Lake Natron: A summary of the major discussion points at the NEMC Technical Committee to review the ESIA for a Soda Ash Factory

The National Environment Management Council (NEMC) organized a technical committee meeting on Friday 2nd November 2007 at the Luther House Conference Room in Dar es Salaam. The technical committee was convened to review and hear inputs from stakeholders about the Environmental and Social Impact Assessment (ESIA) that has been carried out for the development of a Soda Ash Facility on the north-eastern shore of Lake Natron. NEMC stated on 5th November 2007 that a full stakeholder consultation meeting would be held - please see the newspaper article of 6th November 2007 below. It seems for now that the Soda Ash Factory development is in the balance, not least due to the strong reservations expressed at the Technical Committee Meeting. An unoffical summary of some of the many points raised at the meeting is provided below:

i. The ESIA discloses insufficient information about the hydrological impacts and implications of the factory on the lake and its surrounds. ii. The reproductive ecology of the Lesser Flamingo remains poorly understood - particularly since Lake Natron is by far the most important breeding site for the species. Much more information is required before a sufficiently informed decision can be made in terms of risking the potential impact of the factory on breeding success. iii. That a full cost-benefit analysis of the factory's construction hasnot been carried out, particularly in terms of evaluating the benefitsaccruable to the nation, local communities and the private sector compared to the continuation/development of existing land use practices as well as environmental costs associated with the proposed development. iv. The consideration of alternatives is weak and in particular,

a. an alternative location, b. alternative processes and c. the "no - project" alternative.

v. Stakeholder consultation was weak and in some cases, stakeholders across the border were not sufficiently consulted. In particular the issue of the Ewaso Ngiro River and its impact was raised. Stakeholders cautioned NEMC that Kenya had not abolished the project, but it had been simply put on hold. It was noted that if the Natron Soda Factory Project was pushed ahead without sufficient involvement and agreement of Kenya, probably the Ewaso Ngiro Dam Project would be revived and it would not only have a substantially adverse impact on the ecology of the whole Lake Natron ecosystem but also on the Soda Ash Factory Project. vi. Stakeholders requested the ESIA team to revisit their stakeholder consultations and ensure that their views are integrated in the report vii. It was also noted that the EIA report lacked sufficient analysis of cumulative effects arising from the proposed Soda Factory development, ancillary activities and several on going plans and programmes including road construction and oil exploration in the area, on tourism, wildlife management and livestock keeping and agriculture. The impacts of the proposed industrial and infrastructural developments on land use, energy and water were argued to have not been adequately addressed in the ESIA. viii. Technically, meeting participants observed that the ESIA report is weak in several areas including its impact analysis for key issues. Several of the highlighted impacts are concluded as being moderate even when the analysis in the detailed text shows these to be critical issues. Moreover the basis for determining the level of impacts is not explained adequately in the ESIA report. ix. The ESIA report is silent about monitoring of issues including about parameters for monitoring, indicators, frequency and reporting requirements and standards upon which monitoring can be based upon. x. Also, issues were raised regarding the fact that the area is a Ramsar site. According to the Ramsar Convention, such areas must be used wisely - namely following principles of sustainable utilization of wetland resources. A question was posed: ‘Will the proposed development would lead to wise use of the wetland resource in compliance with the Ramsar Convention?' xi. It was also noted that the quoted figure of tourism earning in the area (of US$ 500,000 per annum) was too low and perhaps underestimated in order to project huge economic benefits arising from the proposed development - only indicated in terms of millions of US$. Stakeholders called for fresh assessment of the actual monetary values.

Almost all stakeholders agreed that the report was inadequate and that in its current status, it could not be used confidently to assist the Minister to make a balanced and sufficiently informed decision about the project. It was apparent that more work, more information - particularly in terms of the hydrological balance of the ecosystem, and a more thorough cost-benefit analysis - was needed before decisions could be made on the next course of action. A recent press article can be obtained here (East African Newspaper article on Lake Natron 02-11-07) The Environmental and Social Impact Assessment for the construction of a Soda Ash Factory at Lake Natron is now available for download (below):