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ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FOR A PROPOSED CONSTRUCTED WETLAND




ENVIRONMENTAL IMPACT ASSESSMENT  FOR THE PROPOSED CONSTRUCTED WETLAND  IN EGERTON UNIVERSITY

ACKNOWLEDGEMENT
We Elvin, Isaack, Karanja, Zephaniah, Judy and Wycliffe would like to register our gratitude to the following: Egerton University for offering us admission to Environmental Science department for this short intensive course together with the departmental lecturers for their untiring efforts in ensuring we get the correct concepts of E.I.A and Mr. Koech for guiding us through report writing in the wetland.
Lastly but not least we like to appreciate our parents for their financial, emotional and social support they accorded to us during the two week period.

EXECUTIVE SUMMARY


LIST OF ACCRONYMS
1.      EIA                 Environmental Impact Assessment
2.      EMCA            Environmental Management and Coordination 
3.      WSP                Water Stabilization Ponds
4.      NEMA            National Environmental Management Authority
5.      MCN               Municipal Council of Nakuru
6.      FGD                Focused Group Discussion
7.      EMP                Environment Management Plan
CW                  Constructed wetland


INTRODUCTION

1.1 PROJECT BACKGROUND
Egerton University is located along Nakuru-Mau Narok road, 5 km from Njoro. It has a population of approximately 16000 students and 4000 staff members. The wastes produced from the institution is directed through the Egerton University wastes stabilization ponds (WSPs) to the constructed wetland and released to river Njoro. The WSPs consists of three lagoons mainly used to filter out the nutrients, biodegradable wastes and pathogens. The constructed wetland further removes the excess nutrients and heavy metals. Due to the increased population in the institution magnified by the double intake of students there is increased amount of waste water that needs to be treated thus facilitating the need of an additional constructed to increase the efficiency of the current existing wetland.
A proposed constructed wetland will be beside the existing one on grassland adjacent to the River Ndarugu which serves local residents downstream and even drains into Lake Nakuru which is a Ramsar site. Therefore releasing inadequately treated water with excess nutrients and components of heavy metal may lead to eutrophication and bioaccumulation and biomagnification.
The proposed wetland  is the upgrade of the existing wetland that was constructed back in 2006.The environmental experts embarked with the assignment from 15th to 23rd may 2013 with various consultations on the key stakeholders in Egerton. The following are some of the departments and groups that were consulted over the proposed project;  Egerton university students, teaching and non-teaching staff, water and sanitation department, department of environmental sciences, estates department  among others.
It was noted from our in-depth consultation that the study area or the project site is also not part of, or near any area of conservation concern regarding plant species as well as and other forms. These have been mapped and the site does not appear on any lists. There is also no traditional cultural site recorded there or in the locality.
The environmental experts complied with Environmental management coordination act of 1999 environment (impact assessment and audit) regulations 2003 legal notice no. 101 for the purpose of undertaking the fully EIA study which the report will be submitted to NEMA for review and approvals.

1.2 Problem statement
Most developing countries are coping with serious environmental problems. In sub-Saharan Africa, meeting basic needs such as clean water and food is a daily struggle for many. Growing populations and climate change are exacerbating these problems even more.
The study area considered in this report is Egerton University in Njoro District, Nakuru County. The high density of intake over the last five years has a considerable influence on the health and sanitation status community adjacent to River Njoro and the entire environment.
Egerton University turns out 500,000 litres of waste water daily. This project will involve the university community, the local community in the surrounding areas to construct vegetation based wetland to treat 100,000 litres of the waste water from the Egerton University. This project will assist in cleaning River Njoro, which is the main river that flows into Lake Nakuru, A ramsar site of international importance. Polluting Lake Nakuru has greatly affected the biodiversity in Lake Nakuru. This project will serve as an example for the community to ask other industrial companies and factories around Lake Nakuru to also clean up their waste water. This project brings together those in academia, private sector, NGOs and communities in learning about constructed wetlands for cleaning waste water

STUDY OBJECTIVES
The study objectives were to:
        i.            Conduct an Environmental Impact Assessment to identify both positive and negative impacts of the proposed project and propose most appropriate interventions during construction, operation and decommissioning of the project;
      ii.            Collect baseline socioeconomic data of the project area and potential impact expected from project construction, implementation, operation and decommissioning;
    iii.            Develop an Environmental Monitoring Program during construction and operation and present plans to minimize, mitigate, or eliminate negative effects and impacts;
    iv.            Describe Environmental Management Plan implementation mechanisms;
      v.            Identify and contact stakeholders to seek the views on the proposed project;



TERMS OF REFERENCE
The study terms of reference included:
·         Establish the suitability of the proposed location for construction of wetland site.
·         A concise description of the National Environmental Legislative and RegulatoryFramework, Baseline Information, and any other relevant information related to the project.
·         A description of the technology, procedures and processes to be used, in the implementation of the project.
·         A description of materials to be used in the construction and implementation of the project, the products, by-products and wastes to be generated by the project.
·         A description of the potentially affected environment.
·         A description of environmental effects of the project including the social and cultural effects and the direct, indirect, cumulative, irreversible, short-term and long-term effects anticipated.
·         To recommend a specific environmentally sound and affordable wastes’ management system.
·         Analysis of alternatives including project site, design and technologiesand reasons for preferring the chosen technology and processes.
·         Development of Environmental Management Plan proposing the measures for eliminating, minimizing or mitigating adverse impacts on the environment, including the cost, timeframe and responsibility to implement the measures.
·         Provide an action plan for the prevention and management of the foreseeable hazardous activities in the cause of the project cycle.
·         Propose measures to prevent health hazards and to ensure security in the working environment for the employees, students’ and for the management of emergencies.
·         An identification of gaps in knowledge and uncertainties which were encountered in compiling the information.
·         An environmental, economic and social analysis of the project.

