vibrations Regulations, 2009.
• Adherence to the NEMA Integrated National Land Use guidelines
• Carry out exploration for aggregates such as ballast, sand and murram and map out the
deposits. The areas should also be physically planned, and appropriate land use
assigned and Environmental and Social Management Plan (ESMP) for the whole area
prepared.
• Establish at least 10 meters buffer zone between the quarry, burrow or batching plants
and the 30-meter riparian reserve of the river, wetland and water catchment areas. (i.e.
40 meters buffer zone between the quarry and the edge of the river, wetland and water
catchment area)
• Siting of material sites should be in harmony with other land uses and Provide for defined
buffer zone between quarries and other land uses. The following safety distances should
be maintained in quarry operations:
a. For quarry operations without blasting:
o 500m to any aerodromes/landing ground
o 100m to any shopping centre, school and hospital.
o 50m to any house irrespective of consent from the owner
o 40m to any river, road reserve or rail.
b. Quarry operations with controlled blasting
o A technical officer (inspector of mines/explosives) to advice accordingly as
provided for under Subsidiary Legislation 78 of Explosives Act and MSR 90 of
the Mining Act
• Contractor should establish quarry/burrow pit rehabilitation and/or after use plan to be
approved by the NEMA as prescribed in the EMCA
• Discourage undercutting and tunnelling in quarries and sand mining to avoid damage to
property, injury or loss of life.
• Prohibit vertical faces exceeding 2.5 m when quarrying on soil, sand, gravel, soft rock or
debris – these shall be worked in terraces/ benches or at a safe angle of slope.
• Hard rock quarry faces to be benched or worked from top to bottom.
• All quarry faces/cliffs should be securely fenced. The fence should be at least 3 meters
from the edge of the cliff using chain link of at least 1.5meters high.
Pan-19-003 -168 -
KeNHA
• Warnings signs of appropriate font size and in the appropriate language should be
erected in all quarry entries and in areas with high cliffs e.g. Danger Quarry Deep Pit’ or
‘Caution Flying Stone and Debris’.
• All access roads to and from quarries and burrow pits to be made safe and accessible
and transportation of quarried material to follow a designated route.
• Contractors to ensure provision of clean water, sanitation and well equipped first aid kit
with trained first aiders
• Provide protective gear for persons working in quarries as provided for in the Public
Safety Regulations
• Contractors workers to be trained on safety, health and environmental issues and the
quarry site should have a person in charge of safety and ensure establishment of ‘Safety,
Health and Environment Committees’ (SHEC).
• Each quarry site (where blasting is required) should have suitable skilled blaster to carry
out safe blasting and acquiring blasting permits.
• All blasting materials /explosives should be acquired and conveyed legally through
acquisition of relevant permit(s) from Mines and Geological Department.
• Because of the negative impacts on human population it is advised that material
harvesting sites are located far from human settlements and due consideration should
be made before any blasting is undertaken with regards to the regulations and best
practice.
• Adopting a simple, linear layout for materials-handling and processing operations to
reduce the need for multiple transfer points should be designed and installed (e.g.
processing plants like the crusher should preferably be located within the quarry area);
• Material processing Plants like Crushers, Asphalt Plants, ConcreteBatching Plants are
to be located as far away as possible from settled areas considering wind direction (down
wind side so that polluted air is driven away from the community.
Air Emissions
• Dust emissions from drilling activities should be controlled at the source by dust
extractors, collectors, and filters, and wet drilling and processing should be adopted,
whenever possible;
• Dust emissions from processing equipment (e.g. crushers, grinders, screens) should be
adequately controlled through dust collectors, wet processing, or water spraying. Dust
control applications should consider the final use of extracted material to avoid
compromising the final product.
• Procedures to limit the drop height of falling materials should be adopted;
• Use of mobile and fixed-belt transport and conveyors should be preferred to hauling the
material by trucks through internal roads (enclosed rubber-belt conveyors for dusty
materials are recommended in conjunction with cleaning devices);
• Internal roads should be adequately compacted and periodically graded and maintained
to minimize fugitive dust emission;
• A speed limit for trucks should be considered and implemented;
• Water spraying and surface treatment of roadways and exposed stockpiles using a
sprinkler system or a” water-mist cannon” should be implemented;
• Carry out daily air quality monitoring during construction using portable equipment
• Workers operating at these facilities must have appropriate PPE
Noise
• Reduction of noise from drilling rigs by using downhole drilling or hydraulic drilling;
• Implementation of enclosure and cladding of processing plants;
• Installation of proper sound barriers and (or) noise containments, with enclosures and
curtains at or near the source equipment (e.g. crushers, grinders, and screens);
Pan-19-003 -169 -
KeNHA
• Use of rubber-lined or soundproof surfaces on processing equipment (e.g. screens,

chutes, transfer points, and buckets);
• Use of rubber-belt transport and conveyors;
• Installation of natural barriers at facility boundaries (e.g. vegetation curtains or soil
berms);
• Optimization of internal-traffic routing, particularly to minimize vehicle-reversing needs
(reducing noise from reversing alarms) and to maximize distances to the closest sensitive
receptors;
• The use of electrically driven machines should be considered;
• A speed limit for trucks should be considered;
• Avoidance of flame-jet cutting;
• Construction of berms for visual and noise screening.
• Carry out daily noise monitoring using portable equipment.
• One out the hazardous noise areas for each facility and ensure workers use appropriate
PPE
Vibrations
• Develop a robust rock blasting plan that specifies preparation procedures including use
of a qualified and registered explosives expert with Mines and Geology Department of
Ministry of Environment and Forestry,
• Issuance of adequate warnings to all staff and community members and evacuation of
vulnerable persons within the impact range to safer zones.
• Community awareness and emergency preparedness and response planning should be
undertaken, including control of third-party access to blasting areas;
• Vibrations caused by blasting have potential community impacts. Implement monitoring
procedure (e.g. preconstruction surveys of buildings, infrastructure, and structures,
including photographic and video image recording) to ensure that potential household
damages caused by the project activities can be adequately identified and managed
• Use of specific blasting plans; correct charging procedures and blasting ratios; delayed,
micro delayed, or electronic detonators; and specific in situ blasting tests (the use of
downhole initiation with short-delay detonators improves fragmentation and reduces
ground vibrations);
• Development of blast design, including a blasting-surfaces survey, to avoid over confined
charges and a drill-hole survey to check for deviation and consequent blasting
recalculations;
• Implementation of ground vibration and overpressure control with appropriate drilling
grids (e.g. grid versus hole length and diameter, orientation of blasting faces) and
appropriate charging and stemming process of boreholes, to limit potential issues with
fly rock and air blasts;
• Hydraulic hammers or other mechanical methods should be preferred to improve rock
fragmentation and minimize fly-rock risks, instead of using secondary blast (plaster
blasting);
• Mechanical ripping should be preferably used to avoid or minimize the use of explosives;
• Other sources of vibrations are primary crushers and plant screening equipment.
Adequately designed foundations for these facilities should sufficiently limit vibrations.
8.3.2.8 Oil and Fuel Spills
Impact
457. During construction, oil spills may result from construction site equipment and
storage, which may affect the flora, fauna, soils, and waterways in the area
Pan-19-003 -170 -
KeNHA
Mitigation Measures
• Contractor will prepare Waste Management Plan
• The Contractor will ensure that the employees on site are aware of the company
procedures for dealing with spills and leaks from oil storage tanks e.g. using dispersants
or adding biological agents to speed up the oil breakdown for the construction machinery
though induction and safety training (the contractor will propose a method of clean-up
which will be subject to approval);
• In case of spillage the Contractor will isolate the source of oil spill and contain the spillage
to the source of leakage before it makes it leave from the affected area, using sandbags,
sawdust, absorbent material and/or other materials approved by the Resident Engineer;
• The Resident Engineer and Contractor will ensure that there is always a supply of
absorbent material such as saw dust on site during construction, readily available to
absorb/breakdown spill from machinery or oil storage, this can be incinerated after use;
• All vehicles and equipment serviced regularly in accordance to the manufacturers
specifications and stored in an area approved by the Resident Engineer;
• Contractor provide for oil/grease interceptors in motor vehicle garages
• Ensure the fuel dispensing areas are paved
• The Contractor will assemble and clearly list the relevant emergency telephone contact
numbers for staff, and brief staff on the required procedures
8.3.2.9 Soil Degradation
Impacts
458. All construction activities have some form of impact on the soil. In the case of a
road, the road surface is primarily an embankment, which will be compacted to form the
formation of the different road layers. The compaction of the embankment will reduce the
infiltration rate of the soil in these areas. In addition, the roadside slopes can lead to
erosion and increased sedimentation in the existing watercourses. Removal of vegetative
cover exposes the soil to erosion. In addition, works on the various borrow/quarry sites
occasioned steep slopes and deep pits may lead to an increased risk of erodibility if the
sites are not decommissioned.
Mitigation Measures
• Provide adequate drainage facilities to allow water to flow from one side of the road to
the other, and at all steep slopes, to prevent localized erosion
• In cases where it is identified that during construction there is a danger of increased run-
off water at the project site, then temporary drainage channels should be constructed
along the road
• After completion of the construction works, restoration of the ground should be done to
facilitate revegetation. In addition, sowing grass and planting of trees need to be
embarked on.
• Planning emergency response measures in case of accidental oil spills.
• The Contractor shall prepare and provide a borrow pit/quarry site rehabilitation plan in
order to ensure a means of backfilling these sites to reduce their erodibility. In addition,
each new borrow pit should undergo an ESIA for each site to analyse the specific impact
on these sites
Pan-19-003 -171 -
KeNHA
8.3.2.10 Proliferation of Invasive Species – Juliflora Prosopis
Impact
459. The entire road construction will involve moving materials from one location to
another and usage of it in environments that are not native to the material. These
relocations may lead to the proliferation of invasive species in these areas.
460. For example, if an exhausted borrow pit/quarry site is backfilled with spoil from a
different location with a different set of plants leading to the proliferation of these plants
in an area where they may be harmful to the new environment an example of such a
plant is the Prosopis Juliflora (Mathenge) plant.
Mitigation Measures
• The valuable top soil containing organic material, nutrients as well as seeds and the soil
fauna will be excavated separately and piled in an adequate manner for re-use in the
original area of use.
• Making use of cut and fill road material within similar homogeneous areas
• Minimal stockpiling periods in order to prevent new species from growing in the stockpiled
material.
• Proper storage of stockpiled material in areas free of vegetation and covering to prevent
spreading to other areas.
8.3.2.11 Interference with existing Water Sources
Impact
461. The road corridor is located in an area that is water scarce, as such use of existing
sources for construction may increase pressure on water resources.
462. The various construction activities may have a negative impact on the existing
hydrology via natural drainage patterns. Solid as well as liquid waste if not properly stored
or disposed of, may seep into groundwater or find its way into the surface water, thus
affecting the water resources of the area.
Mitigation Measures
• Prepare and implement a waste management plan
• Store bitumen, oils and lubricants on paved surface
• Ensure proper solid and liquid wastes disposal mainly from the construction camps, sites
and offices.
• Ensure proper measures are in place for collection and disposal of used oils and
lubricants.
• The Contractor will source for new water sources for construction e.g. Boreholes, pans
and rain water harvesting, after construction these facilities can be given back to the
communities
• Engage a NEMA registered firm to collect used oils and lubricants for appropriate
disposal
• Prepare and implement a waste management plan
8.3.2.12 Increased Traffic along the Project Road
Pan-19-003 -172 -
KeNHA
Impact
463. The project area will experience increase in traffic from the project related vehicles
of the Contractor. This will occur along the road alignment, borrow pit, and quarry site
and construction offices.
464. The project site is located in a remote area with limited vehicular traffic and high
domestic animal traffic, as such there is bound to be increased interaction between
contractor vehicles and the community creating the potential for accidents with the
Contractor’s vehicles to occur.
Mitigation Measures
• The Contractor will prepare a traffic management plan to provide safety measures for
motorists, contractor workers including diversion routes, road signs and barriers.
• The Contractor will provide traffic controllers/marshals at active construction sites to man
and control the traffic.
• The Contractor will provide temporary legible and reflective road signs or notices to
indicate ongoing works and deviation routes to guide motorists.
• The Contractor is to implement traffic controls to avoid congestion and accidents on the
road;
• The Resident Engineer and Contractor shall choose traffic routes to reduce the impact in
the neighbourhood avoiding, as far as practical any sensitive areas;
• For the site traffic the Contractor has to ensure that they
✓ Only park in designated parking areas;
✓ Do not block pedestrian routes;
✓ Do not block traffic routes;
✓ Obey the speed limit
✓ Follow the instructions of the traffic marshals
• The resident Engineer is to ensure that the Contractor:
✓ Introduces segregated pedestrian walkways;
✓ Introduces and enforces speed limits particularly in the residential areas;
✓ Reduces the need for reversing vehicles, by introducing a one-way system;
✓ Uses a qualified banksman to control deliveries and reversing vehicles;
✓ Designates loading/unloading areas.
• Provision of a road safety analysis and campaign, including discussing with the local
community on provision of road suitable crossing facilities for domestic animals, children,
etc
• Drivers and equipment operators drive safe within the project area and sign Code of
Conduct
8.3.2.13 Impacts on Physical Cultural Resources
Impacts
465. The project road traverses centres/towns with human settlements that have
residential houses and commercial buildings. Cultural resources and sacred sites exist
within these settlements. They include Mosques, graves and water wells. Considering
the initial design of the road corridor of 60m, there would have been significant impacts
on these resources.
Mitigation Measures
• Before construction commences, the contractor is to carry out reconnaissance survey to
establish that the road corridor does not have any mosques, graves or Wajir wells
• Inform the local community on the actions being taken to avoid such sites.
Pan-19-003 -173 -
KeNHA
• Re-design of the road corridor width in town centres from 60m to 30m to avoid impacting
property including physical cultural resources
• Apply the “Chance Find Procedure” provided in Annex 6 to protect any cultural
resources that may be underground and may be encountered during excavations of the
road.
Pan-19-003 -174 -
KeNHA
8.3.2.14 Occupational and Health and Safety
Impacts
466. Construction workers will be exposed to safety and health hazards and nuisance
arising from construction activities. The project workers will be exposed to occupational
risks due to handling of heavy machinery, construction noise, electromechanical works
etc. Construction activities of vegetation clearing, excavation, materials delivery and
concrete mixing and construction traffic will generate a lot of fugitive dust and this may
affect the respiratory system.
467. The high temperatures in the project area will expose the workers to difficult working
conditions including the temptation to remove safety gear while working in areas that
require such safety precaution. Construction sites may be a source of both liquid and
solid wastes.
468. If these wastes are not well disposed these sites may become a breeding ground
for disease causing pests such as mosquitoes and rodents. Borrow sites may pose risks
to the safety of the workers who may accidentally fall into these pits.
469. Migrant workers will be exposed to local diseases, including vector-borne diseases
to which they have no immunity. They may be infected by the locals with diseases that
could spread such as HIV and STDs. At the concrete and bitumen mixing plants, the
exposure of human skin to these materials may lead to damage of the skin.
Mitigation Measures
470. The Contractor is to:
• Prepare a detailed Occupational Safety and Health Management Plan (OSHMP) that will
provide all the required health and safety measures needed for the project activities.
• Prepare a Code of Conduct that inter alia commits to the Implementation of the OSHMP
and that also commits at individual level to compliance to OSHMP requirements and
standards.
• Carry out work assessment and identify hazardous substances and working conditions
and include safety measures in the OSHMP
• Conduct a road safety analysis and campaign with the local community, including road
crossings for domestic animals, children etc.
• Ensure that all construction machines and equipment are in good working conditions and
to manufacturer’s specifications to prevent occupational hazards.
• Provide road signs and barriers to block off working areas from the rest of the traffic.
• Appoint qualified full-time health and safety advisor and fire marshal on-site for the
duration of the construction work.
• Establish Health and Safety committee
• Induct and train all construction workers on OHS procedures
• Hold daily tool box meetings for all workers
• Provide workers with appropriate personal protective equipment (PPE).
• Provide workers with adequate portable drinking water and breaks.
• Provide workers training on safety procedures and emergency response such as fire, oil
and chemical spills.
• Roads passing through population centres will be water sprayed to suppress dust.
• Work to minimize or altogether eliminate mosquito breeding sites.
• Contractor to provide for medical clinic and nurse within the camp facilities
Pan-19-003 -175 -
KeNHA
• Contractor to provide a vehicle ambulance to evacuate for emergency situations

• Prepare Emergency Response Plan
• Provide a waste management plan
• Provide a HIV/AIDS management plan
• Provision and implementation of an employee code of conduct
• Provide a whistle-blower policy to ensure wellbeing of whistle-blowers
• Fence off the site with security to avoid unauthorized access to the borrow site(s) and
hence mitigate potential injuries from accidental falls.
• Provide clean and enough toilets for workers, these toilets will be to World Health
Organisation standards
8.3.2.15 Community Health and Safety
Impacts
471. Community members will be exposed to safety and health hazards and nuisance
arising from construction activities. The road construction activities will interfere with the
normal way of life of the local communities including movement across the road for
domestic animals and increased risk of traffic accidents during construction. The project
will also absorb some of the community members as workers. This will expose them to
occupational risks due to working in areas where there are heavy machinery and trucks
in operation. There will also be heavy machinery activities at the borrow pits, quarry sites
and stone crusher sites.
472. The exposures include accidents occurring from the machine operations, moving
trucks or accidental fall into the quarry or borrow pits. Construction activities of vegetation
clearing, excavation, materials delivery, concrete mixing and construction traffic will
generate a lot of fugitive dust and this may affect the respiratory system of and community
members
473. Construction sites may be a source of both liquid and solid wastes. If these wastes
are not well disposed these sites may become a breeding ground for disease causing
pests such as mosquitoes and rodents. Borrow pits and quarry sites may pose risks to
the safety of the surrounding communities and their livestock who may accidentally fall
into these pits. The construction workers may have communicable diseases like TB and
HIV which they can transmit to the local community.
474. The mentioned construction activities may result in severe illness, debilitating injury
or may even result in death of the community member.
Mitigation Measures
The Contractor is to:
• Carry out meetings with community members on safety issues at the project area
• Provide and implement a community engagement plan
• Fence off the site with security to avoid unauthorized access to the borrow site(s) and
hence mitigate potential injuries from accidental falls.
• Carry out regular monitoring and assessment of community health and safety issues with
a view to improve on performance
• Provide a HIV/AIDS management plan including Voluntary Counselling and Testing
(VCT) and awareness creation initiatives.
Pan-19-003 -176 -
KeNHA
8.3.2.16 Impacts on Lorian and Borji Swamp Ecosystems
Impacts
475. During construction, the swamps wll be exposed to impacts from potential oil spills
from construction machinery and vehicles, waste dumpimg by the workers, proliferation
of invasive species, interference with surface and shallow groundwater flow systems,
loosening of soils from excavations activities that will cause siltation. Presence of the
construction teams within the swamp areas will disturb the wildlife and the presence of
many people will change their behaviour. There would also be visual and auditory
disturbance due to the presence of machinery, construction workers, and associated
equipment.
During operation, the wildlife will be may disturbed considering they will may not have
freedom of movement from one side to the other side of the road, however, the ESIA
study has recommended for design engineer to review and provide for features that will
facilitate free movement of livestock and wildlife from one side of the road to the other .
Reduced movement of wild animals may lead to concentration in certain areas leading
to overgrazing, damage to natural vegetation and general loss of ecological integrity of
the ASAL ecosystem along the road. There would also be visual and auditory disturbance
due to the presence of machinery, construction workers, and associated equipment
Mitigation Measures
• Implement a code of conduct that prohibits workers from interfering with wildlife
• Construction activities at the swampy areas should be minimized and restricted to
activities that must be carried out there.
• All construction machinery, equipment and vehicles must be inspected on a daily basis
for oil leaks before being used within the the two swamps
• Minimize clearing of indigenous plant species and replanting of indigenous plant species
in disturbed areas.
• Provide adequate protection against scour and erosion; and consider the onset of the
rainy season with respect to construction schedules.
• Carry out water quality analysis of the surface water in the two swamps and Ewaso Ng’iro
River every two weeks during rainy season
• Design features and construction of appropriate livestock and wildlife crossings such as
culverts or ramp slope to avoid or minimize habitat fragmentation.
• Contractor to prepare location specific biodiversity management plans or controls to
address local biodiversity issues
• The Contractor to liaise with key stakeholder such as KWS and conservation institutions
to consider all biodioversity issues , including species presence and /or movement in
relation to construction schedule and associated activities
• Separate EIAs should be conducted for sub-projects including camps, borrow pits,
quarries, boreholes, sand-pans, social infrastructure such as market shades, milk
cooler, slaughterhouses, veterinary posts, livestock holding area, etc
• None of the sub-projects should be located within the swamps.
8.4 Social Impacts and Mitigation Measures
476. The proposed road project will generate social impacts during the following phases
• Pre-Construction Phase (Planning Phase)

• Construction Phase
• Operation Phase (When the Road is in use)
• Decommissioning Phase)
Pan-19-003 -177 -
KeNHA
Pre-Construction Phase/ Impacts
Impact
477. During this phase of the project, impacts are expected to come from acquisition of
the road corridor and resettlement of persons. The road is traversing market centres and
towns where communities have both residential and commercial properties. Since the
project area is largely community land, the project may impact grazing land for livestock.
Mitigation Measures
478. A Resettlement Action Plan (RAP) that defines the process of how Project Affected
Persons (PAPs) are to be assisted, has been prepared and will be implemented.
• Identification of the project road corridor and preparation of road design that minimizes
impacts at the market centres and towns to avoid displacement of persons.
• Identification of Project Affected Persons (PAPs) through the RAP Report) Study
• Those affected by the project to be compensation and assisted to resettle elsewhere.
• Community members to be consulted by KeNHA on how compensation for grazing land
is to handled
• Those that have suffered income losses are to be assisted as provided for in the RAP
Report
• The Grievance Redress Mechanism (GRM) is to be activated and the project area
community sensitized on its operation
• Monitoring of resettlement is to be done as provided for in the RAP Report to ensure that
PAPs do not suffer adversely due to the implementation of the project.
8.4.1 Construction Phase Impacts
479. Majority of the project impacts will emanate during construction. Majority of
inhabitants are Muslims and they abide by the belief system, culture. The in-migration of
people from other parts of Kenya to the project site will create impacts due to difference
in culture and religion. Both the Borana and Somali are conservative Muslims and they
do not entertain the use of alcohol or eating of pork in their communities. The project
workers are likely to infringe on these norms thus offending the VMGs. There will be
labour influx that will create competition and conflict with the local community. Other
forms of impacts include Gender Based Violence (GBV), Sexual Exploitation and Abuse
(SEA), Sexual Harassment, potential increase in Sexually Transmitted Diseases
especially HIV/AIDS, abuse on women who come to vend food and other merchandise
and increase prostitution. These potential impacts are discussed below and mitigation
measures proposed.
8.4.1.1 Employment of Locals
480. During construction the project will have clear benefits with regard to local
employment opportunities. The project will additionally require various skills and services
which may not be available on the local level but certainly on the regional level, e.g. iron
workers, concrete workers, etc. for which appropriate personnel will be contracted.
481. The increase in employment will temporarily lead to an overall increase of income
directly and indirectly (through increased demand of other local services). Consequently,
Pan-19-003 -178 -
KeNHA
food vendors will have new opportunities to sell their commodities to the construction
workers.
Measures to improve the positive impacts include:
Mitigation Measures
• Prepare Labour Management Plan
• Unskilled construction and skilled (if available) labour to be hired from the local population
as far as possible to minimize on influx of foreigners into the community.
• Use of manual labour where possible to ensure more employment of locals and hence
ensure project support throughout the construction process.
• The contractor will ensure that all workers’ pay adheres to minimum wage requirements
to avoid labour unrest.
• The Contractor will prepare an employment plan to manage employment of labour
• The Contractor will establish workers grievance mechanism
• Sensitize workers and the surrounding community on awareness, prevention and
management of HIV / AIDS through staff training, awareness campaigns, multimedia,
and workshops or during community Barazas.
• Provide an onsite clinic to provide VCT services to construction crew and provision of
ARVs for vulnerable community members as well as provide first aid services
• The Contractor will enforce and maintain a code of conduct for his employees
• There should be some skills transfer for some of the staff to promote learning.
• With consultation with local communities come up with suitable CSR measures for the
community
8.4.1.2 Increase in cases of HIV and AIDS
Impact
482. Th in migration of people from different regions may lead to behavioural influences
including prostitution which may increase the spread of diseases such as HIV/AIDS.
Mitigation Measures
• Sensitize workers and the surrounding communities on awareness, prevention and
management of HIV/AIDS through staff training, awareness campaigns, multimedia, and
seminars/workshops and during community Barazas.
• Provide an on-site clinic to provide VCT services to construction crew and provision of
ARVs for vulnerable community members
• The Contractor will prepare and implement a HIV/AIDS management plan
• Ensure workers are regularly reminded about the code of conduct and the potential
consequences if not adhered to.
8.4.1.3 Liability for Loss of Life Injury or Damage to Private Property
Impact
483. The project activities include operation of machines and excavation works at the
project road, borrow pit, quarry sites, stone crusher plant, concrete batching plant. There
will be potential occurrence of accidents that may cause loss of life, injury to workers or
community members. The construction activities may also cause damage to
neighbouring private properties like buildings that was not envisaged in the RAP Study.
Pan-19-003 -179 -
KeNHA
Mitigation Measures
• Workers to be provided with appropriate PPE
• Induction of workers on appropriate operation of the machinery and equipment
• Provision of adequate signage at working sites
• Ensuring that the prepared code of conduct for staff is followed to prevent accidents.
• Developing a site safety action plan.
• Cordon off unsafe working areas
• Keeping records of all injuries that occur on site in the incident register, corrective actions
for their prevention are instigated as appropriate.
• Compliance with the Workmen's Compensation Act, ordinance regulations and union
agreements.
• Provide an onsite clinic to provide first aid services to the staff
• Repair/compensate any damage done to private property.
• Prepare and implement a grievance redress mechanism
8.4.1.4 Labour Influx
484. The project construction is bound to attract labour from surrounding counties and
beyond in order to meet the needs of the project. In addition, business opportunities may
present themselves attracting businessmen and women from surrounding counties.
There will be increase in labour that will lead to competition with the community and also
increase in pressure on existing resources including water, food, healthcare,
accommodation. This coupled with different lifestyle of the locals may lead to conflicts
between in migrants and local communities. The influx of people from different
backgrounds and cultural beliefs as part of the road construction workers is likely to
infringe on some of the VMGs culture and religion.
485. Influx of in-migrants is likely to lead to an increase in communicable and vector-

borne diseases such as malaria, TB, HIV/AIDS and other sexually transmitted diseases,
exacerbated by increased pressure on health care facilities and the possible introduction
of new diseases
486. The construction of the highway is likely to exacerbate any of the various forms of
GBV including Rape, SEA, Sexual Harassment and Violence Against Children (VAC). if
precautions are not put in place.
487. Project workers may also perpetuate GBV by promising jobs or promotion in
exchange for sexual favours.
488. In migrants will contribute to the rapid physical expansion of towns and villages and
uncontrolled squatter development along road. The in migration from the rural areas or
non-locals from other parts of Kenya will result in:
• Increase in population
• Physical expansion of towns and villages
• Informal development on the outskirts and alongside roads and tracks approaching
settlements
• There will be conversion of land use from rangeland to unplanned settlements
• There will be a surge in demand for services like water, power, sewerage and waste
facilities, health and education facilities
Pan-19-003 -180 -
KeNHA
• There will be pressure on land could potentially displace or introduce conflict with existing
land owners and communities.
Mitigation Measures
• Unskilled construction and skilled (if available) labour to be hired from the local
population as far as possible to minimize on influx of foreigners into the community.
• Use of manual labour where possible to ensure more employment of locals and hence
ensure project support throughout the construction process.
• Prepare a labour influx plan to manage labour influx
• Sensitize workers and the surrounding community on awareness, prevention and
management of HIV / AIDS.
• Provide an onsite clinic to provide VCT services to construction crew and provision of
ARVs for vulnerable community members as well as provide first aid services
• The Contractor will enforce and maintain a code of conduct for his employees
• Contractor is to monitor and report on the implementation and effectiveness of the labour
influx related mitigation measure
• Due to the possibility of conflicts arising between workers and the locals, the Contractor
shall ensure all key staff, receive training regarding the likelihood, significance and
management of influx-related issues.
• Through the Non-Governmental Organization that will be handling GBVSEA issues,
hold sensitize the community on possible occurrence of GBV and how they should
respond.
• The Contractor shall ensure that the Grievance Redress Mechanism (GRM) addresses
issues related to labour influx
• Labour management plan
8.4.1.5 Economic Impacts
Impacts
489. According to Exploring Kenya’s Inequality report, the Counties of Isiolo, Garissa and
Wajir have very high poverty incidences. Isiolo County had 71% of its population living
below the poverty line, in Wajir County the population living under absolute poverty was
estimated to be 84.2% while Garissa the poverty level is 55%.
490. The underlying causes of such high poverty levels are persistent marginalization of
the region by successive governments, widespread insecurity, unreliable rainfall resulting
to frequent draughts, high levels of illiteracy, poor crop and animal husbandry practices,
poor infrastructure, inaccessibility to credit facilities, poor marketing systems and natural
disasters like frequent droughts, floods, livestock diseases, wildlife menace and
environmental degradation. Due to the above challenges, most people rely on the
government and other organizations working in the region for food support.
491. Socio-economic impacts of in-migration will include an increase in prices of goods

and services. The categories of goods and services that may experience price increases
include construction materials, food, fuel and transport. Such inflationary trends can
reduce the availability and affordability of basic goods and services to the existing
population
Pan-19-003 -181 -
KeNHA
Mitigation Measures/Project Benefits

