ENVIRONMENTAL IMPACT ASSESSMENT (EIA) FULL STUDY FOR THE PROPOSED GOLF RESORT WITHIN ENONKISHU, NAROK DISTRICT

Fig. 1: Proposed houses around the golf course will be built along the lines of the above cottages, in Olerai, using local materials

PREPARED BY: Elizabeth Nzani Wachira (Lead EIA/EA Consultant) P. O. Box 21212, 00505 Nairobi Email: info@ecoplankenya.com Telephone: 020-2424114, 020-3570075

Proponent: Olerai Ltd. Management. February 2012

TABLE OF CONTENTS
SIGNATURES: EXECUTIVE SUMMARY 1 INTRODUCTION AND BACKGROUND Tourism Sector in Kenya Tourism’s Impact on the Environment 1.1 Terms of Reference 1.2 Project Proponent Identification 1.3 Objectives and Scope of the Proposed Project IV IV 1 1 2 3 3 3

1.3.1 Objective of the Proposed Project 1.3.2 Scope of the Proposed Project 1.3.3 Total Cost of the Project
1.4 1.5 Project Activities EIA Approach and Methodology

3 4 4
4 5

1.5.1 Phase 1: Desk Top Study 1.5.2 Phase 2: Site Walk Assessment Survey 1.5.3 Phase 3: Stakeholder Consultation Meeting and Questionnaire Administration 1.5.4 Phase 4: Environmental Impact Assessment (EIA) Study Report Preparation
2 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 3 3.1 3.2 3.2.1 3.2 3.3 3.4 3.5

5 6 6 7

REVIEW OF ENVIRONMENTAL POLICY, INSTITUTIONAL AND LEGAL FRAMEWORK AND COMPLIANCE 9 Environmental Management and Coordination Act (EMCA) 9 The Water Act, 2002 11 Water Quality Regulations, 2006 13 The Land Planning Act, CAP 303 14 The Physical Planning Act, CAP 286 14 The Local Government Act, CAP 265 16 The Public Health Act, CAP 242 17 The Factories and Other Places of Work Act (CAP 614) 18 PROJECT LOCATION AND PHYSICAL ENVIRONMENT Location of Proposed Project PHYSICAL ENVIRONMENT Climate, Topography, Geology and Hydrology .2 Biodiversity Vegetation Threat to biodiversity Description of the Biophysical Environment 20 20 21 21 22 23 23 24

3.5.1 Climate 3.5.2 Physiography 3.5.3 Drainage
3.5.4 WATER RESOURCES AND QUALITY

25 25 25
25

3.5.5 Soils 3.5.6 Vegetation
3.5.7 WILDLIFE

26 26
26

3.5.8 The Mara River 3.5.9 Maasai Culture and Community

27 28

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3.6

Biological Environment

29

3.6.1 General 3.6.2 Flora 3.6.3 Fauna
4 4.1 PROJECT DESCRIPTION AND BASELINE EVALUATION PROJECT DESCRIPTION

29 29 29
30 30 30 32

4.1.1 GOLF COURSE 4.2 Neighbouring Property Use

4.2.1 Existing Land use Practices
4.2.2 EXISTING INFRASTRUCTURE ON THE FARM

32
32

4.2.3 Community
4.3 4.4 4.5 Pre-Construction Activities Site Alteration during Construction Construction Activities

33
34 35 36

4.5.1 Construction Materials 4.5.2 Construction Supervision
4.6 4.7 4.8

36 38

Provision of Security to Workers and Tourists 39 Facilities and Services to be provided at the Golf Resort 40 Special Facilities for Solid and Liquid Waste/Effluent Handling and Disposal at the Golf Resort 41 4.9 Facility Operation and Maintenance 42 4.10 Power Provision for the Proposed Resort 43 4.11 Water Provision for Proposed Resort 43

4.11.1 4.11.2 4.11.3

Surface Water Abstraction from Mara River Water Use Conservation at the resort Annual Environmental Audit

44 44 44
44 45 46

4.12 Diseases and Disease Vectors of the Project Area 4.13 Socio-Economic Environment 4.14 Infrastructure Facilities

4.14.1 Proper infrastructure is essential in ensuring that visitors and service providers are able to offer their services and also enjoy their stay in this remote area. 46 4.14.2 Telecommunication 46 4.14.3 Roads 46 4.14.4 Airstrips 47 4.14.5 Water 47 4.14.6 Electricity Supply 48
4.15 4.16 4.17 4.18 4.19 Location of Nearest Fire and Police Response Teams Demographic Characteristics Land Tenure Employment Opportunities and Operations Stakeholder Consultations 48 48 49 50 50

4.19.1 4.19.2 4.19.3 4.19.4 4.20.1 4.20.2

Purpose of Stakeholder Consultation Mode of Stakeholder Consultation Stakeholder Consultation Results Consulted Stakeholders Alternative to a Golf Resort Facility Alternative to Site
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50 50 51 52
53

4.20 Analysis of project alternatives

53 53

4.20.3 4.20.4 4.20.5
5 5.1 5.2

Alternative to Design Alternative to Energy Source The “No Project” alternative

54 54 55
56

4.21 Project Lifespan and Decommissioning

POSITIVE AND POTENTIAL NEGATIVE ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES 57 Positive Impacts 57 Potential Negative Impacts 59

5.2.1 Potential Impacts of Construction Activities 5.2.2 Potential Impacts from Operation Activities
6 6.1 6.2 7 7.1 ENVIRONMENT MANAGEMENT PLAN Environmental Monitoring Plan Internal Audit (Environmental Operation Survey) CONCLUSIONS AND RECOMMENDATIONS Conclusion

59 59
74 74

6.1.1 Sound Environmental Monitoring

74
75 78 78

7.1.1 Positive Effects 7.1.2 Potential Negative Effects
7.2 7.3 Project Evaluation for Recommendations Project Recommendation

78 79
79 81 83 85

APPENDICES REFERENCES

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SIGNATURES:

The Proponent: ..............................................................

Date: .............................................................................

EIA Consultant Elizabeth Nzani Wachira (Lead Expert) Reg. No. 0848

.....................................................................................

Date: ............................................................................

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EXECUTIVE SUMMARY Introduction and EIA Study Approach Introduction This Environmental Impact Assessment (EIA) Full Study has been carried out on behalf of Olerai Ltd with respect to the proposed development of a golf resort next to the Enonkishu Conservancy in Narok District. The proposed name for the development is Naretoi. A Project Report for the same project was submitted to NEMA in May 2009. In January 2012 NEMA reverted to the Proponent with the request that a Full EIA Study be carried out. This report is a response to the NEMA request. Study Approach In accordance with the Environmental Management and Coordination Act (EMCA) 1999, environmental impacts have been assessed and proposals for mitigation measures and monitoring plans prepared with regard to the construction, operation and decommissioning phases of the Proposed Development. EIA Study Legislation The Study has been conducted in accordance with the following legislation:  The Environmental Management and Coordination Act (EMCA) 1999  The Water Act 2002  The Land Planning Act CAP 300  The Local Government Act CAP 265  The Public Health Act CAP 242  The Factories and Other Places of Work Act CAP 614  The Wildlife (Conservation and Management) Bill 2009  GOK’s Wetlands Policy  GOK’s Wildlife draft policy 2006  Vision 2030 This study was carried out through desk and field investigations. The Consultants conducted extensive literature review pertaining to the current study. During field investigations, a reconnaissance survey was conducted
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to gather information on biophysical and socio-economic aspects of the area and its environs. This EIA Report comprises the following fourteen main sections: 1. Executive Summary 2. Introduction 3. Review of environmental policy, Institutional and legal framework 4. Description of Proposed Project 5. Description of the Environment 6. Significant Positive and Negative Environmental Impacts 7. Analysis of Project Alternatives 8. Mitigation Measures (Mitigation Management Plan) 9. Environmental Monitoring Plan 10. Stakeholder Consultation and Involvement 11. Conclusions and Recommendations 12. List of People Contacted During the EIA Study 13. List of References 14. Appendices Origin of idea of developing a golf resort within Enonkishu Conservancy, Narok County Council Since the year 2000, the Proponent (Olerai Ltd.) has carried out intensive pivot-irrigation farming in Olerai. This has had varying degrees of success over the years. The Olerai Ltd Management, however, has always felt that agriculture is not the best use of the land, hence the desire to utilize the said land for wildlife conservation and environmental management purposes. It is for this reason that Olerai Ltd intends to enhance tourists’ game viewing possibilities by creating a Conservancy in the area (Enonkishu Conservancy) surrounding the proposed golf resort. This proposed Conservancy has submitted a Management Plan to NEMA reference Number MP 004 . It is anticipated that this will take considerable pressure off the Maasai Mara National Reserve as tourists will be offered alternative activities like golf and tennis from the traditional game viewing. Revenue earned from golf-playing tourists will go towards sustaining the Conservancy. Maasai from nearby manyattas (Maasai villages) will benefit from an increased job market at the golf resort. In addition, Olerai
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Ltd. have taken it upon themselves to work closely with the Maasai in better herd-management. This will help reduce over-grazing as well as make the herds stronger and better able to survive drought with improved grazing management. This EIA Full Study has several objectives, the three main ones being To carry out an EIA Full Study and obtain the requisite NEMA approvals;  To ensure that there is no significant opposition to the proposed project, and to clearly illustrate how any negative impacts shall be mitigated;  To ensure that all development is done in a sustainable manner in line with the Environmental Management Plan which shall result from this EIA study. The proposed Naretoi Golf Resort The proposed Golf Resort activities will mainly involve civil works associated with construction and operations of:  Reception Offices  a central club house, swimming pool and ancillary buildings with 16 accommodation units, built in the first phase.  an 18-hole golf course and tennis courts  A cricket pitch  An air strip  The construction of 80 units of lodge style real estate built in 8 phases. Phases 1-7 will be 46 houses, then phase 8 will comprise of a golf course and additional houses if the market allows.  Staff Houses  Parking area for approximately 20 cars  Waste water and Storm water management and recycling facilities  Protective Guard Rail on the Mara River side of the camp  Perimeter wall electric fence  A Dam  Stables and a Bush Polo Pitch  Access all-weather murram road network

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The projected cost of the project is USD15m. This includes shaping and construction of the golf course and first phase infrastructure. In conducting the Environmental Impact Assessment, the study team has ensured compliance with the Environmental (Impact Assessment and Audit) Regulations, 2003, the Environmental Impact Assessment draft Guidelines, the EIA guidelines for the tourism sector and the World Bank Environmental Assessment guidelines. The Environmental considerations evaluated on the proposed development include: Ecological Considerations (biological diversity, sustainable use and ecosystem maintenance), Social Considerations (economic impacts, social cohesion or disruption, effects on human health, immigration or emigration, communication and effects on culture and objects of cultural value), Landscape Considerations (views opened up or closed, visual impacts, compatibility with surrounding areas and amenity opened up or closed) and Land Use Considerations (water sources, effects of proposal on surrounding land uses and land use potentials and possibility of multiple uses). In order to alleviate any negative impacts emanating from the construction and operation activities of the proposed development, relevant and cost effective mitigation measures have been proposed. The disposal of human sanitary waste is going to be done through well constructed sewage lines and septic tanks located in all areas (guest houses, staff quarters, lounge/dining, kitchen and recreation area – swimming pool). Biodigesters and constructed wetlands will form an essential part of water management at the resort, with a resultant 65% of water being recycled for use on the golf course and secondary piping system for the resort, reducing demand and reliance on existing water bodies. See Annex 3 for detailed information on Biodigesters. All solid waste shall be collected and disposed of at a designated area using appropriate waste bins with lids. These shall then be regularly collected by an appointed waste disposal firm that shall transport it away from the golf resort for disposal following NEMA and Local Authority regulations on waste collection, handling and disposal. Site Location
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The proposed site is located next to the Mara river, approximately 50 kms to the north west of the Maasai Mara National Reserve (MMNR). Across the river is the Trans-Mara, and Chepalungu Districts. The area is largely composed of black cotton soil that overlies metamorphic rock formation, which is predominant in the area. Conspicuous outcrops of the rock formation is evident along the Mara River basin. Olerai Ltd management are keen on alternative land use to replace intensive farming that in the opinion of the environmental consultants and the Proponent themselves is degrading the environment. The Olerai management recognises the need to sustainably conserve the area for posterity by abandoning farming and embracing environmentally sound and eco-friendly golf tourism. Adoption of Golf tourism will ensure restoration of a greater part of the land to its natural state and attract golf loving tourists nationally and internationally. The revenues realized will not only improve the national economy but will also enhance the local economy and contribute towards sustained livelihoods of the local Maasai communities.