DEFINITION OF TERMS
1.      Environment:
2.      Constructed wetland:
3.      EIA:
4.      Waste water treatment:
5.      Natural wetland:
6.      Eutrophication:
7.      Bioaccumulation:
8.      Biomagnifications:
9.      Ramsar site:
10.  Alien species:
11.  Biodiversity:
12.  Impact:

STUDY METHODOLOGY
This study was carried out through desktop review and field investigations. The experts conducted extensive literature review pertaining to this project. During the field investigation, reconnaissance survey was conducted to gather information on biophysical and socio-economic aspects of the area and its environs.
In order to address these issues the study team adopted a participatory approach where the client and the immediate surrounding communities were consulted in addition to reviews and references to sources of information including legal statutes, design and relevant project documents. Among the key activities undertaken during the assessment are:
        i.            Interviews and consultations with the immediate neighbouring water users. A questionnaire was circulated to the people in the neighbourhood to obtain their honest opinion regarding the project (samples have been annexed to this report),
      ii.            Review of documents with necessary information on the proposed project details, the site planning and implementation plan as well as the desired nature of the substation,
    iii.            Physical inspections of the proposed site and photography,
    iv.            Evaluation of the activities around the site and the environmental setting of the wider area, through review of existing information, literature and physical observations,
      v.            Reporting, review and submissions.

The Environmental considerations evaluated for the proposed development include: Ecological considerations (biological diversity, sustainable use of ecological resources and ecosystem maintenance), social considerations (economic impacts, effects on human health,and effects on culture and objects of cultural value), Landscape considerations (views opened up or closed, visual impacts, compatibility with surrounding areas) and land use considerations (water sources, effects of proposal on surrounding land use potentials and possibility of multiple uses).

PROJECT DESCRIPTION
The proposed project would establish a wetland to purify the polluted water from Egerton University that is released into River Njoro. Efforts have previously been made to address the problem of polluted waste water that is channelled into River Njoro by construction of a wetland which has since been overwhelmed by the waste water load.
The primary mission of the proposed project is to improve the water quality of the Njoro River to World Health Organization‘s standards for irrigation, which is an appropriate standard for water that people may come in casual contact with and with which fish and vegetative products will likely be produced. It is possible to achieve this by constructing a biological filter in the form of a wetland that is designed to improve the quality of Njoro River water. Within a wetland plants and the soil in which they grow clean the water as it flows by. The roots of the plants can adsorb and absorb pollutants. A wetland is typically constructed with concrete cells filled with gravel or soil and submerged, emergent and/or floating vegetation. The next chapter will explain in more detail what a wetland is and how it works.


Project Location
The specific project site has been chosen by the Egerton University community.
The proposed wetland project is located in Nakuru county, Njoro district within Egerton University. At the proposed site we have the following human activities: to the east there is a tarmac road leading to the University entrance, to the north we have Njoro river adjacent to Njoro canning factory, to the south are the horticultural plots while to the west are the water stabilization ponds, private land( wheat farms) and the sports ground. The wetland is estimated to cover 0.25 hectares of land. The terrain of the area is gradually sloping towards the river and its landforms meet the suitability of topography in terms of shape, size and orientation to the prevailing winds (US Environmental Protection Agency, 1995). While a constructed wetland can be built almost anywhere, we decided to select a site with gradual slope that could be easily altered to collect and hold water which simplifies design, construction and minimizes costs.

Constructed wetland technology
Constructed wetlands constitute an increasingly popular technology for treating wastewater, particularly in developing countries that lack adequate financing for conventional technologies. The process by which the constructed wetland purifies water and design methodologies is variable but the proposed EU constructed will entail a meandering compartments (reduce the water speed hence ensure maximum nutrient removal); gravel, asphalt, and sand (purify and restore the water colour); and wetland plants such as water hyacinth, water cabbage, papyrus and cattail.

Components of a constructed wetland
A constructed wetland consists of a properly designed shallow basin filled with substrate, usually soil or gravel, planted with vegetation tolerant of saturated conditions. Water is introduced at one end of the wetland and flows over the surface or through the substrate, and is discharged at the other end through a weir or other structure which controls the depth of the water in the wetland. The polluted water loses nutrients and other pollutants to both the substrate and the plants. The plants can be harvested so that new vegetation can grow and absorb new pollutants. The substrate eventually becomes saturated with pollutants and may need to be replaced in order to regenerate the effectiveness of the cleaning process