• Reduced Insecurity due to quicker movement and less breakdown of vehicles
• There will be reduction in travel time and costs
• There will be creation of employment
• There will be improved access to social services
• There will be reduction in vehicles operating costs, bringing benefits to vehicle owners
plying the road:
• The local economy will be diversified by investors coming into the area
• The increased economic growth will improve household incomes
• Livestock production will improve due to the established market shades, milk cooler,
slaughter houses, veterinary posts, livestock holding areas.
• The National and County Governments will be able to provide better health, security
services to the communities along the corridor
• Improvement of the livestock trade will not only benefit the north eastern region but will
benefit the country at large from livestock export products.
8.4.1.6 GBV, Sexual Harassment and SEA
Impact
492. Construction workers are predominantly younger males. Those who are away from
home on the construction job are typically separated from their family and act outside
their normal sphere of social control. This can lead to inappropriate and criminal behavior,
such as sexual harassment of women and girls, exploitative sexual relations, and illicit
sexual relations with minors from the local community. A large influx of male labourers
may also lead to an increase in exploitative sexual relationships and human trafficking
whereby women and girls are forced into sex work. The Borana and Somali community
are patriarchal, where women’s position is viewed as subservient, marginalized, and
disempowered. This predisposes the women and girls to SEA
493. Potential high labour influx may cause GBV and Violence Against Children (VAC)
Mitigation Measures
• Provide and implement a gender-based violence strategy, which will include:
• Gender mainstreaming in employment at the worksite with opportunities provided for
females to work, in consonance with local laws and customs
• Gender sensitization of workers (this will be done by the HIV/AIDS services provider; see
above)
• Provision of gender disaggregated bathing, changing, sanitation facilities
• Grievance redress mechanisms that incorporates non-retaliation and specific procedures
for GBV.
• Provide and implement an employee code of conduct for workers
• The works contractor will be required, under its contract, to prepare and enforce a No
Sexual Harassment and Non-Discrimination Policy, in accordance with national law
where applicable
• KeNHA to ensure NGO concerned with GBV issues to be engaged as early as possible
before construction commences since GBV and cases Violence Against Children are
likely to arise.
• Contractor to prepare and enforce a code of conduct that will be signed by all project
workers prohibiting SEA and SH by workers and providing an accountability and
response framework including non-retaliation against those who report.
Pan-19-003 -182 -
KeNHA
• KenHA to engage a NGO to educate all workers and nearby communities and
stakeholders on preventing and responding to SEA, sexual harassment and GBV ahead
of any project related works;
• Popularize /put in place safe, ethical and confidential mechanisms and hotlines for
reporting SEA/SH/GBV cases;
• Strategies such as male involvement will be employed in preventing and responding to
GBV/SEA and sexual harassment;
• Establish partnerships with relevant government agencies, GBV Service Providers and
NGOs to ensure survivors of GBV and sexual offences access survivor centred services
such as medical care, psychosocial support, legal redress, safety, etc as and when
necessary;
• Provision of gender disaggregated facilities - separate bathing, changing, sanitation
facilities for men and women;
• Grievance redress mechanisms with specific procedures for GBV including confidential
reporting with safe, and ethical documenting of GBV cases should be set up for the
workers and community;
8.4.1.7 Project Impacts on Women
Impacts
494. There is need to promote gender equality in all aspects of economic development
and more so in construction. Women roles in construction are mainly confined to supply
of unskilled labour and vending of foodstuffs to the construction workers. Where available
skilled women will be used. Construction workers are predominantly younger males.
Those who are away from home on the construction job are typically separated from their
family and act outside their normal sphere of social control. This can lead to inappropriate
and criminal behavior, such as sexual harassment of women.
495. In the Somali Household set-up, women normally perform domestic duties such as
tending the home and children, milking animals, fetching water and firewood, looking
after home herds. The advent of the project may provide them with job opportunities
which may stop them from performing the normal roles. This may result in confrontation
with their spouses and other members of the family.
Mitigation Measures
• Ensure equitable distribution of employment opportunities between men and women
• Provide toilets and bathrooms for both male and female workers on site
• The women will be involved in the periodic dialogues/consultations with the contractor
and host communities during construction to enable them accommodate their other roles
while working with contractor.
8.4.1.8 Security Risks and Crime Management
Impact
496. The project is located within a generally insecure part of the country; hence, the
construction works can have negative impact on the project. The positive benefit includes
increased activity will lead to increased security of the Contractor and his staff leading to
general improved security, however on the downside the expensive construction
machinery and materials may attract thieves, terrorism, exacerbate existing conflicts and
Pan-19-003 -183 -
KeNHA
bandits to the area or even the Contractor’s own employees to the area. Employee
misconduct in the host communities can also occur.
Mitigation Measures
• The Contractor will prepare Security Management Plan for the road section
• Contractor will recruit qualified security coordinator to coordinate and manage security
risks
• The Contractors camp containing equipment and machinery is going to be securely
fenced off.
• The Contractor’s team will work with security agencies to provide security within the site
in addition to the Contractor’s own security.
• Any employee who persists in any misconduct or lack of care, carries out duties
incompetently or negligently, fails to conform to any provisions of the contract, or persists
in any conduct which is prejudicial to safety, health, or the protection of the environment
will be removed
• All reasonable precautions will be taken to prevent unlawful, riotous or disorderly conduct
by or amongst the contractor's personnel, and to preserve peace and protection of
persons and property on and near the site.
• Alcohol, drugs, arms, and ammunition on the worksite among personnel will be
prohibited.
• The contractor and Resident Engineer will register in a log all events of a criminal nature
that occur at the worksite or are associated with the civil works activities.
• The contractor and Resident Engineer will report all activities of a criminal nature on the
worksite or by the contractor's employees (whether on or off the worksite) to the police
and undertake the necessary follow-up. Crime reports will include nature of the offense,
location, date, time, and all other pertinent details.
• The Contractor will ensure that all of his staff sign a written code of conduct to govern
employee behaviour on site
• KeNHA has carried out a Safety Risk Assessment and prepared Security Management
Plan for the project and provided overall mitigation measures for the project road
• Security agencies providing armed security to the project will siagn Code of Conduct
aligned to International Good Practices including the World Bank Good Practice Note on
Assessing and Managing the Risks and Impacts of the Use of Security Personnel
8.4.1.9 Impacts on Children
Impacts
497. The Children Act of Kenya prohibits contractors from “employing children in a
manner that is economically exploitative, hazardous, and detrimental to the child’s
education, harmful to the child’s health or physical, mental, spiritual, moral, or social
development. It is also important to be vigilant towards potential sexual exploitation of
children, especially young girls. The contractor should adopt a ‘Child Protection Code of
Conduct’; that all staff of the contractor must sign, committing themselves towards
protecting children, which clearly defines what is and is not acceptable behaviour
Mitigation Measures
• Provide and implement a child protection strategy
• Ensure no children are employed on site in accordance with national labour laws
• Ensure that any child sexual relations offenses among contractors' workers are promptly
reported to the police
Pan-19-003 -184 -
KeNHA
• Community sensitization on child protection and eradication of child labour.
8.4.1.10 Intra/Inter Community Conflict
Impact
498. The project area (north-eastern counties) The project area is home to several
communities relying on limited resources including water, pasture. The road upgrading
project is bound to increase the population within the project area, leading to increased
pressure on community resources including water, food and healthcare. In addition,
removal of vegetation during construction of the road and sourcing for construction
materials will lead to increased scarcity on already limited resources. The increased
pressure on these resources may lead to conflicts between communities, within
communities and between the communities and the Contractor.
Mitigation Measures
• The Contractor will source for new water sources for construction e.g. Boreholes, pans
and rain water harvesting, after construction these facilities can be given back to the
communities.
• The Contractor will develop Resource Use Management Plan.
• KeNHA and Contractor to convene meetings with the Somali and Borana communities
in Modogashe to discuss project implementation plans to avoid conflicts arising during
implementation.
• Convene similar meetings in Samatar/Guticha and Laghbogol to diffuse intra community
conflicts that may arise over resources during construction (selection of camp sites and
• Provision of CSR where possible to reduce some of the pressures on resources
• Ensure working grievance redress with the communities within the project area to
mitigate any grievances early before escalation to conflict.
• Preparation and conducting a stakeholder engagement plan to ensure continuous
communication and discussions of all stakeholders
• Provide regular updates on project progress and fulfill agreed actions
8.4.1.11 Conflicts from Project Construction Activities
Impacts
499. Physical Disturbance or Damage to Cultural Heritage Sites: As reported by the
SA Report, cultural heritage sites are fixed and discrete. Project risks and impacts will
come from direct physical disturbance or damage to the resources themselves.
Disturbance can result directly from earth-moving activities, from vibration and dust
produced by heavy vehicles and machinery, or damage resulting from a change in water
flows
500. Disruption of Access to Cultural Heritage Sites: Similarly, project activities may
disrupt access to cultural heritage such as cemeteries, preventing their usage and limiting
their value to site users, who may include local residents and visitors. The magnitude of
this type of impact is measured by the duration and severity of the disruption of access
and the potential for alternative access routes.
Mitigation Measures
• Contractor to establish presence of any cultural resources near sites of construction and
avoid them
Pan-19-003 -185 -
KeNHA
• Contractor to consult with local/religious leaders to ensure Cultural Sites are identified
and measures put in place to avoid disturbance.
• Contractor to ensure access is provided to all cultural resources near the road
8.4.2 Operation Phase Impacts
501. When the project road becomes operational, the positive impacts will greatly
outweigh the negative impacts and with proper monitoring and maintenance, the potential
negative impacts that will arise can be mitigated
8.4.2.1 Positive Environmental Impacts during Operation
502. The many positive impacts of the project include:
• Improved regional road network,

• Reduced travel time along and across the roads,
• Enhanced operational efficiency of the road,
• Promotion of economic growth within the region,
• Improved safety and reliability for all road users,
• Attraction of traffic that will foster regional economic growth,
• Improved security within the project area,
• Reduced fugitive dust in the area.
• Provision of community social amenities.
503. The positive impacts may be ameliorated through continuous monitoring to ensure
that the system is functioning at maximum efficiency to ensure maximum benefit to all.
Other potential impacts typically associated with operation and maintenance activities
are such as:
8.4.2.2 Increased Traffic along the Project Road
Impact
504. The upgraded road will attract more traffic to the region due to the improved road
surface and the shortened travel time. This will result in increased traffic congestion,
hence, there is bound to be traffic accidents between the vehicles and local communities.
Mitigation Measures
• Provision and maintenance of safety signage along the corridor.
• Periodical road safety audits to establish any issues with the road and establishment of
mitigation measures
8.4.2.3 Air Quality
Impact
505. The new increased traffic along the project road will have some negative effects
since there will be increased exhaust emissions.
Mitigation Measure
• Policing of unroadworthy vehicles to reduce air pollution
Pan-19-003 -186 -
KeNHA
8.4.2.4 Community (Public) Health and Safety
Impact
506. Since the project corridor contains wildlife and habited settlements where
community members keep large herds of livestock, there will be high likelihood of traffic
accidents occurring due to increased speed of travel. Spread of communicable diseases.
Mitigation Measures
• Provision and maintenance of safety signage along the corridor.
• Periodical road safety audits to establish any issues with the road and establishment of
mitigation measures.
• Carry continuous Public Health Awareness
8.4.2.5 Risk of Truck Drivers Stopping along the Project Road
Impact
507. The opening of a major road corridor will lead to increased vehicular traffic along
the road including trucks ferrying goods to the Northern Region of the Country. Due to
their limited speeds, truck drivers will need to take breaks during the drives to improve
on road safety. The design has provided for truck stops at intervals and on both sides of
the road, with large enough parking spots. However, it will be important to ensure that
the trucks actually make use of these stops instead of parking on the sides of the main
highway
Mitigation Measures
• Provision of visible signage showing the truck stops along the road.
• Working with the police to ensure that trucks are actually using the stops instead of the
side of the road.
• Encouraging the establishment of businesses near the truck stops including
accommodation, sanitation and restaurants to encourage truckers to stop at these
locations.
8.4.2.6 Impacts of newcomers to the project area
Impacts
508. The improved road coupled with shortened travel time, the potential for business
opportunities and availability of land will lead to an increase in the in migration of people
to the project area. This may lead to inter and intra community conflict, due to differences
in religion, culture, and lifestyle
Mitigation Measures
KeNHA is to work with the County Governments of the three counties on how integration
between newcomers and host communities will be carried out.
8.4.3 Impacts during Decommissioning
509. The de-commissioning of the Project is not envisaged. However, some aspects of
the project will require decommissioning including the borrow pit, quarry sites and the
Pan-19-003 -187 -
KeNHA
Contractor’s camp. Other project components including the project road will be
maintained/rehabilitated over time having served their useful life.
510. Before decommissioning, the Contractor will prepare a decommissioning plan for
the elements that will require decommissioning
8.4.3.1 Decommissioning of Exhausted Material Sites
511. Once the material source sites have been exhausted or the works have been
completed, the Contractor will be expected to rehabilitate these sites or if the sites are.
Water sources that the community can continue using, they can be handed back to the
community.
Mitigation Measures
• Prepare a Decommissioning Plan and submit to NEMA and the County Governments of
Garissa, Isiolo and Wajir and obtain approval for implementation.
• Implement the decommissioning plan including backfilling, revegetation, disposal of
waste material, recycling of recyclable material.
• Hand over the sources to the community through the relevant authority (County
Government.
8.4.3.2 Decommissioning of Contractor’s Camp
512. On the completion of the construction works for the road, the Contractor will
decommission his camp.
Mitigation Measures
• Prepare a Decommissioning Plan and submit to NEMA and the County Governments of
Garissa, Isiolo and Wajir and obtain approval for implementation.
• Implement the decommissioning plan including backfilling, revegetation, disposal of
waste material, recycling of recyclable material.
8.5 Cumulative Impacts
Impacts
513. Cumulative impacts are defined as those that may result from incremental impact,
on areas or resources used or directly impacted by the project, from other existing,
planned , or reasonably defined planned developments , at the time the risks and impacts
identification process is undertaken.There are potential cumulative impacts that will arise
since there other projects or actions that are planned for the region where this project is
located. The proposed or ongoing projects that are likely to generate cumulative impacts
include:
• The proposed Isiolo-Modogashe (A13) road which joins the Modogashe -Wajir road
from the south
• The ongoing construction of the Garissa-Modogashe (A13) road that joins the
Modogashe-Wajir road from the eastern side
• The proposed planned LAPSSET road project from Lamu to Isiolo to South Sudan
and Ethiopia
Pan-19-003 -188 -
KeNHA
• The proposed Wajir-El-Wak road that will connect with the project road from Wajir
Town on the northern side.
• The proposed 748km fibre optic cable between Isiolo and Mandera to improve
internet connectivity.
• The proposed social infrastructure projects that are part of the larger NETIP project
• Potentail impacts on sourcing of construction materials including water, energy, road
construction materials along the corridor;
• Impacts on resources in the project area due to labour influx
• Any other initiatives in the project road corridor that may result in positive or negative
cumulative impacts that have been included in the ESIA Study
• Potential impacts on the on culture and religion, increase in crime, increase in GBV,
SEA, Sexual Harassment and abuse of Children
8.5.1 Identification of Potential Cumulative Impacts
514. Table 46 provides a summary of the likely potential cumulative impacts that may
result from the construction and operation of the proposed road project, services roads,
interchanges and bypass, and in combination with other proposed development
described in Section 6-9.
Table 46: Summary of Potential Cumulative Impacts

Loss of flora and Potential cumulative impacts will only During the operational phase, it is
fauna, proliferation of occur during the construction phase if expected that influx of people to
invasive species the construction of other nearby the area and change in land uses
projects coincides with that of the with increased settlements along
proposed project. During construction it the project corridor this will
is expected vegetation clearance along excaberte pressures on the fauna
the alignment, material sites, spread of and sensitive ecosystem such as
invasive species, poaching, speed kills Lorian Swamp that may result to
and disruption of animal habitats .If this reduced biodiversity and
is the case, even greater attention will degradation .
need to be paid to the outlined
mitigation measures to ensure the Cumulative impacts may become
cumulative impacts remain insignificant significant on traffic accidents
involving community members,
livestock and wildlife.
Implementation of proposed
mitigation measures will ensure
impact is moderate.
Increased Traffic Potentail cumulative impacts are Given that traffic volumes will
anticipanted with use of construction increase in the project area due
vehicles and heavy machinery during to improved road conditions. The
construction. Implemnattion of design and proposed ESMP
mitigations measures including mitigation measures will ensure
operationalizing traffic management the impact is low.
plans will ensure the impact is low.
Road Safety Potential cumulative impacts on road Anticipanted during operational
safety are anticpanted given the area phase is increased traffic and
remoteness and little knowledge on speed for vehicle to the project
traffic regulations. Project has proposed area. Road signages and
mitigation measures and when implementing community road
implemented will maintain impact at safety awreness initiatives will
moderate level. ensure the impact is low.
Pan-19-003 -189 -
KeNHA

Water Resources Potential cumulative impacts are likely Potential cumulative impacts will
to occur during construction period in be negligible
relation to abstraction of water from
ground water sources due to large
demand for construction, and potential
contamination from oil spills and waste.
The proposed mitigation measures will
suffice and will require continuous
monitoring.
Air Quality Cumulative impacts will only occur Efficient vehicular movement
during the construction phase if the arising from a multiplicity of
construction of other nearby projects improvement initiatives will
coincides with that of this proposed effectively lead to a reduction in
project. emissions, especially CO2.
If this is the case, even greater attention Cumulatively, the initiatives will
should be paid to the mitigation contribute to Climate Change
measures outlined in order to ensure mitigation.
the cumulative impact will remain of
minimum
Social Impacts Implementation of the project and the The enhanced transport
including: proposed social infrastructure among improvement targeted is soon
• Labour influx, others is expected to cause influx of going to attract more settlements
• Crime, workers into the area seeking for either and commercial activities which
• Disruption of skilled or unskilled employment. This may also be accompanied by
services, may pose increased social risks with sprawl of informal settlements.
• Increased respect to among others; new cases of The situation may not get an
conflicts, HIV/AIDS contraction and subsequent immediate back up of necessary
• Impacts on spread, illegal poaching, native’s amenities including sufficient
children, cultural dilution due to influence with the housing, water supplies,
• GBV, sexual incoming workers from other areas in sanitation, drainage systems and
exploitation and the Country, Gender Based Violence, power supply. Hence the
abuse drug trafficking, insecurity issues due to available limited resources will be
presence of ‘strangers’ (project over-stretched by the increased
workers) and other social challenges. population leading to communal
conflicts over the little available
resources.
Economic Impact Positive cumulative economic Impact Travel time reduction in the area
will occur during the construction will be more efficient.
phases of the projects since there
would be increased local and regional
employment benefits. The Local
businesses would experience an
increased demand for products and
services during construction.
Population Increase Upon commissioning of the road,
and migration provision of other infrastructure
such as water, electricity, health
centres, learning institutions and
fibre cable internet among others
will be enabled and easily
implemented compared to when
the road is not there. Hence, the
people from within and outside
the project counties will be
attracted to move into the project
area either to settle there, set up
Pan-19-003 -190 -
KeNHA

businesses or provide needed

services. This will cause an
increase in population numbers in
the area, also, from the rural
areas to the urban areas in
serach of opportunities hence
urbanisation.
Sourcing of Large quantities of aggregate and
construction materials quarry material will be required during
along the corridor construction, this will result on potential
cumulative impacts along the project
corridor. This situation will lead to
serious degradation of land and general
environment in the project counties
arising from over-extraction and
haulage which may take many years to
restore.
Increased demand for more

construction materials will result into
more land being excavated for material
at the expense of other sustainable land
use practices. The outlined mitigation
measures should be implemented to
ensure the potential cumulative impacts
remain of moderate
Pan-19-003 -191 -
KeNHA
9 ENVIRONMENT AND SOCIAL MANAGEMENT PLAN (ESMP)
506. The ESMP has been developed to be used as tool to manage the environmental
and social impacts that the activities of the road construction may generate. It is expected
that before construction of the road commences, the contractor will use the ESMP to
generate specific implementation plans for each construction activity. There are certain
areas of the construction activities that will generate hazardous wastes, safety risks and
adverse impacts to the environment that will require the specific plans to guide the teams
that are implementing the project.
507. The ESMP shall be converted into Contractors’ ESMPs (C-ESMP) by the successful
Contractors based on the final design. The C-ESMP shall be prepared by the Contractor,
reviewed and approved by the Supervision Engineer and KeNHA and reviewed and
cleared by the World Bank before the Contractor is allowed to commence construction.
9.1 Objectives of the ESMP
508. The objectives of the ESMP include:
• To monitor the implementation of mitigation measures against potential adverse impacts

of construction and operation phases of the project to ensure that they conform and
comply with relevant environmental and social policies, guidelines and legislation
• To assess for emerging non-anticipated adverse environmental and social impacts and
implement relevant mitigation measures to maintain them within acceptable levels
• To maintain best practice in environmental, social health and safety during project
construction and operation
• To address capacity building needs within KeNHA, Supervision Consultant, Contractor
and the Ministry of Transport and Infrastructure, where necessary.
9.2 Responsibilities for Environmental and Social Management Plan
509. In order to ensure effective implementation of the ESMP, it will be necessary to

identify and define the responsibilities and functions of different agencies that will be
involved in the implementation of this project. The following agencies will be involved on
the implementation of this ESMP:
Table 47: Responsibilities for Environmental and Social Management

# Institution Responsibility on ESMP
1 Ministry of Transport, Infrastructure, • Provide Policy Guidelines
Housing & Urban Development • Enforce regulations and standards to
ensure safe, secure and efficient transport
and infrastructure systems
2 Kenya National Highways Authority • Overall supervision of Project ESMP
(KeNHA) - • Carry out monthly site safeguards
• Project Engineer – Team Leader & inspection to determine compliance
Employer Representative • Oversee internal and External Monitoring
• Deputy Director - Environment and of ESMP
Social Safeguards Department • Receive and evaluate Supervising
• Environmental Safeguards Specialist Consultant and Contractor safeguards
• Social Safeguards Specialist Reports
Pan-19-003 -192-
KeNHA
# Institution Responsibility on ESMP