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Fig. 2: Access road to the existing facilities within the proposed site for the Golf Resort

Site History and Present Status The proposed area is currently being farmed by Olerai Ltd. The farm has been operational since 2001. Currently, the farm is under intensive agricultural production of maize, wheat, and French beans for export. Olerai Farm Ltd is located 87 km from Narok town off the Narok-Bomet Road, 30 km past Molot. It is in the Narok district. The closest town near the farm is Emarti which has a population of 20,000 people, about 3 kms away. The farm is securely fenced and is divided by a government road. This road connects the farm to the main Narok-Bomet road and is being largely maintained by the farm. The neighbouring farms are the wheat growing estate Shimo Ltd, another large scale irrigation farm and the Ntutu family.

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The project has 1,300 acres of farmland, of which 700 acres are currently under pivot irrigation. Irrigation on these fields is through a computerised central pivot irrigation system. The 700 acres is divided into 5 centre pivots which vary from 86 – 172 acres per centre pivot. The rest of the farm is natural bush land or shrubbery. Much of this has been left intact, although more trees have been planted. In addition, the farm’s management is committed to environmental conservation and has planted over 100,000 trees which are in different stages of maturity. These are planted to try and create an alternative fuel source from the local bush. Olerai has already started creating charcoal and firewood for sale to camps and lodges in the Maasai Mara. This is reducing the amount of illegal charcoal and firewood being cut in the area. In addition these trees will be used as timber for building once the project starts. This project gives a historical evaluation of environmental values and how these values influence wildlife conservation and the development of naturebased tourism. Olerai farms are also associated with World Wildlife FundWWF as corporate members and are active participants of Mara River Water Users Association of which Hugo Wood, the founder and owner of Olerai, is the Chairman. In conjunction with the WWF, the farm is involved in watershed management in the Mau forest and its surroundings, which has been overexploited. Olerai also own the Tree Education and Planting Advisory Centre (TEPAC) in Ololunga which aids environmentally aware landowners in choosing the correct and appropriate varieties for their land. Through tree seedling development, education and tree planting initiatives the programme is geared towards preserving and afforesting the Mau watershed. Olerai has also started educating the next generation about the importance of indigenous trees by donating trees every year for the past 4 years and planting at the local schools. The proposed site area is generally dry and exhibits a semi-arid type of climate. However the Mara River is perennial and contains water throughout. The proposed site and its immediate environs along the Mara River bank is conspicuously green and generally flat with a moderate to steep slope towards the river. Large trees with moderate to thick flora cover the immediate vicinity of the site providing a cool forested appearance.

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The Mara River is significantly wide at the site location but narrows further downstream with bedrock exposures on the river bed. The vegetation around the site area is largely composed of various flora including river acacia (Acacia Xanthlophoea and Ficus sycomorus (fig tree) closer to the river valley basin.

Facility Structure (Source and Use of Construction Materials) Source of Construction Special construction materials including various fittings, basins and equipment shall be sourced from Nairobi while others including stones, sand, cement etc shall be sourced locally to promote local business. Structure Foundation Floors The Basement System Bedrock at this site is relatively shallow with outcrops conspicuously exposed a few metres down stream of the River Mara. The proposed structures will therefore have strong foundations. Walls The walls will be constructed of local stones that will be made to blend with the surroundings. The walls will be composed of random stoned phasing. Roofs All the structures shall be constructed using sisal poles and gum pole trusses covered with grass thatching and IT5 coloured mabati sheets for rainwater collection. Fire retardants shall be used on the thatched roofs to reduce flammability. As a safety measure, pressurised fire hose systems shall be fitted on all roofs. Positive Impacts The proposed resort is envisaged to have the following positive impacts:  A unique “bush golf” experience attractive to local and international golfers;  Availability of a convenient and comfortable tourist facility not too far from the MMNR area with alternative facilities to enjoy;
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 The proposed resort shall contribute in easing the availability of accommodation in the reserve itself thereby opening up the Emarti area, promoting tourism while taking pressure off the main reserve;  The site area where the proposed resort is going to be located has scenic views and the Proponent will make sure that these views are enhanced and protected for the future;  The proposed development shall also create both direct and indirect stable employment opportunities in an area of 82% unemployment (during the construction and operation phases). There shall be approximately 500 members of staff (junior and senior) and there will be other opportunities accruing from the operations through jobs for tourist drivers visiting the resort. The local community of the region shall be given priority when considering job opportunities. At least 50 caddies will be employed.  The facility shall contribute to Government Resources (Mara and Narok County Councils) through game park gate collections from tourists who will also contribute to the generation of revenue from services provided at the resort.  Vision 2030 – the proposed resort will contribute towards the Government’s realisation of high-end tourist attractions, combining sport and tourism, and hence earning the Government increased revenue;  The Proponent undertakes to maintain and improve the site area through maintenance of the indigenous trees during the resort’s development to enhance the scenic beauty of the semi arid area and enhance its biodiversity;  The project will start and operate the Enonkishu conservancy, a 24,000 acre conservancy which is currently being severely degraded. The most recent incident occurred on 13 March 2012 – 5 elephants were poached in the area. If the project had been operational not only would these elephants not have been brutally killed, but the Conservancy would protect the elephants’ natural ecosystem where they would flourish.  The project will help to sustain the river water levels. Olerai farm extracts significant volumes of water (upto 6000 cubic meters) from the river, these volumes are increased in the dry season, when the river is most vulnerable, to irrigate the crops.  The resort will generate the possibility of local farmers providing their produce to the resort and hence generating some income for the local farming community.
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Potential Sources of Negative Impacts Construction Activities During the construction phase, sources of negative environmental impacts may emanate from the site preparation activities including:  Excavation of soils and other geological formations;  Levelling of landscape and subsequent construction activities;  Generation of domestic waste by workers and construction material waste;  Inappropriate construction working hours that could affect wildlife and security of workers. The construction activities will have varying negative impacts on the biophysical environment, which includes disturbance of topsoil with possible soil erosion and siltation. However, these can be considered minor since the proposed design and construction standards shall be high and geared at mitigating any possible negative effects. The Proponent proposes to reduce any disturbance to soil and vegetation to a minimum by accommodating a majority of the site features during construction and maximising harmony between the proposed structures and the current environment. Solid and Liquid Waste Generation and Disposal (During Construction) The proposed golf resort is expected to generate several types of waste during construction. These shall include the following: Domestic Waste from the Construction Camp – The workers are expected to generate domestic waste from their regular upkeep. This is expected to occur within the site area and in the immediate vicinity. The management of such waste will need to be incorporated in the Construction Phase Site Management Plan by the Contractor as proposed in this report. Other forms of waste include sanitary waste. The provision of toilets will therefore need to be considered both for the site construction workers and any visiting population. Site Construction Waste –The project will generate waste from the site construction activities. This shall include excavated soil that will require
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proper handling and disposal, site waste materials including wood and other raw material, container wrapping and packaging material and debris, plus left over construction materials. Dust Emission – The construction activities that will take place, particularly during the site excavation process, will generate a considerable amount of dust and other particulates that will need to be arrested. Noise – The contractor vehicles that will come and go to the site, and site equipment/machinery including generators and water pumps are expected to generate noise during the construction phase of the project. The contractor shall be required to use well maintained machinery and vehicles with reduced noise levels. Smoke Emissions – Site machinery and vehicles are expected to generate smoke emissions during construction activities. The contractor shall be required to minimise use or to use well maintained machinery and vehicles with reduced smoke emission. Working Hours The contractor shall be required to observe appropriate construction working hours to avoid interfering with roaming wildlife during late hours.

Solid and Liquid Waste Generation and Disposal (During Operation) Domestic Waste –The daily operations of the facility office will generate waste like paper and other sanitary waste including foodstuff packaging material and food leftovers. It is estimated that during peak occupancy, the resort shall generate an average of between 800 and 1000 Kg of solid waste per month. The waste receptacle shall be located at the service area which should be at least 50m away from the river bank, and at least 50m away from the nearest house. Sanitary waste shall be handled through the resort’s sewerage network and deposited in septic tanks. The septic tanks shall be regularly emptied by an exhauster and taken to the nearest waste disposal site in Narok for appropriate disposal. It is estimated that on average approximately 10m3 of sewage waste shall be generated every day during peak occupancy. The septic tanks shall be located at least 50m away from the river bank.

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Fig. 3: The Mara River is the only perennial river in the Maasai Mara Ecosystem

Smoke Emissions –Tour vans and other vehicles that will be coming to the facility are expected to emit smoke at various levels. Well maintained vehicles shall be used and drivers shall be instructed not to over-rev the engines. Noise –Tour vans and other vehicles that will be coming to the facility and the site equipment (generator and water pumps) are expected to generate noise during the operation phase of the project. These shall require mitigation intervention by observing slow speeds and minimal use of generators and other noise generating machinery. Dust Emission – Tour Vans and other vehicles supporting the operations of the facility shall be potential sources of dust emission since the roads and walkways within the facility shall not be tarmacked. The roads within the facility shall have a gravel finish and all drivers shall be instructed to drive at low speeds (less than 30km/hr) to minimise dust. Roadside signs depicting such instructions shall be strategically positioned.

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Security Provision (During Construction and Operation) The site is located on the fringes of the national reserve and potential security threats from intruders and wild animals are very real. The Proponent shall provide 24-hour security (a minimum of two security guards) on duty throughout the project period (during construction and operation periods). Since no armed security by private citizens is allowed in the reserve or on the reserve’s periphery, the Olerai Ltd management will endeavour to seek security support from the Maasai Mara National Reserve management (Narok County Council) as well as the Kenya Wildlife Service (KWS) during the operation phase of the project. All houses will be fitted with panic buttons, and guests made aware of their presence during orientation. It is anticipated that increased security will put an end to cattle raiding which is fairly common in this area. Source of Water for Construction and Operations The construction and operation of the proposed golf resort including the swimming pools shall require adequate provision of water. The Proponent and the Project Architect have gone to great lengths to incorporate alternative ways of acquiring water for the project, namely through constructed wetlands and through installation of bio-digesters. This means that as much as 65% of water used in Naretoi will be recycled. It is estimated that the resort will require approximately 50 - 70m3 of water every day during peak occupancy. This is much less than what is currently being used for irrigation using the pivot irrigation system (See water abstraction permit, annex 1). Roofing will be designed to allow for rainwater collection. The Proponent will utilize a portion of the already permitted rations for irrigation from the Mara River.