ANALYSIS OF PROJECT ALTERNATIVES
This section analyses the project alternatives in terms of site, technology scale and waste management options.
Zero or No Project Alternative
The No Project option in respect to the proposed project implies that the status quo is maintained. This option is the most suitable alternative from an extreme environmental perspective as it ensures non-interference with the existing conditions. This option will however, involve several losses both to the institution and the community as a whole. The No Project Option is the least preferred from the socio-economic and partly environmental perspective due to the following factors:
• The economic status of Kenyans and the local people would remain unchanged.
• The local skills would remain under utilized.
• Plenty of waste water would be drained into River Njoro.
• No employment opportunities will be created for thousands of Kenyans who will work in the wetland site.
From the analysis above, it becomes apparent that the No Project alternative is no alternative to the local people, Egerton University students, and the interested stakeholders.
Relocation Option
Relocation option to a different site is an option available for the project implementation. At present the institution has an alternative site to accommodate the scale and size of the project and completing wetland project on the empty land behind the new anatomy laboratory that is located next to the University main gate. Assuming the project will be given a positive response by the relevant authorities including NEMA, Council among others, this project would have been delayed for about two (2) years before implementation. This is a delay that our economy can’t afford. This would also lead to a situation like No Project Alternative option. The other consequence of this is that it would be a discouragement for developments in their bid to expand existing facilities.
In consideration of the above concerns and assessment of the current proposed site, relocation of the project is not a viable option.
Analysis of Alternative Construction Materials and Technology
The proposed wetland site will be constructed using modern, locally and internationally accepted materials to achieve public health, safety, security and environmental aesthetic requirements. Equipment that saves energy and water will be given first priority without compromising on cost or availability factors. The concrete pillars and walls will be made using locally sourced stones, cement, sand (washed and clean), metal bars and fittings that meet the Kenya Bureau of Standards requirements.
The alternative technologies available include the conventional brick and mortar style, prefabricated concrete panels, or even temporarily structures. Due to cost and durability, the brick and mortar style is the most popular more so in Kenya. The scale and extent of the project is determined by design, the plot size and funds available. The various technologies available include; concrete frame construction, timber construction, prefabricated space frame construction, steel frame and aluminium frame. The technology to be adopted will be the most economical and one sensitive to the environment. Heavy use of timber during construction is discouraged because of destruction of forests. The exotic species would be preferred to indigenous species in the construction where need will arise.
Waste water management alternatives
Five locally available technologies are discussed below:
Alternative one: Waste water treatment plant
This involves the construction of a plant that will enable the recycling of the waste water from the project activities to reusable standards and utilised within the site in activities such as irrigating the flower gardens and flashing of the toilets. It is usually expensive to construct and maintain, but it is the most reliable, efficient and cost-effective in the long term. This is the most preferred option for such project because of its benefits.
2 Alternative two: Use of stabilization ponds/lagoons
This refers to the use of a series of ponds/lagoons that allow several biological processes to take place, before the water is released back to the river. The lagoons can be used for aquaculture purposes and irrigation. However, they occupy a lot of space but are less costly. No chemicals are used, heavy metals sink and decomposition processes take place. They are usually a nuisance to the public because of smell from the lagoons/ponds. This option is not preferable in the area because the required space is not available.
3 Alternative Three: Use of Constructed/A rtflcial wetland
This is one of the powerful tools/methods used in raising the quality of life and health standards of local communities in developing countries. Constructed wetland plants act as filters for toxins. The advantages of the system are the simple technology, low capital and maintenance costs required. However, they require space and a longer time to function. Long term studies on plant species on the site will also be required to avoid weed biological behavioural problems. Hence it is not the best alternative for this kind of project because of the large amount of land required.
4 Alternative Four: Construction of a septic tank
This involves the construction of underground concrete-made tanks to store the sludge with soak pits. This option is viable in instances where the project is far from a sewer line. The method is made expensive due to construction technology and regular exhaustion.
In conclusion, the recommended course of action for the waste water management from the proposed project is the construction of a waste water treatment plant within the site that will be properly maintained.
8.5 Solid waste management alternatives
A lot of solid waste will be generated from the proposed mini bakery project in Nkoroi. An integrated solid waste management system is recommendable. First, the proponent will give priority to Waste reduction at source of the materials. This option will demand a solid waste management awareness programme among the management and the users of the facility. Secondly, Recycling, Reuse and composting of the waste; this will call for a source separation programme to be put in place. The fma option will be combustion of the wastes that are not recyclable.



PROJECT POTENTIAL IMPACTS AND MITIGATION MEASURES
Both positive and negative impacts that are associated with the proposed wetland construction. The following positive and negative impacts are associated with the proposed project.
Positive Impacts
The following are positive impacts associated with the proposed wetland:
·         Improvement in the quality of water in river Njoro.
·         Direct and indirect, temporal and permanent, skilled and non-skilled employment opportunities.
·         Provision of market for supply of building materials.
·         Informal sectors benefits through development of informal trading.
·         Optimal use of land.
·         Improvement in health status as a result of clean water drained into the river.
·         Improvement in people’s living standards.
·         Creation of manure
·         Facility will be a teaching resource for the University in future
·         Incorporation of aquaculture during operation of the project.
·         Water from the wetland can  be used for general purposes like watering landscape and flushing sanitary facilities
·         Wetland will serve as an example to other industries and institutions on the management of waste water. 