• Registered Valuer • Provide Guidance safeguards to
Supervising Consultant and Contractor
safeguards teams
3 National Environment Management • Approve ESIA Report
Authority (NEMA) • Issue EIA License
• Carry out independent monitoring on
compliance with ESMP
4 County Governments of Wajir, Garissa • Ensure contractor complies with
and Isiolo requirements of the ESMP
• Coordinate activities in consultation with
KeNHA
5 Water Resources Authority (WRA) • Ensuring Water Sources are protected
• Issuance of water abstraction permits (for
boreholes, rivers etc)
6 Contractor • Construction of the road while protecting
• Environmental Specialist the community and the environment.
• Social Specialist • Execution of the ESMP
• Registered OHS Expert • Ensuring compliance with ESMP
7 Supervising Consultant • Daily supervision and monitoring of
• The Resident Engineer compliance with ESMP by Contractor
• Environmental Safeguards Specialist • Daily supervision and Monitoring of OHS
• Social Safeguards Specialist compliance by Contractor
• Preparation of monthly Reports on ESMPs
compliance by Contractor and any
incidences with regards to construction
activities
Table 48 provides the Environmental and Social Management Plan for the Modogashe-Wajir
Road Upgrade to Bitumen Standard.
Pan-19-003 -193-
KeNHA
Table 48: Environmental and Social Management Plan
Period (3yrs)
Pre-construction Potential Undertake the following specialized studies • KeNHA 15,000,000 Lumpsum -
environmental and • Biodiversity assessment for Lorian , Borji Swamps and
ecological impacts of other section of the proposed road corridor before
commencement of works
the Project Road
• Prepare Biodiveristy Management Plan to be
incorporated to the works contract
• Consult with communities along the road corridor to
identify additional livestock and Wildlife and livestock
crossing points and recommend the best design
features
Pre-construction Potential Preparation and use of CESMPs • KeNHA Included in Lumpsum
environmental and • Waste Management Plan • Contractor Contractor’s Cost
social impacts of • Traffic Management Plan
• Social Management Plan
construction activities
• Occupational Health and Safety Plan
by contractor
Pre-construction Loss of: • Carry out fair and adequate compensation and • KeNHA As per RAP Lumpsum
• Community and resettlement as per RAP and provide livelihood • NLC
Privately-owned restoration assistance to PAPs until their livelihoods
Land are restored to pre-project levels or better.
• Loss of Structures • Implement internal and external monitoring to ensure
• Loss of Livelihood the RAP is implemented appropriately.
• A grievance redress mechanism (e.g. establishment of
PAP Committee) will be put in place to address all
emerging complaints and grievances from the PAPs
and project area community.
Pre-construction Lack of Free Prior and • Prepare a community engagement plan • KeNHA Included in - -
Informed • Carry out regular consultation with VMGs especially • Contractor Contractor’s cost
on key issue like project implementation and selection • Resident
Consultations
of sites for contractor’s camp, quarry/borrow pits and Engineer
throughout the project water sources
implementation phase
for VMGs
Pan-19-003 -194-
KeNHA
Period (3yrs)
Pre-construction Displacement of Vulnerable HH to be provided with extra assistance as • KeNHA As per RAP - -
Vulnerable persons per RAP (e.g. sourcing host land, support with • NLC
exposing them to dismantling of structures, moving and building new
resettlement related structures).
impacts
Pre-construction Potential occurrence • Prepare a Grievance Redress Mechanism (GRM) • KeNHA Included in - -
of conflicts, and • Set up a Grievance Redress Committee (GRC) • Contractor Contractor’s
• Carry out training of GRC members • Garissa, Isiolo
complaints/grievances Clause
and Wajir
that need to be County
addressed representatives
• Community
Pre-construction Loss/disruption of • Provision of compensation for loss of net income for a • KeNHA As per RAP - -
livelihood due to period of 3 months • NLC
• Provision of livelihood restoration plan
project activities
Construction Contractors Camp • Institute proper domestic and office waste collection • Contractor Included in - -
Construction and and disposal. Practice waste segregation. supervised by Contractor’s cost
• Monitor septic tanks and exhaust before overflow the Resident
operation of
• Pave waste collection area at the camp Engineer
contractors Camp • Engage NEMA registered firms for collection and
• Pollution from disposal of ordinary and hazardous wastes
garage operations • Pave fuel dispensing areas with containments
and stored • Store all materials and chemicals on paved surfaces
materials • Provide appropriate ventilation for workers house/fans
• Domestic and • Provide disaggregated toilet facilities for men and
construction Waste women considering cultural and religious differences
Management
• Contractor to ensure proper construction of roads
within the camp that minimizes dust
• Technicians working at the garage to be instructed to
service vehicles on paved areas of the garage
• Store used oil and other fluids recovered from vehicles
and machinery in drums placed on paved surfaces
with containment
Pan-19-003 -195-
KeNHA
Period (3yrs)
• Make use of chain of custody forms for handling and
disposal.
Construction Loss of Flora along • Vegetation clearance should be restricted to the • Local Included in - -
the road corridor project footprint Administration Contractor’s cost
• Discuss with the local community and relevant • Community
authorities on methods of revegetation or members
compensation for the lost vegetation • Contractor
• Monitor planted trees for 2 years supervised by
• Areas to be cleared should be demarcated Resident 100,000/= Monthly 2,400,000
beforehand Engineer
• Except to the extent necessary for establishing the •
construction site and carrying out the construction
works, vegetation shall not be removed, damaged or
disturbed - -
• The construction workers should be sensitized on the
need to use alternative sources of fuel to meet their
energy requirement
Included in
• It is practically difficult to abate the advancement of
Prosopis juliflora however control measures can be Contractor’s cost
implemented by constantly monitoring the area to
control the advancement.
• Areas with dense indigenous vegetation shall not to be
disturbed unless required for construction purposes,
• Trees shall be trimmed rather than removed wherever
possible;
• The Contractor should plant indigenous and native
trees along the project road
• Stockpile construction materials in areas that are
naturally void of vegetation.
• The proposed biodiversity assessment to identify
additional design measures on wildlife crossings and
provide for free passage during construction
• Contractors to consider strategically locating borrow
areas so that during rain season they can harvest rain
water, the ponds can act as small reservoirs to
recharge groundwater, act as local watering holes for
Pan-19-003 -196-
KeNHA
Period (3yrs)
livestock and wildlife so at to lower frequency of
crossings by some wildlife and livestock herders
Construction Disturbance/loss of • Contractor will prepare a code of conduct to ensure • Contractor Included in - -
Fauna along the that workers do not consume game meat from the • Local Contractor’s cost
area, whether supplied by the locals or killed by Administration
project road corridor themselves.
• Awareness creation amongst the local people and the • Contractor
construction workers of laws that relate to wildlife supervised by
hunting and consumption, and the importance of Resident
wildlife as a natural resource and heritage. Engineer
• Avoid night time construction when noise is loudest.
Avoid night-time construction using heavy machinery,
from 10:00pm to 6:00am near areas known to have
wild animals
• Design and provide animal crossing infrastructure at
the identified animal crossing points (Lorian and Boji
Swamps, seasonal laggas). For large animals like the
Giraffe and elephants consider tapering the road
embarkments at the swamps and lagga areas to
facilitate crossing from one side of the road to the
other.
• KWS Officers need to be stationed at the construction
site
Construction • Harvesting of • Locate Quarry and borrow pit sites as far away as • Contractor Included in - -
Construction possible from human settlements supervised by contractors’ cost
Materials (Borrow • Locate processing plants (Crushers, Asphalt Plant and the Resident
Pits and Quarry) Concrete Batching Plants etc) away from settlement Engineer
• Processing Plants areas considering dominant wind direction which
(Crusher, Asphalt should be away from away from human settlements
Plant and • Use hydraulic hammers or other mechanical methods
Concrete Batching to extract rock material instead of using explosives
Plants) • Where blasting is not avoidable prepare a robust plan
- Noise together with KWS and implement appropriate
- Air Pollution evacuation
- Damage to • Maintain roads to material sites by adequately
property compacting the road to minimize fugitive dust.
Pan-19-003 -197-
KeNHA
Period (3yrs)
• Implement speed limit controls
• Adherence to the NEMA Integrated National Land Use
guidelines
• Establish at least 10 meters buffer zone between the
quarry, burrow or batching plants and the 30-meter
riparian reserve of the river, wetland and water
catchment areas. (i.e. 40 meters buffer zone between
the quarry and the edge of the river, wetland and water
catchment area)
• Siting of material sites should be in harmony with other
land uses and Provide for defined buffer zone between
quarries and other land uses. b. Quarry operations with
controlled blasting
• A technical officer (inspector of mines/explosives) to
advice accordingly as provided for under Subsidiary
Legislation 78 of Explosives Act and MSR 90 of the
Mining Act
• Contractor should establish quarry/burrow pit
rehabilitation and/or after use plan to be approved by
the NEMA as prescribed in the EMCA
• Discourage undercutting and tunnelling in quarries and
sand mining to avoid damage to property, injury or loss
of life.
• Prohibit vertical faces exceeding 2.5 m when quarrying
on soil, sand, gravel, soft rock or debris – these shall
be worked in terraces/ benches or at a safe angle of
slope.
• Hard rock quarry faces to be benched or worked from
top to bottom.
• All quarry faces/cliffs should be securely fenced. The
fence should be at least 3 meters from the edge of the
cliff using chain link of at least 1.5meters high.
• Warnings signs of appropriate font size and in the
appropriate language should be erected in all quarry
entries and in areas with high cliffs e.g. Danger Quarry
Deep Pit’ or ‘Caution Flying Stone and Debris’.
Pan-19-003 -198-
KeNHA
Period (3yrs)
• All access roads to and from quarries and burrow pits
to be made safe and accessible and transportation of
quarried material to follow a designated route.
• Contractors to ensure provision of clean water,
sanitation and well equipped first aid kit with trained
first aiders
• Provide protective gear for persons working in quarries
as provided for in the Public Safety Regulations
• Contractors’ workers to be trained on safety, health
and environmental issues and the quarry site should
have a person in charge of safety and ensure
establishment of ‘Safety, Health and Environment
Committees’ (SHEC).
• Each quarry site (where blasting is required) should
have suitable skilled blaster to carry out safe blasting
and acquiring blasting permits.
• All blasting materials /explosives should be acquired
and conveyed legally through acquisition of relevant
permit(s) from Mines and Geological Department.
Construction Noise Pollution • Contractor shall avoid night time construction when • Contractor Included in - -
noise is loudest near residential areas or areas near supervised by contractors’ cost
wildlife. the Resident
• There shall be no discretionary use of noisy machinery Engineer
within 50m of residential areas and near institutions or
use of manual labour in these sections
• Contractor shall ensure good maintenance and proper
operation of construction machinery.
• Contractor shall ensure that where possible, non-
mechanized construction shall be applied to reduce the
use of machinery
• Ensure that all vehicles and construction machinery
are kept in good condition all the time to avoid
excessive noise generation.
• Ensure that all workers wear ear muffs and other
personal protective gear/equipment when working in
noisy sections.
Pan-19-003 -199-
KeNHA
Period (3yrs)
• Ensure the NEMA maximum noise level is observed
for the eight working hours i.e. 55 dB.
• Undertake loud noise and vibration level activities
during off-peak hours during the day (i.e. between 8.00
am and 5.00 pm)
Construction Air Pollution (Fugitive • Control speed of construction vehicles and Prohibit • Contractor
Dust and Exhaust idling of vehicles; supervised by
• Water is to be sprayed during the construction phase the Resident
Emissions) Engineer Included in - -
on dusty areas to reduce dust emission;
• Regular maintenance of vehicle & equipment to Contractor’s cost
reduce smoke;
• Provision of dust masks for use by workers in dusty
conditions;
• Use of serviceable vehicles/machinery to avoid
excessive exhaust emissions;
• Operation and maintenance of contractor’s plant in
compliance with relevant vehicle emission standards
and manufacturer’s specification to minimize air
pollution.
• Install improvised screens to minimize dust at stone
crusher.
• Monitoring of daily air quality during and after
construction to ensure no major negative impacts or
come up with mitigation measures
Construction Risk of site pollution • Employee awareness on company procedures for Contractor Included in the - -
by oil and fuel spills at dealing with spills and leaks from oil storage tanks. supervised by the Contractor’s cost
• Isolation of source and containment of leaks.
camp, construction Resident
• Provision of absorbent material for emergency
and material sourcing cleanup in case of spill Engineer
sites • Maintenance of contractor’s machinery and vehicles
• Contractor to provide for oil/grease interceptors in
motor vehicle garages
• Recovered used oil will be kept in a paved store house
with containment.
Pan-19-003 -200-
KeNHA
Period (3yrs)
• Contractor will keep records of all recovered used oil
and hydraulic fluids in a chain of custody form for
appropriate handling and disposal
• Fuel dispenser (pump) and dispensing area will be
paved with containment.
• Fuel Skid Tanks will be mounted within a leak proof
bunded wall with equivalent capacity to the tank for
containment
• Servicing of machinery and vehicles will be restricted
to the paved garage area
• Provision of relevant emergency numbers
Construction Soil Degradation • Provision of adequate drainage facilities to channel • Contractor • Included in - -
water from one side of the road to the other. supervised by Contractor’s
• Provision of temporary drainage for run-off water the Resident cost
• Restoration of the ground by allowing for natural Engineer • Restoration
revegetation or planting adequate grass and trees. cost covered in
Flora and
• Provision of a borrow pit/ quarry site rehabilitation Fauna cost
plan, including a standalone ESIA/ESMP for each new • Included in the
borrow pit/quarry site. Contractors
• Planning emergency response measures in case of clauses
accidental oil spills. • Oil spill costs
are included in
Contractor’s
cost
Construction Proliferation of • Re-use of nutrient rich top soil in the areas of origin. • Contractor Included in - -
invasive species • Making use of cut and fill road material within similar supervised by Contractor’s cost
homogeneous areas the Resident
• Minimal stockpiling periods. Engineer
• Proper storage of stockpiled material.
Construction Water Resources • Proper solid and liquid waste disposal from the • Contractor Included in the - -
construction camp and offices will be done supervised by Contractor’s
• Water will be reused where possible to reduce the Resident
Engineer clauses
demand on ground water sources
• Oil water separators and grease traps will be installed
and maintained as appropriate at fueling facilities, - -
Pan-19-003 -201-
KeNHA
Period (3yrs)
workshops, parking areas, fuel storage and Included in the
containment to reduce potential contamination risk to Contractor’s cost
water sources
• All equipment, machinery and vehicles being used at
the Ewaso Ngiro River Bridge, Lorian and Boji Swamp
areas and River Laggas will be inspected on a daily
basis for any fuel/oil leaks before use
• During the rainy season when Ewaso Ng’iro River and
other streams crossing the road are flowing, water
samples will be collected once every two weeks for
TPH and PAH analysis during construction at each
facility to monitor impact of the construction activities
on the water sources. The water samples will be
collected
o approx. 100m upstream,
o at the crossing (where the bridge or culvert is being
constructed) and
o 100m down stream
• Ensure measures are in place to quickly recover any
spilled fuel, oils and lubricants for appropriate
disposal.
• All waste will be disposed of to appropriate NEMA
licensed facility
• Handling, storage, treatment and disposal of
hazardous substance will be in line with appropriate
standards to reduce contamination of water
resources. The procedures for all stages of
hazardous waste handling, storage, use and disposal
will be defined in the CESMP
• The Contractor will contruct/drill own water sources
for construction activities and after construction these
facilities can be given back to the communities
• The Emergency Response Plan will identify
procedures that will include measures to protect water
environment from contamination in the event
emergencies such as spills and leaks
Pan-19-003 -202-
KeNHA
Period (3yrs)
Construction Increased Traffic • Contractor will implement the Traffic Management • Contractor Included in - -
Plan supervised by Contractor’s
• Provide traffic controllers/marshals the Resident
clauses
• Provision of retro reflective night time signage at Engineer
ongoing works and road deviations
• Effecting traffic controls to avoid congestion and Included in - -
accidents on roads. Contractor’s cost
• Choosing suitable traffic routes to reduce impact in the
neighbourhood.
• Ensuring no interference with traffic through traffic
control, designated parking, speed limits.
• Provision of a road safety analysis and campaign
including provision of temporary and permanent road
crossing facilities for domestic animals, wildlife and
people
• Maintain temporary diversion and access roads
Construction Impacts on Physical • Before construction commences, the contractor should • Contractor Included in - -
Cultural Resources carry out reconnaissance survey to establish that the supervised by Contractor’s costs
road corridor does not have any mosques or graves. the Resident
• Inform the local community on the actions being taken Engineer
to avoid such sites. • National
• Re-design the road routing to avoid the encountered Museums of
physical cultural resource Kenya (NMK)
• Apply the “Chance Find Procedure” provided in Annex Officers
6 to protect any cultural resources that may be
underground.
Construction Disruption of Service • Preparation of a stakeholder engagement plan Contractor Included in
Delivery Impacts • Provide alternative routes, traffic controllers, concrete Contractor’s costs
barriers and speed limits for motorists.
• Communication on any intended disruption of the
services. • KeNHA & 15,000 Monthly 540,000
• Repair of any affected areas in consultation with the Relevant Included in
local authorities. service
provider Contractor’s
clauses
Pan-19-003 -203-
KeNHA
Period (3yrs)
Construction Occupational Health The Contractor is to: • Contractor Included in - -
and Safety • Prepare a detailed Occupational Safety and Health supervised by Contractor’s
Management Plan (OSHMP) that will provide all the the Resident
Engineer clauses
required health and safety measures needed for the
project activities.
• Prepare Emergency and Response Plan • Appointed
• Provide a whistle-blower policy to ensure wellbeing of Health and
whistle-blowers Safety Officer
• Trained occupational health and safety staff and fire
marshal shall be appointed on-site for the duration of
Included in
the construction work.
• Prepare a Code of Conduct that inter alia commits to Contractor’s cost
the Implementation of the OSHMP and that also
commits at individual level to compliance to OSHMP
requirements and standards.
• Carry out work assessment and identify hazardous
substances and working conditions and include safety
measures in the OSHMP
• Carry out daily tool box meetings for all workers
• Conduct a road safety analysis and campaign with
the local community, including road crossings for
domestic animals, children etc.
• Ensure that all construction machines and equipment
are in good working conditions and to manufacturer’s
specifications to prevent occupational hazards.
• Provide road signs and barriers to block off working
areas from the rest of the traffic.
• Appoint qualified health and safety advisor staff on-
site for the duration of the construction work.
• Provide workers with appropriate personal protective
equipment (PPE).
• Provide workers with adequate drinking water and
breaks.
Pan-19-003 -204-
KeNHA
Period (3yrs)
• Provide workers training on safety procedures and
emergency response such as fire, oil and chemical
spills.
• Roads passing through population centres will be
water sprayed to suppress dust.
• Work to minimize or altogether eliminate mosquito
breeding sites.
• Project for worker’s health clinic with a nurse on -site
• Provide for an ambulance vehicle to evacuate
emergency cases
• Fence off the site with security to avoid unauthorized
access to the borrow site(s) and hence mitigate
potential injuries from accidental falls.
• Provide clean toilets for workers, these toilets will be
to World Health Organisation standards
• Carry out regular and statutory health and safety
audits
• Contractor to undertake WIBA insurance for workers
Construction Community Health The Contractor is to: • Contractor Included in - -
and Safety • Prepare and implement an occupational health and supervised by Contractor’s
safety plan. the Resident
Engineer clauses
• Carry out awareness and sensitization meetings with
community members on safety issues at the project area
• Fence off the camp site, borrow Pit sites and Quarry • Appointed Included in -
Sites with security to avoid unauthorized access and Health and Contractor’s cost
also protection of community members and their Safety Officer
livestock from accidental fall into the borrow and
Quarry excavations to mitigate potential injuries.
• Carry out regular monitoring and assessment of
community health and safety issues with a view to
improve on performance
• Conduct a road safety analysis and campaign with the
local community, including road crossings for domestic
animals, children etc.
• Barricade working areas from the rest of the traffic
Pan-19-003 -205-
KeNHA
Period (3yrs)
Construction Employment of locals • Contractor will prepare Labour Management Plan • Contractor Included in - -
• The Contractor will prepare an employment plan to supervised by Contractor’s
manage employment of labour the Resident
clauses
• Contractor will prepare a code of conduct to ensure Engineer
that workers follow established work ethics and avoid
discrimination, Gender Discrimination, annoyance, Included in
promote tolerance of different cultures and religion Contractor’s cost
• Unskilled construction and skilled (if available) labour
• Use of manual labour where possible to ensure more
employment of locals and hence ensure project
support throughout the construction process.
• The contractor will ensure that all workers’ pay
adheres to minimum wage requirements to avoid
labour unrest.
awareness, prevention and management of HIV / AIDS
through staff training, awareness campaigns,
multimedia, and workshops or during community
Barazas.
• The Contractor will enforce and maintain a code of
conduct for his employees
• Skills transfer will be enhanced to enable some of the
local staff to gain new skills.
• In consultation with local communities come up with
suitable CSR measures for the community
• Contractor will provide Workers’ grievances redress
mechanism
• Hire qualified Human Resources Officer to manage
labour related risks
Pan-19-003 -206-
KeNHA
Period (3yrs)
Construction Increase in • The Contractor will prepare and implement a • Contractor Included in - -
incidences of HIV and HIV/AIDS management plan • Appointed Contractor’s
• Sensitize workers and the surrounding communities Health and
AIDS clauses
on awareness, prevention and management of Safety Officer
HIV/AIDS through staff training, awareness • Public Health
campaigns, multimedia, and seminars/workshops Officer Included in
and during community Barazas. Contractor’s cost
• Provide an on-site clinic to provide VCT services to
construction crew and provision of ARVs for
vulnerable community members
• Ensure workers are regularly reminded about the
code of conduct and the potential consequences if
not adhered to
Construction Liability for loss of life, • Developing a site safety action plan. • Contractor Included in - -
injury or damage to • Prepare and implement a grievance redress supervised by Contractor’s
mechanism the Resident
private property clauses
• Workers to be provided with appropriate PPE Engineer
• Induction of workers on appropriate operation of the • Appointed
machinery and equipment Health and Included in
• Provision of adequate signage at working sites Safety Officer Contractor’s cost
• Ensuring that the prepared code of conduct for staff is
followed to prevent accidents.
• Cordoning off unsafe areas using barriers or barrier
tapes
• Keeping records of all injuries that occur on site in the
incident register, corrective actions for their prevention
are instigated as appropriate.
• Compliance with the Workmen's Compensation Act,
ordinance regulations and union agreements.
• Carry out baseline evaluation of property near the
project road, borrow sites and quarry to minimize
controversy on damages caused by construction.
• Repair/compensate any damage done to private
property.
Pan-19-003 -207-
KeNHA
Period (3yrs)
Construction Labour influx • Prepare a labour influx plan to manage labour influx Contractor Included in - -
• Unskilled construction and skilled (if available) labour supervised by the Contractor’s
Resident clauses
• Use of manual labour where possible to ensure more Engineer
employment of locals and hence ensure project Included in the
support throughout the construction process. Contractor’s Cost
awareness, prevention and management of HIV /
Included in
AIDS.
• The Contractor will enforce and maintain a code of Public Health Contractor’s Cost
conduct for his employees Officer
• Sensitize workers on the different cultures and
inculcate tolerance
• Enforce and maintain a code of conduct for employees
• Contractor is to monitor and report on the
implementation and effectiveness of the labour influx
related mitigation measure
• Due to the possibility of conflicts arising between
workers and the locals, the Contractor shall ensure all
key staff, receive training regarding the likelihood,
significance and management of influx-related issues.
• Through the Non-Governmental Organization that will
be handling GBVSEA issues, hold sensitize the
community on possible occurrence of GBV and how
they should respond.
• Monitor potential occurrence of annoyance, conflicts
that may arise from differences in lifestyle and culture
between community and in-migrants
• The Contractor shall ensure that the Grievance
Redress Mechanism (GRM) addresses issues related
to labour influx
• Monitor the potential occurrence of Gender Based
Violence (GBV), Sexual Harassment and Violence
Against Children (VAC)
Pan-19-003 -208-
KeNHA
Period (3yrs)
Construction GBV, Sexual Contractor will: • Contractor Included in the - -
Harassment and • Provide and implement a gender-based violence supervised by Contractor’s
strategy, which will include: the Resident
Sexual Exploitation Engineer clauses
• Provide and implement an employee code of conduct
and Abuse (SEA) and
for workers • Local
Violence Against Administration
Children (VAC) • Ensure there is Gender mainstreaming in employment
at the worksite with opportunities provided for females
to work, in consonance with local laws and customs
• Liaise with KeNHA to ensure NGO concerned with
GBV issues to be engaged as early as possible before
construction commences since GBV and cases
Violence Against Children will arise early in the project
• Grievance redress mechanisms that incorporates non-
retaliation and specific procedures for GBV.
• The works contractor will be required, under its
contract, to prepare and enforce a No Sexual
Harassment and Non-Discrimination Policy, in
accordance with national
• Contractor to prepare and enforce a code of conduct
that will be signed by all project workers prohibiting
SEA and SH by workers and providing an
accountability and response framework including non-
retaliation against those who report.
• Ensure there is Gender sensitization of workers (this
will be done by the HIV/AIDS services provider; see
above)
• NGO engaged by KeNHA to mobilise early in order to
educate all workers and nearby communities and
stakeholders on preventing and responding to SEA,
sexual harassment and GBV ahead of any project
related works;
• Popularize /put in place safe, ethical and confidential
mechanisms and hotlines for reporting
SEA/SH/GBV/VAC cases;
Pan-19-003 -209-
KeNHA
Period (3yrs)
• Strategies such as male involvement will be employed
in preventing and responding to GBV/SEA and sexual
harassment;
• Establish partnerships with relevant government
agencies, GBV Service Providers and NGOs to ensure
survivors of GBV and sexual offences access survivor
centred services such as medical care, psychosocial
support, legal redress, safety, etc as and when
necessary;
• Provision of gender disaggregated facilities - separate
bathing, changing, sanitation facilities for men and
women;
• Prepare grievance redress mechanisms with specific
procedures for GBV including confidential reporting
with safe, and ethical documenting of GBV cases
should be set up for the workers and community;
Construction Project Impacts on • Ensure equitable distribution of employment Contractor Included in - -
Women opportunities between men and women supervised by the Contractor’s cost
• Provide toilets and bathrooms for both male and
Resident
female workers on site
• The women will be involved in the periodic Engineer
dialogues/consultations with the contractor and host
communities during construction to enable them
handle their other roles while working with contracto r
Construction Security Risks and Contractor will: Contractor Included in the - -
Crime Management • Prepare Security Management Plan supervised by the Contractor’s
• Prepare a code of conduct for signing by all staff Resident clauses
members
Engineer
• Recruit Security Coordinator to coordinate security
issues with security agencies Included in
• Fence off the Contractor’s camp that contains plant
Contractor’s cost
and materials.
• Work with local committees in addition to the
Contractor’s own security.
Pan-19-003 -210-
KeNHA
Period (3yrs)
• Remove any employee who persists in any
misconduct or lack of care, carries out duties
incompetently or negligently, fails to conform to any
provisions of the contract, or persists in any conduct
which is prejudicial to safety, health, or the protection
of the environment.
• Take all reasonable precautions to prevent unlawful,
riotous or disorderly conduct by or amongst the
contractor's personnel.
• Prohibit alcohol, drugs, arms, and ammunition on the
worksite among personnel.
• Log in all events of a criminal nature that occur at the
worksite or at the civil works activities.
• Report all activities of a criminal nature at the worksite
or contractor's employees to the police.
• KeNHA has carried out a Safety/Security Audit of the
project road and provided mitigation measures for the
project road
Construction Impacts on children • Provide and implement a child protection strategy • Contractor Included in the - -
• Ensure no children are employed on site in accordance supervised by Contractor’s
with national labour laws the Resident
clauses
• Ensure that any child sexual relations offenses among Engineer
contractors' workers are promptly reported to the
• Local
police
Administration
• Sensitize Community on child protection and
• County
eradication of child labour.
Governments of
Isiolo, Garissa
and Wajir
All Project Intra/Inter Community • Contractor will prepare a Security Management Plan • Contractor Included in the - -
Phases Conflicts • The Contractor will develop Resource Use supervised by Contractor’s
Management Plan. the Resident
clauses
• Contractor will prepare and implement a stakeholder Engineer
engagement plan to ensure continuous communication • Local
and discussions with all stakeholders Administration
• The Contractor will source for new water sources for • Security Agents
construction e.g. Boreholes, pans and rain water
Pan-19-003 -211-
KeNHA
Period (3yrs)
harvesting, after construction these facilities can be • County Included in
given back to the communities. Governments of Contractor’s cost
• KeNHA and Contractor will convene meetings with the Isiolo, Garissa
Somali and Borana communities in Modogashe to and Wajir
discuss project implementation plans to avoid conflicts
arising during implementation.
• Contractor and KeNHA will convene similar meetings
in Samatar/Guticha and Lagbhogol to diffuse intra
community conflicts that may arise over resources
during construction (selection of camp sites and
• Contractor and KeNHA to consider providing CSR
where possible to reduce some of the pressure on
resources
• Contractor to ensure there is a working grievance
redress mechanism to address/mitigate any
community grievances early before escalation to
conflict.
• Contractor and KeNHA are to provide regular updates
on project progress and fulfill agreed actions
Construction Conflicts from project • Contractor to establish presence of any cultural • Contractor Included in the - -
construction activities resources near sites of construction and avoid them. supervised by Contractor’s cost
• Contractor to consult with local/religious leaders to the Resident
ensure Cultural Sites are identified and measures put Engineer
in place to avoid disturbance.
• Contractor to ensure access is provided to all cultural
resources near the road.
Construction Project • Contractor will appoint a Liaison Officer to facilitate • Contractor Included in the - -
Communication smooth communication between the project and the • KeNHA Contractor’s
community
clauses
• Contractor will prepare and implement a
communication and community/stakeholder
engagement plan that addresses all project issues
Pan-19-003 -212-
KeNHA
Period (3yrs)
Construction Complaints from the • Contractor will prepare an effective and strong • Contractor Included in the - -
communities and Grievance Redress Mechanisms (GRM) that is • KeNHA Contractor’s
responsive to GBV reporting and other issues that may
other stakeholders arise. clauses
Construction and Flooding in Lorian To minimize the impact, the design has incorporated • Contractor Included in the - -
operation and Borji due to climate resilience measures which include: • KeNHA Contractor’s cost
• Increasing of capacity and frequency of drainage
Climate Change structures
• Raising of road surface level above expected flood
levels
• Strengthen Lorian swamp embankments
• Provide bank protection for culverts and bridges
• Provide road overtopping protection
• Reduce Sedimentation Rates from Sand – ensure
culverts are free of sedimentation to ensure design
capacity
Operation Increased Traffic • Provision and maintenance of safety signage along the KeNHA 600,000 Annually -
along the Project corridor.
Alignment • Periodical road safety audits to establish any issues
measures
Operation Air Quality • Policing of unroadworthy vehicles to reduce air KeNHA - - -
pollution Traffic Police
Operation Community (Public) • Provision and maintenance of safety signage along the KeNHA Included in Traffic - -
Health and Safety corridor. Cost
• Periodical road safety audits to establish any issues
measures.
• Carry continuous Public Health and Safety awareness
Operation Risk of truck drivers • Provision of visible signage. KeNHA - - -
stopping along the • Working with the police to ensure drivers make use of
truck stops.
project area
• Encouraging the establishment of businesses near the
truck stops to service the truck stops.
Pan-19-003 -213-
KeNHA
Period (3yrs)
Operation Impacts of KeNHA to work with the County Governments of the KeNHA, County 1,000,000.00 Annually
newcomers to the three counties on integration between newcomers and Governments and
project area. along host communities. Administration
the project area
Decommissioning Decommissioning • Prepare a Decommissioning Plan and submit to NEMA Contractor Included in the - -
Plan of exhausted and the County Governments of Garissa, Isiolo and Contractor’s cost
Wajir and obtain approval for implementation.
material sites and
• Obtain approval of decommissioning plan from NEMA
camp
Decommissioning Decommissioning of • Implement the decommissioning plan including Contractor Included in the - -
the Contractor’s camp backfilling, revegetation, disposal of waste material, Contractor’s cost
recycling of recyclable material
• Obtain Clearance Certificate for successful
rehabilitation/restoration for each facility (Camp,
Borrow Pit or Quarry Site)
Source: ESIA Study 2019
Pan-19-003 -214-
KeNHA
9.3 Contractor Clause
9.3.1 Contractors Obligations
510. Contractor will be expected to address all aspects of the construction activities in
compliance with all laws and regulations, approvals, licenses and permits which are
applicable to the proposed road project. The Contractor shall ensure that he is familiar
with the ESMP for the project. He shall prepare his work plan and strategy taking into
account the relevant provisions of the ESMP. The prepared Management plans shall be
reviewed and approved by Environment and Social Safeguards Department of KeNHA
before commencement of the works.
511. The Contractor will also be expected to evaluate the construction