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Observance of Riparian Buffer Distance A buffer distance of 30m away from the River Bank shall be observed for any permanent construction. This shall be necessary to ensure that the river is protected from human activities and also river flooding does not affect any developments and put human life at risk. The project Architects shall ensure civil works take into account river bank stabilisation through use of gabions. Environmental Management Plan The environment where the proposed golf resort will be located has been put to various land uses. A lot of it is virgin bush, while 600 acres is being farmed. This area under farming will be replaced by the proposed golf course, interspersed with eco-friendly housing. Several acres have been used to plant trees for wood fuel. A few acres have been set aside for equestrian activities as an added attraction for the proposed resort. These various land uses require that environmental protection be enhanced to ensure that there are no major adverse effects occurring from construction or operation activities of the proposed golf facility. The proposed golf resort shall comply with the following as per the Environment Management Plan (EMP):  The proposed resort shall be constructed while ensuring minimal disturbance is caused to the existing exotic vegetation by ensuring that where possible existing trees are incorporated as part of the facility development.  The proposed resort shall leave a buffer distance of at least 30m away from the banks of Mara River to ensure that there is no interference with the flow of the river during construction and operation activities and also that should the Mara River flood, the whole infrastructure shall be safe.  Water recycling is being given priority with as much as 65% of water being recycled through use of constructed wetlands and biodigesters. All natural flows shall be respected and left intact.  Any soils that are disturbed during construction are carefully handled to minimise erosion and siltation of the Mara River. To this end, the banks will be carefully managed and stabilised through use of gabions.

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 All domestic and construction material waste is put together during construction and later collected at proper intervals (to avoid impact to the largely virgin environment) and appropriately disposed of.  Sanitary facilities with septic tanks shall be provided to cater for staff during the construction period.  A guided septic tank exhausting programme shall be put in place to collect all generated sewerage waste during construction and operation phases.  Use of solar power shall be maximised, with generators only being used on a stop-gap basis. Wind power shall be investigated and heat exchanges shall be effected (e.g. kitchen heat diverted to heat the swimming pool).  Annual environmental auditing and monitoring will be undertaken to ensure continual improvements. Environmental Monitoring All potential significant negative impacts associated with the proposed resort that could emerge shall be monitored during the construction and operation phases to ensure that they are eliminated or reduced to a minimum. Several potential negative environmental impacts that may be introduced by the proposed resort and which would therefore require monitoring, include the following:

Solid and Liquid Waste Handling and Disposal The proposed golf facility shall have solid and liquid waste generated during the entire project cycle (construction and operation periods). The Proponent shall be required to put in place a monitoring schedule to ensure that the handling and disposal mechanism of the generated waste is effective. This shall include:  Regular checking/monitoring of the sewerage lines and the septic tanks is done to ensure that they are working effectively without any overflows and failures occurring especially during the peak periods.  The schedule of emptying the septic tank is followed without lapses/failure and that the response time for any need to empty the septic tank earlier than the required schedule is achievable to alleviate any disastrous overflows occurring.
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 Solid waste generated during construction and operation phases has the potential of impacting the environment and affecting any wildlife coming close to the golf facility. It shall therefore be important to monitor the handling and disposal mechanism of all the solid waste generated in terms of handling, storage and collection for appropriate disposal. This is particularly important when considering that there may be a possibility of waste (from the resort operations and tourists alike) including plastic materials (wrappings, packaging material or containers) being released to the environment if not properly contained. Groundwater and Mara River Water Resources  The most sensitive receptor within close proximity to the proposed site is groundwater and the Mara River which is perennial, and serves as a water source for human population, livestock and wildlife alike. It is therefore an important resource that requires protection from any impact. Quarterly water quality monitoring in terms of quantity and quality shall be instituted to ensure that the advent of the golf recreational facility does not affect the quality of the river or groundwater. Interference with its natural existence shall be brought to a minimum both during construction and operation phases. Wildlife Habitat  The site area where the proposed golf resort is going to be developed is approximately 50 kms from the Maasai Mara National Reserve. The site provides a wildlife dispersal area where a variety of herbivores and carnivores exist. The emergence of the golf facility and increased human and vehicle traffic shall necessitate environmental monitoring through an annual Environmental Audit to establish any changes requiring mitigation measures. However without any tourists paying to see the wildlife this area would become totally decimated from the advance of agriculture and human disturbance. Analysis of Alternatives During the course of formulating the proposed project, several project alternatives were considered to ensure that the best option of project development was adopted. Alternatives with respect to the project from the Environmental and Socio-Economic perspectives are discussed in this section. This includes a discussion on the project activity alternatives and the
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project design alternatives. The project alternatives considered include the following:

The ‘No Action’ Alternative Without the proposed development, the area would continue to be impacted by anthropogenic and natural factors. The alternative of having no resort constructed would mean that the locality would remain as it is - an intense agricultural farm, with soils that are difficult to cultivate. Looking at the current status of the site area, the pivot irrigation consumes a lot of water. In addition, experimental farming of Jatropha curcus has not been successful. An alternative land-use with better socio-economic benefits would be better than what is currently happening. The Proponent undertakes to maintain existing biodiversity and to improve any affected areas by planting indigenous trees and maintaining the landscape thereby enhancing the entire habitat of the area. The alternative of not having the project would deny the local population of increased employment opportunities, increased market for their products and exacerbate continued declining livelihoods. There would be a status quo in accommodation for visitors if the no project alternative is adopted and the country would lose the much-needed economic gains. Moreover, with pressure on the country to produce an exciting new tourism product, other than the traditional beach and wildlife tours, the “no action” alternative would deny Kenya the opportunity of coming up with a new and fresh tourism alternative. From a socio-economic perspective the “no action” alternative is not the best alternative as the numerous environmental and socio-economic benefits to be gained from the development both locally, nationally and internationally would not be realised and the resources in the area would continue to be underutilised and even misused through wild-life poaching and illegal charcoal burning, if local people do not realize any tangible benefits.

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Fig. 4: Some of the Mara ecosystem that the project will be protecting through eco tourism and conservation security in partnership with the local landowning community.

The proposed golf resort project alternative The development area for the proposed golf course will see some changes to its environmental attributes (physical and biological). Ecologically there will be a gain of habitat and species diversity in the area due to the rehabilitation of the agricultural land. Drainage patterns, groundwater, surface water and soil quality will be improved. It is worth mentioning that all naturally occurring wetlands will be left intact and will continue to be recharged by the enhanced replanted ecosystem. From a socio-economic perspective the proposed development will contribute significantly to national, regional and local income generation. In addition numerous jobs will be created by the development either directly or indirectly as well as community growth and development for the surrounding communities. A total of 200 landowning families will benefit from leasing their 24,000 acres of land to the Enonkishu Conservancy who will protect the environment through the success of the proposed project.

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Irrigated Agriculture Alternative The area for the proposed development could be converted to more intensive agriculture than what currently takes place if the proposed development is not implemented. The large expanse of land available for development in this area could make it suitable for intense agricultural activity. The current crops grown have relatively low profit margins in comparison to other crops such as the growing of flowers for export. From an environmental perspective, more intensive agriculture (i.e. floriculture) would present more negative impacts due to additional cleared vegetation, higher levels of water abstraction from the Mara River, lost habitat for species which could otherwise occupy the development area, increased use of fertilisers and pesticides leading to possible leaching into the water courses and ultimately the river. Floriculture would bring along with it greenhouses, which would have significant negative environmental impacts. Moreover the area is much too hot to be able to grow flowers without the increased disease pressure and therefore the increased use of pesticides. From a socio-economic perspective considerable revenue could be gained from agriculture through the supply of produce for export. Utilisation for Mining and Quarry Alternative Mining is another alternative for land-use in the development area. Land-use information shows that the site consists mainly of murram with limited opportunity for mining and quarrying. However this option would degrade the area making it unattractive for game viewing and would indeed be a source of negative visual impacts. Pastoralism The land could revert to its old use, that is, pastoralism. Experience has shown though that the tendency of the Maasai to keep large herds of cattle (cattle is wealth to the Maasai) leads to serious over-grazing. From an environmental perspective this is a negative impact as the land is left parched and dry, eventually leading to desertification. Moreover in the
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drought years herds get decimated leaving cattle-owners with very few heads of cattle. Socio-economically, pastoralists stand to benefit from the proposed project as the Proponent intends: a) b) to introduce better farming methods (e.g. inter-breeding) among the Maasai for a stronger, more drought-resistant herd; to work with the Maasai in creating income-generating projects, such as supply to the golf resort of beef and other beef products.

Housing and tourist camp alternative A housing or tourist camp alternative would not degrade the environment as the proposed development is basically an improvement of the existing structures at the site. Moreover the replanting of the area with indigenous species and grass would also have positive effects on the drainage patterns, the soil and significantly improve the microclimate of the project area. From a socio-economic perspective the increased accommodation would mean an increase in the income earnings for the developers, as well as the increase in job creation and income generation for the surrounding communities. Equally important would be the protection of 24,000 acres of the Mara ecosystem which is in danger of being destroyed. Considering the proposed construction design, there is going to be a significant enhancement of biodiversity since the Proponent intends to blend the development with the existing flora by planting indigenous trees. The need for a Recreational Golf Facility Currently there are several tented camps and logdes within the Maasai Mara National Reserve and within the larger Mara ecosystem. Some of these are permanent, others are temporary. The majority are close to the Mara River. At present, the nearest Camp within the site area is Fairmont ( 10 kms away from Olerai), between the Ngerende landing strip and Olerai estate.
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Fairmont hotels are eager to have such a golf course nearby to give their guests an alternative activity between game drives. The proposed facility will provide high end alternative accommodation together with a unique and exciting blend of playing golf in the wild, with game and spectacular views of sweeping plains where an irrigation farm currently lies. It is anticipated that this unusual combination, in a unique, natural environment, will increase the possibility of local and international tourists visiting Naretoi. Energy Source for the facility The Proponent has indicated that priority for energy source shall be ecofriendly (solar panels). This shall significantly reduce smoke and noise pollution that could affect the harmonious habitat/existence of wildlife. Another possible source of energy that could be considered is windmills since it is also eco-friendly. However this is not a common energy source in Kenya and the area being remote would increase maintenance costs. Energy source from generators will only be limited to backup the solar energy during cloudy days, or when the principle energy source fails. This is due to its elevated noise levels and smoke emissions. The Proponent is keen to engage in carbon trading with the aim of making Naretoi as carbon neutral as possible. The conservancy has a large area of forest and by realising the extent of carbon absorption from these forests visitors would be able to offset their carbon foot print based on the fact that their presence in Enonkishu is protecting forests which absorb carbon.

Analysis of Site Area Accessibility The present site location is close to an existing road and can easily be accessed via a government dirt road (C10). There will be need to create more internal roads given the expanse of the proposed project area. There is an airstrip (Ngerende) located about 15kms away from the site which is in usable condition. Naretoi also have their own private landing

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strip which they intend for guests to use once the project becomes operational. Analysis of resort Construction Designs Several options of design have been evaluated and the current adopted design has been considered to blend well with the existing environment. The proposed resort has been designed to have a maximum of 58 units of lodge style real estate, each with an area of between 0.75 of an acre to 1 acre. Given the large area (approximately 600 acres) of the proposed facility, each house shall have sufficient space and privacy. Hence this can generally be considered a low to medium impact facility. As much as possible, locally available materials will be used in construction.