Negative Impacts
Against the background of the above positive impacts, there will be negative impacts emanating from the construction and subsequent operation activities of the facility. The negative impacts will include:
1.      Dust emissions: Dust will be generated during the construction. This will affect construction staff as well as the neighbours. The impact will be direct, temporary and minor.
2.      Noise Pollution and increased vibration: The proposed civil works and operation of the facility will bring about an increase in cumulative noise levels. Noise pollution from the proposed development during construction noise will be generated from the construction machines and construction workers during day time. Considering the existing background noise level, the operations activity during daytime is not expected to seriously affect the noise level in areas adjacent to the project site.
3.      Soil Erosion: There is a likelihood of localized soil erosion during the civil works which entail compacting, earth excavations and moving works. However, these impacts will be largely localized to the project area and will only occur during the construction phase.
4.      Oil Spills: There is a possibility of oil leaking from the machineries. This may lead to potential contamination of surface and groundwater as well as soil.
5.      Increase in traffic flow: During the construction phase, heavy vehicles moving in and out of the project site are likely to increase traffic along the main road near the project site and could cause congestion.
6.      Strain in local resources: The proposed development is likely to strain the resources available like water in the area in the short term mostly during the construction phase. This is as a result of increased population in the project without commensurate services and facilities
7.      Occupational Health and Safety: There will be potential risk of occupational hazards that could lead to occupational accidents during construction and operation of the project. Adverse impacts on the workers’ health and safety is likely to occur especially through workers’ interaction with the equipment and machines during construction and operation of the wetland. Accidents, injuries and diseases are likely to occur during project construction and operations and this could potentially harm the health of the employees.
8.      Solid waste generation: Solid waste materials during construction and solid waste during operation and decommissioning are likely to be encountered. The waste will include soil, construction materials and office papers.
9.      Visual Intrusion: The proposed project will change the natural appearance of the project area landscape.

PROPOSED MITIGATION MEASURES
Dust Emissions
·         Fugitive dust emissions from site work to be eliminated or minimized by applying water on a need to need basis to unpaved surfaces and exposed construction areas during the dry season;
·         Cover all trucks hauling soil, sand and other loose materials or require all trucks to maintain at least two feet of freeboard.
·         During construction, where water is available, sprinkle the construction area with water to keep dust levels down.
·         Construction trucks removing soil from the site, delivering sand and cement to the site should be covered to prevent material dust into the surrounding areas;
·         During construction, any stockpiles of earth should be enclosed / covered / watered during dry or windy conditions to reduce dust emissions;
·         Masks should be provided to all personnel in areas prone to dust emissions throughout the period of construction.

Noise Abatement Measures
·         All construction equipments and machinery to be used must be tested to verify if they are compliant with Kenya and the internationally acceptable standards of noise. Tested noise levels should be recorded as baseline and used for future monitoring.
·         Noise emitting equipment should be properly maintained.
·         All workers in the project site must be equipped with suitable and adequate Personal
·         Protective Equipment (PPE) for hearing protection.

Soil Erosion Mitigation Measures
·         Excavations of the site will be confined only on the sections of the wetland where structures and equipment shall be located.
·         Excavated earth will be held away from the drains and on locations of the site not susceptible to surface runoff of storm water,
·         The earth removed for external disposal will require to be deposited on sites without the risk of being washed down during rains and where it will not compromise other land use activities in those areas,
·         Caution will be required during construction at times of heavy rains.
·         Re-vegetate exposed areas around the site so as to mitigate erosion of soil by storm water runoff.
·         The final site grade should facilitate drainage and avoid flooding and pooling. A site drainage plan should be developed to protect against erosion.
·         Protecting stockpiles through the use of silt fencing and reduced slope angles should be used to minimize soil erosion during construction.
·         Installation of drainage ditches, construction of runoff and retention ponds is necessary. Minimization of disturbances and scarification of the surface should be observed to reduce erosion impacts.
·         All slopes and working surfaces should be returned to a stable condition.
·         Topsoil on the final site would be graded and planted as appropriate.