activities/components and prepare appropriate project implementation management
plans including:
a) Construction Environment and Social Management Plan

b) Waste Management Plan
c) Occupational Safety and Health Plan
d) Traffic Management Plan
e) Community Engagement Plan
f) Child Protection Strategy
g) Workers Code of Conduct
h) HIV and AIDS Management Plan
i) Stakeholder Engagement Plan
j) Labour Influx Plan
k) Grievance Redress Mechanism
l) Employment Plan
m) Quarry and Borrow Pit Management Plan
n) Prevention and Protection Against GBV and Sexual Exploitation
o) Whistle-blower
512. The Contractor will be expected to engage the following safeguards officers on a
full-time basis for the period of the project.
i. Environmental Specialist
ii. Social Specialist
iii. Registered OHS Expert
513. During the bidding process, the Contractor will be expected to include a brief
methodology on the implementation of Environmental and Social Safeguards and attach
a cost of implementation of these plans in his proposal bid. In addition, the Contractor
will have to provide relevant staff for the implementation of the safeguards including a
CLO and EHS expert. The above officers will have the responsibility of assisting the
Contractor to comply with the safeguard’s requirements. Among other duties, the
safeguards officers will be responsible for carrying out roles as listed in Table 49.
514. The Contractor’s Safeguards Team will be reporting to the Supervising Consultant
on Safeguards achievements, issues and challenges on regular basis.
Pan-19-003 -215-
KeNHA
Table 49: Roles of Safeguards Officers Engaged by the Contractor

No Title/Designation Duties/Roles
1 Environmental • Assist the Contractor to Develop CESMPs
Safeguards Officers • Implement Environmental Safeguards in the project to protect
people and the environment
• Prepare Sub-Project ESIA Reports for various approvals and
Permits
• Coordinate environmental compliance in the project
• Oversight waste management
• Ensure environmental information reaches team leaders
• Prepare environmental safeguards reports
3 Occupational • Review of Health and safety plan
Safety and Health • Supervision of Implementation of Health and safety safeguards
Officer in the project.
• Prevent and mitigate injury
• Evaluate project risk for mitigation
• Carry out surveillance on safety issues
• Enforce site safety plan on scene.
• Carry out safety training
• Carry out regular Safety Tool Box Talks
• Prepare of Health and Safety Reports
3 Social Specialist • Interface between the Contractor and the workers, community
and Consultant Engineer staff.
• Support the contractor on social safeguards and helps mobilize
and organize committee and other stakeholder meetings.
• Record incidences taking place during construction work and
liaises with the RE Sociologist to address the emerging issues.
9.3.2 The Supervising Consultant
515. The Supervising Consultant will also have its team that will be overseeing
safeguards implementation in the project. The team will be fully engaged by the
Supervising Consultant on a full-time basis for the period of the project. Their role will be
to work together with the Contractors safeguards Team as they oversee safeguards
implementation. They will be advising the Supervising Consultant on compliance levels
and required action.
516. Supervising Consultant Team in safeguards will be composed of the following:
i. Supervising Engineer (RE)

ii. Social Safeguards Specialist
iii. Environmental Safeguards Specialist
9.3.3 Kenya National Highways Authority (KeNHA)
517. Kenya KeNHA Implementation Team will be composed of the following Officers:
i. Project Engineer (Team Leader & Employer Representative)

ii. Deputy Director-Environment & Social Safeguards (overseeing safeguards
implementation)
iii. Environmental Safeguards Specialist
iv. Social Safeguards Specialist
v. Registered Land Valuer
Pan-19-003 -216-
KeNHA
518. The KeNHA Safeguards Team who will be operating under the KeNHA Project
Implementation Team will be visiting the project site regularly to monitor safeguards
compliance, resolve any emerging issues and provide guidance.
9.3.4 KeNHA Safeguards Capacity Enhancement
519. KeNHA has engaged full time environmental and social safeguards consultants to
enhance inhouse safeguards capacity and provide dedicated support for NETIP project.
Support from State Agencies

NB: The above team will be supplemented by officers from other state agencies like NEMA,
DOSH, NLC, National Gender Commission, National Aids Control Council etc.
Pan-19-003 -217-
KeNHA
10 GRIEVANCE REDRESS MECHANISM (GRM)
10.1.1 Proposed Grievance Redress Mechanism
521. An Effective Mechanism to Redress Grievances requires:
• That grievances do not linger on and become contentious issues between project
authorities and the affected community and result in opposition to the project;
• PAHs and the overall community appreciate efforts by the project authorities to reach
out to hear concerns, proactively address and resolve issues; and
• PAHs particularly demonstrate willingness to support and benefit from the
implementation of proposed mitigation measures.
Box 1. Essentials in Grievance Redress

• Acknowledge dissatisfaction: Accept that the displacement due to a development
shall generate grievances, rather than ignore or turn away
• Effective listening: Careful listening to elicit information regarding the grievance shall
help to accurately define the problem
• Separate facts from fiction: Ask for facts and record it (preferably by the PAH
himself). If illiterate, provide support as necessary;
• Quick turn-around: Take optimum time to analyse ascertain and decide and finally
communicate the decision to the PAP. Keep communicating with PAHs in case of
delays
• Follow-up: If decision requires a follow up action, take it soonest to instil confidence
in the PAP regarding the grievance mechanisms and process
522. Grievance Redress Mechanism Players “The Key Players in the Grievance Redress
Process are:
Box 2. Grievance Redress Mechanism Players

• VMGs and affected parties living in the project area
• Influential persons in the project affected village
• County Government
• National Government
523. The Grievance Mechanism provides affected parties with a mechanism to express any
issues and problems that they may have with the project implementation process in a
way which is free of cost and without retribution. Affected parties will also have ultimate
recourse to the courts in accordance with the provisions of Kenyan law. To ensure that
the basic rights and interests of project affected people are protected, that their concerns
are adequately addressed and that entitlements are delivered, a grievance procedure is
outlined.
10.1.2 Appointment of Grievance Redress Committee Members
524. Membership to committees will be elected by the VMGs except the assistant chiefs’
locational chiefs, sub county administrators, county administrators, contractors, KeNHA
PIU who will automatic members of the team by virtue of their positions. Each committee
will elect their chairperson and a secretary. The members of the GRCs will be appointed
through an election process with all the affected PAHs in the project area participating.
Pan-19-003 -218-
KeNHA
525. The elections will be facilitated by KeNHA/PIU and the local administration including
national and county government.
10.1.3 Remuneration of Grievance Redress Committee Members
526. All the members of the GRCs established at the different levels will perform their
duties on a voluntary basis. There will be no remuneration other than costs associated
with transport, communication, meals and sitting allowance.
10.1.4 Capacity-Building for Grievance Committee
527. The Grievance Committee members will also need to be oriented to the grievance
management system suggested. The capacities of the Grievance Committee members
will also need to be built around issues of conflict identification, conflict information
analysis and conflict resolution Below, A 5 tier/level grievance redress structure is provided
for to ensure amicable review and settlement of grievances that may arise in the project.
528. Level 1: Maslaha: The Maslaha is a body comprising of village elders that plays a
significant role among the local communities and is respected. They have the mandate
to resolve conflicts including land related conflicts; natural resources related conflict e.g.
pasture; interclan conflicts; among others.
Box 3. Maslaha
1. The Maslaha is composed of village elders of good reputation and who have
knowledge of customs and culture of the local communities.
2. Village elders forming the Maslaha are not elected, as long as one has a good
reputation in the society and is regarded as impartial then he is welcomed in the
council. Women are not part of this forum.
3. Maslaha decisions are strongly respected. In case a person defies their decision,
the person will be fined and/or banned from attending any social functions e.g.
burials, marriages or any other function that brings the community together. The
person is may be excommunicated from the community.
521. This social assessment prefers this as the first level of grievance or conflict redress.
A record of any/all grievances received and handled will be kept at all phases of the
implementation process.
522. However, the use of maslaha as an alternative system of dispute and conflict
resolution in solving issues of rape and other forms of gender and sexual based violence
is not advocated for in this project based on the fact that the system is recognized as
contributing to the rise of such cases due to the nominal compensation required from
offenders. Grievances not resolved by the Maslaha will be taken to the second level.
523. Level 2: Village Grievance Redress Committees: Grievances that are not
resolved by the Maslaha and those where the parties are either non-Muslim or have
shown a preference for an alternative mechanism may be taken to the second level
categorized as the Village Grievance Redress Committees with the following
membership: -
Pan-19-003 -219-
KeNHA
Box 4. Composition of Village Grievance Redress Committees

1. The sub locational chief,
2. Assistant chief,
3. One project affected youth,
4. One project affected woman,
5. One project affected male
6. Ward Administrator
7. Contractor representative
524. Level 3: Sub County Grievance Redress and Resettlement Committee: There
will be a mediation committee at the Sub County level to handle grievances that cannot
be resolved by the village level committees and membership will include:
Box 5. Composition of Sub County Grievance Redress Committees

• One representative of the Administration; - National Government
• One representative of County Administration; - County Government
• One representative of the construction contractor,
• One project affected youth
• One project affected female
• Supervision consultant/social specialist
• A representative of NEMA
• A representative of WRMA
525. Level 4: County Grievance Redress and Resettlement Committee: There will
be a mediation committee at the County level to handle grievances that cannot be
resolved by the sub county level committee. This will be a high-level committee
constituted on a need basis. It will comprise of KeNHAs project implementation unit and
other relevant government agencies called upon depending on the matter under
consideration.
526. Level 5: Formal systems of dispute resolution: This entails using the courts of
Kenya to litigate the dispute.
10.1.5 The Commission on Administrative Justice (CAJ) – the Ombudsman
527. Another avenue for grievance redress is the Commission on Administrative Justice.
The Ombudsman is the formal feedback and complaints handling mechanism in Kenya.
Its mandate is to receive and address complaints against public officers and public
institutions to improve service delivery. Three types of complaints can be made to the
office of the Ombudsman including: (i) Citizen against State/public officers and
institutions; (ii) Public Officers against fellow public officers; and, (iii) Public Institutions
against other public institutions. The Ombudsman has a three step and time bound
mechanism for feedback and grievance redress as illustrated below;
Step 1: Complainant fills in a Complaint Form

• Complaint is assessed for compliance with CAJ Mandate;
• If within mandate, CAJ commences inquiries and complainant is issued with
copy of communication – CAJ 2 [Sec. 43];
• If NOT within CAJ mandate, Complainant is advised accordingly and/or referred
to appropriate government agencies;
Pan-19-003 -220-
KeNHA
• If a response is not received from the respondent after 14 working days, CAJ
sends a first reminder giving the respondent 7 days to comply;
• If no response is received after this, a final reminder of 7 days is sent;
• If there is still no response after 28 days, summonses are issued to the
respondent in line with [Sec. 27(a)].
Step 2: If after the summonses the respondent still fails to comply, the Ombudsman
proceeds to:
• Determines the complaint in the absence of the respondent;
• Institutes legal proceedings against the respondent [according to Sec. 52];
• Cites the respondent as an unresponsive State or Public Office or Officer, and/or
declares such State or Public Officer to be unfit to serve in the Public Service;
Step 3: How the Ombudsman Undertakes Grievance Redress Action: In Resolving A

Complaint, The Ombudsman May:
• Conduct investigations according to articles [A.59 (2)(i)] [Sec 8 b)] [A.252(1)(g)]
[Sec. 53 (1)];
• Demand and obtain information or documents [S.26 (d)];
• Conduct an inquiry [A.252(1)(g)]
• Undertake mediation, negotiation and conciliation [A.252 (1) (b)];
• Constitute a hearing panel;
• Invite or summon any person or persons to attend to the Commission [S.26 (f)];
• Obtain orders from the Court authorizing Searches or Seizures [Sec.26 (e)].
• Obtain warrants of arrest for breach of any summons or orders of the
Commission.
During the social assessment, it was established that the office of the ombudsman
has devolved to Wajir and Isiolo towns. It has however not extended its services to
the interior parts of either Counties. This may pose a challenge to VMGs who live-
in far-flung areas and are unable to make frequent trips to the towns due to lack of
transport and attendant costs.
10.1.6 National Land Commission
528. The National Land Commission is tasked with facilitating and increasing access to
fair and equitable mechanisms for resolving land and natural resource-based disputes
and conflicts. The commission is mandated to initiate investigations, on its own initiative
or on a complaint, into present or historical land injustices, and recommend appropriate
redress and to encourage the application of traditional dispute resolution mechanisms in
land conflicts. It carries out its mandate through various means including holding public
inquiries. The NLC presents an alternative formal mechanism for dealing with grievances
to VMGs. It is particularly relevant to this project due to the anticipated resettlement of
families living along the proposed project area, and who will be entitled to due process
when the decision to resettle them is reached. This avenue is therefore also proposed.
10.1.7 Courts of Kenya
529. Courts in Kenya provide a robust avenue for resolution of disputes for aggrieved
persons and will be the final level for grievances that remain unresolved.
Pan-19-003 -221-
KeNHA
10.1.8 grievance mechanism for workers
530. Contractors will put in place a Grievance Mechanism for their workers that is
proportionate to their workforce, according to the following principles1:
• Provision of information. All workers should be informed about the grievance
mechanism at the time they are hired, and details about how it operates should be
easily available, for example, included in worker documentation or on notice
boards.
• Transparency of the process. Workers must know to whom they can turn in the
event of a grievance and the support and sources of advice that are available to
them. All line and senior managers must be familiar with their organization's
grievance procedure.
• Keeping it up to date. The process should be regularly reviewed and kept up to
date, for example, by referencing any new statutory guidelines, changes in
contracts or representation.
• Confidentiality. The process should ensure that a complaint is dealt with
confidentially. While procedures may specify that complaints should first be made
to the workers’ line manager, there should also be the option of raising a grievance
first with an alternative manager, for example, a human resource (personnel)
manager.
• Non-retribution. Procedures should guarantee that any worker raising a complaint
will not be subject to any reprisal.
• Reasonable timescales. Procedures should allow for time to investigate grievances
fully, but should aim for swift resolutions. The longer a grievance is allowed to
continue, the harder it can be for both sides to get back to normal afterwards. Time
limits should be set for each stage of the process, for example, a maximum time
between a grievance being raised and the setting up of a meeting to investigate it.
• Right of appeal. A worker should have the right to appeal to KeNHA or national
courts if he or she is not happy with the initial finding.
• Right to be accompanied. In any meetings or hearings, the worker should have the
right to be accompanied by a colleague, friend or union representative.
• Keeping records. Written records should be kept at all stages. The initial complaint
should be in writing if possible, along with the response, notes of any meetings
and the findings and the reasons for the findings.
• Relationship with collective agreements. Grievance procedures should be
consistent with any collective agreements.
• Relationship with regulation. Grievance processes should be compliant with the
national employment code.
• Workers committees are formed to help resolve the grievances.
• Workers are encouraged to join unions.
1
Based on Annex D of the Guidance Note for IFC’s Performance Standard 2.
Pan-19-003 -222-
KeNHA
11 SOUND ENVIRONMENTAL AND SOCIAL MONITORING
531. Most of the environment where the proposed road upgrading will take place is an
existing road in use but currently a murram road. Environmental and Social monitoring is
an integral part of the environmental and social management process. It rationally
completes the process that begins with, establishing the environmental baseline
condition followed by carrying out the Environmental and Social Impact Assessment then
Implementation of mitigation measures and Monitoring the success of those measures.
532. Environmental and Social monitoring is envisioned as an important process in

project management. The monitoring programme will reveal changes and trends brought
about by the presence and operations of the project. Such information will be useful in
the formulation of sustainable project management and operation strategies. The basic
activities for a sound-monitoring programme for the road once it starts operating should
at least include the following parameters:
• Collection and analysis of relevant environmental and social data of the site including:
✓ Evaluation of the site vegetation cover that is to be cleared before construction
✓ Evaluation of the type and quantity of solid waste generated at the construction site
✓ Inspection of the materials being used;
✓ Evaluation of the construction practices;
✓ Monitoring to ensure to prevent invasion by exotic species;
✓ Evaluation of noise generation and duration during construction activities;
✓ The amount of water consumed during the construction of a section of the road;
✓ Quality of life of the project area community;
✓ Monitor sources of energy for cooking and lighting;
✓ Change in health trends of the project area community;
• Identification of unexpected environmental and social impacts;
• Formulation of counter-measures to mitigate unexpected negative impacts and
comparing them with actual impacts as identified during the assessment.
11.1.1 Internal Environmental and Social Monitoring
533. Internal Monitoring of the project activities will be carried out by the following:
KeNHA
534. Safeguards Team from the Environment and Social Safeguards Department will
carry out project montly and quarterly site visits and carry out safeguards compliance
audits on a nnual basis and reports prepared.
Supervising Consultant -
535. Safeguards officers in Supervising Consultants Office to carry out daily monitoring
of safeguards compliance by contractor. They are to convene regular safeguards
meetings (monthly) to discuss environmental, social and OHS issues and performance .
They are to ensure Contractor organises brief daily toolbox talks on Health and Safety.
Pan-19-003 -223-
KeNHA
• Incident/accident notification and reports to be prepared submitted to KeNHA

Environment and Safeguards Department within 28 hours
• Safegurds Reports (Environmental, Social and OHS) to be submitted on a monthly basis
Contractor
536. Safeguards Team in the Contractor’s Office to carry out daily supervision of
safeguards compliance by construction workers. Contractor’s Supervisers to hold daily
toolbox talks on safety and ensure all workers have appropriate PPE before start of work
every morning.
537. Submit weekly reports on safegurds to Superving Consultants Office. Table 50

provides safeguards monitoring activities to be carried by different project implementation
offices.
Table 50: Internal Environmental and Social Monitoring of Construction Activities

Officers Activity Aspects/Parameters Output
Carry out • Inspect project safeguards Preparation of
environmental documents includig CESMPs, environmental
safeguards permits, safety induction, meetings safeguards
inspection of and tool box talks monthly Audit
construction • Inspect waste management at the reports
activities on a camp and construction sites
monthly basis or • Inspect Environmental protection
as soon as (Garage, Workshop, field etc)
KeNHA KeNHA deems • Inspect traffic traffiic management
Environmental necessary. and signages
Safeguards • Inspect PPE use by workers
Specialist • Inspect incident records and reports
Meeting with • Discuss findings with safeguards
Safeguards staff on the project
officers from the • Establish whether there are
Contractor and challenges requiring intervention
Supervising from KeNHA
Consultants Office • Provide Guiidance on non-
after field compliance to Supervising
inspection Consultant and Contractor
KeNHA Social Carry out social • Review social safeguards Preparation of
Safeguards safeguards documents social
Specialist inspection of the • Evaluate GRM performance safeguards
construction • Evaluate Stakeholder/Community monthly Audit
activities Engagement/Meetings reports
• Review involvment of VMGs in
project activities
• Review information disclosure
• Review labour influx and its impact
on VMGs
• Review GBV and Violence Against
Children (VAC)
• Provide Guiidance on non-
compliance to Supervising
Consultant and Contractor
Pan-19-003 -224-
KeNHA
Supervising Supervision of • Carry out daily supervision and Preparation of

Consultant Construction monitoring of the ESMP Compliance monthly reports
(Environmental activities ensuring by Contractor on Safeguards
and Social Contractor • Carry out daily supervision and performance
Safeguards complies with monitoring Monitoring of OHS
Specialists) safeguards compliance by Contractor
requirements • Provide guidance to Contractor on
non-compliance
• Monitor safety induction/meetings of
Contractor team
Contractor Implementation of • Carry out daily monitoring of Preparation of
(Environmental, ESMP compliance with ESMP during weekly reports
Social and OHS construction on safeguards
Safeguards • Provide appropriate PPE compliance for
Specialists) • Carry out daily Monitoring of OHS of submission to
workers Supervising
• Monitor safety induction/meetings Consultants
activities to ensure compliance Office
• Review accident logs and
investigation reports/corrective
action plans
538. The ESIA study has revealed that the proposed upgrading of Modogashe-Wajir
Road to bitumen standard will generate potential project impacts that require mitigation
measures during construction period. These potential impacts will also require close
monitoring during construction and post construction period.
539. Monitoring will involve measurements, observations, evaluations, assessment and

reporting on various variables during construction and operation.
Arising from the study, the aspects to be monitored are given in Table 51.
Pan-19-003 -225-
KeNHA
Table 51: Environmental and Social Monitoring Plan (Monitoring Plan)

2. Construction
Contractor’s Public health and • Reports from Community • Provision of condoms, contraceptives and Monthly • RE’s
Camp safety • Physical inspection mosquito nets. Environmental
• EHS records • No of campaign meetings on transmission of Supervisor
• Incident logs maintained by diseases like HIV/AIDS and other STDs. • Contractor’s
Contractor • Availability of adequate solid waste bins and Environmental
waste disposal procedures Supervisor
• Availability of first aid facilities.
• Outpatient attendance registers.
• Prevalence rates of common diseases.
• Compliance with the Occupational Safety and
Health
• Compliance with Public Health Act.
Solid and liquid • Physical inspection of Camp • Presence of scattered litter. Monthly • RE’s Environmental
wastes from Offices • Physical inspection of • Confirm records of waste disposal Supervisor
and Residential sewage system • Signs of obstruction of water courses. • Contractor’s
areas • Number of complaints • Evidence of engaging a NEMA registered waste Environmental
disposal firm Supervisor
Hazardous/Chemical • Physical inspection • Presence of oil spillage Weekly • RE’s Environmental

waste (Used Oil, Oil of Garage and workshops • Chain of custody forms for handling, storage Supervisor
filters, hydraulic fluids • Records of hazardous waste and transportation for disposal by NEMA • Contractor’s
and Lubricants) handling and disposal registered firm Environmental
• Contract of NEMA Registered Firm Supervisor
HIV&AIDS • Inspection of HIV/AIDS • Number campaign meetings on transmission of Quarterly • RE’s Social Supervisor
prevention services in the diseases like HIV/AIDS and other STDs. • Contractor’s Social
project • Number of condom dispensers within the site. Supervisor
• Number of condoms, ARVs • Number of ARVs provided to vulnerable • Community
provided. persons Representative
Pan-19-003 -226-
KeNHA