Fig. 5: Stakeholder Consultations between Community Elders, the Proponent and the EIA Consultant

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Fig. 6: Field reconnaissance visit – Opinion leaders from the Community

Consulted Stakeholders During the field investigations, the Consultants held discussions and interviews with several stakeholders including the following: Water Resources Management Authority (WRMA) –Narok Outpost Kenya Wildlife Service – KWS (Narok Conservation Area ) Ewaso Ngiro South Development Authority –Have endorsed the project World Wildlife Foundation.- Have endorsed the project Naibosho Conservancy – Have endorsed the project Olchorro Conservancy – Have endorsed the project Fairmont hotels – the project’s nearest neighbours, have endorsed the project Ministry of Regional Development Authorities – have endorsed the project County Council of Narok and other Government Departments The Chief Park Warden of the MMNR, Narok County Council The District Commissioner, Narok South District The District Physical Planning Officer, Narok South District – have approved the project The District Water Officer, Narok South District Chairman, Enonkishu Conservancy Councillors of Emarti
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The area Chief The Member of Parliament for Narok South Neighbouring tourist facility – approval letter Community-based conservation advisors, and The local Community through several stakeholders’ meetings As will be observed from attached questionnaires (Annex 4), extremely wide consultations have been carried out. The Proponent has worked closely with the Community to the extent that the Community is eagerly awaiting implementation of the project. Minutes of Stakeholder meetings are in appendices (Annex 5). Concerns of Stakeholders The stakeholders contributed their views during a stakeholder’s meeting, through verbal interviews and filling in of questionnaires. The main concerns of the stakeholders were:  Location of facility at safe distance from the Mara River Bank;  There should be no introduction of exotic species of plants during rehabilitation;  The lighting should be regulated to reduce impact on animal behaviour;  Solid waste should be carried away and the use of bio-digesters should be explored;  Management of solid and liquid waste generated by the facility which should be done through properly constructed facilities and well managed collection and disposal procedures;  Increased noise levels from tour van traffic to be controlled;  Air pollution emanating from dust during construction and operation phases to be reduced;  Visual intrusion of project structure if it does not blend with the existing environment;  Security provision for staff during construction and operation phases and the tourists who shall be visiting the facility;

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 There should be Annual Environmental Audits to assess the impact of the facility’s operations on the environment and timely institution of mitigation measures on any observed impacts;  The proprietor should ensure dispersal of visitors by providing a variety of attractions away from the usual/typical park attractions;  The carrying capacity of the ecosystem should be assessed to ensure that it does not overburden the area and impact on biodiversity;  Where feasible as much as possible, the local community should be given priority in job opportunities, supply of locally available produce and entertainment opportunities by being given consideration to have cultural performances. Conclusions and Recommendations Conclusions Arising from the analysis by the Consultant, the proposed project is unlikely to generate any irreversible or permanent negative impacts. The report has provided adequate mitigation measures for the identified temporary impacts. It is therefore recommended that the proposed project be approved provided that the proposed recommendations given below are strictly adhered to. Recommendations In order to alleviate any negative impacts that may emanate from the construction and operation phases of the Camp facility and its affiliate development, relevant and cost effective management and mitigation measures shall be put in place. The following recommendations are proposed: a) Stakeholder Recommendations Stakeholders consulted agreed that the project is beneficial and should be approved to proceed. However, the following should be observed:  The project is fairly large hence to reduce severe impacts on the environment, proper mitigation measures need to be instituted;  The project should blend in with the environment;
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 Mara River should be protected from any negative impacts;  Institute solid and liquid waste management mechanisms that would safeguard the environment;  Local Community should be given priority when employing staff and providing other services like locally available foodstuff and cultural entertainment;  Strictly follow the approved plans during development;  Promote dispersal of visitors to avoid unnecessary or undue congestion at one attraction that would create overloading;  Provide appropriate buffer distance from the Mara River (30m away);  Promote planting of indigenous plant species to provide shade and maintain the existing biodiversity;  Have regular (annual environmental audit) review of the resort’s environment. b) Waste Management Recommendations Solid and liquid waste shall be generated during the project lifespan and has to be managed in such a way that it does not impact negatively on the environment.  Construction of sewerage lines linking all sanitary facilities within the facility to the constructed wetlands and biodigesters;  Empty the septic tanks regularly using an exhauster and disposal should be done away from the resort area (Narok town sewerage facility);  Provision of solid waste bins at every facility within the facility area and emptying these bins into a central waste collection bin that is emptied on call and disposed of away from the resort area (Narok town waste disposal site).  More efficient ways of managing waste will continue to be explored. One possibility is the introduction of a community cooker, which is fuelled by solid waste to create hot plates for cooking. Another possibility is converting combustible waste to heat for central heating systems, particularly in the cold months, or for hot water in showers.

c) Environment Management Plan Recommendations In order to ensure a healthy and safe environment on the proposed site and its environs, a plan for environmental management has to be instituted

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through monitoring. This involves the collection and analysis of relevant environmental data of the site including:  Health and Security provision for workers and tourists;  Fire fighting equipment that is strategically placed for easy access;  Devoted maintenance status of sanitary facilities (sewerage lines);  Safeguard against accidents and observation of occupational safety by all regulations provided by the management of the resort;  following appropriate energy production and use;  Ensuring that water recycling systems work efficiently through the construction of wetlands and installation of biodigesters, and rainwater is collected, limiting the amount of water that would need to be abstracted from the Mara River;  Quantification on amount of waste generated and its management to obtain information for continued improvement in handling and disposal;  Observation of vehicle traffic characteristics and their effect on wildlife (whether they scare away any animals that would have ordinarily existed within vicinity of the resort);  Evaluation of any changes to biodiversity;  Observation on socio-economic and demographic characteristics of the projects life cycle and identification of unexpected environmental impacts; and  Formulation of counter-measures to mitigate the observed unexpected negative impacts and compare them with actual impacts. d) Routine Management Schedules During operation, the proposed facility has to put in place routine management schedules to ensure that all employees, and the responsible officer, are aware of what is required. This includes the following:

Solid waste management through regular checking of waste bins status and emptying them at hourly intervals, every two-hour intervals or more depending on use to avoid overflow. On a daily basis a hotel officer is appointed to be in charge of this task and his/her duty shall include alerting the management on the need to collect the waste from the main waste collection point for disposal away from the reserve. Sewerage waste management through checking several times in a day to ensure that all sanitary facilities are working properly and there are no leakages. The septic tank is also checked daily to monitor its rate of
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filling up in order to inform management when exhausting should be done before overflow occurs. An officer in charge is appointed to periodically examine the river banks to ensure bank stability. An officer in charge of the compound upkeep is also appointed and he/she is to ensure that the compound is well maintained and waste collected for disposal. This is particularly important to safeguard against waste inadvertently being released or blown into the wild and impacting the surrounding environment. The security of the Camp area is regularly monitored and adjustments made to match any challenges.

e) Project recommendations  Construction design to blend in with the environment;  Proposed management of the facility operations (solid and liquid waste handling and disposal) be implemented;  Mitigation measures and monitoring plan that will be put in place be implemented, and  A commitment to carry out an Annual Environmental Audit be implemented. The proposed development is considered an important, new type of tourism product. It is strategic and beneficial in creating the provision of convenient, high end tourism accommodation with the added attraction of golf. Indeed Sport Tourism is a type of tourism the Government of Kenya has been keen to promote for sometime. It is our recommendation that the development be implemented taking into account the proposed Mitigation Measures and Environment Management Plan (EMP).

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1

INTRODUCTION AND BACKGROUND Tourism Sector in Kenya Tourism is a major world industry and one of the fastest growing sectors of global trade. In Kenya, it can be traced back to early 1930s when the first foreign visitors started coming into the country mainly for big-game hunting expeditions which were locally referred to by the Swahili word "Safari" thus its entry into the travel world literature. The main attractions in Kenya are its relatively pristine wildlife in natural habitats, captivating landscapes and expansive beaches. Tourism products in Kenya have been broken down into seven different categories, namely:- Beach, Wildlife, Cultural tourism, Sports tourism, Scenic tourism, Adventure tourism and Specialized tourism which includes educational tourism etc. Tourism’s social, economic and environmental impacts are immense and complex, not least because tourism concentrates on vulnerable natural and cultural sites. Sports tourism is an emerging area of diversification the Government has decided to adopt as a way of attracting niche, high-end tourists. The Government has realised that Kenya’s traditional tourist attractions, that is the parks and the beaches, are not enough if Kenya is to realise the goals outlined in Vision 2030 of increased tourist beds. See publicity brochure on golf developed by the Ministry of Tourism in appendices (Annex 2). Positive impacts arising from tourism include foreign exchange earnings, improved livelihoods through the provision of cash income and employment, cross cultural exchanges, infrastructural development and conservation. Kenya as a Golf Destination The International Golf Travel Writers Association (IGTWA), sister association of IAGTO, the global trade organization of the golf tourism industry, has awarded Kenya as “The Best Undiscovered Golf Destination of 2008”. 107 golf travel writers participated in the voting of this award. For the travelling Golfer teeing off in one of Kenya’s many world class golf courses makes for a perfect break from the normal tourist circuits. Kenya’s
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weather is ideal for golf all year round making it one of the world’s top golfing destinations. Golf is undoubtedly one of the world’s best travelling sports. Golf offers the chance to relax and unwind in a natural environment while participating in a highly competitive and skilled game. For the traveller seeking a diverse range of golf courses, combined with world class standards and service, Kenya is the perfect choice. Kenya’s courses offer international golfing standards and some of the world’s finest designs and landscaping. Kenya’s world famous wildlife is never far away. A round of golf in Kenya can often be a nature walk in itself, with a remarkable profusion of bird life and wildlife surrounding the greens. Naretoi offers a unique opportunity in that it combines all these attractions into one package. Tourism’s Impact on the Environment In Kenya, as in many other countries, tourism is essentially nature-based and therefore has considerable influence on environmental quality. Unless properly planned, it has the potential to destroy biological and cultural diversity despite its huge importance. A major feature of Kenya’s tourism has been the heavy visitation to just a few of the better-known parks and reserves, and a preoccupation with the beaches. This has led to rapid deterioration of facilities due to heavy usage, inadequate regulation, and poor management of both the infrastructure and visitor behaviour. Potential negative impacts arising from the tourism industry on the environment include pollution of water resources, land degradation and unsustainable use of land, loss of vegetation, air pollution and noise, solid waste and littering, sewage pollution, aesthetic pollution and introduction of invasive species, physical impacts arising from infrastructure, destruction of marine ecosystems, trampling of vegetation due to off road driving and hiking, anchoring, destruction of fragile ecosystems due to marine sports, and alteration of ecosystems and animal natural behaviour due to intense tourism activities. The challenge is therefore to ensure that tourism is developed in harmony with environmental standards.

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Fig. 7: Maasai and their cattle on land for which a conservancy is planned, by Olerai Ltd together with the Maasai themselves

1.1

Terms of Reference The Terms Of Reference (ToR) for this full EIA study are attached to this report. The project proposes cost effective mitigation measures, looks at project alternatives and enhances identified positive aspects.

1.2

Project Proponent Identification This Environmental Impact Assessment full study is carried out for and on behalf of O l e r a i L im i te d .