Oil Spill Mitigation Measures
·         To prevent oil spills and environmental contamination, the substation should be designed with spill prevention and detection systems to protect the environment especially where the transformers will be located.
·         Need to design appropriate protection devices against accidental discharge of transformer oil substances.
·         Storage and liquid impoundment areas for fuels, raw and in-process material solvents, wastes and finished products should be designed with secondary containment to prevent spills and the contamination of soil, ground and surface water.
·         The substation design should provide adequate storage areas for the transformer oil.
·         Frequent inspection and maintenance of the transformers should be done to minimize spilling.
·         A written substation response plan should be prepared and retained on the site and the workers should be trained to follow specific procedures in the event of a spill.
·         Constructing and maintaining facilities should be done so as to enable the easy removal of rainwater from the secondary containment structures and proper removal of oil from the surface of the accumulated storm water.
·         The substation operator should ensure the proper containment or collection and disposal for the used transformer oil. In the Environmental Management Plan (EMP), disposal of used oil will be the responsibility of the project operator.
·         All waste oils from maintenance of transformers and other associated equipments’ should be segregated and disposed properly by a reputable/registered waste handler in accordance with the waste disposal plan.
Solid waste generation
·         The solid waste would consist primarily of packaging materials for lubricants, used oil filters and used rags.
·         Contractor should develop a solid waste disposal plan which includes the provision of receptacles at strategic points within the site, recycling programmes for recyclable wastes.
·         Solid wastes must be segregated and labelled to separate hazardous from non-hazardous waste. The substation should be provided with an inbuilt solid waste collection bin with compartments for recyclable materials, biodegradable materials and hazardous materials.
·         The most appropriate options in waste management are identification of the waste types, segregation into the various categories and establish suitable mechanisms of collection, storage, transfer and final disposal. The ultimate destination for each of the waste categories should also be known.
·         The contractor and project operator should engage a refuse handling company to remove the wastes from the site to the recommended waste management site.
·         Warning signs against littering and dumping wastes in wrong places within the project site should be erected.
·         Earth excavated from the construction site should be used as land fill in quarries or other excavated sites within or outside the project site. It is suggested that the contractors identify suitable land fill sites.
·         Solid waste audit should be an integral section of the annual environmental audit of premises upon commissioning.
Hazardous waste
·         The amount of hazardous waste generated will be very low and possibly originate from maintenance sources.
·         Hazards on the site should be clearly marked and the entire workforce trained to recognize the hazards and familiarize themselves with procedures to be followed before entering hazardous areas.
Soil Erosion Mitigation Measures
·         Excavations of the site will be confined only on the sections of the substation where structures and equipment shall be located.
·         Excavated earth will be held away from the drains and on locations of the site not susceptible to surface runoff of storm water,
·         The earth removed for external disposal will require to be deposited on sites without the risk of being washed down during rains and where it will not compromise other land use activities in those areas,
·         Caution will be required during construction at times of heavy rains.
·         Re-vegetate exposed areas around the site so as to mitigate erosion of soil by storm water runoff.
·         The final site grade should facilitate drainage and avoid flooding and pooling. A site drainage plan should be developed to protect against erosion.
·         Protecting stockpiles through the use of silt fencing and reduced slope angles should be used to minimize soil erosion during construction.
·         Installation of drainage ditches, construction of runoff and retention ponds is necessary. Minimization of disturbances and scarification of the surface should be observed to reduce erosion impacts.
·         All slopes and working surfaces should be returned to a stable condition.
·         Topsoil on the final site would be graded and planted as appropriate.

Oil Spill Mitigation Measures
·         To prevent oil spills and environmental contamination, the substation should be designed with spill prevention and detection systems to protect the environment especially where the transformers will be located.
·         Need to design appropriate protection devices against accidental discharge of transformer oil substances.
·         Storage and liquid impoundment areas for fuels, raw and in-process material solvents, wastes and finished products should be designed with secondary containment to prevent spills and the contamination of soil, ground and surface water.
·         The substation design should provide adequate storage areas for the transformer oil.
·         Frequent inspection and maintenance of the transformers should be done to minimize spilling.
·         A written substation response plan should be prepared and retained on the site and the workers should be trained to follow specific procedures in the event of a spill.

Public and Workers Health and Safety Mitigation Measures
·         All workers entering the construction site must be equipped with Personal Protective Equipment (PPE) such as ear muffs, safety footwear, overalls, gloves, dust masks, among others. The PPE’s should be those that meet the international standards.
·         Personal protection gear must be provided and its use made compulsory to all. The entire workforce of the substation should be trained in the use and care of protective gear and in all relevant safety measures.
·         Restricted ‘ENTRY’ signs should be installed to keep away unauthorized persons from access to restricted areas.
·         Machines and Equipments must be operated only by qualified staff and a responsible person should be on site at all times to ensure adherence to safety requirements.
·         The contractor and operator must develop a workplace Safety and Health Policy Manual which should be communicated to all persons at the site.
·         The contractor and operator should develop a Substation Response Plan for handling any emergencies arising thereof during the construction.
·         During construction, temporary washrooms should be constructed with soak-pits that can be easily exhausted.
·         A well equipped first aid kit and a person who has been trained in first aid should always be available at the site.
Visual Impact
·         Structures at the site should be designed in such a way that they will improve the beauty of the surroundings.
·         Restore site area through backfilling, landscaping and planting of trees, shrubs and grass on the open spaces to re-introduce visual barriers,
·         Landscaping and planting of trees at the site would also serve to mitigate any perceived negative visual impacts

Economic and Social Impact
·         The Proponent should continually participate in community development activities where possible as part of their corporate social responsibility.
·         Casual labourers should be sourced from the local community to boost them economically and create employment for the youth.

LEGAL FRAMEWORK
Legal Legislative Reforms
The Kenyan Government has undertaken reforms aimed at conservation of environmental resources including wetlands. This includes enactment of legislations related to conservation and management of wetlands in the country. The relevant laws include the Environment Management and Coordination Act (EMCA 1999) section 42, the Lakes and Rivers Act cap 409, and the Water Act (2002) which deals with management, conservation and control of water sources.
The government has also developed strategies for water services development and water resources management. It has also gazetted subsidiary legislation aimed at protection of wetlands.
These include the Water Resources Management Rules 2007, Environmental Management and Coordination Water Quality Regulations 2006, that set stringent standards for effluent discharge into aquatic bodies.
In-spite of the above reforms Kenyan wetlands are still greatly threatened by degradation.
Policy Statement 1: Monitor and ensure implementation of the National Wetlands Policy through development of appropriate legislation
Policy Statement 2: Mechanism for reviewing Environmental Impact Assessments (EIA) on proposed development projects in wetland areas should ensure use of relevant expertise.
Policy Statement 3: Develop wetlands conservation and management guidelines, regulations and procedures.
Policy Statement 4: Integrate wetland concerns into all sectoral reforms
Institutional Arrangements
Lack of a holistic institutional framework has affected wetland management in Kenya. Different aspects of wetland conservation and management are handled by different agencies, such as KWS, fisheries, water, regional development authorities, agriculture, local authorities, and communities, without clear legal framework. This has therefore meant that no single agency is in charge of overall coordination. This status highlights the fact that wetlands have often been marginalized and regarded as “wastelands” and this neglect has contributed to massive wetland loss and degradation.
Policy Statement 1: The government will identify a National Institution to spearhead and coordinate implementation of the policy
Policy Statement 2: Establish a National Wetlands Interministerial Steering Committee to guide implementation of the policy bearing in mind that wetlands are cross sectoral resources.
Policy Statement 3: Measures to establish site management committees made up of adjacent communities to conserve and manage wetlands at national level and their respective wetlands at local level.
Policy Statement 4: Encourage development of stakeholder management plans for wetlands with clearly defined management regimes centered on local community participation.
Policy statement 5: Promote implementation of water resources strategic management plans