Material Sites Solid and liquid • Physical inspection • Scattered litter Monthly • RE’s Environmental
(Quarry, wastes • Number of complaints • Signs of obstruction of water ways. Supervisor
Borrow Pits) • Flow of wastewater on the ground surface. • Contractor’s
and Crusher • Provision of sanitary facilities to the Environmental
Plant construction crews. Supervisor
Noise • Documentation on • Level of noise generated.by quarry • RE’s Environmental

complaints about noise • Provision of PPE. • Use of portable and EHS Supervisors
• Carry out noise daily • Compliance with existing noise standard issued equipment to monitor • Contractor’s
measurements by NEMA. noise levels on Environmental and
• Zone out elevated noise a) Health, Educational facility regular and adhoc EHS Supervisors
areas for mandatory use of 109 dB(C) Max basis
PPE (ear muffs) • Monitor daily during
b) Residential, Commercial Facilities active operation
114dB(C)
• Exhaust emissions • Interview residents including • Provision of PPE. equipment to monitor Supervisor
• Fugitive dust workers • Compliance with existing air quality standards air pollution on • Contractor’s
• Liaise with other issued by NEMA regular and adhoc Environmental and EHS
stakeholders - Sulphur Oxides (SOx) - 60µg/m3 basis Supervisors
• Carry out daily air quality - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor daily on
measurements (SOx, NOx, - Respirable Particulate Matter (RPM) - active operation
PM10 and HC) 50µg/m3
- Total Volatile Organic Compound (VOC) -
600µg/m3
Rock Blasting • Physical inspection • Area of influence of the rock blasting After every blast • RE’s Environmental
causing damage to • Field determination of area • Baseline status of nearby structures Supervisor
structures of influence • Contractor’s
Environmental and EHS
Supervisors
Stone Crusher, Noise • Documentation on • Level of noise generated. • Use of portable • RE’s Environmental
Asphalt and complaints about noise • Provision of PPE. equipment to monitor and EHS Supervisors
• Carry out daily noise noise levels on
Concrete
measurements
Pan-19-003 -227-
KeNHA

Batching • Zone out elevated noise • Compliance with existing noise standard issued regular and adhoc • Contractor’s
Plants areas for mandatory use of by NEMA. Maximum allowed for sites in basis Environmental and EHS
ear muffs Construction sites • Monitor daily during Supervisors
c) Health, Education, Residential active operation
Day - 60 dB(A), Night – 35 dB(A)
d) Place of Worship
• Liaise with other - Sulphur Oxides (SOx) - 60µg/m3 and adhoc basis Environmental and EHS
stakeholders - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor daily during Supervisors
• Carry out daily air quality - Respirable Particulate Matter (RPM) - active operation
measurements (SOx, NOx, 50µg/m3
PM10 and HC) - Total Volatile Organic Compound (VOC) -
600µg/m3
Risk of falling into • Physical inspection of fence • Incident records Monthly • RE’s EHS Officer
excavations at line surrounding facility
borrow pits and
quarry
Road Vibration causing • Physical Inspection • Establish baseline of existing structures Monthly • RE’s Environmental
Construction damage to • Field measurement of neighboring the road and Social
neighboring vibration level and distance • Compliance with existing noise standard issued Supervisors
Activities structures of influence. by NEMA. • Contractor
• Liaise with other - Sulphur Oxides (SOx) - 60µg/m3 and adhoc basis. Environmental and EHS
stakeholders - Oxides of Nitrogen (NOx) - 60µg/m3 • Monitor 3 times a week Supervisors
• Carry daily out air quality - Respirable Particulate Matter (RPM) - near settlement
measurements (SOx, NOx, 50µg/m3 centres and institutions
PM10 and HC) - Total Volatile Organic Compound (VOC) - like mosques, hospitals
600µg/m3 and schools
Pan-19-003 -228-
KeNHA

Traffic Management • Physical inspection of the • Incident records Daily • RE’s Environmental
during the day road under construction to • Accidents and road kill and EHS Supervisors
ensure flagmen are active • Compliance with approved traffic management • Contractor’s
and road signs are in place plan Environmental and
• Maintaining speeds EHS Supervisors
recommended by KWS due
to presence of
livestock/wildlife
Traffic Management • Installation of retro-reflective • Incident records Daily • RE’s EHS Supervisor
at night road signs • Accidents and road kill • Contractor’s Traffic
• Physical Inspection of road Management
signs Supervisor
Drainage Discharge • Physical inspection of water • Registered complaints of damages Weekly during the rainy • RE’s Environmental
causing damage drainage discharge routes • Records of damage caused season when drainages Supervisor
• Reports from Community contain water • Contractor’s
• Damage caused Environmental
Supervisor
Water Pollution at • Physical inspection of • Lab analysis results • Use of Portable • RE’s Environmental
camp (garage) and machinery, equipment and equipment to monitor Supervisor
River/Lagga vehicles for oil leaks hydrocarbon pollution • Contractor’s
crossings including • Water quality monitoring on regular and adhoc Environmental
Lorian and Borji upstream, road crossing and basis Supervisor
swamps downstream for TPH and • Monitor weekly during
PAH analysis rainy season when
rivers/laggas and
swamps contain water
Noise • Documentation on • Level of noise generated. • Use of portable • RE’s Environmental

• Carry out daily • Compliance with existing noise standard issued noise levels on • Contractor’s
• noise measurements by NEMA. regular and adhoc Environmental and
• Zone out elevated noise a) Residential Outdoor basis EHS Supervisors
areas for mandatory use of Day - 50 dB(A), Night – 35 dB(A) • Monitor daily during
PPE (ear muffs) b) Place of Worship active operation
Pan-19-003 -229-
KeNHA

Flora and Fauna • Records of uprooted trees • Amount of vegetation removed Quarterly • Environmental
• Physical observation • Change in animal behavioral pattern Supervisor
• Discussions with KWS
Gender • Review of company staff • Number of female employees Quarterly RE’s Social Supervisor
Empowerment records. • Number of male and female toilets
• Physical Inspection
Crime Management • Review of records • Number of reported crimes Monthly RE’s Social Supervisor
and security • Interviews with staff and • Number of complaints
local community
Impacts on Children • Review of records • Record of employees including IDs Monthly RE’s Social Supervisor
• Interviews with staff and
local community
GBV, Sexual • Review of grievance redress • Number of complaints Monthly • RE’s Social Supervisor
Exploitation and forms. • NGO Handling GBV
Abuse • Interviews with local issues
community
Loss of Life, Injury • Interviews with staff and • Record of accidents and damages done Monthly • RE’s Environmental
and Damage to local community. and Social
Private property • Review of records Supervisors
• Contractor
Labour Influx • Interviews with local • Number of grievances Monthly RE’s Social Supervisor
administration on influx and • Incidences of conflicts
conflicts
• Complaints log
• Interviews with grievance
committee members
Increased Conflicts • Police incidence reports • Records of conflicts with local administration Monthly RE’s Social Supervisor
• Information from Local • Number of grievances
Administration • Complaints logs
• Grievance/Complaints logs
Pan-19-003 -230-
KeNHA

Operation
Completed Road Safety – • Inventory of signages • Missing road signage Replacement of signage KeNHA
Road missing road signage especially at settlement
areas and wildlife crossing
Completed Traffic Accidents • Number of accidents • Police accident reports Monthly KeNHA
Road • Cause of accidents
Completed Wildlife movement • Road Kill records • No of wildlife able to across the road Monthly KeNHA
Road across the road • Ease of movement of KWS
livestock and wildlife across
the road
Completed Noise pollution from • Complains from community • Level of noise generated. Monthly KeNHA
Road traffic at settlement • Noise measurements • Compliance with existing noise standard issued KWS
centres and Lorian • Wildlife behavioral change by NEMA.
Swamp where a) Residential Outdoor
significant wildlife is Day - 50 dB(A), Night – 35 dB(A)
found b) Place of Worship
Completed Drainage • Complaints from community • Records of drainage water damages Rainy season KeNHA
Road • Route taken by drainage
water after leaving the road
infrastructure
Source: ESIA Study, 2019
Pan-19-003 -231-
KeNHA
12 CONCLUSIONS AND RECOMMENDATIONS
12.1 Conclusions
540. Arising from the analysis the proposed project is unlikely to generate irreversible or
permanent negative impacts. The project area community and key stakeholders support
the project and would like that it is implemented as soon as possible so that they can
start enjoying its benefits.
541. The ESIA has identified potential negative environmental and social impacts that
are likely to arise and proposed appropriate mitigation measures that require
implementation. The impacts include temporary; significant, short term, long term and
cumulative impacts. Some of the issues that have been noted by the consultant regarding
the project include the following:
a. The Modogashe-Wajir Road serves as the administrative boundary of:

• Garissa and Isiolo Counties for the segment between Modogashe and Habaswein
• Wajir West and Wajir South Sub-Counties from Habaswein to very close to Wajir
Town.
This occurrence is generating competition over resources even for residents of the same
centre where the road is the only thing separating the communities.
b. It was observed that inclusive stakeholder consultations have to be done on every

aspect throughout the life of the project to avoid potential conflicts arising. KeNHA and
the contractor have to ensure that thorough stakeholder consultations are done with the
community(ies) and representative committees that will be set up before the following is
implemented:
• Selection of location for Camps and material sites
• Selection of the sites where the boreholes are drilled .
• Local workers are hired and engaged
• The Community is regularly informed about the progress on issues that are
affecting them
3. ESMP is implemented according to recommendations provided.
12.2 Recommendation
542. Arising from the findings of the study, the following recommendations are made:
1. Contractor is to make robust Contractor’s environmental and social management plan to

address the many challenges that will arise during construction phase of the project. The
list of required management plans is provided in Section 9.3 of this report.
2. Contractor is to ensure the managements plans for this project are implemented as
proposed.
3. Due to the significant labour influx expected at the project area GBV issues and Violence
against Children (VAC), crime, conflict over job opportunities and cultural issues are likely
to increase. The Contractor shall ensure the following plans are ready for implementation
before commencement of construction activities:
• Stakeholder engagement plan
• Labour Management Plan
• Workers Code of Conduct
Pan-19-003 - 232 -
KeNHA
• NGO handling GBV issues is ready to mobilize

• Grievance Redress Mechanism (GRM)
• Contractor and the local NGO who will be managing the GBV/SEA issues to
ensure sensitization and training plans are in place.
Pan-19-003 - 233 -
KeNHA
BIBLIOGRAPHY
ACTS-UNEP (2001). The Making of a framework Environmental Law in Kenya. Acts press,
Nairobi, Kenya.
Africa Waste and Environment Management Centre (2012). Environmental and Social
Impact Assessment Study Report for The Proposed Mombasa-Nairobi Standard
Gauge Railway Project.
Ahmad, Y. J., and Sammy, G. K. (1985). Guidelines to Environmental Impact Assessment

in Developing Countries. Sponsored by the United Nations Environment
Programme.
AWEMACand HCG Infra Ltd (2017). Environmental and Social Impact Assessment Study
for Modogashe-Samatar Road
De Leeuw, J. et al., 2012. Benefits of riverine water discharge into the Lorian Swamp,
Kenya. Water, 4(4): 1009-1024.
E-Cue Associates (2014). Environmental and Social Impact Assessment (ESIA) Study
Report for the Proposed Dongo Kundu-Mariakani 400kV Transmission Line.
Gereau, Roy E.; Cumberlidge, Neil; Hemp, Claudia; Hochkirch, Axel; Jones, Trevor;
Kariuki, Mercy; Lange, Charles N.; Loader, Simon P.; Malonza, Patrick K.;
Menegon, Michele; Ndang’ang’a, P. Kariuki; Rovero, Francesco; and Shirk, Phillip,
"Gobally Threatened Biodiversity of the Eastern Arc Mountains and Coastal
Forests of Kenya and Tanzania" (2016). Journal Articles. Paper 272
Gereau, R. E., Karlukl, M., Ndang ang a, P.K.,Werema, C. & Muorla, P. (2014) Biodiversity
Status and Trends In the Eastern Arc Mountains and Coastal Forests of Kenya
and Tanzania Region, 2008-2013.Nairobi: Birdlife International - Africa
Partnership Secretariat
Gichuki, F., H. Liniger, L.C. MacMillan, G. Schwilch, J.K. Gikonyo. 1998. Scarce water:
exploring resource availability, use and improved management. Eastern and
Southern Africa Geographical Journal 8: 15-27.
Pan-19-003 - 234 -
KeNHA
Hughes, R.HH; Hughes, J.S. (1992) A directory of African Wetlands. IUCN.
Howard Humphreys (2018). Environmental and Social Impact Assessment Study for the
Isiolo - Kulamawe Road
IFC Handbook for Preparing a Resettlement Action Plan.
Intercontinental Consultants & Technocrats and ITEC Engineering Limited (2018/19).

Design Report for the Modogashe-Samatar Road
Intercontinental Consultants & Technocrats and ITEC Engineering Limited (2018/19).

Design Report for the Samatar-Wajir Road
Intercontinental Consultants & Technocrats and ITEC Engineering Limited, Preliminary

Environmental and Social Impact Assessment (ESIA) Study for Samatar-Wajir
Road, April 2018
Intercontinental Consultants & Technocrats and ITEC Engineering Limited, Preliminary

Environmental and Social Impact Assessment (ESIA) Study for Modogashe-
Samar Road, March 2018
Intercontinental Consultants & Technocrats and ITEC Engineering Limited, Draft

Resettlement Action Plan (RAP) Report for Modogashe-Samatar Road, March
2018
Intercontinental Consultants & Technocrats and ITEC Engineering Limited, Draft

Resettlement Action Plan (RAP) Report for Samatar-Wajirr Road, January 2019
JICA (2010). Guidelines for Environmental and Social Considerations.
Kenya Government (2012). The Land Registration Act, No. 3 of 2012.
Kenya Government (2012). Land Act, No. 6 of 2012.
Kenya Government (2010). The Local Government Act, CAP 265 (Revised).
Kenya Government (1997). Community Land Act 2016.
Pan-19-003 - 235 -
KeNHA
Leon Bennun and Peter Njoroge (1999), Important Bird Areas in Kenya
Muchoki, I. (2019). Resettlement Action Plan Studyfor the Modogashe-Wajir Road
National Atlas of Kenya, Fourth Edition (1991).
Otieno Odongo and Partners (2008). Environmental and Social Impact Assessment Study
for the Isiolo-Garbatula-Modogashe Road
Panafcon Ltd (2017). Reviewing & Updating of Resettlement Action Plan (RAP) for The
Proposed Dualling of Mombasa - Mariakani A109 Road Project.
Research Sound Support Limited – Social Assessment Report for Isiolo-Mandera

Road Corridor – 2018
Risper A. Pete (2019). Social Safeguards Performance Audit - LOT 1 Lodwar-

Lokitaung Junction
UNEP (1996). Environmental Impact Assessment: Issues, Trends and Practice.
UNES (2016). Dongo Kundu Resettlement Action Plan (RAP) Study Consultancy. Final
RAP Report Volume I & II.
World Bank (2016). Project Information Document/Integrated Safeguards Data Sheet

(PID/ISDS) – North Eastern Transport Improvement Project (P161305)
World Bank (1993). The World Bank and the Environment.
World Bank (1991). Environmental Assessment Sourcebook. Volume I. Policies,

Procedures and Cross-Sectoral Issues. Environment Department. Technical
Paper No. 139.
World Bank (1991). Environmental Assessment Sourcebook. Volume II. Sectoral

Guidelines. Environment Department. Technical Paper No.140.
Pan-19-003 - 236 -
KeNHA
World Bank (1991). Environmental Assessment Sourcebook. Volume III. Guidelines for
Environmental Assessment of Energy and Industry Projects. Environment
Department. Technical Paper No.154.
Zamconsult Consulting Engineers (2019). Environmental and Social Impact Assessment

Study for the Isiolo-Modogashe Road Road
Pan-19-003 - 237 -
KeNHA
13 COLOPHON
KeNHA/Revised and Updated ESIA for the Upgrading of Modogashe-Samatar-Wajir

157Km (A13) Road
Pan-19-003
Client : Kenya National Highways Authority (KeNHA)
Project : ESIA for the Proposed Upgrading of Modogashe -
Samatar - Wajir Road to Bitumen Standards
File : 19-003
Length of report : 238 pages
Author : Joshua P. Oyieko
Contributions : Technical Team
Date : October 2019
Name/Initials : jo/oro
Pan-19-003 - 238 -
KeNHA
ANNEXES
Pan-19-003 - 239 -
KeNHA
Annex 1: People Contacted During the ESIA Study
Pan-19-003
KeNHA
PEOPLE CONTACTED DURING THE ESIA STUDY

# People Contacted # People Contacted
1 Dr Walter Barongo Nyatwang'a 9 E.ng. E. Wambua
Deputy Director, Environment & Regional Director
Social Safeguards North Eastern Regional Office
Kenya National Highways Authority Kenya National Highways Authority
(KeNHA)
(KeNHA)
P.O.BOX 41 – 70100
Blue Shield Towers, Hospital Road, GARISSA.
Upper Hill Tel: 0727 461040
P.O. Box 49712 – 00100, Email: rm.northeastern@kenha.co.ke
Nairobi Kenya
Tel: +254-20-4954116
2 Eng Albert Semutwa 10 Osman Bagaja
Regional Director Director
Upper Eastern Regional Office Environment, Energy and Natural
Resources Isiolo County Government
Kenya National Highways Authority
ISIOLO
(KeNHA) Tel: 0721819981
P.O.BOX 325 -60300
ISIOLO
Tel: 0645352074
Email:
rm.uppereastern@kenha.co.ke
3 Penuel Kemboi 11 Yahya Dahir Osman
Director Department of Environment, Energy and
Ministry of Roads and Transport Natural Resources Wajir County Government
(Garissa County) WAJIR
Tel: 0725848134
Tel: 0720764633
Email: Yaxya4580@gmail.com
Email: keboichepkew@gmail.com
4 Daud Yakub Guliye 12 Mohamed Farah
County Director Of Livestock County Director Water Services
Production Wajir Water Services (Wajir County)
Wajir County Tel: 0723929349
Tel: 0725923781 Email: engmfarah10@yahoo.com
5 Hon. Mowlid Issack Mussa 13 Loyford Kibaara
Member of County Assembly County Commissioner
Wajir, Ademasjida Ward Interior (Wajir County)
Tel: 0727447813 Tel: 0727929751
Email: Mowlid.issack@ gmail.com
6 Abdull Ibrahim 14 Hassan Mohamed Said
Chief Officer Education and Vocational Chief
Training Ministry of Interior and National Coordination
Wajir County Government (Wajir County)
Tel: 0721669407 Tel: 0715275531
Email: abdullIbrahim2014@gmail.com
7 Philip Lenaiyasa 15 G.K Mwaura
County Chief Officer Ecosystem Conservator
Tourism and Wildlife Isiolo County Kenya Forestry Services (Isiolo County)
Government Tel: 072340584
Pan-19-003
KeNHA

Tel: 0720595755
8 Hadija G. Guyo- CCO 16 Dr. Aden Mohamed Dahiye

County Chief Officer Chief Officer
Youth and Sports Isiolo County Ministry of environment, Energy, Tourism &
Government Mining (Garissa County)
Tel: 0726666160 Tel: 0720914491
Email: Adeshmoha2009@gmail.com
17 Mohamed Idriss 27 S.O. Migiro
Chief HRMO Ecosystem Conservator
Department of Agriculture, Livestock, Kenya Forestry service (Garissa County)
Fisheries and Irrigation (Garissa Tel: 0728388106
County) Email: zmgarissa@kenyaforestservice.org
Tel: 0720716828
Email: midrissm@gmail.com
18 Benjamin Lepetet 28 Kenneth Murithi-
County Chief Officer Assistant Technical Co-ordination Manager
livestock and fisheries Isiolo County G.W.O
Government Water Resource Authority Isiolo
Tel: 0725016762 Tel: 0710459076
19 Qabale Golicha 29 Huqa Gedho
County Chief Officer NEMA (Wajir County)
Roads and Infrastructure Isiolo County Tel: 0722928978
Government Email: huqagedho@gmail.com
Tel: 0716624326
20 Mohamed Dayib 30 Noor Kato Abdikadir
County Government of Wajir – Roads & County Public Health Officer
Transport Ministry of Health (Wajir County)
Tel: 0710743708 Tel: 0720254624
Email: Modayib2010@gmail.com
21 Ambia Abdi Osman 31 WAJWASCO
Ecosystem Conservator Wajir County
Kenya Forest Service (Wajir County) Tel: 0721290121
Tel: 0720969074 Email: abdi.mohamed9@yahoo.com
Email: Zmwajir@kenyaforestservice.org
22 Dida Abdi 32 Hussein Haji Boru
Ass. Chief Senior Chief
Isiolo, Garbatula, Komor Bula Location, Isiolo, Garbatula, Modogashe Location
Modogashe, Nort Sub Location Tel: 0728460762
Tel: 0722606056
Email: adjtullusaubura@ gmail.com
23 Abdirahman Hussein Gure 33 Yusuf Mohamed Sheikh
Chief Chief
Garissa, Lagdera, Modogashe Location Garissa, Lagdera - Skanska, Ilan Location
Tel: 072879776 Tel: 0722768383
Email: yusufsheikh@ gmail.com
24 Mohamed Omar 34 Hussein Abdulah Abdille
Snr Asst. Chief Asst. Chief
Leheley (Wajir County) Borji (Wajir County)
Tel: 0724773349 Tel: 0710931187
Pan-19-003
KeNHA

Email: mohamedomarbarreh@
gmail.com
25 Mohamed Ibrahim Abdulahi 35 Mohammed I. Abdi

Senior Chief Senior Chief
Lagbogol North (Wajir County) Lagbogol South (Wajir County)
Tel: 0721881589 Tel: 0722377331
Email: Moibab93@gmail.com
26 Adbiaziz Mohamed 36 Nassir Ali Elmi
Chief Asst. Chief
Wajir Township (Wajir County) Wajir Township (Wajir County)
Tel: 0722722383 Tel: 0720336992
Email: abdinasir72@ live.com
37 Abdikadir Barrow Adan 47 Barud Abdi Diis
Chief Asst. Chief
Alimaow (Wajir County) Furaha (Wajir County)
Tel: 0721290121 Tel: 0724926715
Email: Abdikadirbarrow@gmail,com Email: Barudabdi492@gmail.com
38 Alinoor Abdi 48 Abdirahman Hassan Hussein
Asst. Chief Chief
Guticha, Wajir West (Wajir County) Kanchara, Wajir West (Wajir County)
Tel: 0725231533 Tel: 0728754021
39 Adan Abdi Madey 49 Osman Hassan Ali
Chief Asst. Chief
Lagdima, Wajir South (Wajir County) Lagdima, Wajir South (Hadado South Sub
Tel: 0723764377 Location) (Wajir County)
Email: adanamadey@gmail.com Tel: 0722306385
Email: Oskaa075@ gmail.com
40 Felix Ingasia 50 Khalif Sirat Farah
Asst. County Commissioner Senior Chief
Habaswein (Wajir County) Habaswein (Wajir County)
Tel: 0728807573 Tel: 0728628718
Email: Khalifsirat1959@ gmail.com
41 Mohamed Adan Abdikarim 51 Wajir Bus Service
Asst. Chief Transport (Wajir County)
Habaswein, Hadado South Location Tel: 0795477788
(Wajir County)
Tel: 0724549965
Email: Taliyal20302030@ gmail.com
42 Hussein Abdullahi Yakub / Nuh 52 Mohamed Ali Hirey
Mohamed Chief Officer
Samatar Bus Service Limited (Wajir Ministry of Environment, Energy Tourism &
County) Mining (Garissa County)
Tel: 0723809313 / 0721555167
Email: Nuhow53@gmail.com
43 Kuyoni Lemereu 53 Abdi Ali
Warden Chief Officer
Kenya wildlife service (Garissa County) Department of Gender,Culture & Social
Tel: 0725581681 services (Garissa County)
Email: klemereu@kws.go.ke Tel: 0722697401
Email: abdinuriye@gmail.com
44 John M. Mwangi 54 Abdiweli Mohamed
Pan-19-003
KeNHA

GWO Principal Administrator
WRA (Garissa County) Department of Lands (Garissa County)
Tel: 0723207195 Tel: 0722704631
Email: mwangijm667@gmail.com Email: weliyrwooq.am@gmail.com
45 Kadubo Adano 55 Kimuta Matthew
County Chief Officer Planning officer
Public Works, Housing and Urban Lands,Physical Planning and urban
Development Isiolo County Development Isiolo County Government
Government Tel: 0712549712
Tel: 0722333361
46 Council of Imams 56 Religious Leaders
Habaswein(Wajir County) Supreme Council of Kenya Muslims -
Tel: 0722932161 SUPKEM (Wajir County)
Tel: 0729298426
Email: supkemwajiruranch@gmail.com
57 Lands Wajir County
County Chief Officer
Lands, Housing and Physical Planning
Department of lands (Wajir County)
Tel: 0721250190
Email: Abdibra10@yahoo.com
Pan-19-003
KeNHA
Annex 2: Minutes of PCMs and Attendance Registers
No. of
# Location PCM Venue Day Date Time Women Men
Participants
1. Leheley Leheley Centre Wednesday 20/02/2019 9.00 a.m. 22 43 65
2. Wajir Town Baraza Park Wednesday 20/02/2019 02.30pm 13 26 39
3. Borji Centre Borji Centre Thursday 21/02/2019 09.30am 29 58 87
4. Lagbogol Centre Lagbogol Centre Thursday 21/02/2019 02.30pm 44 81 125
5. Guticha/ Samata Guticha/ Samata Friday 22/02/2019 09.30am 17 17 34
Centre Centre
6. Kanchara Centre Kanchara Centre Friday 22/02/2019 02.00pm 37 31 68
7. Lagdima Centre Lagdima Centre Saturday 23/02/2019 10.00am 3 27 30
8. Habaswein Habaswein Saturday 23/02/2019 02.30pm 28 86 114
9. Skanska Skanska Monday 25/02/2019 10.00am 8 31 39
10. Lagdera Modogashe Monday 25/02/2019 02.30pm 14 39 53
11. Sericho Modogashe Monday 26/02/2019 10.00am 18 50 68
Total 233 489 722
Pan-19-003
KeNHA
MINUTES OF THE PUBLIC CONSULTATION MEETING (PCM) FOR THE ESIA STUDY FOR
THE UPGRADING OF MODOGASHE-WAJIR ROAD (157km) TO BITUMEN STANDARD (A13).
THE MEETING WAS HELD ON WEDNESDAY FEBRUARY 20, 2019 AT LEHELEY

TRADING CENTRE STARTING AT 09.00AM.
AGENDA OF THE MEETING
1. Opening prayer by one of the participants.

2. Introduction of Participants
• National Government Representatives
• County Government Representatives
• KeNHA
• Study Team
• Project Area Leaders/NGOs/CBOs
3. Purpose of conducting the Public Consultation Meeting (KeNHA/Study Team).
4. ESIA Study Activities carried out along Modogashe-Wajir Road (Study Team)
5. Findings of the Study/Project Environmental Impacts (Study Team).
6. Proposed Mitigation Measures
7. Views of the Participants
a. Comments on Project Impacts and Mitigations.
b. Suggestions of CSR Projects along the Road Corridor.
c. Q & A.
8. Closing Remarks by (KeNHA/County Government/National Government).
9. A.O.B.
10. Closing Prayer by one of the participants
Minute 01: Opening Prayers

The meeting was called to order at 9.45am and began with a word of prayer from one of the
participants.
Minute 02: Introduction of the Participants.