1.3

Objectives and Scope of the Proposed Project

1.3.1 Objective of the Proposed Project The Proposed Olerai golf resort is intended to provide a unique golfing experience for the golfer looking for excitement, game-viewing and birdwatching in a comfortable, rustic Kenyan setting. All this, plus breathtaking
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views of sweeping African landscapes, is offered within driving distance from the MMNR. 1.3.2 Scope of the Proposed Project The proposed facility shall cover an area of approximately 700 acres. The proposal caters for approximately 120 houses providing accommodation for both local and international tourists. These will be built in 7 phases, with the first phase comprising of only 5 houses, and the golf course only being constructed once the developer is satisfied with market demand and has sold over 30 houses by phase 3. Other facilities shall include:  Reception Offices  A club house (Dining Area/Bar/Lounge and Kitchen and accommodation of up to 16 rooms) built in the first Phase  A Swimming Pool and associated changing rooms  Senior staff houses and junior staff quarters 1.3.3 Total Cost of the Project The proposed Olerai Golf Resort shall cost the Proponent approximately Kshs USD 15m to develop. 1.4 Project Activities Ground preparation Shaping of the golf course Construction of various resort facilities as elaborated in the approved design plan Construction of wetlands for water recycling Installation of biodigesters for water recycling Limited abstraction of water from Mara River (see attached permit) Installation, if feasible, of a small turbine in Mara River for Power Generation Operation of resort (Offering of accommodation to tourists)

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1.5

EIA Approach and Methodology This EIA has been guided by both EMCA (the Environmental Management and Coordination Act, 1990) and the EIA guidelines for the tourism sector. The EIA guidelines for the tourism sector were devised to ensure environmentally sustainable tourism development in Kenya. In particular, the objectives of the guidelines are: a. To streamline activities and infrastructure for sustainable development in the tourism sector; b. To guide tourism development to conform with the existing regulatory framework; and c. To ensure an integrated approach to sustainable management of natural resources within the tourism sector.

The EIA Study approach adopted for the proposed Olerai golf resort was separated into Four Phases. The four phases include:  Desk Top Study  Site Walk Assessment Survey  Stakeholder Consultation Meetings and Questionnaire Administration and  EIA Study Report Preparation 1.5.1 Phase 1: Desk Top Study Literature reviews pertaining to the project development and operation activities have been done. This has included the review of the Environmental Management and Co-ordination Act, (EMCA), the Environmental Impact Assessment (EIA) Guidelines, the EIA Tourism Guidelines by the Ministry of Tourism and Wildlife, Vision 2030, the Physical Planning Act, relevant studies and reports (in particular write-ups on golf tourism in or near national parks with particular reference to South Africa, which has four (4) world-famous golf courses in Kruger park). Other legislative references include:

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The Water Act  Legal Notice No. 120 (relating to Water Quality Regulations 2006)  Legal Notice No. 121 (relating to Waste Management Regulations 2006) and  Legal Notice No. 131 (relating to Fossil Fuel Emission Control Regulations 2006). Reports and reference materials associated with the wider Mara Conservation Area have also been reviewed. This was necessary to enable a deeper understanding of the context in which the proposed golf project will fit. It should be pointed out here that the proposed golf project is only the first phase of a two-phase project; the second phase entails creating a conservancy. The two will be symbiotic and mutually beneficial. A separate EIA study is being conducted for the Olerai wildlife conservancy. However a management plan has already been submitted to NEMA on the Enonkishu Conservancy reference number Conservancy Management Plan 004. 1.5.2 Phase 2: Site Walk Assessment Survey A field reconnaissance survey was conducted to collect information on the biophysical and socio-economic environment of the proposed site area and its environs. The EIA Consultant made observations on the biophysical and socioeconomic environments including landscape, geology, soils, and the presence of nearby sensitive receptors (like water bodies), flora and fauna. All these were recorded. Photographs were also taken where necessary. Issues such as wildlife integration, water abstraction and management systems were also discussed at length. 1.5.3 Phase 3: Stakeholder Consultation Meeting and Questionnaire Administration As part of the EIA study, relevant stakeholders were contacted and invited for a meeting to discuss the proposed golf resort during both of the abovementioned visits. Opinions were sought on the proposed development.
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Among the stakeholders who attended the meeting and filled in the EIA Stakeholder questionnaires included:
  

 

The Local Chief Narok County Council Planners Water Resources Management Authority (WRMA) Officer in charge of Narok Outpost The area Councillor Other Local Leaders

The participants aired their views and filled in the EIA questionnaires and signed an attendance list as evidence of participation (Refer to Annex 4 and Annex 5). 1.5.4 Phase 4: Environmental Impact Assessment (EIA) Study Report Preparation All the information and data collected during the four stages of the EIA Study has been evaluated and forms the basis of compiling this EIA Study.

Fig. 8: Pivot Irrigation. Casual labourers picking string beans for export in the back-ground. This is the current land use. Irrigation water, for which there is a permit, is abstracted from the Mara River.

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Fig. 9 (below): Pivot irrigation in use. The proposed project will need a lot less water than what is currently being used for horticultural farming.

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2

REVIEW OF ENVIRONMENTAL POLICY, INSTITUTIONAL AND LEGAL FRAMEWORK AND COMPLIANCE Environmental Management and Coordination Act (EMCA) Every Kenyan, according to the Environmental Management and Coordination Act (EMCA), 1999, is entitled to a clean and healthy environment and has the duty to safeguard and enhance the environment. Environmental Impact Assessment (EIA), as a tool for better planning, is undertaken to check compliance with environmental policies and legislative environmental requirements in order to check risks associated with any upcoming project and expose them for correction. It provides information for periodic review and alteration of the environmental management plan as necessary, ensuring that environmental management is optimised at all stages of development through best practice. Policies and laws that relate to Environmental Impact Assessment aim at promoting sound environmental management. According to Section 58 of the Environmental Management and Coordination Act (EMCA): Subsection (1) Notwithstanding any approval, permit or licence granted under this Act or any other law in force in Kenya, any person, being a Proponent of a project, shall before financing, commencing, proceeding with, carrying out, executing or conducting or causing to be financed, commenced, proceeded with, carried out, executed or conducted by another person any undertaking specified in the Second Schedule to EMCA, submit an EIA Report to the Authority, in the prescribed form, giving the prescribed information and which shall be accompanied by the prescribed fee. Subsection (2) The Proponent of a project shall undertake or cause to be undertaken at his own expense an Environmental Impact Assessment Study and prepare a report thereof where the Authority (NEMA), being satisfied, after studying the EIA Report under subsection (1), that the intended
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project may have or is likely to have or will have a significant impact on the environment, so directs. Subsection (7) Environmental Impact Assessment shall be conducted in accordance with the environmental impact assessment regulations, guidelines and procedures issued under EMCA. Legal obligations relating to EIA which must cover all projects specified under the Second Schedule of EMCA, 1999 include compliance with:  Environmental Management and Coordination Act, 1999, Part V, Section 42 (3). The Minister may, by notice in the Gazette, issue general and specific orders, regulations or standards for the management of river banks, lake shores, wetlands or coastal zones and such orders, regulations or standards may include management, protection, or conservation measures of any area at risk of environmental degradation and shall provide for:– (b) the development of an overall environmental management plan for a lake, river, wetland or coastal area, taking into account the relevant sectoral interests; (e) contingency plans for the prevention and control of all deliberate and accidental discharge of pollutants into the sea, lakes or rivers; (f) plans for the protection of wetlands; (i) promotion of environmentally friendly tourism; (j) the management of biological resources.  Environmental Management and Coordination Act, 1999, Part V, Section 50. The Authority shall, in consultation with the relevant lead agencies (including Ministry of Wildlife and Tourism – KWS) prescribe measures necessary to ensure the conservation of biological diversity in Kenya and in this respect the Authority shall – (c) Identify potential threats to biological diversity and devise measures to remove or arrest their effects.  Environmental Management and Coordination Act, 1999, Part V, Section 51. The Authority shall, in consultation with the relevant lead agencies including KWS and Ministry of Tourism prescribe measures adequate to ensure the conservation of biological resources in-situ and in this regard shall issue guidelines for:–

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 

(a) Land use methods that are compatible with conservation of biological diversity. Environmental Management and Coordination Act, 1999 section 72, 74,75, and 76 (deal with water pollution, water pollution prohibition and license to discharge effluent). Environmental Management and Coordination Act, 1999 section 91 and 94 (deals with the classification of waste, waste handling and their management). Environmental Management and Coordination Act, 1999 section 107 (Standards for the control of noxious smells). Environmental Management and Coordination Act, 1999, Part XIII, Section 142 deals with penalties related to pollution of resources including land and water including restoration of the environment.

Compliance  The Proponent has commissioned the carrying out of an Environmental Impact Assessment for submission to NEMA for approval.  The Proponent undertakes to protect the environment during the implementation (Construction and Operation) of the project and also carry out annual Environmental Audits.  The Proponent undertakes not to cut down existing trees but to incorporate them in the design and restore any disturbed environment as a result of the project by planting Indigenous Trees. 2.2 The Water Act, 2002 Water Act, 2002 Part III, Section 23 says that the authority shall not approve any community project unless the proposed project is approved by the person owning or occupying at least two thirds of the particular area concerned in the project. Water Act, 2002 Part III, Section 25 indicates that a permit shall be required for any use of water from a Water Source. Water Act, 2002 Part III, Section 27 says that a person who not being a holder of a permit constructs or employs any works for a purpose for which a permit is required shall be guilty of an offence.

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Water Act, 2002 Part IV, Section 73 allows for a person with a licence to supply water and make regulations for protecting the source against degradation. Water Act, 2002 Part IV, Section 75 says that a person not being a holder of a permit constructs or employs any works for a purpose for which a permit is required shall be guilty of an offence. Water Act, 2002 Part VI, Section 94 says that no person shall, without authority under the Act: (a) Wilfully obstruct, interfere with, divert or abstract water from any watercourse or any water resource, or negligently allow any such obstruction, interference, diversion or abstraction; or (b) Throw or convey, or cause or permit to be thrown or conveyed, any rubbish, dirt, refuse, effluent, trade waste or other offensive or unwholesome matter or thing into or near any water resource in such manner as to cause, or be likely to cause, pollution of the water resource. A person who contravenes this section shall be guilty of an offence Compliance  The Proponent already has a water abstraction permit from the Narok Outpost Water Resources Management Authority Office.  The Proponent undertakes to safeguard the Mara River by maintaining a buffer distance of 30m away from the Mara River bank.  The Proponent undertakes to safeguard the Mara River by providing a guard rail on the Mara River side and also ensure that all solid and sewerage waste is collected for disposal away from the area.  The Proponent undertakes to put in place solid and liquid waste management mechanisms to ensure they do not impact the surface or groundwater. These shall include the following:  Provision of adequate solid waste collection bins within the facility  The posting of polite notices to staff and tourists (visitors) not to litter the resort area but use the provided waste bins for disposal.  Provision of well constructed sewerage lines and septic tanks to contain domestic waste.

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 The provision of concrete containers for any installed machinery to collect any oils/fuels incase of spillage/leakage.  The Proponent undertakes to provide a well structured programme for solid waste collection and sewage septic tank exhaustion. 2.3 Water Quality Regulations, 2006 4 (1) Every person shall refrain from any act which directly or indirectly causes or may cause immediate or subsequent water pollution and it shall be immaterial whether or not the water resource was polluted before the enactment of these Regulations. (2) No person shall throw or cause to flow into or near a water resource any liquid, solid or gaseous substance or deposit any such substance in or near it, as to cause pollution. 6 No person shall (a) discharge any effluent from sewage treatment works or other point sources without a valid effluent discharge licence issued in accordance with the provisions of the Act. (b) abstract groundwater or carry out any activity near any lakes, rivers, streams, springs and wells that is likely to have any adverse impact on the quantity and quality of the water without an EIA licence issued in accordance with the provisions of the Act. (c) cultivate or undertake any development activity within full width of a river or stream to a minimum of six metres and a maximum of thirty metres on either side based on the highest recorded flood level. Compliance  The Proponent undertakes to safeguard the Mara River by maintaining a buffer distance of 30m away from the Mara River bank.  The Proponent undertakes to safeguard the Mara River by providing a guard rail on the Mara River side and also ensure that all solid and sewerage waste is collected for disposal away from the area.  The Proponent undertakes to put in place solid and liquid waste management mechanism to ensure they do not impact the surface or groundwater. These shall include the following:  Provision of adequate solid waste collection bins within the facility

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 The posting of polite notices to staff and tourists (visitors) not to litter the area but use provided waste bins for disposal.  Provision of well constructed sewerage lines and septic tanks to contain domestic waste.  The provision of concrete containers for any installed machinery to collect any oils/fuels incase spillage/leakage. The Proponent undertakes to provide a well structured programme for solid waste collection and sewage septic tank exhaustion.