Artificial Wetlands
Artificial wetlands have gained prominence worldwide as alternative technologies in wastewater treatment, food production and aesthetic uses. In Kenya the use of these types of wetlands has been minimal despite their huge potential for affordable wastewater treatment and other uses.
Policy Statement 1: Promote the use of artificial wetlands in the relevant sectors such as industries, sources of water for increased agricultural production, municipalities, hotels, communities among others, as way of reducing pressure on natural wetlands.
Policy Statement 2: Demonstration and training sites will be established to promote the use and benefits of constructed wetlands.
Policy Statement 3: Establishment of fishponds for food production in local communities will be promoted as part of the National food security program.

PUBLIC CONSULTATION
Consultations were also undertaken as part of the EIA in order to obtain the views of immediate community, interested groups, stakeholders and affected groups within the site’s immediate area of influence. The consultation was done with the immediate neighbourhood of the proposed site and involved use of a semi-structured public participation form.
We designed fifty questionnaires whereby 20 copies were distributed to students, another 20 to the community members who resided along Njoro river bank and the wetland and the remaining 10 questionnaires were issued to the staff both teaching and non-teaching staffs.
In general the project is acceptable and no objections were raised concerning the proposed wetland construction. Students were very concerned about the wastes that they produce because they are not directly affected by the water quality in river Njoro. Some even have not visited water stabilization ponds nor the constructed wetland.
The community along the river Njoro were very bitter about the water quality in river Njoro. They thought water borne diseases like typhoid; cholera and amoeba which are common among their members are attributed to release of waste water from Egerton University. About five people die and hundreds are affected by the water quality in the river.
On the side of staff, most teaching staff said that Egerton has attributed to poor water quality in the river. The non/teaching staff mostly skilled and unskilled supported the project because some of them hoped to get job and renew their working contracts.


Conclusion
In view of the above findings, it can be concluded that there is a high level of acceptance of the Wetland project by all stakeholders including the communities living along the stream as well as the students’ population. This follows drainage of poor quality water into the nearby Njoro River. Among the most notable aspects include the following:
1.      The wetland will contribute immensely towards improvement of water quality that is released into River Njoro.
2.      The wetland will not only uplift the living standards of the communities, but will also lead to appreciation of water values, improve the livelihoods and enhance hygiene and sanitation at homestead levels.
3.      The wetland will further into developing a water treatment plant to ensure availability of clean water for domestic use in the target areas,
4.      The wetland will enable moderation of flows in Njoro River downstream and ensure constant availability of water throughout the year.
5.      Management of the wetland will contribute towards environmental conservation initiatives such as to include sustainable water reuse, and access to biological resources in the area,
It is also concluded that the project magnitude will be significant such as to impose impacts to the physical and biological environment as well as the social, cultural and economic setting of the area.
The negative impacts, however, are identifiable and can be mitigated through design and administrative measures. However, the overall positive impacts of the project far outweigh the negative projects through the mitigation measures outlined for the project.

Recommendations
It is recommended that the wetland project proceed with the main objective remaining to enhancing effective water treatment before it is released into River Njoro. In order to minimize environmental and social impacts from the wetland construction and operation, the following broad recommendations are also proposed;
1.      Vegetation clearing shall only be done on the wetland construction area such to reduce loss of indigenous plants around the construction site,
2.      Water quality will be of high importance. It will, therefore, be necessary to identify and decommission all pit latrines and waste holding locations for total removal for disposal into approved and pre-agreed dumping areas. This should also apply to cattle pens found in each homestead,
3.      Culturally, the water will be unacceptable for consumption if graves are submerged into the river. In this regard, the project management will need to negotiate with the communities on the logistics of relocation of the graves to pre-agreed sites,
4.      Provide an opportunity for the local communities (land owners) dispose off natural resources on their land before acquisition. This could include controlled charcoal burning and briquette making as well as removal of sand accumulated at the dam site.
5.      Undertake a comprehensive risks assessment study of the wetland components downstream the entire Njoro river basin with quantification and appropriate preventive propositions,
6.      An all-inclusive participatory resettlement Action Plan should be systematically conducted to establish who owns (interested parties and shareholders) what so as to determine the rightful owners who should benefit and the share each should receive
7.      In order to ensure safety, there is need to fence the wetland.
8.      Organization of the community into a strong unit to control local resources as well as social and economic benefits resulting from construction of the wetland including sand harvesting and marketing of products such as fish, crops and livestock.
ENVIRONMENTAL MANAGEMENT PLAN (EMP)
Significance of the EMP
Environmental Management Plan (EMP) for developing projects is usually to provide a logical framework within which identified negative environmental impacts can be mitigated and monitored. In addition the EMP assigns responsibilities of actions to various actors and provides a timeframe within which mitigation measures and monitoring can be done. The EMP is a vital output of an Environmental Impact Assessment as it provides a checklist for project monitoring and evaluation. The EMP outlined below will address the identified potential negative impacts and mitigation measures of the proposed project based on the chapters of Environmental Impacts and Mitigation Measures of the Negative Impacts.
Pre- construction & Construction Phase EMP
The necessary objectives, activities, mitigation measures, and allocation of costs and responsibilities pertaining to prevention, minimization and monitoring of significant negative impacts and maximization of positive impacts associated with the construction phase the proposed project are outlined below.