The Leheley Sub-Location Senior Assistant Chief (Mohamed Omar Barreh)) welcomed everyone
in attendance. He acknowledged and thanked the participants for finding time to attend the meeting.
He introduced the elders that attended the meeting.
Mr Oyieko introduced himself and the Study Team (Jane Ogonji – Sociologist, Yusuf and Shaan
who were assisting as interpreters during the meetings.
Mr Howard Omutoko (KeNHA Garissa Office) Introduced himself and the other members of the
KeNHA Team (Charles Aduke and Onesimus Satoh)
Minute 03: Purpose of conducting the Public Consultation Meeting (PCM).

Mr. Oyieko started by highlighting that Study Team had called for the Public Consultation Meeting
to highlight the following:
a) Previous ESIA Study: Mr Oyieko elaborated that Environmental and Social Impact
Assessment (ESIA) Studies had been carried out in 2017/18 and an ESIA Study Report
prepared and submitted to KeNHA
b) Review and Update of ESIA Study: Study Team is carrying out the review and update of the
Environmental and Social Impact Assessment of the report prepared in 2017/18.
c) Disclosure of the Project Environmental and Social Impacts and Proposed Mitigation
Measures: Mr Oyieko elaborated that the purpose of conducting the PCMs is to disclose to the
Project Area Community and Stakeholders the Findings of the Environmental and Social
Impact Assessment (ESIA) Studies and the Proposed Mitigation Measures.
Pan-19-003
KeNHA
Minute 04: The ESIA Study Activities carried out along the Modogashe-Wajir Road
Study Team has carried out assessment activities along the Modogashe-Wajir Road and evaluated
the following:
a) Assessment of existing vegetation, water sources (rivers, streams, wells, boreholes, springs
and surface water pans that exist in the project area. An evaluation was also done on the
presence of forests, wildlife and birds. The ESIA Study identified the existing plants and animals
along the project corridor establishing the project impacts on them.
b) Administration of Key Stakeholder Questionnaires to County Departments and Local Leaders.
c) Convening of Focus Group Discussions with Men, Women and Youth along the project corridor
from Modogashe-Wajir.
d) Convening of Public Consultation Meetings (PCMs) at various centres along the project road
corridor.
Minute 05: Findings of the ESIA Study/Project Environmental Impacts

Mr Oyieko mentioned that the road covers a distance of 157km. He highlighted the project benefits,
Impacts and mitigation measures to the participants.
Minute 06: Brief by KeNHA Officer (Howard Omutokoh)

Mr Omutokoh highlighted the following:
• The Modogashe-Wajir road covering 157km was initially a Class B road that has been
upgraded to Class A.
• Before construction commences all compensation for affected land and assets will be
compensated and affected persons given time to relocated.
• During construction there will be jobs available for all. The contractor will be advised to engage
local community members however, community members engaged by the contractor will need
to observe job requirements so as not to have issues with completion of the project in time.
• The contractor will need to get some road construction materials locally like quarry stones,
sand etc. Since the land in the project area is largely community land, there will be need to
negotiate payments for the quarries and borrow pits. The negotiation should be done by an
appointed group to avoid conflicts arising where different groups (women, men or youth) claim
ownership.
• The contractor will be given a time bound contract to complete construction of the road. He will
therefore require the support of the community during construction. All persons engaged by the
contractor will be expected to provide services as agreed and not disrupt construction activities
by breaking off early from work without any good reason just because the project is in their
backyard.
• The community members through their representatives will be expected to guide the contractor
on what is to be done with the quarries/borrow pits after completion of the construction work.
The community may choose one of the following:
− Backfilling of the quarry/borrow pit sites and restoring the area to its original status
− Converting the quarry/borrow pit sites to water collection points (pans) for use by the
community after completion of the construction works.
• The contractor will sink several boreholes for construction of the road. After completion of the
work, these boreholes will be handed over to the community for their use. The community
through their selected leaders will take the responsibility of operating these boreholes and
making sure it serves the community where the boreholes are located.
• The Public Consultation Meetings (PCMs) have been called to ensure the following is achieved:
− Community is informed about the project and its negative and positive impacts.
− The community is informed about the mitigations that KeNHA is putting in place regarding
affecting project persons.
− To provide an opportunity for the community to ask questions and seek clarification before
the project commences in order to avoid interruption of the construction activities.
Pan-19-003
KeNHA
Minute 07: Questions and Comments on the Proposed Upgrading of Modogashe-Wajir Road
to Bitumen Standard
Q1: Our main income is from pastoralism and there is drought affecting us. We are now
worried about the destruction of property for the construction of the road. Give us
assurance that affected land property will be compensated. Secondly, there are schools
bordering the road that do not have fences and we are worried about the safety/security of
our students? (Mr. Ahmed Haji Abdulahi).
A1: All the affected property including land that has been affected by the road project will be
compensated before construction of the road commences. Appropriate measures will be put in
place to ensure that schools along the road are secure during construction of the road. Contractor
staff will be sensitised on the same to ensure that there is no interference with the school
operations.
Q2: What will happen if the compensation is less than the value of the affected property?
(Mr. Ugas Abdille).
A2: All the affected property including land will be valued and compensated at the current market
rate (replacement value). This is done to ensure that that the property owner is able to build a
similar structure or purchase an equal size of land in the area where the asset has been affected.
Q3: What will the Government do to those who are displaced from their land since it appears
that all the land within the trading centre area has been taken? (Mr. Maalim Adan).
A3: The compensation for affected land will be done at the current market rate. This will enable
affected land owners be able to purchase land for their use within the same area.
Q4: What will happen to those who have frontline businesses that are affected by the road
project? ((Mr. Maalim Adan).
A4: The affected businesses within the designated road Right of Way (RoW) will be given ample
notice to vacate. Those whose businesses are affected and do not lie within the road RoW will be
compensated for land, structures and disrupted businesses.
Q5: There have been very many meetings yet no compensation has been paid. Can valuers
be brought in and compensation paid? How will those without land documents be
compensated? (Mr. Salat Mohamed Kuzo).
A5: There are set procedures that need to be followed to ensure that all persons in the project area
are and those affected by the project are fully consulted and are aware of their rights as far as
project environmental impacts, compensation and resettlement is concerned. Compensation will
be done before road construction commences.
Local Administration and County Government will be able to confirm land ownership to enable
compensation to be done to the rightful owners.
Q6: There are too many different people calling for meetings on the same project. Can we
have a local committee that can coordinate activities so that there can be some progress.?
(Mr. Mohamed Ibrahim).
A6: There are set procedures that have to be followed to ensure that all persons in the project area
and those affected by the project are fully consulted and understand project environmental impacts,
compensation and resettlement procedures. A committee will be formed to oversee the
compensation and resettlement process.
Q7: Why is this road RoW 60m while other roads are much narrower. There are certain
places where project affected persons have not been compensated. How sure can we be
that we will be compensated.? (Mr. Adan Salat).
A7: Roads have different classes hence different RoWs. Initially the Modogashe-Wajir Road was
Class B (40m wide) It has now been upgraded to Class A (60m wide). All affected persons will be
compensated before construction commences.
Pan-19-003
KeNHA
Q8: When the project construction starts, women are the most affected. The Government
should consider to give women consideration since a good number are poor widows
struggling to earn a living along the road to feed their children through small kiosk
businesses along the RoW? (Madam Hadila Abdi Karim).
A8: There will be ample notice for those operating kiosks along the RoW. The vendors have an
opportunity to continue the small businesses outside the road RoW
Minute 08: AOB

The chief made announcements about local issues of security and on-going projects in the area.
Minute 9: Closing remarks

The area Chief thanked KeNHA, Study Team and all who had attended the meeting and asserted
that the community fully support the project.
Minute 10: Closing Prayer

There being no other business, the meeting ended at 11.40am with a word of prayer from one of
the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON WEDNESDAY FEBRUARY 20, 2019 AT THE CHIEFS OFFICE
IN WAJIR TOWN STARTING AT 4.00pM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

The meeting was called to order at 4.45pm and began with a word of prayer from one of the
participants.

The Wajir Township Chief (Abdiaziz Mohamed) welcomed everyone in attendance. He
acknowledged and thanked the participants for finding time to attend the meeting. He introduced
the elders that attended the meeting.

Pan-19-003
KeNHA
the following:
corridor.


• The Modogashe-Wajir road that covers 157km was initially a Class B road that has been
compensated and affected persons given time to relocate.
negotiate payments for the quarries and borrow pits.
The negotiation should be done by an appointed group to avoid conflicts arising where different
groups (women, men or youth) claim ownership.
backyard.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: What will happen to graves that are affected by the road project? (Mr. Ali Abdi Fara).
A1: If there are any graves affected by the road project, KeNHA will review the road design to avoid
such graves.
Q2: Can we get the EIA Report here in Wajir. When contractor comes to the ground workers
may interact with our girls and make them pregnant. How will this be controlled? (Mr. Mr.
Aden Garat Abdi).
A2: ESIA Report - The ESIA Report will be widely circulated and there will be a copy in Wajir for
the community to review.
Unwanted Pregnancy - Parents of children in the project area are encouraged to carry out
sensitisation/education of their children how to protect themselves from sexually transmitted
diseases and unwanted pregnancy.
Q3: Wil the community be given jobs during construction of the road project. We request
that affected people should be fully compensated? (Madam Duba Aden).
A3: Jobs – Community members will be offered first priority on jobs available during construction.
Men, women and youth will all be considered.
Compensation – All affected persons will be fully compensated before construction of the road
project commences.
Q4: When the project construction starts, women are the most affected. The Government
should consider to give women consideration since a good number are poor widows
struggling to earn a living along the road to feed their children through small kiosk
businesses along the RoW? (Mama Hadila Abdi Karim).
A4: There will be ample notice for those operating kiosks along the RoW. The vendors have an
opportunity to continue the small businesses outside the road RoW
Priority Community Projects

The participants were asked to list the projects they consider as priority.
1. Sanitation facilities that can serve the Soko Mjinga Vendors in Wajir Town
2. Provision of Veterinary Services to Pastoralists.
3. Provision of Adequate Water to the residents of Wajir Town


There being no other business, the meeting ended at 5.45pm with a word of prayer from one of the
participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON THURSDAY FEBRUARY 21, 2019 AT BORJI TRADING
CENTRE STARTING AT 9.00AM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The area Senior Chief (Hussein Osman Abdi – Borji Location) welcomed everyone in attendance.
He acknowledged and thanked the participants for finding time to attend the meeting. He introduced

Pan-19-003
KeNHA
the following:
corridor.


ownership.
backyard.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Is there a way of solving the various issues that arise on the ground when the roject
construction is being undertaken? There should be a committee composed of local leaders
and community representatives that solve issues in good time? (Mr. Hussein Abdulahi).
A1: There will be a committee composed of local leaders, religious leaders, community members
and KeNHA who will be charged with the responsibility of addressing issues as they emerge.
Q2: There are persons who do not know their fate as to whether they are affected or not.
Can the status be confirmed? (Mr. Mohamed Osman Abdi).
A2: The Initial RAP Study for the road project has been done to identify those affected. There will
be a review of the same very soon to confirm if there is anybody that may have been left out. Later
there will be a team of surveyors that will carry out marking of the road alignment boundaries. The
team will be composed of surveyors from the following organisations/Institutions:
• KeNHA Surveyor
• County Roads Surveyor
• County Housing and Planning Surveyors from Wajir, Isiolo and Garissa Counties
• PAPs Surveyor (if need be)
The above road marking will be done openly and in the presence of the PAPs representative so
that every PAP will be able to know how they are affected.
Q3: We had mentioned before that we would like to have bumps where people and animals
cross along the highway but this has not been included in the reports so far, why? (Mr Mahat
Abdi Hassan).
A3: The issue of speed control to avoid accidents in areas where community members and wild
animals cross will be addressed. Where necessary appropriate measures including bumps will be
put in place.
Q4: We are worried that large shade trees along the road that communities use as resting
places when on long journeys will be cut down? (Mr Olad Mohamed Dubow).
A4: Only trees that must be cut down will be cut down during road construction. Those large trees
that can be avoided will not be touched. As part of the reforestation, KeNHA will facilitate planting
of trees to replace those that have been cut. They will also encourage/facilitate planting of trees
along the road corridor to improve the project area environment.
Q5: What measures have you put in place to address the affected land since this area is arid
and land owner will suffer when affected by the project? Mr Ibrahim Abdi Bulle).
A5: Land owners will duly be compensated for the affected land and businesses that will be
disrupted by the project. Ample notice will be provided to affected persons to relocate to new areas
where they can continue with their businesses.
Q6: There some people who were given letters indicating that they have been affected by
the project while others have not received any. Could those who have not received letters
proceed with their development activities? (Mr Omar Osman Kusow).
A6: In the next few days there will be a team that will carry out a review of the road corridor affected
persons. There will also be a team of surveyors that will demarcate the road corridor that will
conform who has been affected and those that have not been affected. No new development should
be done along the road corridor since a cut-off date (Feb 21, 2018 for Modogashe-Samatar Road)
had already been set and if the new development falls within the corridor, no compensation will be
paid out.
Q7: We fear that when the contractor completes his work, the boreholes that are supposed
to be used by the community will be hijacked by politicians and closed and therefore
community members will not be able to use them? (Mr Noor Abdi Bulle).
Pan-19-003
KeNHA
A7: When the contractor completes road construction activities, the boreholes will be handed over
to the community through their representatives (committee).
Q8: There are mechanisms that can be used to solve issues since we have elders that can
provide solutions to emerging issues. Can local mechanisms be used first before issues are
escalated to higher offices? (Mr Abdi Adan Abikar).
A8: All emerging issues and conflicts will be solved locally through the committees that will be set
up. Issues will only be escalated to higher offices if the local mechanisms fail to provide a solution.
Q9: There was a consultant who measured the road corridor and those affected were given
forms to fill while others were not given any forms yet they were neighbouring the property
that was registered as affected. Why is there such difference? (Mr Hussein Osman Abdi).
A9: The road corridor will be marked by a team of surveyors and it will become very clear who is
affected and who is not.
Q10: Boreholes that are drilled in Borji are never completed to the required depth hence the
boreholes never get to the water level. It appears there is someone against Borji getting
successful boreholes? (Mr Adan Dugow Ibrahim).
A10: The contractor will be able to drill boreholes for construction and hand them over to the
community once construction is completed.
Priority Community Projects (CSR)

4. Water (Boreholes – BH)
5. School for the Community – The existing school is small and students learn under trees).
6. There is a dispensary without beds. Pregnant mothers have to be taken to hospitals in Wajir
Town (approx. 37km away) to go and deliver.


the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON THURSDAY FEBRUARY 21, 2019 AT LAGBOGOL TRADING
CENTRE – BARAZA PARK - STARTING AT 02.00PM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The area Seniour Chiefs who share similar names (Mr Mohamed Ibrahim Abdullahi – Lagbogol
West and Mr Mohamed Ibrahim Abdullahi – Lagbogol South) welcomed everyone in attendance.

Pan-19-003
KeNHA
the following:
corridor.


ownership.
backyard.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Will the Government actually construct this road? It has been a promise to us for such
a long time? (Mr. Adow Abdullahi Rahim).
A1: The road is going to be constructed as has been indicated. This ESIA Study and the RAP study
are being carried out to identify project environmental impacts and project affected persons for
resettlement.
Q2: We have attended several meetings and yet we do not know when the project will
commence. We are having doubts about the survey that was done since some people are
being told they are affected while others along the same row are not being told anything?
(Mr. Sheikh Abdi).
A2: The ESIA study are being done to get EIA license and to identify potential environmental and
social impacts of the project before construction commences. We are not able to mention the exact
date of commencement, but once the ESIA and RAP studies are completed and the project affected
persons are compensated and resettled, the road will be ready for construction.
Q3: The project is going to affect a number of people and we hope they will be well
compensated. Why is the project taking such a long time to commence? (Madam Halima
Hassan).
A3: Compensation: All project affected persons will be compensated at the current market value
for land and replacement cost (cost required to put a similar structure at the current market rate).
This will enable project affected persons to purchase land in the same area and put up similar
structures to replace the demolished ones.
Project Commencement: The road construction has taken time to commence because of the
preparations required including the ESIA and RAP studies and proper determination of project
affected persons for compensation and resettlement. This process has to be followed to ensure
everybody affected by the project are appropriately compensated and resettled.
Q4: When will project commence? (Mr Abdi Adowo).

A4: We are not able to mention the exact date of commencement, but once the ESIA and RAP
studies are completed and the project affected persons are compensated and resettled, the road
will be ready for construction. KeNHA is in the process of identifying a contractor.
Q5: We do not know the exact boundary of our land and how it is affected by the road
corridor? (Mr Abdi Rage).
A5: The RAP study team who carried out survey identified project affected persons. Another team
will soon come to confirm the affected persons. To make sure everybody knows the boundary of
the road corridor affected by the road corridor, a team of surveyors will carry out survey and mark
the road corridor so that all PAPs are made aware how the road corridor is affecting them. For
those who do not know the boundary of their land, they are advised to seek assistance from their
County land and planning Office.
Q6: The Centre of Lagbogol was started by ourselves even before the Council demarcated
land to set a side road corridor. We should therefore not be penalised that we have put up
structures within the road corridor? (Mr Mohamed Ibrahim Abdullahi – Senior Chief
Lagbhogal West).
A6: If the centre was set up before the councils demarcated the area, then such information should
be provided to the authorities so that appropriate measures can be put in place to safeguard land
property. Such information will guide further consultations on the next cause of action.
Q7: Who will pay for accidents affecting livestock and wildlife that may take place along the
road corridor? (Mr Mahat Ahmed).
A7: Accidents that are caused by the contractor’s vehicles and machinery will be taken care of by
the contractor.
Pan-19-003
KeNHA
Any other accident caused by road users will be the responsibility of the individual road user. The
contractor will be responsible for ensuring that signage at all road sections under construction and
deviations are well and clearly marked

7. Water is the biggest challenge. There is no potable water and boreholes sunk in the area are
saline. There are 2 water pans that need improvement that can serve the community.

The area Chiefs (South and West) thanked KeNHA, Study Team and all who had attended the
meeting and asserted that the community fully support the project.

There being no other business, the meeting ended at 04.50pm with a word of prayer from one of
the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON FRIDAY FEBRUARY 22, 2019 AT GUTICHA/SAMATAR

TRADING CENTRE STARTING AT 09.00AM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The Guticha Sub-Location Assistant Chief (Mr Alinoor Abdi) welcomed everyone in attendance. He

Pan-19-003
KeNHA
the following:
corridor.


ownership.
by braking off early from work just because the contractor will not be able to take any action
just because the project is in their backyard.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Last time we were told that the road corridor was 30m from the centre to the corridor
boundary one side and now we are being told it 100 feet. Which is the correct one.? (Mr.
Osman Aden).
A1: The new road corridor is 30m from the centre of the road which is equivalent to about 100 feet.
Both are the same distance.
Q2: Where is the contractor coming from? We hope an international contractor will be
engaged. We expect and hope that our elders will be the ones allocating available jobs
during construction (Mr. Ibrahim Abdi).
A2: Contractor: The contractor that will be constructing the Modogashe-Wajir Road is yet to be
appointed. The road is now Class A classification that will be constructed according to the
requirements of a Class A road. The contractor that will be engaged will be required to show
competence of being able to construct Class A road.
Jobs Allocation: The committee that will be formed at the local level composed of religious
leaders, local leaders, County representatives will be involved in all activities related to the road
construction. They will participate in fare distribution of available job opportunities to the community
members.
Q3: I was starting to construct a building but had to shift when we were informed about the
road. Now considering the dimensions of the Class A road, it wold appear that I may still be
affected. Can you clarify the true position? (Ali Abdi Hashi).
A3: Class A requires a road corridor of 60m (30m on either side from the centre of the carriage
way. Before compensation is done, a team of surveyors will come to the ground and mark the road
corridor. All persons with land and structures next to the road corridor will be shown how they have
been affected by the new road corridor.
Q4: We had put our request to an earlier survey team that we as a community we need a
water pan, school buildings (students are learning under a tree) and a dispensary. Did our
request go without consideration or is this the same team? (Mr Abdi Salan).
A4: The requests were recorded and the report is with KeNHA. KeNHA has the mandate of
constructing roads but they will share the requests with other relevant agencies. To a large extent,
the issue of water will be addressed by the contractor since he will be sinking boreholes for
construction activities. These boreholes will be handed over to the community after completion of
construction works. The will be allowed to use he borehole water during construction but priority
will be the road project during construction.
Q5: Can you clarify to us the compensation issues surrounding the Nuno-Modogashe
Road? (Mr Kulow Mohamed).
A5: The delay in carrying out compensation arose from the fact that the PAPs changed their minds
about the compensation value after initially accepting it. This resulted in some delay since the
compensation had to be revisited again and construction can only progress when compensation
process has been completed.
Q6: Most facilities like schools, water pan and Boreholes are located in Kanchara Location
Wajir West Sub-County while Samatar Sub-location Wajir South Sub-County has none. The
borehole that was drilled 5 months ago has not been equipped? (Mr Mahmud Farah Abdi).
A6: The issues raised have been noted and will be forwarded for action.
Q7: We have been informed that the contractor will drill boreholes for his use and hand over
to the community after completion of the road works. Can the contractor target good water
that the community can use for irrigation? (Mr Hassan Abdullahi).
Pan-19-003
KeNHA
A7: The contractor will target good quality water for the road construction but may not guarantee
that he will get good water for irrigation. The interest of the community in carrying out irrigation
agriculture is noted and perhaps development of water pans should be considered.
Q8: Women are the backbone of the community. They are the ones providing for the families.
When the road is being constructed, ensure that you provide ample shades at the bus stops
where women can keep their milk while waiting for transport to urban areas. We also request
that quarries/borrow pits be converted to water pans so that we can have adequate water
irrigation? (Madam Habiba Abdi Omar).
A8: Shades at bus stops: The contractor will include ample shades at the bus stops so that
women can be able to keep their commercial milk that is being transported to other centres/towns.
Borrow Pits/Quarries to Water Pans: The Borrow pits/Quarries will be developed into water pans
for use by the community if they choose to advise so.
Q9: We fear that the contractor will bring a lot of money into the project area that will
influence our girls and wives into sexual activities that may result into unwanted
pregnancies, sexually transmitted diseases and other ills? (Mr Ali Abdi Hashi).
A9: KeNHA together with the project area religious and administrative leaders should
sensitize/educate community members including youth on the consequences of engaging in illicit
sexual activities. The contractor will also be expected to caution and also sensitize/educate the
workers on the same. Parents will be expected to talk to their children about the changes and
influences that might be brought about by the project and how they can guard themselves against
falling prey to illicit activities.
Q10: Women of this area have a women’s group in the area that is struggling to survive (Al
Furqan Women Group). Can this group be supported to enhance women in this area?
(Madam Magala Abdi).
A10: The request has been noted and will be shared with potential agencies that can offer support

8. School Facilities
9. Health Facility – Dispensary
10. Water Pans.

The area Assistant Chief thanked KeNHA, Study Team and all who had attended the meeting and
asserted that the community fully support the project.

the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON FRIDAY FEBRUARY 22, 2019 AT KANCHARA TRADING
CENTRE STARTING AT 02.00PM.

• KeNHA
• Study Team
3. Purpose of conducting the Public Consultation Meeting (KeNHA/ Study Team).
c. Q & A.
9. A.O.B.

participants.

The Chairman for Peace in Kanchara area (Mr Bishar Bare) welcomed everyone in attendance. He

Mr. Oyieko started by highlighting that the Study Team had called for the Public Consultation
Meeting to highlight the following:
b) Review and Update of ESIA Study: The Study Team is carrying out the review and update of
the Environmental and Social Impact Assessment of the report prepared in 2017/18.
Pan-19-003
KeNHA
The Study Team has carried out assessment activities along the Modogashe-Wajir Road and
evaluated the following:
corridor.


ownership.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: How will project affected people be assisted now that they will be losing land, structures
and other property? (Mr Mahat Ahmed Samow).
A1: All project affected persons are being identified and their assets inventoried and valued for
compensation and resettlement. They will be compensated and resettled before construction
activities commence.
Q2: We hosting a safaricom mast on our land parcel and it appears that our land may be
affected by the road corridor. What are we supposed to do? (Mr. Osman Abdi Hussein).
A2: If your land is affected by the road corridor and your will need to be acquired by KeNHA, the
affected area will be surveyed and valued for compensation. The survey that will be done to mark
the road corridor will guide you to know whether the safaricom mast is affected or not. If it is affected
and it deserves to be compensated as an affected structure, then compensation to relocate it will
be paid.
Q3: When implementing the road project, kindly consider both sides of the highway (Wajir
West and Wajir South? (Madam Shalla Abdi).
A3: All sides of the road will be considered during implementation of the project. The contractor will
work very closely with the committee that will be put in place to oversee project activities within the
area. These will include distribution of job opportunities and businesses that will arise during road
construction like provision of materials and other services to the contractor.
Q4: I have a private water pan that may be affected by the road corridor. Will I be
compensated? (Mr Mohamed Gabow).
A4: If the water pan is affected by the road corridor and deserves to be compensated then KeNHA
will pay out the compensation after valuation of the affected part.
Q5: The dimensions of the Class A road of 60m wide corridor is big and hence many people
will be affected. The project area also has very few title deeds that can be used to identify
the true land owners (Mr Osman Salat).
A5: Community members, local leaders and elders know who the land owners are and will assist
in identifying them. The County Government will also provide assistance in establishing true land
owners for compensation. Land owners who are affected but do not have land documents will be
identified and compensated using the above mechanism.
Q6: There are many women who earn their daily livelihoods from businesses along the road
corridor. Majority of them are widows. How will such persons be assisted? (Madam Amina
Ahmed).
A6: A RAP study on the project affected persons is being carried out and recommendations will be
provided on how such persons will be assisted. KeNHA only has the mandate of constructing and
maintaining highways but they allow small businesses to be conducted along the road corridor
without interfering with the flow of traffic.
Q7: The youth request to be given first priority when job opportunity become available
during road construction? (Mr Osman Abdi).
A7: Equal opportunities for jobs will be provided to community members during construction. There
will be jobs that can be done by skilled and unskilled workers. Committee members that include
elders and religious leaders will assist in ensuring equitable distribution of job opportunities is done.
Q8: Can you clarify what will happen during compensation for those doing business along
the road corridor? (Mr Hassan Abdille).
A8: Those doing business along the road corridor and have been determined to be genuinely
affected by the expansion of the corridor will be compensated.
Pan-19-003
KeNHA
The rest will be given notice to relocate outside the corridor. Urban centres where demarcations
are not very clear, KeNHA will carry out a case by case review to determine how compensation
should be implemented.
Q9: If part of your land is affected by the road, will you be paid for affected part only or the
whole land? (Madam Rukia Hassan).
A9: If the remaining part of the land is large and usable for the intended purpose, then the
compensation will only be for the affected area. If the remaining part of the land is too small to be
put into any meaningful use, then compensation will be for the whole parcel of land.
Q10: We trust that KeNHA will engage a contractor that will do a good job. How will you
(KeNHA) ensure that the selected committee does not get influenced by the high and mighty
of the society? (Bishar Bare – Chairman Peace).
A10: Quality of Work: KeNHA will engage a qualified contractor who fulfils the requirements since
construction of a class A road has its requirements.
Committee Operations: The committee members will be composed of religious leaders, local
leaders and representatives from the community. We believe these persons will have the integrity
to safeguard the interest of the community and guard against any influence from outside.
Q11: I am the only Borana in this community. Where I run my business is rented and it has
been affected by the road project. What will happen to me? (Mr Omar Mohamed).
A11: If the affected rented structure deserves compensation, the disruption of your business will
also be determined and compensated. This is done by paying the net monthly income for a period
of 3 months. It is believed that within 3 months the affected business can be relocated and re-
established.