2.4

The Land Planning Act, CAP 303 The Land Planning Act Cap 303, Subsidiary Legislation (The Development and Use of Land/Planning Regulations):Part IV – Control of Development 10. (1) Subject to these Regulations, no person shall carry out development in an interim planning area except with the consent of the Authority under these Regulations empowered to grant consent. (2) Any person who carries out development without consent shall be guilty of an offence and shall be liable to prosecution. 11. (1) Every person requiring consent for development shall make application to the interim planning authority for the area in which the land concerned is situated. Compliance  The Proponent has launched and obtained all required approvals of the project development and licences from the Narok County Council and other relevant Local Authority Offices.

2.5

The Physical Planning Act, CAP 286 Part V – Control of Development. Section 29 provides that subject to the provisions of the Act, each Local Authority shall have the power:

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(a) to prohibit or control the use and development of land and buildings in the interests of proper and orderly development of its area; (b) to control or prohibit the subdivision of land or existing plots into smaller areas; (c) to consider and approve all development applications and grant all development permissions; (d) to ensure the proper execution and implementation of approved physical development plans; (e) To formulate by-laws to regulate zoning in respect of use and density of development; and (f) To reserve and maintain all the land planned for open spaces, parks, urban forests and green belts in accordance with the approved physical development plan. Section 30 (1) No person shall carry out development within the area of a Local Authority without a development permission granted by the local authority. (2) Any person who contravenes subsection (1) shall be guilty of an offence and shall be liable to prosecution. Section 32 (2) provides that a Proponent of development forwards an application to the Local Authority for approval of any development. Section 33 deals with the issuance of Approvals or denial of Approvals, with reasons. Section 36 provides that if in connection with a development application a local authority is of the opinion that a particular proposed development activity will have injurious impacts on the environment, the applicant shall be required to submit an Environmental Impact Assessment report. Compliance  The Proponent has designed the proposed golf resort and obtained all the necessary approvals by the Local Authority.  The Proponent has initiated an Environmental Impact Assessment Full Study for submission to NEMA for approval.

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2.6

The Local Government Act, CAP 265 Section 155 Every County, Municipal or Town Council shall have power:(d) To establish and maintain game parks, including accommodation for visitors thereto. Section 164 (1) A local Authority shall have power to summon any applicant for, or any objector to, the granting of a licence to give evidence or to produce books or documents at any sitting of the Local Authority or a committee thereof held for the purpose of hearing the application for such licence, and any such person refusing or omitting without sufficient evidence to produce books or documents in his possession or under his control as required by such summons shall be guilty of an offence. Section 165 (1) A Local Authority may refuse to grant or renew any licence which it is empowered under this Act or any other written law to grant on any such grounds as it may, by by-law, specify and in addition upon any of the following grounds whether specified in such by-laws or not: (a) With respect to any licence whether relating to a trade, business or occupation, or to premises or otherwise – (i) That the premises in or at which the applicant intends to carry on his trade, business or occupation does not conform to the requirements of any by-laws in force in the area of such local authority, whether made under this Act or any other written law. (iii) That the granting of such licence or the renewal thereof, as the case may be, would be contrary to the public interest. Compliance  The Proponent has designed the proposed resort and obtained approval from the Local Authority.  The Proponent has initiated an Environmental Impact Assessment Full Study for submission to NEMA for approval.

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2.7

The Public Health Act, CAP 242 Section 115. No person shall cause a nuisance or shall suffer to exist on any land or premises owned or occupied by him or of which he is in charge any nuisance or other condition liable to be injurious or dangerous to health. a) Public Health Act, Cap 242 part IX on Sanitation and Housing, section 118- b, c, d, e, h, I, j, l provides what constitutes nuisance. This includes: (1) Any dwelling or premises or part thereof which is or are of such construction or is in such a state or situation or so dirty or so verminous as to be dangerous to health (2) Any street, road or any part thereof, any stream, pool, ditch, gutter, watercourse, sink, water tank, cistern, water closet, water tank urinal, septic tank waste pipe, drain, sewer, garbage receptacle, dust bin, refuse pit is in such way or so situated or constructed to be offensive or to be injurious or dangerous to health (3) Any noxious matter or waste water, flowing or discharged from any premises (4) Any accumulation or deposit of refuse (5) Any accumulation of stones, timber or other material (6) Any dwelling or premises which is so overcrowded, among other provisions.

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Fig. 10: Views from the proposed site. Horticultural farming in the middle-distance section of the photo.

Compliance  Seeing as the proposed facility will be located in a peripheral area of a national reserve where there is presence of wild animals and other potential insurgents, the Proponent undertakes to provide and guarantee security to the workers (during the construction and operation phases) and the tourists (during the operation phase);  The Proponent shall also include safe disease vector control by ensuring that all persons (workers and tourists alike) are provided with effective mosquito nets to guard against malaria;  The Proponent undertakes to comply by collecting all waste (solid waste from the golf resort operations and sewage waste) and have it put in solid waste bins and septic tanks respectively for collection and disposal away from the area. 2.8 The Factories and Other Places of Work Act (CAP 614) The Act and its subsidiary legislation elaborates on the provision for health, safety and welfare for all persons employed in factories and other places of work. It also provides for the emission of dust, fumes or impurities into the

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atmosphere without proper treatment to prevent pollution or effects to life and property. These situations require that practical measures are provided to protect all persons from harmful effects, while also protecting the environment. Compliance  The Proponent and contractor undertake to minimise the emission of dust and production of noise during the process of shaping the golf course and construction of surrounding structures.  The Proponent undertakes to provide all workers with Personal Protective Equipment for all works associated with this project.

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3 3.1

PROJECT LOCATION AND PHYSICAL ENVIRONMENT Location of Proposed Project The proposed resort is to be located in a semi-dense wooded area on the eastern banks of the Mara River. It is intended to develop 58 lodge-style houses meant to provide accommodation for local and international tourists. It will be located approximately 3 kms south of Emarti which is the nearest town. Map 1 below shows the location of the proposed Naretoi golf resort. The size of the proposed development site is approximately 600 acres. The site lies within longitude E 0380 23’ 34.6’’ (X Co-ordinates) and latitude S 000 04’ 36.5’’ (Y Co-ordinates) and altitude of approximately 1650 meters above sea level.

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3.2

PHYSICAL ENVIRONMENT

3.2.1 Climate, Topography, Geology and Hydrology The Naretoi area receives between 600 to 800 mm of rainfall in eastern areas, rising up to 1000mm at the western side where climate is strongly influenced by the Lake Victoria weather system. The “short rains” are received between October and November while the “long rains” are received between March and May. Soil moisture is generally sufficient to maintain a single growing season from November to June, the July – October periods being the dry season. The climate and vegetation of Naretoi are characteristic of eco-climatic zone 4, the semi -arid to subhumid zone.

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The geological basement of the wider Mara is comprised of Miocene quartzites , gneisses and schists, overlain by volcanic tuffs, described as having moderate to high fertility. In the East and North the basement is exposed as Siana and Lemek hills respectively, in the west a major fault in the basement has created the prominent Sirisia escarpment, capped by a thick mantle of Precambrian granite. In the Naretoi area the main source of water is the Mara River which is the most important drainage channel. This river is an important source of water for both domestic, livestock and wildlife use. Many dry river beds exist in the wider Mara which are normally filled with storm water during the rainy season. Several small springs provide water for mainly domestic purposes. There are man made dams at Ilpoori and Eluai that supply water for domestic use, livestock and wildlife. 3.2.2 Biodiversity The natural wealth of the wider Mara, including Naretoi, is intimately tied to the history and culture of the Maasai people. Their common language – Maa - historically links the Maasai people. There are several Maasai subgroups referred to as “sections”. The occupants of this study area are the IlPurko Maasai, who originally migrated from the north in the Laikipia plateau to settle in the southern parts of Kenya particularly in Narok, Transmara and parts of Kajiado districts. The land in Enonkishu within which Naretoi falls acts as a wildlife dispersal area. In the past this land with its resources was communally held trust land, but this has changed due to land adjudication, subdivision and registration. At present, various land-uses are at play including large-scale agricultural production, subsistence farming, livestock rearing and wildlife habitation. This multiple use of land, coupled with unfavourable climate, has resulted in significant loss of biodiversity, land degradation, humanwildlife and human-human conflicts. Species of wildlife found in the greater Mara are also found in Naretoi including lions, elephants, rhinos, leopards and giraffes. There is widespread presence of natural forest, grassland and swamps that are
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critical to sustenance of broad biodiversity of wildlife and other land resources. However there has been little effort to manage these resources and no formal scientific monitoring. 3.3 Vegetation Vegetation at Naretoi, the areas that have not been already cleared for agriculture, comprises of tall and short grass-lands dominated by Themeda Triandra and Pennisetum Spp, interspersed by patchwork of Acacia woodlands and Euclea bushlands, thicket and riverine forest (Trapnell et al 1969). During the 1960s previously wooded areas were radically transformed into grassland by the actions of fires and elephants (Dublin 1995). Hillslopes remain colonised by extensive tracts of Tarchonanthus camphorates (Maa: ol-leleshwa ) bushland which is unpalatable to stock. Wetlands and river banks are characterised by vegetation such as Typha sedge grass, while areas with high water tables are dominated by Acacia xanthophloea. 3.4 Threat to biodiversity High population growth poses one of the main threats to biodiversity conservation in the area due to high demand for land for crop farming, livestock rearing, settlement, and recreational purposes. Hence, there exists a wide and varied view on use of natural resources between the Maasai community, settlers/agriculturalists and conservation partners. Traditionally a pastoral community, the Maasai have with modernisation slowly taken on agricultural practices and have begun to cultivate, albeit on a small scale. While in the past the Maasai shared their land, pasture and water with wildlife, the emerging changes in land tenure system have threatened this set-up. The greatest threat to biodiversity is land subdivision. . However with no tourism activities in this area the wildlife is being abused and numbers are falling dramatically. On March 12, 2012, 5 elephants were poached for their ivory. Tourism and security management would help mitigate this problem.

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One of the five elephant speared in the proposed Enonkishu Conservancy. If poaching continues at the current rate it is estimated that in 7 years elephants will be extinct. The poaching rate is worse than it was in the height of poaching in the 1980s.