Expected Negative Impacts
Recommended Measures
Responsible Party
Time Frame
Cost (Kshs)
Run off and soil erosion
§  Create storm water management practices, such as piping systems or retention ponds or tanks, which can be carried over after the building is complete
Proponent & Contractor
Throughout construction period
50,000
§  Apply soil erosion control measures such as leveling of the project site to reduce run-off velocity and increase infiltration of storm water into the soil.
Proponent & Contractor
Throughout construction period
10,000
§  Ensure  that construction vehicles are restricted to existing graded roads to avoid soil compacting within the project site.
Proponent & Contractor
Throughout construction period
§   
Solid waste generation







































§  Through accurate estimation of the sizes and quantities of materials required, order materials in the sizes and quantities they will be needed, rather than cutting them to size, or having large quantities of residual materials
Proponent & Contractor
Throughout the construction period
20,000
§  Ensure that construction materials left over at the end of construction will be used in other projects rather than being disposed of.
Proponent & Contractor
Continuous
5,000
§  Provide facilities for proper handling and storage of construction materials to reduce the amount of waste caused by damage or exposure to the elements
Proponent & Contractor
Continuous
20,000
§  Use building materials that have minimal or no packaging to avoid the generation of excessive packaging waste.
Proponent & Contractor
Throughout construction period
-
§  Use construction materials containing recycled content when possible and in accordance with accepted standards 
Proponent & Contractor
Throughout the construction period
-

§  Reuse packaging materials such as cartons, cement bags, empty metal and plastic containers to reduce waste at the site
Proponent & Contractor
Throughout the construction period
-
§  Dispose waste more responsibly by dumping at designated dumping site or landfills only; the use of a registered waste disposal company is encouraged
Proponent & Contractor
Throughout the construction period
100,000
Air/Dust pollution
§  Ensure strict enforcement of on-site speed limit regulations
Proponent & Contractor
Throughout the construction period
5,000
§  Avoid excavation works in extremely dry weathers
Proponent & Contractor
Throughout the construction period
-
§  Sprinkle water on graded access routes each day to reduce dust generation by construction
Proponent & Contractor
Throughout the construction period
10,000/Month
Noise Pollution 
§  Sensitize construction vehicle drivers and machinery operators to switch off engines of vehicles or machinery not being used.
Proponent & Contractor
Throughout the construction period
10,000
§  Sensitize construction drivers to avoid gunning of vehicles engines or hooting especially when passing through sensitive areas such as churches, residential area and hospitals
Proponent & Contractor
Throughout the construction period
1,000
§  Ensure that construction machinery are kept in good condition to reduce noise generation
Proponent & Contractor
Throughout the construction period
10,000
§  Ensure that all generators and heavy duty equipment are insulated or placed in enclosures to minimize ambient noise levels.
Proponent & Contractor
Throughout the construction period
10,000
Depletion of energy resources
§  Ensure electrical equipment, appliances and lights are switched off when not being used
Proponent & Contractor
Throughout the construction period
-
§  Install energy saving fluorescent tubes at all lighting points instead of bulbs which consumer higher electric energy
Proponent & Contractor
Throughout the construction period
50,000
§  Ensure planning of transportation of materials to ensure that fossil fuels (diesel, petrol) are not consumed in excessive amounts
Proponent & Contractor
Throughout the construction period
10,000
§  Monitor energy use during construction and set targets for reduction of energy use.
Proponent & Contractor
Throughout the construction period
5,000
Exploitation of water resources





§  Promptly detect and repair of water pipe and tank leaks
Proponent & Contractor
Throughout the construction period


10,000
§  Ensure taps are not running when not in use
Proponent & Contractor
Throughout the construction period
1,000

Ignorance
§  Provisions must be put in place for the formation of a Health and Safety Committee, in which the employer and the workers are represented
Proponent & Contractor
Continuous 
5,000
Injuries caused by machineries and equipments