1. Water Pans
2. School Facilities – students are learning under a tree.
3. Health Facility – Patients have to be rushed to Habaswein (approx. 22km away) for medical
attention

The Chairman for Peace in Kanchara area (Mr Bishar Bare) thanked KeNHA, Study Team and all
who had attended the meeting and asserted that the community fully support the project.

the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON SATURDAY FEBRUARY 23, 2019 AT HABASWEIN TRADING

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The Senior Chief of Habaswein (Mr Khalif Sirat Farah) welcomed everyone in attendance. He
Mr. Oyieko started by highlighting that The Study Team had called for the Public Consultation
Pan-19-003
KeNHA
corridor.


ownership.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: I built my house next to the road corridor. I am now and wondering what will happen?
(Mr Haret Salah).
A1: If the road corridor was observed then there is no cause for alarm. The road corridor will be
marked by a team of surveyors and all persons with property close to the road corridor will be able
to whether they are affected or not and the magnitude of the impact.
Q2: Can you clarify on who will be compensated and will not? (Mr Guled Ibrahim Farah).
A2: Those who have built outside the original building line but have now been affected by the road
corridor will be compensated. Those who built within the old building line will not be compensated
since they have encroached the road corridor.
Q3: It appears that many people will be affected by the road project since the initial
measurements given to the land owners by the local authority was 20 feet from centre of the
road? (Madam Nuria Abdi).
A3: The County Councils (County Government) were giving a distance of 20m and not 20 feet.
This will be verified since records are with the County Governments of Wajir, Garissa and Isiolo
Q4: Will there be proper documents showing affected property that will be compensated
and demolished? Land allocations have not been properly done and this may create
challenges during compensation. (Mr Bare Abdi Ogle).
A4: Property affected by the road project will be well documented for compensation. As far
establishment the true land owners is concerned, local and religious leaders and community
members will be consulted. There will be further consultation with County Offices to establish true
land owners since very few land owners have documentation.
Q5: We are worried that important trees to us will be cut down. Some of these trees offer
shade for travellers. (Mr Osman Salat).
A5: Trees that do not have to be cut down will be avoided. There will be a campaign to plant trees
to replace those that have been cut down.
Q6: Since majority of land owners only have allotment letters, will KeNHA be able to pay
compensation using them? (Madam Amina Ahmed).
A6: Compensation will be done if land ownership will be confirmed by the County land offices and
NLC.

4. Cattle Dip
5. Hospital Upgrading (should consider both sides of the highway
6. Slaughter House.

The Senior Chief of Habaswein (Mr Khalif Sirat Farah) thanked KeNHA, The Study Team and all
who had attended the meeting and asserted that the community fully support the project.

There being no other business, the meeting ended at 1130am with a word of prayer from one of
the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON SATURDAY FEBRUARY 23, 2019 AT LAGDIMA TRADING
CENTRE STARTING AT 02.00PMM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The Chief of Lagdima (Mr Daud M. Muktar) welcomed everyone in attendance. He acknowledged
and thanked the participants for finding time to attend the meeting. He introduced the elders that
attended the meeting. The Study Team (Jane Ogonji – Sociologist, Yusuf and Shaan who were
assisting as interpreters during the meetings.

Pan-19-003
KeNHA
corridor.


ownership.
Pan-19-003
KeNHA
to Bitumen Standard
All the speakers welcomed the project and suggested that it is long overdue and should start
immediately.

7. Lagdima Centre has been provided with a borehole located 1km away. They are looking for
support install a pipeline from the borehole to the trading centre. They are also need support
to install a solar plant that can pump water from the borehole to the trading centre
8. School requires support to expand the classrooms.
The Chief of Lagdima (Mr Daud M. Muktar) thanked KeNHA, The Study Team and all who had
attended the meeting and asserted that the community fully support the project.

There being no other business, the meeting ended at 1130am with a word of prayer from one of
the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON MONDAY FEBRUARY 25, 2019 AT MODOGASHE TOWN
(LAGDERA) STARTING AT 09.00AM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The Chief of Modogashe Location - Garissa (Mr Abdirahman Hussein Gure) welcomed everyone
in attendance. He acknowledged and thanked the participants for finding time to attend the meeting.
He introduced the elders that attended the meeting.

i. Previous ESIA Study: Mr Oyieko elaborated that Environmental and Social Impact
ii. Review and Update of ESIA Study: The Study Team is carrying out the review and update of
iii. Disclosure of the Project Environmental and Social Impacts and Proposed Mitigation
Pan-19-003
KeNHA
corridor.


ownership.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Can you clarify how the road will affect people? (Mr Rashid Segel Abdi).
A1: If persons with land next to the road corridor have not built inside the building line then they
have not encroached hence if they are touched by the road corridor, they will be compensated. On
the other hand, if they have constructed inside the building line, they have encroached and will not
be compensated. In urban centres, like Modogashe Town, further consultation is taking place to
address past oversights that may have resulted in encroachments being observed.
Q2: There should be a proper plan on the payment for quarry and borrow pit sites to avoid
misunderstanding among community members? (Mr Mohamed Sambu).
A2: There will be a committee comprising religious and local leaders that will represent the
community during negotiations. The community will decide how the funds are going to be used.
Q3: Can our people who are already working in the existing quarry sites be considered for
job opportunities? (Mr Madei Nyunyo).
A3: All community members will be given equal opportunity for the available jobs during
construction.
Q4: Will there be a possibility that the contractor moves in to construct before compensation
is paid. (Madam Lulu Aden).
A4: The contractor will only commence construction after all persons are paid compensation and
resettlement is done. Hence KeNHA wants to ensure that all issues are resolved before
construction commences to avoid disruption of construction activities.

9. Boreholes was domestic water supply

The Chief of Modogashe Location - Garissa (Mr Abdirahman Hussein Gure) thanked KeNHA, the
Study Team and all who had attended the meeting and asserted that the community fully support
the project.

the participants.
Pan-19-003
KeNHA
THE MEETING WAS HELD ON MONDAY FEBRUARY 25, 2019 AT SKANSKA TRADING

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.
One of the elders of the centre welcomed everyone in attendance. He acknowledged and thanked
the participants for finding time to attend the meeting. He introduced the elders that attended the
meeting.

Pan-19-003
KeNHA
corridor.


ownership.
therefore require the support of the community during construction.
All persons engaged by the contractor will be expected to provide services as agreed and not
disrupt construction activities by braking off early from work just because the contractor will not
be able to take any action just because the project is in their backyard.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Can you clarify the issue affecting compensation on the Nuno-Modogashe Road. There
were two neighbouring structures along the road corridor, one was to be affected while the
other was left out. Can you clarify how this is possible? (Mr Mikail Rashid).
A1: Delay in Compensation: Project affected persons accepted the compensation offers that had
been given to them. Later on a few decided to change their mind and refused the offers. This meant
that the affected section could not be released for construction until a settlement is reached. This
resulted in the delay of compensation payment
Neighbouring Houses: If the two houses are on the same front line to the corridor, they should
both be affected, however there will be a team of surveyors who will mark the road corridor so that
everyone is made aware of whether they are affected or not.
Q2: We hope that jobs will be given to the community members? We will ensure they
perform the jobs well (Mr Mohamed Garane Isaack).
A2: Community will be given priority consideration for jobs when the contractor starts the
construction work. The community religious and administrative leaders serving in the committee
that represents the community will ensure that there is fairness in the distribution of job
opportunities.
Q3: There are affected land parcels that do not have anything. What will happen thiese
parcels of land? (Mr Jelle Hussein).
A3: The land owners will be compensated for the affected areas of the land.
Q4: Our fear is that there may be external influence from politicians that may change what
we have agreed on and this may result in conflict. We do not have land documents. How will
compensation be handled? (Mr Mahat Hassan).
A4: External Influence: KeNHA will ensure that what has been agreed on is implemented. The
committee representing the community will oversee this.
Lack of Land Documents: KeNHA and NLC will use information local offices, elders and
community members and also support from the County Land offices to establish land ownership
for compensation
Q5: How will women benefit from job opportunities from the project? (Madam Mahata
Dubow).
A5: There will be equal opportunities for jobs in the project. The contractor will identify jobs that
women can perform. Community members will also be able to get jobs within the contractor camp
like cleaning, cooking etc.

The elder thanked KeNHA, The Study Team and all who had attended the meeting and asserted

the participants.
Pan-19-003
KeNHA
MINUTES OF THE PUBLIC CONSULTATION MEETING (PCM) FOR THE ESIA STUDY FOR THE
UPGRADING OF MODOGASHE-WAJIR ROAD (157km) TO BITUMEN STANDARD (A13).
THE MEETING WAS HELD ON MONDAY FEBRUARY 26, 2019 AT MODOGASHE TOWN
(SERICHO) STARTING AT 09.00AM.

• KeNHA
• Study Team
c. Q & A.
9. A.O.B.

participants.

The Chief of Modogashe Location - Isiolo (Mr Hussein Haji Boru) welcomed everyone in attendance.
Mr Oyieko introduced himself and the Study Team (Jane Ogonji – Sociologist, Yusuf and Shaan who
were assisting as interpreters during the meetings.

Mr. Oyieko started by highlighting that The Study Team had called for the Public Consultation Meeting
a) Previous ESIA Study: Mr Oyieko elaborated that Environmental and Social Impact Assessment
(ESIA) Studies had been carried out in 2017/18 and an ESIA Study Report prepared and
submitted to KeNHA
Project Area Community and Stakeholders the Findings of the Environmental and Social Impact
Assessment (ESIA) Studies and the Proposed Mitigation Measures.
Pan-19-003
KeNHA
a) Assessment of existing vegetation, water sources (rivers, streams, wells, boreholes, springs and
surface water pans that exist in the project area. An evaluation was also done on the presence
of forests, wildlife and birds. The ESIA Study identified the existing plants and animals along the
project corridor establishing the project impacts on them.
corridor.


local community members however, community members engaged by the contractor will need to
observe job requirements so as not to have issues with completion of the project in time.
• The contractor will need to get some road construction materials locally like quarry stones, sand
etc. Since the land in the project area is largely community land, there will be need to negotiate
payments for the quarries and borrow pits. The negotiation should be done by an appointed group
to avoid conflicts arising where different groups (women, men or youth) claim ownership.
by braking off early from work just because the contractor will not be able to take any action just
because the project is in their backyard.
on what is to be done with the quarries/borrow pits after completion of the construction work. The
community may choose one of the following:
work, these boreholes will be handed over to the community for their use. The community through
their selected leaders will take the responsibility of operating these boreholes and making sure it
serves the community where the boreholes are located.
− To provide an opportunity for the community to ask questions and seek clarification before the
project commences in order to avoid interruption of the construction activities.
Pan-19-003
KeNHA
to Bitumen Standard
Q1: Where is the beginning of the road in Modogashe because we have issues with the
alignment. We are concerned that structures inside the 40m corridor will not be paid and yet
there were no proper guidelines regarding road corridor wayleave. We also expect that the
road alignment will avoid Mosques/Graves? (Mr Mohamed Mandera).
A1: Start of the Road: The surveyors are working on the final designs and they will come to the
ground to identify the start. Discussions are underway at very high level to discuss the concerns
about the start.
Compensation: The issue regarding compensation of affected property in centres like Modogashe
is being reviewed to arrive at a win-win situation.
Mosques/Graves: These special places will be avoided during construction of the road.
Q2: People in Sericho are marginalised. The place is dry and the people are suffering. The
town was started way back in 1957 before systems were put in place hence there should be
no penalisation during road construction. All affected property should be compensated? (Mr
Ibrahim Kanata).
A2: KeNHA has taken note that there should be further consultations regarding road corridor in
centres including Modogashe due to lack of enforcement of the required road wayleave in the past.
This will assist in the determination of how compensation will be handled.
Q3: Who will pay for the affected property (Government of Kenya or Financier? (Mr Ibrahim
Halake).
A3: Compensation payment for the affected property (land, structures and businesses) will be done
by Kenya Government
Q4: We trust that the contractor will provide jobs to local community members. (Mr Hussein
Dida).
A4: The constructor will be made aware that community members will be given jobs during
construction. The committee representing the community will work with the contractor to realise
equitable distribution of jobs is achieved and those given jobs work to the satisfaction of the job
requirements
Q5: We Expect that the demolitions will have a human face so that it does not displace our
people and make our community members poorer. (Mr Hussein H. Boru).
A5: Affected persons will be given ample time to relocate their structures and their businesses.
Appropriate compensation will be paid out to affected persons.
Q6: Contractor camps should be located away from community settlements to avoid sexual
exploitation and abuse by contractor workers.
A6: The committee that will be set up to work with the contractor will look into all the issues affecting
the community and help the contractor identify a suitable location.

1. Water (Boreholes/water pans)
2. School (Boarding for Girls)
3. Health Facility (Upgrade Dispensary to Hospital)

The Chief of Modogashe Location - Isiolo (Mr Hussein Haji Boru) thanked KeNHA, The Study Team
and all who had attended the meeting and asserted that the community fully support the project.
Pan-19-003
KeNHA

There being no other business, the meeting ended at 11.45am with a word of prayer from one of the
participants.
Pan-19-003
KeNHA
Annex 3: FGD Registers
Pan-19-003
KeNHA
Women FGD Register
Pan-19-003
KeNHA
Youth FGD Register
Pan-19-003
KeNHA
Men FGD Register
Pan-19-003
KeNHA
Annex 4: Biophysical Features along the Modogashe-Wajir Road
Pan-19-003
KeNHA
Annex 9: Biophysical Features Along the Modogashe - Wajir Road
Element Locality Feature Distance from Coordinates Environmental Description Photograph

No. Modogashe (Km) Element
001 Modogashe Shopping 00 Easting – Trees and Commercial and
Town Centre 0519038 buildings residential houses
Northing - Few Acacia trees
0080957 Junction to
Lagdera
002 Modogashe Trees 0.3 Easting – Ecosystem Acacia tree with

0519083 bird nests
Northing -
0081066
003 Modogashe Culvert/Bridge 0.3 Easting – Drainage Under

0519062 construction with
Northing - stone bunds on
0981184 Shubhur River
Pan-19-003
KeNHA

004 Modogashe Dry river 1.8 Easting – Seasonal river Crosses the road
valley 0519204 from the eastern
Northing - side Shallow in
0082790 depth due to sand
accumulation
Acacia and
Prosopis trees are
found here
005 Modogashe Culvert 5.8 Easting – Drainage/Flood Culvert along the

0521088 plain road on a flood
Northing - plain Acacia and
0086402 Prosopis trees
adjacent to culvert
006 Modogashe Culvert 6.6 Easting – Drainage/Flood Cracks visible on

0521490 plain culvert Water
Northing - passes through
0087027 from western side.
Acacia and
Prosopis trees
found here
Pan-19-003
KeNHA

007 Modogashe Cu;vert 10.3 Easting – Drainage/Flood Half burried in
0523985 Plain sand Too much
Northing - siltation
0089818
008 Modogashe Community 11.4 Easting – Water Borehole is not

Skanska borehole 0524755 collection and functional. Seems
Northing - storage to have been
0090722 abandoned
009 Modogashe Culvert 17.7 Easting - 528275 Drainage/Flood Open on both

Skanska Northing - plain sides
0095925
Pan-19-003
KeNHA

010 Modogashe Culvert 19.5 Easting – Drainage/Flood Acacia trees with
Skanska 0529572 plain bird nests
Northing -
0097173
011 Skanska Houses 24.5 Easting – Settlement Human settlement

centre, 0533245 with several
Isiolo Northing - structures
County 0100804
012 Skanska Water pan 24.5 Easting – Water source Water point with a
Town, 0533270 variety of bird
Lagdera Northing - species Water is
Sub county 0100779 also used by
human beings
Pan-19-003
KeNHA

013 Skanska Culvert 27.5 Easting – Drainage/Flood Culvert with a
Isiolo 0535575 plain shallow water pan
County Northing - Acacia and
found here
014 Skanska Box culvert, 31.1 Easting – Drainage/Flood Box culvert.

Dry river bed 0538591 plain and Presence of dry
and Trees Northing - Natural habitat river bed.
0104621
Acacia and
Prosopis trees
with bird nests.
Monkeys were
also noted to be
present here.
015 Skanska Large box 33.8 Easting – Drainage/Flood Dry storm water
Isiolo culvert 0540907 plain channel
County Northing - Presence of
0106039 Acacia trees,
shrubs and grass
Pan-19-003
KeNHA

016 Skanska, Water pan 35.2 Easting - Water source Bridge erected
Lagdera with culvert 0542393Northing over a river joining
Sub County - 0106597 a shallow water
pan. Presence of
Acacia trees,
shrubs and grass
017 Habaswein, Bridge 44.7 Easting – Ewaso Ngiro Narrow bridge

Wajir West 0551318 River and over Ewaso Ngiro
and Wajir Northing - riverine River separating
South 0110354 ecosystem Wajir County,
Isiolo County and
Garissa County
Shrubs including
Lantana Camara
and Euphorbia
Large seasonal
river with lots of
Acacia and
Prosopis trees
Presence of
gabions
Pan-19-003
KeNHA

018 Habaswein Town Centre 48.8 Easting – Human Commercial and
Town, Wajir 0554469 settlement residential houses
South and Northing - on both sides of
Wajir West 0112566 the road
019 Lagdima Shopping 56.6 Easting – Settlement Lagdima shopping

centre, centre 0561105 centre with
Wajir West Northing - structures
& Wajir 0117379 Settlement with
South trees and bushes
area is sparsely
populated
020 Lagdima River 57.1 Easting - Dry river bed Sand filled dry
Lagdima 0561707 river bed
Northing - Ferested riverine
0117801 ecosystem with
aesthetic value
Lagga over the
road Large trees
next to lagga used
Pan-19-003
KeNHA

to provide shade
to travelers
021 Lagdima Flood plain 66.9 Easting – Flood plain Flat plain land
0569652 with Acacia trees
Northing - Presence of
0123866 eroded furrows
022 Kanchara, Shopping 71.0 Easting – Settlement Structures on both

Kanchara centre 0572997 sides of the road
South and Northing - Residential and
West 0126432 business
premises
Pan-19-003
KeNHA

023 Kanchara Culvert 76.9 Easting – Drainage, Double culvert
0577865 Flood water Slightly filled with
Northing - crossing the sand. Dry river
0130213 road bed on the
eastern side.
Scattered Acacia
trees. Dry land
biodiversity
024 Guticha Culvert 80.1 Easting - Drainage This is a town

0580564 centre Box culvert
Northing - across the road.
0132270 Sand filled furrow
on the eastern
side
Pan-19-003
KeNHA

025 Samatar Water pan 85.6 Easting – Water source Samatar Guticha
and Culvert 0585095 and abandoned Dry water pan.
Northing - settlement Dry at the
0135711 moment but
recharges during
wet season.
Abandoned
settlement close
to tree with bird
nests
026 Lagbogol Drift 90.6 Easting – Drainage/ Eroded drift

0589104 Waterway adjacent to
Northing - Mathenge tree.
0138887 Soils appear
loamy clay. Area
has scattered
vegetation
Pan-19-003
KeNHA

027 Lagbogol Structures 95.3 Easting – Settlement, Shopping Centre
Centre 0592944 Few trees with homesteads.
Northing - Town set up with
0142009 Acacia trees
along the road.
Lagbogol
Dispensary
present
028 Lagbogol River 96.6 Easting – Water point River Lagbogol

Lagbogol and 0593693 with lagga across
drift Northing - it. Acacia and
along the banks.
Dry at the
moment.
Recharges during
Pan-19-003
KeNHA

wet season
Dumping of waste
noted near this
drift
029 Lagbogol Waterlogging 100.6 Easting – Drainage Mature trees

0595257 along the road
Northing - boundary which
0147055 need to be
conserved
Waterlogging area
along the road
030 Lagbogol Flood plain 104.4 Easting – Drainage and Flood plain with
0596438 Forestry Acacia trees on
Northing - both sides of the
0150871 road. Presence of
cracks on the
flood plain
Pan-19-003
KeNHA

031 Lagbogol Flood plain 107.8 Easting – Drainage and Flood plain with
0597668 Forest Acacia trees. End
Northing - of Acacia Tortilis
0154197 forest
032 Lagbogol Trees 110.6 Easting – Forestry and A collection of

0598856 drainage trees and shrubs
Northing - off the flood plain.
0156798 The tree type here
is Acacia. The
area is flat with
loamy soils
033 Borji Town, Shopping 115.2 Easting - Settlement There residential

Borji West centre 0600751 and commercial
and South Northing - houses.Very
0161115 dusty
Pan-19-003
KeNHA

036 Borji Cross roads 119.3 Easting - Cross roads Multiple roads
0602085 created by
Northing - vehicles
0164965 Degradation of
the natural
ecosystem
034 Leheley Shallow 132.0 Easting - Waterlogging Two shallow

depression 0609423 depressions.
Northing - Mature fairly
0175809 green trees at the
roadside implying
high water table/
Presence of
multiple roads
035 Leheley Trees 135.5 Easting - Leheley Mature trees

0611219 ecosystem alongside the
Northing - road. The area is
0179016 forested and acts
a fodder for
livestock
Pan-19-003
KeNHA

036 Lehley Shopping 136.8 Easting - Settlement Residential and
Town Centre 0611838 commercial
Northing - houses Trees and
0180156 shrubs present
037 Leheley School 139.0 Easting - - Leheley

0613035 secondary school
Northing - Sign board and
0182308 school gate next
to the road
038 Leheley Rangeland 141.8 Easting - Wildlife Area with trees,

0614404 grass and shrubs
Northing - Presence of wild
0184710 and domestic
animals
039 Leheley Road 144.5 Easting - Cross section Last mile road
0615367 of main road proposed for
Northing - and last mile heavy commercial
0187400 road vehicles
The road
surrounds Wajir
municipality
Pan-19-003
KeNHA

040 Wajir town Dumpsite 145.8 Easting - Waste Waste
0615350 management management site
Northing - No segregation of
0188521 wastes
041 Wajir Town Town centre 150.8 Easting - Commercial Commercial
0617581Northing area houses and Wajir
- 0193502 market along the
road. Hawkers
along both sides
of the road
042 Wajir Town Round about 151.3 Easting - Round about This is a
0617643 commercial area
Northing - with several
0193884 businesses.
Termination of the
road next to
Equity Bank End
of Modogashe
Wajir road
Pan-19-003
KeNHA
Pan-19-003
KeNHA
# Stakeholder Name Organization of Telephone/ email Stakeholder Interest, Goals, and Concerns
Location
1. Adbiaziz Mohamed Wajir Township 072272238 Positive Aspects

• The upgrade will improve accessibility
• Will create more job opportunities
• Will attract more investors to region
Concerns
• The project will affect properties and land of so many people without compensation
• The bush clearing was not done well, the trees i.e. early growers were cut down and just thrown on the
road
Suggestions
• Compensate for affected properties
• Project should proceed
2. Nassir Ali Elmi Wajir Township 0720336992 Positive Aspects
abdinasir72@ live.com • The upgrade will improve free flow of traffic and links to other major towns
Concerns
• Compensate affected PAPs
• Safety of pedestrians should be guarded at all cost by erecting bumps and pedestrian crossings
• There are some permanent structures which were not properly surveyed before
• If the PAPs are not compensated it may cause problems
Suggestions
• Project should proceed
3. Abdikadir Barrow Adan Alimaow 0721290121 Positive Aspects
Abdikadirbarrow@gmail.com • The upgrade will increase business activities and also faster transportation from Nairobi to Wajir
• Will create employment for the youth
Concerns
• The upgrade will affect business, graves and nearby households
• Compensate for affected properties
• The quality and sustainability of the road should be guaranteed
4. Barud Abdi Diis Furaha 0724926715 Positive Aspects
Barudabdi492@ gmail.com • Upgrade will improve the accessibility and reliability of transportation
• More investors will come and there will be job creation
Concerns
• Contract should not be given to a contractor who will build low/poor grade road
• If bush clearing is not done well, the thorny trees will be scattered all over the road
Suggestion
Pan-19-003
KeNHA
Location
• Remove all thorny trees dumped on the road to a safer place as they pose danger to both human and
animals
5. Mohamed Omar Leheley 0724773349 Positive Aspects

mohamedomarbarreh@ • It will provide quick transportation
gmail.com • Will create jobs and also improve business
Concerns
• Cutting of trees, dust, high sound and air pollution during construction
Suggestion
• Plant more trees after construction
• Compensate affected families
6. Hussein Abdulah Boji 0710931187 Positive Aspects

Abdille • Will help improve on communication/transportation and leads to growth of business and the town
Concerns
• May cause deforestation and soil erosion due to cutting don of trees
Suggestions
• Construct bumps near schools etc.
• Construct water contours
• Employ the youth
• Compensate affected families without delay
7. Mohamed Ibrahim Lagbogol North 0721881589 Positive Aspects

Abdulahi Moibab93@gmail.com • The project will reduce cost of transport
• Ease of transportation during emergency services e.g. sickness, women in labour etc.
• Reduced dust/cleaner environment after construction
Concerns
• Will cause social conflicts during demolition/resettlement
• Will cause cutting of trees and dust
Suggestions
• Reduce cutting of trees and plant more trees
• Sprinkle water during construction
• RAP should be carried out
Pan-19-003
KeNHA
Location
8. Mohammed I. Abdi Lagbogol South 0722377331 Positive Aspects

• Good development which improve on local economy
• Job creation
Concerns
• Cultural changes due to influx of people from other parts of the country
• Cutting down of trees and a lot of dust
• Project will cause displacement of people
Suggestions
• Provide jobs to the locals
• Reforestation should be given priority
• Compensate displaced people
9. Alinoor Abdi Guticha, Wajir West 0725231533 Positive Aspects
• Will result in easy movement and creation of job opportunities
• Reduce insecurity
• Promote business
Concerns
• No of accident will increase and also import of foreign cultures
• There will be clearing of vegetation, use of heavy machines etc.
Suggestions
• Afforestation package should be introduced
• Sexually transmitted disease awareness/campaign should go side by side with the project
• Implement CSR projects
10. Abdirahman Hassan Kanjara, Wajir West 0728754021 Positive Aspects
Hussein • Will create ease of movement, job opportunities, improved security and business growth
Concerns
• However, there will be import of other cultures, cutting of trees, a lot of dust and heavy machine
operations
Suggestions
11. Adan Abdi Madey Lagdima, Wajir South 0723764377 Positive Aspects
adanamadey@ gmail.com • Ease of access, decreased cost vehicle maintenance, expansion of business
• Community are ready for the road and also ready to cooperate during the construction
Concerns
• Dust and noise pollution during construction
• Increased accident to both human and animals
Suggestions
Pan-19-003
KeNHA
Location
• Government to take serious security measures in the region