Other specific threats include unplanned tourism activities, lack of land use planning and management for the wildlife dispersal areas, escalation of human wildlife conflicts, and poor governance of biodiversity resources outside the game reserves. Others include ignorance and lack of awareness of livestock diseases. In addition, encroachment of wildlife habitats by livestock, wild fires, poaching, illegal charcoal burning water pollution and loss of wood cover due to increasing demand for wood fuel and low levels of literacy are all factors that contribute in the long run to loss in biodiversity. 3.5 Description of the Biophysical Environment

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3.5.1

Climate The proposed recreational site lies within Narok District next to the Mara River. The climate of the area can be classified as hot and dry for most of the year and can be characterized as arid/semi-arid with very unreliable rainfall. The District experiences two rainy seasons. The proposed project would encourage the return of fig trees and other indigenous riverine trees that have been deforested on either side of the river. The mean annual rainfall is approximately 500-800 mm. The mean annual maximum temperature varies between 25oC and 30oC while the mean annual minimum temperature varies between 15oC and 20oC.

3.5.2

Physiography The area where the proposed site is located is on the Western part of Narok District. The River Mara forms the western boundary. Trans-Mara District is across the river. The topography of the area gently rises eastwards towards the Sirisia Hills, upon which there is a steep climb to Kipelea Hill, which forms the highest point of the wider Mara area. The proposed site is at an elevation of approximately 5,500 ft above sea level.

3.5.3

Drainage The land is generally flat with a gradual slope running from the South to the North. This gives the facility site a natural slope with effective drainage. Currently the farm uses its machinery to create contours, which help reduce soil erosion by reducing water velocity at different gradients. The entire farm is covered with contours specifically constructed to contain runoff water responsible for soil erosion on cultivated land, as the land is made of volcanic soils that have greater propensity for erosion.

3.5.4 Water Resources and Quality The water sources of the Mara River system are enough for various agricultural and domestic uses. Drinking water is collected from a spring on the neighbouring land and there is also a rainwater harvesting system in place on the farm. The farm currently has permits to utilize 10,000 cubic
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meters per day. It is predicted that the proposed project will only use 10% of this figure. There are two water catchment areas on the proposed site; one is fairly large while the other one is smaller. Both of these have been avoided in the project design.

3.5.5 Soils The soils covering the area are mainly the latosolic and planosolic soil types. The main soils are imperfectly drained loams with dark brown subsoils. The soils have moderate to high fertility. Planosolic soils are less well drained with highly textured top soil. Well drained humic loams are also found. Over-intensive wheat production has already led to a loss of humus and topsoil in this area. The proposed project would no longer cultivate the land, therefore improving the soil structure and reducing the compaction associated with constant cultivation. 3.5.6 Vegetation Much of the vegetation on the proposed project site has been disturbed by agricultural practices carried out by Olerai as a commercial horticultural farm. Considerable large tracts of land have been cleared of vegetation. It is hoped that the proposed project will restore the majority of the land back to its natural state. On the whole, two vegetation types with different vegetation composition and structure can be identified on the proposed site, based on the microhabitat they occupy, that is location and soil type. The two plant communities are the plains vegetation of Acacia tortillis and Balanites aegyptica found on the plains. The riverine vegetation of Acacia xanthophloea dominates the river beds. 3.5.7 Wildlife Though not much wildlife was observed during the study, the area has great potential for animal habitation. Animals and birds that were seen in the area include Common Duiker and Bush Buck; birds sighted included Crested Cranes, Kites, Bee Eaters, Sunbirds, Black Crested Eagle and Herons. Olerai would like to manage the habitat to control healthy populations of a wide variety of species. The proposed project would
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encourage and be responsible for more wildlife, especially birds, with the water features that would be created.

3.5.8 The Mara River The Mara River is the only perennial river in the Mara ecosystem. It rises in the Mau Escarpment from where it flows through the MMNR and the Serengeti National Park, onto Lake Victoria. It is the primary, and occasionally the only, dry-season source of water for wildlife in the MMNR. The survival of large mammal migrations depends on seasonal access to this river, especially during periodic droughts. Its main tributaries are the Amala and the Nyagore Rivers, which drain from the Western Mau escarpment, and the Sand and Talek rivers, which rise in the Siana and Loita Hill.

Fig. 11: The Mara River

The Mara River plays several important roles. Because it is scenic, several tourist campsites and lodges are on its banks. Ecologically the river provides a habitat for key wildlife species, flora and fauna. The worldfamous migration, now dubbed “The Great Migration”, occurs at the Mara
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River and at some of its tributaries. The river is home to hippos and crocodiles, both species that interest local and international tourists. Civil works on the project will include bank stabilisation through use of gabions.

3.5.9 Maasai Culture and Community The Maasai are one of Kenya’s better-known tribes. This distinct warrior tribe is one of the few remaining tribes in Kenya to have proudly retained most of their traditions and culture. This, however, is being increasingly threatened by rural-urban migration and the lure of modernization. Naretoi intends to provide employment opportunities to the neighboring Maasai community members. Revenue gained from golf tourism at Naretoi will be ploughed back into the community to help the Maasai improve the value and quality of their herd. More emphasis will be placed on quality rather than quantity. It is envisaged that this will have two positive impacts: 1. Land will no longer be over-grazed; 2. The Maasai will be able to cut losses since a smaller but stronger herd will be better able to resist drought, thus breaking the cycle where Maasai herds of cattle are decimated by long periods of drought. 3. With better breeds and faster growing cattle the Maasai will be able to fetch better prices for the cattle. Naretoi also envisage introducing cattle dips and a cultural centre where tourists may visit and experience some interesting Maasai culture. The Maasai are an integral part of any tourists visit to the Mara. This proud tribe has over the years co-existed peacefully with wildlife and have an intimate understanding of all the inter-relationships between their cattle, wildlife and themselves. Despite periodic incidences of Maasai/wildlife conflict, mainly caused by wildlife attacking Maasai herds, the relationship is a harmonious one of mutual respect.

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3.6

Biological Environment

3.6.1 General The site and its environs are located in a serene environment with moderate density of natural indigenous vegetation. The proposed Eco village is to be located on the banks of the Mara River where human activity so far has been pivot-irrigation horticultural farming for international markets. 3.6.2 Flora Apart from the farming area, the flora over the proposed site area and the environs is largely natural having experienced minimal human interference. Most of the vegetation found within the proposed site area is mainly large trees (Fig Tree, Acacia etc) and shrubs. 3.6.3 Fauna The proposed golf resort in Enonkishu has a wide variety of wild animals. Some of these include Kudus, Hippos, Crocodiles, Elephants, Giraffes and Leopards among others. It is possible that some of these could move within close proximity of the golf resort. An early warning system to alert guests of the approach of a dangerous animal has been devised.

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4 4.1

PROJECT DESCRIPTION AND BASELINE EVALUATION PROJECT DESCRIPTION The idea of developing the Olerai Eco-estate as an upmarket tourist and recreation facility was conceived by the management in 2007. An EIA Project Report on the proposed development was submitted to NEMA in 2009. Continued growth of the tourism market in Kenya is anticipated, along with the rising economic and environmental costs involved in farming practices in the region. In addition to protecting the environment and the Mara ecosystem further downstream, the venture is expected to generate more than 500 new jobs in the local community and to earn substantial revenues for the country. The proposed activities for the Olerai Eco estate will comprise of the following:

4.1.1 Golf Course An 18 hole golf course is proposed as one of the main recreation facilities. The golf course will be laid out in the Mara river catchment area, where an agricultural pivot irrigation system is currently in place, around a conservation reservoir which will be created by the construction of an earth dam around one of the Mara river tributaries running through the site. The golf course and associated facilities will cover an area of approximately 120 acres in extent. The planning phase of the golf course will involve surveying. Construction of the golf course will entail removal of the crops, removal of the irrigation pivot, landscaping and the planting of carpet grass. The design and layout of the golf course will be done in a manner which will rehabilitate the top soil, improve water resources and restore indigenous plant resources. The greens are likely to attract a variety of birds and wildlife. During the use of the golf course, the greens will be watered regularly from reservoirs and water features created on the golf course and undesired plants and weeds will be kept in check.

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The club house will keep adequate stocks of golf kits for hiring out to patrons including international visitors and will overlook the golf course. There will be a relaxation area for guests permitting them to absorb the aura and peace that the golf course will create. There also will be 16 semipermanent rooms for accommodation for those guests who would like a more relaxed experience. 4.1.2 Residential Areas The project will adopt green building i.e. use of energy-efficient and nonpolluting construction materials, a modern sewage system and energy saving programme to decrease its impact on the environment. Pollution prevention and waste minimization techniques will also be adopted and implemented within the project cycle. All units will be eco-focused with compulsory solar fitted water heaters, and sewage will be processed through ‘bio-boxes’ with a controlled breakdown and environmentally sound end products. The project will be broken down in phases as follows:Phase 1 – 7 will construct 46 houses and the club house. It is estimated to take 3 years; Phase 8 will construct 34 houses and the golf course so long as the market is still healthy. It is estimated to take a further 3 years. The residential areas of the estate will be established so as to provide high quality, low density areas. As such plot sizes will vary from 2-5 acres and initially there will be only 5 houses. There shall be a subsequent 7 phases of housing development which will bring the total number of houses to 58. Once these initial stages are completed the Proponent would like to embark on the golf course where the additional foot print houses will be constructed on the fringes of the golf course to total 80 deluxe bush homes.

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There shall be no fencing between the homes and each holder shall be required to sign a binding agreement to comply with the environmental management plan of the area. The estate will be maintained as an open area to allow the migration of small game within the estate and to maintain the open views that are expected to be one of the main attractions of the facility. 4.2 Neighbouring Property Use Olerai Ltd purchased the farm from the Nampaso family in 2000. The farm had previously been used for cattle grazing, collection of fuel wood, burning charcoal, clearing of vegetation and growing food crops. Uncontrolled human activities that once occurred on the farm and now in the surrounding land are largely to blame for overgrazing, deforestation, degradation of natural resources and the scarcity of wildlife due to poaching, snaring and the illegal bush meat trade. 4.2.1 Existing Land use Practices Currently the farm is under intensive horticulture, commercially growing wheat, maize and French Beans for export. 300 hectares of the land is under pivot irrigation. This commercial activity although economically viable, is environmentally unsustainable. These practices have had the direct effect of reducing vegetation cover and reducing biodiversity. A substantial amount of agrochemicals are in use and the top soil is more vulnerable to erosion. Olerai believes that the proposed project will reverse these effects and rehabilitate the land to a more sustainable, biodiversity rich ecosystem. 4.2.2 Existing Infrastructure on the Farm The farm currently has the following infrastructure: Access roads to the farm maintained by the farm to the BometNarok road.  3 entrance and exit gates  Internal murram road network  Electric fence surrounding entire farm  Water reservoir and 3 pump systems
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           

5 irrigation pivots of which 3 would be taken out for the new project. Office and ancillary buildings Workshop and ancillary buildings Drying shed Grading shed Fertilizer Store Chemical Store 3 Generator houses 2 Managers houses 1 stable block with 5 stables 60 pit latrines 150 staff houses

4.2.3 Community The surrounding community consists mostly of the Maasai and Kipsigis tribes. Olerai has longstanding relationships with both communities. The Maasai community settlements have not changed much over the years, although they are growing at an alarming rate of 6% per annum. The Kipsigis community has expanded enormously and has spread from Mulot at an exponential rate towards the Emarti Village, which has led to some insecurity in the area as both communities are renowned for cattle rustling and inter-tribal skirmishes. This is a direct result of unemployment and poverty. Since its establishment, Olerai Farm Ltd has come to be one of the most reliable and largest employers of local people within the district. Farmers neighbouring Olerai farm benefit from ploughing and planting timing based on the activities at Olerai farm Ltd, as well as through support that their workshop gives the area. Incorporating golf activities and housing within the farm will create more chances for the community to benefit than before through several ways described in more detail later, including:
 

Construction and rehabilitation of local schools through exposure and fundraising; Contribution to school fees for students from neighbouring community;
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    

The company offsets 80% of the staff’s (including some of their dependants) medical bills; Increasing employment; Modifying logistics and infrastructure in the area; Teaching of new skills; Increased conservation and environmental education.