§  Ensure that machinery, equipment, personal protective equipment, appliances and hand tools used in construction do comply with the prescribed safety and health standards and be appropriately installed maintained and safeguarded
Proponent & Contractor
Continuous 
-
Poor storage of materials
§  Ensure that materials are stored or stacked in such manner as to ensure their stability and prevent any fall or collapse
Proponent & Contractor
Continuous 
10,000
Emergencies
§  Design suitable documented emergency preparedness and evacuation procedures to be used during any emergency
Proponent & Contractor
Continuous 
200,000
§  Provide measures to deal with emergencies and accidents including adequate first aid arrangements
Proponent & Contractor
Continuous 
50,000
Pollution
§  Ensure that workers at the excavation sites and other dusty sites are adequately protected from inhalation of substantial quantities of dust through provision of suitable protective gear (e.g. nose masks)
Proponent &
Contractor
Continuous
100,000
§  Provide workers in areas with elevated noise and vibration levels with suitable ear protection equipment such as ear muffs
Proponent &
Contractor
Continuous
50,000
§  Suitable overall, safety footwear, dust masks, gas masks, respirators, gloves, ear protection equipment e.t.c should be made available and construction personnel must be trained to use the equipment
Proponent &
Contractor
Continuous
100,000
§  Ensure that construction workers are provided with an adequate supply of wholesome drinking water which should be maintained at suitable and accessible points
Proponent &
Contractor
Continuous
5,000/ month
Sanitary












§  Ensure that conveniently accessible, clean, orderly, adequate and suitable washing facilities are provided and maintained in within the site
Proponent &
Contractor
Continuous
5,000
§  Provide and maintain adequate and suitable accommodation for clothing not worn during working hours for construction employees 



Proponent &
Contractor
Continuous
5,000
§  Provide and maintain, for the use of all workers whose work is done standing, suitable facilities for sitting sufficient to enable them to take advantage of any opportunity for resting which may occur in the course of their employment
Proponent &
Contractor
Continuous
5,000
Accidents caused by Hand tools
§  Hand tools must be of appropriate size and shape for easy and safe use
Proponent &
Contractor
Continuous
-
§  Height of equipment, controls or work surfaces should be positioned to reduce bending posture for standing workers
Proponent &
Contractor
Continuous
-

Operational Phase EMP
The necessary objectives, activities, mitigation measures, and allocation of costs and responsibilities pertaining to prevent, minimization and monitoring of significant negative impacts and maximization of positive impacts associated with the operational phase the proposed project are outlined in the table below.
Objective/Plan
Recommended Mitigation Measures
Responsible Party
Monitoring Mechanism
Cost (Kshs)
Health and Safety Risks
§  Implement all necessary measures to ensure health and safety of workers and the general public during operation of the proposed wetland project as stipulated in Factories and Other Places of Work Act Cap 514

Continuous
2,000
Safety and security of the premises and surrounding areas
§  Ensure the general safety and security at all times by providing day and night security guards and adequate lighting within and around the premises during night hours
Proponent

Continuous
20,000/month

Decommissioning Phase
In addition to the mitigation measures provided in two above tables in this chapter, it is necessary to outline some basic mitigation measures that will be required to be undertaken once all operational activities of the proposed project have ceased. The necessary objectives, mitigation measures, allocation of responsibilities, time frames and costs pertaining to prevention, minimization and monitoring of all potential impacts associated with the decommissioning and closure phase of the proposed project are outlined in the table below.
Environmental Impact
Recommended Mitigation Measures
Responsible Party
Time Frame
Cost (Kshs)
Solid Waste Generation
§  All buildings, machinery, equipment, structures and partitions that will not be used for other purposes must be removed and recycled/reused as far as possible.
Contractor 
Continuous
100,000
§  All foundations must be remover and recycled, reused or disposed of at a licensed disposal site
Contractor 
Continuous
200,000
§  Donate reusable demolition waste to charitable organizations, individuals and institutions
Contractor, Proponents
Continuous
-








Cost of the wetland (estimates)
The costs for each of the parts are listed below. Onetime fee
Cost
Design
Ksh 829,000 or more
Construction
Ksh 3,260,000
Permits
Ksh 416,000
Total
Ksh 4,176,000
Maintenance
Ksh 60,000 per year










Questionnaire

Technical analysis: Is building a wetland to clean part of the water of the Njoro River to WHO standards for irrigation technically feasible?
a. Is the soil at the project site suitable for building a wetland?
Yes
b. Is the water of the Njoro River suitable for building a wetland?
Yes
i) How much water and at what rate is flowing in the river?
Rate suitable. More research on hydrology is required.
ii) What is the level of pollution of the water?
Treatment possible
c. Is the site topographically suitable for building a wetland?
Needs adjustments
i) Is the site big enough?
Yes
ii) Is the terrain profile suitable?
Needs some adjustments
d. Is the site environmentally suitable for building a wetland?
Yes
i) Is the climate suitable?
Yes
ii) Is the local flora suitable?
Yes
iii) Is the local fauna suitable?
Yes
e. Can the wetland be maintained and supervised?
Yes

i) What parties are willing to maintain the wetland?

Parties available

ii) Do these parties have the required skills?

Some capacity building is necessary

iii) How can the continuity of the maintenance be guaranteed?

Management by the University administration
Social analysis: Is building a wetland for to clean part of the water of the Ngong River to WHO standards for irrigation socially feasible?

a. Will the community support the wetland?

Yes

b. Will the government support the wetland?

More detailed information on design, feasibility and environmental impact are needed prior to consideration by government agencies.

c. Will other parties that can compromise feasibility support the wetland?

Yes, based on increased water quality.



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