• Trees at Lagdima should be preserved and avoid removal of established trees
• Control dust through sprinkling of water
• Plant trees after the construction
• Create public awareness
• Erect sign posts along the road
12. Osman Hassan Ali Lagdima, Wajir South 0722306385 Positive Aspects
(Hadado South Sub Oskaa075@ gmail.com • Will improve business, living conditions and efficient transportation
Location) Concerns
• There will be dust and noise pollution during construction
• Demolition of houses within wayleave
• increase of accidents
Suggestions
• Education on road safety awareness campaign
• Sprinkle water on the road during construction
• Improve on community participation during the project
13. Felix Ingasia Hbaswein 0728807573 Positive Aspects
• It will ease transport, open up the area for economic activities and improve communication and delivery
of services to the people efficiently and effectively
Concerns
• Will affect operations during rainy season and dust during the construction
Suggestions
• Alternative road to be graded and maintained and ensure that there is a lot watering to minimize dust
14. Khalif Sirat Farah Habaswein 0728628718 Positive Aspects

Khalifsirat1959@ gmail.com • Ease of communication, creation of employment, development growth and economic empowerment
Concerns
• There will be environmental impacts and family conflict due to sexual misbehavior
• Destruction of houses and businesses
Suggestions
• Compensate the affected families for affected properties/assets
• Plant trees
• Expected cooperation from the contractor, respect culture of the community
Pan-19-003
KeNHA
Location
15. Mohamed Adan Habaswein, Hadado 0724549965 Positive Aspects

Abdikarim South Location Taliyal20302030@ gmail.com • Will create employment, development and economic empowerment
Concerns
• Environmental impacts and family conflict due to sexual misbehavior
• Environmental and business premises destruction
Suggestions
• Compensate the affected families for affected properties/assets
• Plant trees
• Peaceful cooperation from the contractor and respect to the culture of the community
• Participation by the community in the project
Implement CSR projects
16. Yusuf Mohamed Garissa, Lagdera - 0722768383 Positive Aspects
Sheikh Skanska, Ilan Location yusufsheikh@ gmail.com • It will improve business ventures
• Reduce cost of transport
Concerns
• Increase of accidents due to over speeding
• It will cause displacement and relocation
• Dust pollution and construction waste on the road
Suggestions
• Bring NEMA on board for better waste disposal
• Sprinkle water during construction
• Create public awareness before construction begins
• Implement CSR projects e.g. Chief’s office, public toilets and piping of water to hospitals and schools
17. Abdirahman Hussein Garissa, Lagdera, 072879776 Positive Aspects

Gure Modogashe Location • Ease of transportation
Concerns
• Will cause displacement
• There will be noise and air pollution during construction
Suggestions
• Sprinkle water on the road to suppress dust
• Reduce noise pollution
• Install road furniture for safe road use
• Employ the youth of the area
• Compensate those affected by the project
Pan-19-003
KeNHA
Location
18. Hussein Haji Boru Isiolo, Garbatula, 0728460762 Positive Aspects

Modogashe Location • Ease of transportation, reduced vehicle maintenance cost, improved business
Concerns
• Increased accidents due to over speeding
• Dust and noise pollution
Suggestions
• Create awareness
• Give priority to the local for employment opportunities
19. Dida Abdi Isiolo, Garbatula, Komor 0722606056 Positive Aspects
Bula Location, adjtullusaubura@ gmail.com • Improved business, ease of transportation, reduced cost of food
Modogashe, Nort Sub Concerns
Location • Will cause displacement and lack of payment
• Influx of migrants’ communities
• Increase of diseases and accidents
• Pollution from dust and construction vehicles
• Cutting down of trees
• Conflict from lack of employment
Suggestions
• Community participation is key
• Employ the locals
• Plant trees
• Create HIV awareness to the community
20. Hon Mowlid Issack Wajir, Ademasjida Ward 0727447813 Positive Aspects
Mussa Mowlid.issack@ gmail.com • Will shorten time taken for travel and boost the economy and improves the living standards of the
people
Concerns
• Unequal distribution of resources because Habaswein is divided in Wajir West and South and there has
never been equal distribution
• There will be air pollution
Suggestions
• Project should proceed as long as it will meet the needs of people of the ward and have direct benefit to
the locals
• Consultation forum with the locals to discuss mitigation measures
• Proper plan for public participation since the project covers two constituencies of Wajir from Ewaso
Nyiro along Habaswein to Samatar and there is Ademasajida and Habeswein Wards.
Pan-19-003
KeNHA
Location
• Give equal opportunity to both sides/wards
21. Noor Kato Abdikadir Ministry of Health (Wajir 0720254624 Positive Aspects
County) • The upgrade will Ease Transportation
• New settlements will come up.
• It will attract local tourism
Concerns
• The spread of diseases such as HIV/Aids, depletion of natural resources due to influx
• There will be occupational & Environmental hazards and outbreak of wash related Diseases
Suggestions
• Construction of Latrines, Implementation of occupational health and safety measures and minimization
of environmental hazards that affect humans should be observed.
22. Ambia Abdi Osman Kenya Forest Service 0720969074 Positive Aspects
Zmwajir@kenyaforestservice. • The upgrade will reduce Transportation costs and time taken to deliver goods services and people. This
org will also help small scale trade flourish.
• There will be job creation during the period which will be beneficial to the youth
• The road will make it easier to respond to emergencies such as bush fired, improve access to better
healthcare, education and Security
Concerns
• The removal of trees and quarrying without backfilling will lead to pollution and creation of breeding
grounds during the rainy season which will affect the health of the people.
Suggestions
• Afforestation should be carried out and awareness creation through public participation.
Pan-19-003
KeNHA
Location
23. WAJWASCO WAJWASCO 0721290121 Positive Aspects

abdi.mohamed9@yahoo.com • The upgrade will open up the northern parts of Kenya
• It will indirectly cut the costs of maintaining boreholes.
Concerns
• There may be conflict of interest between the locals in regards to labour created by the project
• It might temporarily affect water connectivity in major Centres during the operation stage of the project.
Suggestions
• Proper Coordination with the offices and local communities on the ground
• Donors / Government should consider International companies to carry out the The project to ensure
quality Workmanship.
24. Yahya Dahir Osman County Government of 0725848134 Positive Aspects

Wajir Department of Yaxya4580@gmail.com • There will be economical benefits such as employment of the youth and also sourcing of resources from
Environment, Energy and the locals.
Natural Resources Concerns
• From past experience most road upgrades don’t follow EMP, maintenance of the Environment or
observe social impacts of the project.
Suggestions
• The project should adhere to all environmental social regulations.
• It would be nice for us to be consulted to participate especially in the technical aspects of the project.
25. Mohamed Dayib County Government of 0710743708 Positive Aspects

Wajir – Road & Transport Modayib2010@gmail.com • The road will be upgraded to Bitumen Standards easing accessibility and Movement of people within
the different towns in the county.
• It will save the department resource/money which will be deviated to other priority areas..
Suggestions
• Beautification of the road side along the stretch of the road should be considered as it is mostly barren
land
Pan-19-003
KeNHA
Location
26. Loyford Kibaara Interior 0727929751 Positive Aspects

• Will improve facilitate/accelerate development within the region and reduce the cost of traveling.
• Enhancement of Service delivery and quick response to security issues.
Concerns
• It will increase traffic and movement of goods and services (i.e. increase trade of contraband goods).
Suggestions
• A Tree planting Component should be included.
27. Wajir Bus Service Transport 0795477788 Positive Aspects

• There will be a quick transport system that saves time.
Concerns
• During construction our operations will be affected.
Suggestions
• The local communities should be involved.
• Avoid Corruption.
28. Daud Yakub Guliye County Director Of 0725923781 Positive Aspects

Livestock Production • Will facilitate the movement of people and livestock and also shorten the time taken to travel.
• Easier access to the markets.
• Our operations will improve.
Concerns
• Not Aware of the project.
• The project is likely to destroy a lot of vegetation interfering with the grazing patterns of livestock.
Suggestions
• Water pans should be created/rehabilitated along the way.
• Road signs should be erected and Bridges put up for livestock to cross.
• Water should be used to reduce dust generated.
29. Hussein Abdullahi Samatar Bus Service 0723809313 / 0721555167 Positive Aspects
Yakub / Nuh Mohamed Limited Nuhow53@gmail.com • The project will ease transportation, fares will reduce and more people will prefer travelling by road.
• Project should start as soon as possible so that people can enjoy the tarmac road.
• Accidents will reduce
Concerns
• There will be a lot of dust and traffic during construction.
Pan-19-003
KeNHA
Location
30. Lands Wajir Counnty Department of lands 0721250190 Positive Aspects

Abdibra10@yahoo.com • The project will improve infrastructure and promote the economy through trade.
• It will bring beautification of the environment.
Concerns
• Road accidents are likely to increase.
• Health hazards will be created through creation of quarries.
Suggestions
• Sensitization of the public on the benefits of good infrastructure
• It would be nice for the road to be a 3-way passage.
• The residual materials after construction should be collected and recycled if possible, to avoid health
related problems.
31. Mohamed Farah Wajir Water Services 0723929349 Positive Aspects
engmfarah10@yahoo.com • The Upgrade will improve the flow of traffic, reduce travelling time and Ease availability of essential
goods.
Concerns
• There may be an Increase in both accidents and trade of contraband and illegal goods.
Suggestions
• Project should start as fast as possible for the benefits to be realized.
• The economy is reliant on the building of the road and shouldn’t take more than the stipulated time.
32. Chief Officer Education Wajir County Government 0721669407 Positive Aspects
abdullIbrahim2014@gmail.co • The project will make travelling more comfortable; less time will be spent on the road and accessibility
m will be there during the rainy season.
• Easy access to schools for minority and cheap transport costs.
Concerns
• Not aware of the project.
• Accidents may occur due to over speeding causing a risk to young school going children.
Suggestions
• Bumps, Children Crossings/Zebra crossings should be put.
• Upgrading of the feeder roads and creation of alternative routes when the construction is ongoing.
• The local youth should be employed and the affected people compensated.
Pan-19-003
KeNHA
Location
33. Huqa Gedho NEMA 0722928978 Positive Aspects

huqagedho@gmail.com • Better connection, ease of movement of people and the improved economy Concerns
• May cause degradation, loss/interference of bio diversity, loss of vegetation cover and destruction of
environmental goods and services.
• Movement of people during the road construction will be interfered with.
Suggestions
• Contractor should form a committee representing all stakeholders from all the villages affected by the
project.
• Contractor must work with relevant stakeholders and license conditions are to be followed.
34. Religious Leaders Supreme Council of 0729298426 Positive Aspects
Kenya Muslims supkemwajiruranch@gmail.c • It will open up the area for more business opportunities
om • Ease the transport system
• Urbanization
Concerns
• Livelihood of some people will be affected negatively.
• The social fabrics of the society will be affected by introduction of other social ills that come with the
project.
• Noise and dust pollution
Suggestions
• Affected Members of the community to be compensated before commencement of the project.
• Proper and standard workmanship to eliminate pollution of the environment
• Natural Vegetation and wildlife to be taken care of.
• CSR for the community to be incorporated in the project.
35. Council of Imams Council of Imams - 0722932161 Positive Aspects
Habaswein • It will bring and spur economic development
Concerns
• Environmental degradation which will affect operations of the community
• Social Vices such as prostitution which will lead to the spread of HIV&AIDS and other Sexually
transmitted diseases
Suggestions
• The company should be careful not to destroy big trees especially Acacia trees along the road.
• Refill of the dug earthwork sections.
Pan-19-003
KeNHA
Location
36. Hassan Mohamed Said Ministry of Interior and 0715275531 Positive Aspects
National Coordination • Shorter travelling time
• It will bring development
Concerns
• Accidents
• Demolishing of buildings
• Noise pollution
Suggestions
• Avoid demolishing Mosques and graves
• We need the project to be completed for development purposes
37. Philip Lenaiyasa – Isiolo County Government 0720595755 Positive Aspects
CCO Tourism and Tourism & Wildlife • Ease of access to the North-East part of Kenya by locals and foreign tourist.
Wildlife Isiolo County • Improved area development
Government Concerns
• Loss of biodiversity during road construction works
• Wildlife migratory corridors will be affected hence road kills and human-wildlife conflict.
• The project should maintain the current road alignment
• Create wildlife bypasses to avoid road kills
Suggestions
• Involve local Leaders in decision making and consider the community as first priorities for Job
opportunities.
• Consult other key stakeholders such as the Ewaso Lions, Grevy’s Zebra Trust and Save the Elephant.
• Construct Hospitals, Primary and Secondaty Scools.
• Dig Boreholes for the community due to water Scarcity.
38. G.K Mwaura Kenya Forestry Services 072340584 Positive Aspects
• It will open up the region to development
• Improve area security and livelihood
Concerns
• Interference of the ecosystems along the road during construction
• Plant trees and grass along the road after completion to prevent soil erosion and filling up of excavated
areas.
Suggestions
• Provide job opportunities for the local community.
• The project is important to the region and should be allowed to continue
Pan-19-003
KeNHA
Location
39. Osman Bagaja Environment, Energy and 0721819981 Positive Aspects

Natural Resources Isiolo • It will Ease transportation
County Government • Improve area Economy
• Improve Security
• Provide Job opportunities for the youth
Concerns
• Dust emanating during road construction works.
• Potential Displacement of people
• Loss of trees and vegetation as a result of clearing.
Suggestions
• Job opportunities should be given to the community members
• All comments and mitigation measures captured should be well elaborated in the ESMP with proper
enforcement and compliance during the project cycle.
• Trees should be planted along the road
• Watering the roads during construction to prevent dust from raising
• Workers should be provided will the right PPEs
40. Hadija G. Guyo- CCO Youth and Sports Isiolo 0726666160 Positive Aspects
County Government • Provide ease of access to goods and services.
• Improved movement of people to the North-East part of Kenya.
Concerns
• Displacement of persons hence the project should maintain the current road alignment and avoid
diverting the route.
Suggestions
• Employment opportunities should be given to the local communities.
• Hospitals should be built along the road due to the risk of accidents happening once the project is
done especially at Yaka Barsadi, between Kulamawe and Kachuru.
• A police post should be established between Garbatulla and Eldera which is a bandit prone area.
Pan-19-003
KeNHA
Location
41. Kimuta Matthew – Lands Physical Planning 0712549712 Positive Aspects

and urban Development • It will open up the rural Isiolo to further development
• Ease of access to the rural areas.
Concerns
• land acquisition procedures should reflect all the land use regulations and requirements of the physical
and planning act
• There is inadequate sensitization of the project
Suggestions
• Provide employment opportunities to the local communities and engage the elders in decision making
42. Kadubo Adano. Public Works, Housing 0722333361 Positive Aspects

and Urban Development • It will Improve Accessibility and Economical growth
Isiolo County • Improve transport efficiency and trade
Government. Concerns
• Degrading soil cover as a result of excavation works.
• Borrow pits should be covered after material extraction.
Suggestions
• Involve the locals in decision making and offer them job opportunities
• The project should consider connecting to Biligo-Merti-Wajir.
43. Qabale Golicha Roads and Infrastructure 0716624326 Positive Aspects

Isiolo County Government • It will ease access to goods and services (Schools & health facilities)
• Improved access between towns and counties
• Increase in trade/business opportunities
Concerns
• No concerns
Suggestions
• More Schools should be established as the education in the area is wanting.
• A large health facility should be constructed between Isiolo and Wajir.
• More boreholes needed as water scarcity is still a problem.
• Provide Job opportunities to the local community.
• It is a good project
Pan-19-003
KeNHA
Location
44. Kenneth Murithi- Water Resources 0710459076 Positive Aspects

G.W.O Water Authority Isiolo • Ease of access to the interior Northern arid areas.
Resource Authority • Shorten the time taken to travel along the Northern corridor.
Concerns
• Displacement and land grabbing issues especially by foreigners.
• Conflict between communities over the route the road should take in order to benefit from
compensation.
• Exhausting water resources and water pollution
• Ensure boreholes along the road are not interfered with.
Suggestions
• Provide boreholes at designated areas for the community.
• Hospitals and police posts should be considered to improve the area security.
• Provide job opportunities for the local community.
• The contractor should apply for a permit whenever he intends to abstract water.
• The road design should put into consideration the topography of Ewaso-Ngiro river due to its seasonal
change in course.
• Therefore appropriate infrastructure should be put in place.
45. Benjamin Lepetet livestock and fisheries- 0725016762 Positive Aspects
Isiolo County Government • Improve Trade along the Northern corridor, within the county and the neighboring counties.
• Improved area economy
• Ease of access to the far flung areas.
Concerns
• Impact on trees and vegetation loss will rise due to road construction works.
• Appropriate measures such as watering should be put in place to suppress the dust during construction.
Suggestions
• Provide Job opportunities to the local community.
• Livestock sheds, boreholes and health facilities should be considered
46. Dr. Aden Mohamed Ministry of environment, 0720914491 / Positive Aspects
Dahiye Energy, Tourism & Mining Adeshmoha2009@gmail.com • Ease of movement
(Garissa County) • Enhancement of economic development
• Employment opportunities
• Corporate social projects
• Increase in trade
Concerns
• Environmental degradation and destruction
Pan-19-003
KeNHA
Location
• It will hinder movement during the implementation period

• High destruction of biodiversity
Suggestions
• Proper measures should be enforced
• Protect the wildlife corridor
• Placement of sign boards to minimize wildlife killing
• Backfilling of Quarries
Share both implementation and progress report with the department of environment
47. Mohamed Idriss Department of 0720716828 / Positive Aspects
Agriculture, Livestock, midrissm@gmail.com • Enhancement infrastructure
Fisheries and Irrigation • Ease Transportation
(Garissa County) • It will create market for livestock and agricultural produce
• Increase in trade
Concerns
• Environmental degradation
• Insecurity
• Spread of livestock diseases
Suggestions
• They should dig water pans for drip irrigation
• Support livestock Vaccination
• Involve the community and other stakeholders
48. John M. Mwangi WRA (Garissa County) 0723207195 / Positive Aspects

mwangijm667@gmail.com • It will open up the market for livestock and other forms of products within the area.
• Transport will be faster
• Security will increase
Concerns
• During construction water points will be affected
Suggestions
All mitigation measures should be taken seriously
49. Abdiweli Mohamed Department of Lands 0722704631 / Positive Aspects
(Garissa County) weliyrwooq.am@gmail.com • It will improve infrastructure and bring about urbanization
• Land value will increase
• Improve market
Concerns
Pan-19-003
KeNHA
Location
• Degradation of the environment

Suggestions
• Project should employ local community
• Restoring and backfilling of mining sites
Available local resources should be used
50. S.O. Migiro Kenya Forestry service 0728388106 / Positive Aspects
(Garissa County) zmgarissa@kenyaforestservi • Will open up the area for commercial venture with accompanied opportunities
ce.org Concerns
• Clearing of vegetation and biodiversity
Suggestions
• Minimize vegetation removal
• Compensate the local community especially on environmental degradation resulting from clearing vegetation
• Compensation should through CSR i.e. digging boreholes
• Assist in urban tree planting especially along the road
• Assist affected communities especially in supplying water through digging boreholes
• Mitigation measures should be incorporated
51. Abdi Ali Department of 0722697401 / Positive Aspects

Gender,Culture & Social abdinuriye@gmail.com • Transportation costs will reduce and a the area will be easily accessible
services (Garissa County) • Efficiency will increase
• Easy movement of goods and people
Concerns
• Deforestation
Suggestions
• The contractor should take care of trees
• The upgrading should be done within the shortest time possible
Pan-19-003
KeNHA
Location
52. Penuel Kemboi, Ministry of Roads and 0720764633 / Positive Aspects

Roads and Transprt Transport (Garissa keboichepkew@gmail.com • This particular project will open up Habaswein, Modogashe, Garse and Benane towns improving their economic
County) positions
• Improved road safety
• Efficient access to and opening up initially secluded areas
Concerns
• Cutting of trees and other vegetation along the project path may impact the environment
Suggestions
• Planting of trees along the proposed road
Inculcating proper drainage works within the design
53. Kuyoni Lemereu Kenya wildlife service 0725581681 / Positive Aspects
(Garissa County) klemereu@kws.go.ke • Ease of transportation and movement from one point to another
• Creation of jobs
• Security response will improve
Concerns
• Interference with wildlife dispersal within the area
Suggestions
• Water holes / pans should be dug for wildlife
• Road signs should be installed for motorists
54. Mohamed Ali Hirey Ministry of Environment, Positive Aspects

Energy Tourism & Mining • Ease of movement and enhanced economic development
(Garissa County) • Increase trade
• Create employment opportunities
• CSR projects
Concerns
• Environmental degradation
• Destruction of biodiversity
• Normal movement will not be possible during the implementation period
Suggestions
• Sign boards should be put up to minimize wildlife killing
• Backfilling of mining sites
• Reseeding of destroyed indigenous trees / species
• Protect both wildlife corridors and dispersal zones
• Share both implementation and progress report with the department of environment
Pan-19-003
KeNHA
Location
NB: All the Key Stakeholders supported the project
Pan-19-003
KeNHA
Annex 6: Chance Find Procedures
Pan-19-003
KeNHA
Chance Find Procedures
The Contractor will be expected to apply the following chance find procedure to
protect any cultural artifacts that could be encounterd during construction.
in cases where culturally valuable materials are uncovered

during excavation, including:
• Stop work immediately following the discovery of any materials with possible
archaeological, historical, paleontological, or other cultural value,
• The artefact shall not be moved from where it has been found, unless
supervised by the onsite NMK advisor
• Prevent and penalize any unauthorized access to the artefacts.
• Announce findings to project manager and notify relevant authorities;
• Protect artefacts as well as possible using plastic covers, and implement
measures to stabilize the area, if necessary, to properly protect artefacts
• The on-site NMK advisor, together with the contractor I project manager, will
undertake an inspection of the cultural heritage site.
• In consultation with the project manager and Contractor, the onsite NMK advisor
will determine the appropriate course of action to take.
• Sensitive sites defined in the Chance Finds Report shall be marked off with
hazard tape, detour signs and if necessary, the site secured as detailed in the
chance finds report. The site will be secured to prevent any damage or loss of
removable object
•
• Restart construction works only after obtaining authorization from the relevant
authorities.
Places of worship, water wells and graves are expected to be preserved during the
construction phase of the project and not interfered with.
Pan-19-003
KeNHA
Annex 7: Ambient Air Quality Tolerance Limit
Pan-19-003
KeNHA
Pan-19-003
KeNHA
Pan-19-003
KeNHA
Annex 8: Standards for Effluent Discharge to the Environment
Pan-19-003
KeNHA
Pan-19-003
KeNHA
Annex 9: KWS Letter on Wildlife Movement
Pan-19-003
KeNHA
Pan-19-003
KeNHA
Annex 10: Photographic Plates
Pan-19-003
KeNHA
Pan-19-003
KeNHA
Photo 1: PCM Meeting at Lagbogol
Photo 2: Section of the Project Road
Pan-19-003
KeNHA
Photo 3: Marabou Stork at KWS in Wajir
Photo 4: Livestock Using one of the trees as a shade in Lagbogol
Pan-19-003

Modogashe - Wajir Road Section ESIA Report PDF

Загружено:

Сведения о документе

Оригинальное название

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

Modogashe - Wajir Road Section ESIA Report PDF

Загружено:

Авторское право:

Доступные форматы

Review and Update of the Environmental

and Social Impact Assessment for the

Final ESIA Study Report

2.10.2 Hierarchy of Waste Management Practices 29

3.7.1.2 United Nations Convention on Biological Diversity (UNCBD) 63

6.2.2 Environmentally Sensitive Habitats 96

6.6.10 Distance to Health Centre/Dispensary 134

8.4.1.8 Security Risks and Crime Management 183

Map 9: Livelihood Zones of Garissa County 126

Table 45: Potential Positive Impacts and the Justification 161

Figure 1: Typical rural road cross section 10

Plate 1: Photo showing the Flat Terrain of the Project Area 83

Annex 5: Analysis of Key Stakeholder Questionnaires

DEFINITION OF KEY TERMS

Assets: Comprises land, structures or crops/trees, unless otherwise defined.

Ecosystem: Means a dynamic complex of plant, animal, micro-organism communities

Environment: Includes the physical factors of the surroundings of human beings

Environmental and Social Assessment (Assessment) is a process that determines

Environmental and Social Impact Assessment (ESIA) is a comprehensive document

Environmental and Social Management Plan (ESMP) summarizes the commitments

Environmental Management includes the protection, conservation and sustainable use

Environmental Monitoring means the continuous or periodic determination of actual

Household: Family or collection of people, which function as a single economic unit.

Indigenous Peoples: People indigenous to an area and include ethnic minorities as

Pollutant includes any substance whether liquid, solid or gaseous which

Rehabilitation: An enhanced period of maintenance intended to restore a project to its

Socio-economic Survey: Census of project area persons which is prepared through a

UTM (Universal Transverse Mercator): Conformal projection that uses a 2-dimensional

AADT Annual Average Daily Traffic

1. Kenya National Highways Authority (KeNHA) is a state corporation within the

2. The Government of Kenya (GoK), through Kenya National Highways Authority

3. The project will be implemented by Kenya National Highways Authority as part

• Component 1: Upgrading Selected Critical Road Infrastructure and

6. Project description. The Modogashe-Wajir Road project traverses Garissa,

Map Showing the Project Road

11. Legal framework. The main legislation that governs environmental

• OP/BP 4.01 Environmental Assessment

19. Socio-Economic Baseline Situation. In order to bring out the character of

Secondary Socio-economic Data

23. Land use and Land Tenure

25. Transport and Communication

26. Commerce and Industry

27. Local Communities

28. Water and Sanitation Services

29. Energy Source

36. Inter/Intra Clan Conflict

37. The Physical and Biological Baseline Information

38. Flora and Fauna

39. Physical Cultural Resources

aesthetic or other cultural significance. The Consultant identified a graveyard in

Table A: ESIA Public Consultation Meeting (PCM) Venues and Dates

42. The participants were made up of village elders, youth representatives,

Summary of Potential Cumulative Impacts

Environmental Potential Cumulative Impacts

mitigations measures including mitigation measures will ensure

Environmental Potential Cumulative Impacts

Population Increase Upon commissioning of the road,

Increased demand for more

Table B: Environmental and Social Management Plan (ESMP)

47. Table C: Environmental and Social Monitoring

Environmental/ Monitoring Requirements Frequency of Responsibility

Hazardous/Chemical • Physical inspection • Presence of oil spillage Weekly • RE’s Environmental

Environmental/ Monitoring Requirements Frequency of Responsibility