THE PROPOSED EXPANSION OF THE EXISTING SACHANGWAN QUARRY AND CONTRACTOR'S CAMP.
- Category: Policy Research & Analysis
- Date 30-01-2026
The Government of Kenya, through the Kenya National Highways Authority, identified the need for the rehabilitation and expansion of the Nairobi – Nakuru – Mau Summit (A8) highway which serves as an access and transportation link for approximately 6 million Kenyans. The project road is part of the Northern Corridor which is one of the busiest and most important transport corridors in East and Central Africa, providing a gateway through Kenya to the landlocked economies of Uganda, Rwanda, Burundi, Southern Sudan and Eastern DR Congo. The main objective of the project is to expand the road capacity and improve the road quality between Nairobi and Mau Summit in order to accommodate the increasing traffic in a safe and sustainable manner.
Construction of the road will require huge quantities of aggregates, stone chippings, sand and gravel. Sachangwan quarry is an existing quarry and has been identified as a potential source of quality aggregates and a suitable location for other support infrastructure. The Quarry shall however need to be expanded in order to keep up to the demand of the materials required to construct the road.
As required by the Kenyan law, a study was conducted to evaluate the potential and foreseeable impacts of the proposed development. The physical scope was limited to the proposed site and the immediate environment as may be affected or may affect the Quarry expansion and Camp. Any potential impacts (localized or delocalized) were also evaluated as guided by EMCA, 1999 (Amendment 2015) and the Environmental (Impact assessment and Audit) Regulations, 2003 (Amendment 2016).
The National Environment Civil Society Alliance of Kenya (NECSA-K) went through the ESIA report and submitted the memorandum whose contents are discussed here to the National Environment Management Authority (NEMA). NECSA-K is an umbrella platform bringing together over 100 civil society organizations working in the environment and natural resources management sector in Kenya.
NECSA-K acknowledges that Sachangwan Quarry is an existing facility identified as a potential source of quality aggregates for the Nairobi–Nakuru–Mau Summit Highway Project. However, following a review of the ESIA report, the Alliance raises serious concerns regarding its adequacy, accuracy, and compliance with national environmental and social safeguards.
At the onset, NECSA-K notes three overarching weaknesses in the ESIA report. First, the costs associated with the Environmental and Social Management Plan (ESMP) have been significantly downplayed, raising concerns about the feasibility of proposed mitigation measures. Second, the ESIA process failed to achieve meaningful public participation and comprehensive stakeholder engagement, contrary to statutory requirements. Third, the use of evidence, citations, and references throughout the report is inconsistent and unsystematic.
The Executive Summary presents several deficiencies. The project description lacks clarity, particularly regarding the GPS coordinates, which are not presented using a standard referencing system commonly accepted in Kenya. Additionally, the legal and policy framework omits relevant Multilateral Environmental Agreements (MEAs) applicable to quarry operations. NECSA-K recommends that all relevant MEAs be clearly identified and integrated into the policy analysis.
The approach and methodology used in the ESIA are also problematic. The administration of questionnaires and focus group discussions lacks clarity, particularly regarding participant selection criteria. The report contains grammatical errors and typographical mistakes, undermining its professional credibility. Noise assessments include erroneous table references, while the field survey is inadequate in documenting flora and fauna. NECSA-K strongly recommends a comprehensive biodiversity survey, particularly on the south-western side of the site where mature acacia trees serve as nesting habitats for birds.
In the project description, inconsistencies arise from the use of mixed measurement units such as acres and hectares. NECSA-K recommends strict adherence to Kenya’s metric system. Administrative boundaries are also inaccurately referenced, with outdated terms such as “constituency” used instead of constitutionally recognized sub-county structures. These errors should be corrected to align with Kenya’s governance framework.
Concerns are also raised regarding drilling and blasting activities. The ESIA relies on outdated blasting methods and provides only suggestive explanations of explosive use without estimating the magnitude of blasting required. Given the proximity of schools and health facilities—some within 350 to 742 metres of the quarry—NECSA-K recommends the adoption of modern blasting technologies with silencers to minimize noise and vibration impacts.
Waste management planning is weak. Waste inventories and classifications fail to reference applicable regulations, while construction waste and emission inventories incorrectly refer to “local council facilities” instead of County Government facilities. These inaccuracies must be corrected. The legal, policy, and institutional framework further omits several key national policies, strategies, and institutions, including sanitation policy, biodiversity strategies, climate governance institutions, wildlife authorities, and monitoring and evaluation frameworks.
The description of the environmental and social setting is incomplete and inaccurate. Drainage data does not reflect actual baseline conditions, and sections on noise, vibration, poverty, soils, and water supply contain errors, omissions, or incorrect numbering. Notably, water supply discussions focus on sanitation while failing to identify actual water sources such as boreholes. NECSA-K recommends inclusion of alternative water sources and baseline data from the 2019 Census, particularly for vulnerable groups including persons with disabilities and youth.
The analysis of alternatives is insufficient. The report fails to present at least three viable alternatives as required, relies on archaic extraction methods, and does not provide a realistic alternative site. NECSA-K urges consideration of technology-led quarrying approaches, including drone-guided extraction, automation, and modern monitoring systems.
Public participation is critically inadequate. Only one public meeting was held, contrary to legal requirements for multiple consultations with adequate notice. There is no evidence of newspaper notices, stakeholder inclusion, or documented feedback. NECSA-K recommends establishing a Grievance Redress Mechanism, inclusive stakeholder engagement throughout project phases, and verifiable documentation of public participation.
The assessment of environmental and social impacts lacks consistency across sections. Community health and safety concerns are insufficiently addressed, particularly the absence of a resettlement plan for families located within 50 metres of the quarry. No biodiversity assessment was conducted, yet assumptions of minimal ecological impact are made. These gaps undermine the credibility of the ESIA.
Finally, the Environmental and Social Management Plan fails to allocate costs to mitigation measures, rendering it impractical.
The entire memorandum generated by NECSA-K Alliance can be downloaded and read here.