There are no human settlements in the proposed site, thus there are no chances of disturbance or displacement of the settlement patterns within the region. Moreover the management of the project will actively participate in biodiversity conservation and promotion of tourism with the community through financial contribution to schools, healthcare and veterinary facilities for the community, special packages into the communities for excursions, dissemination of information to tourists on sensible uses of natural, cultural features and parks’ ecosystems. The project will also use local supplies and resources for sustainability, provide tourists with guidelines on how to minimize negative impacts on the community and environment amongst other measures. 4.3 Pre-Construction Activities The Proponent has endeavored to obtain all relevant approvals from the Narok local authority and relevant institutions including the following:  Preparation of Design Drawings of the various facilities for approval by the local authority;  Commissioning of an EIA Full Study for the proposed project in line with NEMA requirements;  Launching of an application for water abstraction permits from the Water Resources Management Authority (WRMA – Narok Outpost) to allow the use of Mara River water to supply water for the construction and operation activities. As the constructed wetlands are developed and biodigesters installed, both of which will enable water recycling by up to 65%, abstracted water will reduce dramatically. The proposed golf resort will entail a significant change in land-use, from an intensely farmed horticultural enterprise to a recreational tourist resort. Prior to construction, the site will require major earth-works as the golf
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course is shaped and created. Sites for houses will also need to be identified. While there will need to be some bush clearance, this will be minimal as the intention is to accommodate most of the natural vegetation in the construction so as to blend in with the natural environment. 4.4 Site Alteration during Construction It is envisaged that the proposed site will undergo significant alteration during the construction process to accommodate the proposed golf course, houses and other associated structures. Though the area has a semi-arid climate, the proposed site is relatively green with moderately thick vegetation providing a nice cool atmosphere close to the Mara River. The existing trees and shrubs will require selective clearing by only removing those that have to be cleared while accommodating the rest to blend with the upcoming structures. The potential alterations during construction shall include the following:

Soil Excavation To facilitate the construction of various components of the proposed golf resort, soil excavation shall be done to shape various elements necessary for a golf course. In addition, top soil shall be excavated to lay the necessary foundations for the various resort structures. This is only expected to go up to the shallow basement bedrock (approx. 1-1.5m below ground level or less). Similar excavation shall be done to construct the swimming pool. The swimming pool may require the quarrying of the basement bedrock to reach a depth of approx. 2m below ground level for the deepest area of the pool. The contractor shall carry out the soil excavation process with utmost care to ensure that the excavated soil is not improperly heaped or carried away by any surface flows to the Mara River causing siltation.

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Safety Protocol and established International Environmental Protection Regulations/Standards shall guide the Contractor. This will include safety wear at all times and the Contractor will appoint a Certified Safety Officer on site during all construction activities. The Contractor shall also provide first aid kits since the site is relatively far from medical services. Modest construction procedures will need to be followed in order to reduce noise levels and the generation of dust that may affect people and scare away any wild animals within the vicinity. Existing Vegetation There may be need to remove some existing vegetation to create room for construction. However, this is expected to be minimal since the Proponent intends to include as much of the existing vegetation as possible in the development of the camp in order to retain the natural scenic beauty of the area. It is intended that vegetation shall also provide a natural barrier between houses, ensuring privacy of guests and residents.

4.5

Construction Activities Skilled labour during constrction shall be brought in from Nairobi to ensure that the facility is constructed to the approved specifications while also maintaining the site environmental integrity. The Proponent shall use local manpower to provide any required unskilled labour. This will enure that the project generates employment for the local community who are entitled to enjoy any benefits accruing from the development of the project within their locality. The project will also train the unskilled, local labour to become skilled.

4.5.1 Construction Materials As much as possible, the Proponent intends to use locally available materials for the construction of the various structures. Only where such materials shall not be available locally will they be brought in from Nairobi, or other nearby towns where such materials are available.

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Structure Foundation Floors The Basement System Bedrock at this site is relatively shallow. Majority of the housing structures will have the foundations largely composed of hardcore that will be obtained locally. These will also be used to construct the swimming pool area. Walls The walls will be constructed of local stones that will be made to blend with the surroundings. The walls will be composed of random stoned phasing. Some walls will be gabion walls – these help with temperature control. Roofs All the structures shall be constructed using sisal poles and gum pole trusses covered with grass thatching and shall blend coloured mabati roofing for rainwater collection. This is intended to blend very well with the local environment and also provide a natural cooling effect in an area that is largely semi-arid, therefore often hot. Access Walkways The access walkways connecting the houses with other amenity structures of the resort shall be constructed using locally obtained quarry tiles. Driveways and Parking Areas The driveways and parking areas shall be covered with lose quarry stones obtained locally and ballast to reduce dust emission. This will also help make them all weather driveways and parking lots.

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Fig. 12: A model house for the proposed project. Locally available materials will be used as much as possible.

4.5.2 Construction Supervision During the construction phase, close supervision shall be carried out to ensure:  Workers wear necessary safety gear at all times (including gloves, helmets, safety shoes with metal tipped toes, ear muffs, overalls and dust coats);  Motorised equipment is checked and certified to ensure that it is in good working condition, safe to use with minimal noise levels, not forgetting reduced smoke emission;  First aid kit and fire fighting equipment (portable cylinders) are provided and placed at strategic positions that can be easily accessed;  Proper disposal of waste material and toilet facilities are provided for construction workers;  Emergency response procedures are in place and all workers are trained in effecting them;  Any work involving deep excavations (e.g. swimming pool and golf course bunkers), lifting heavy loads, poses a number of risks to personnel. The Contractor shall develop a Safety Plan before
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commencement of each phase of the construction. This will ensure that personnel are equipped with the correct protective clothing and equipment, and are ready to work safely while also safeguarding the environment. 4.6 Provision of Security to Workers and Tourists The Proponent proposes to provide full time security (several security officers, both Maasai and company contracted). They shall form part of the team on site. This is deemed necessary to ensure that the workers are protected from any wild animals that may encroach the camp site area while the construction activities are in progress. Security is also deemed necessary due to the possibility of the resort being attacked by robbers.

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4.7

Facilities and Services to be provided at the Golf Resort A. description of phasing and construction order of the project Phase Areas(Acres) Houses 1 15 5 houses looking over the Kilelioni hill as well as a temporary tented camp for prospective home owners to stay when looking at purchasing or progress 2 15 5 bush homes tucked into indigenous trees 3 25 9 Nine houses with views both overlooking the Mara River and with views of the hill 4 35 12 Removal of centre pivot irrigation and development of 12 homes overlooking the current maize fields. 5 15 6 5 more houses developed looking over constructed water features and wetlands and Mara River 6 45 10 Houses looking over the indigenous forest planted earlier in the project. 7 200 33 Whilst developing the golf course and building the club house the project will be selling 30 foot print houses in and around the golf course. Total 350 80 The remainder of the 1300 acres will be left to grow back naturally and become important natural habitat

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D E F G H .

Residents Club and Golf Club (phase 8) Safari Style Tented Lodge and Spa (phase 1) Polo Pitch (200x270m) Polo Horse Stables and Stands. Cricket Pitch (100x100m)

Notes on Road Specifications:  Trunk Roads: 12m Road Reserves constructed as stabilized murram roads with storm drainage to Civil Engineer Specifications.  On Village Roads: 9m Road Reserves constructed as stabilized murram roads storm drainage to Civil Engineer Specifications. (Position and routes of on village roads to be determined on village site layout of houses.) 4.8 Special Facilities for Solid and Liquid Waste/Effluent Handling and Disposal at the Golf Resort The resort has incorporated in its design the following: Liquid Waste  Provision of constructed wetlands and biodigesters. These are both ecofriendly ways of recycling as much as 65% of water used. Water
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recycled in this manner will be used for irrigating the lawns and greens in the dry months, and for flushing toilets. This will significantly reduce the need for alternative sources of water. Septic tanks shall be monitored and emptied at regular intervals depending on the resort occupancy and liquid waste generation.  It is estimated that on average approximately 10m3 of sewage waste shall be generated every day during peak occupancy.  The septic tank shall be located at least 50m away from the banks of the Mara River. Solid Waste  Provision of well distributed and easily accessible waste bins that shall also be regularly emptied in the main solid waste bin for collection. The Proponent shall post polite notices in every room for tourists and workers instructing them not to throw away any waste that could litter the environment and also be a health risk to visiting wild animals.  The solid waste generated from the operations of the resort shall not be disposed of within the resort area. The Proponent shall put in place a regular solid waste collection programme where such accumulated waste shall be regularly (once a week) collected and transported for disposal at Narok.  It is estimated that during peak occupancy, the resort shall generate an average of between 1000 and 2000 Kg of solid waste per month.  All solid waste receptacles shall be located at least 50m away from the banks of the Mara River. 4.9 Facility Operation and Maintenance Operation After construction and commissioning of operations, the proposed resort shall regularly carry out its business of hosting local and international tourists and providing them with comfortable and high end accommodation and services. Olerai shall also organise game drives and tours for the visitors. Tourists shall be expected to remain within the perimeter fence of the resort to ensure safety from any visiting wild animals that may approach the resort area. In the event that the odd wild animal comes close to the resort, safely measures have been considered.
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Maintenance Whereas the proposed design and construction of the facility is intended to be of a very high quality, the Proponent undertakes to put on standby a maintenance team that will ensure that all installed facilities within the resort are operating optimally. The existence of a sensitive receptor, (the Mara River) game, and the host largely virgin land, dictates that waste handling facilities that include the septic tank and its associated sewerage line network and the solid waste collection mechanism have to operate efficiently without any risk of failure. 4.10 Power Provision for the Proposed Resort The Proponent has indicated that the priority for energy sources shall be ecofriendly:  Solar panels  Battery operated golf carts if possible These sources are expected to significantly reduce smoke and noise pollution that could affect the harmonious habitat/existence of the wildlife. In addition, KPLC power is about 10kms away from site and is expected to reach the site with the rural electrification programme.

Energy source from generators will only be limited to bridging on cloudy days when the solar is insufficient. This is due to its elevated noise levels and smoke emission. 4.11 Water Provision for Proposed Resort There are two wetlands on the proposed site. Most water will be dammed and treated from the dam and supplied to the houses and resort, reducing the requirement for Mara River water. Upto 65% water will be recycled through the constructed wetlands and biodigesters.

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It is worth mentioning that any water abstracted from the Mara River towards the proposed project shall be a lot less than what is currently being abstracted for horticultural irrigation. 4.11.1 Surface Water Abstraction from Mara River The proposed facility shall be located on the eastern bank of Mara River. Since Mara River is a perennial river, and the current land-use is farming, the Proponent has already obtained a water abstraction permit (10,000 cubic meters per day) from the Water Resources Management Authority (Narok Outpost). The Proponent uses a pivot irrigation system for horticultural farming. The project would only use 10% of the above amount and this would not be abstracted from the river; it would be abstracted from water features created on the golf course, and from harvested rain water from roof tops. This source will remain the primary option and will require the setting up of a small water treatment plant to make the water usable for domestic consumption. 4.11.2 Water Use Conservation at the resort There shall be regulated use of the abstracted water through instituting the following measures:  Installation of auto shut off taps at various water use outlets of the resort.  Prudent use of water at the facility by workers (regular instruction to workers on water use management to reduce wastage). 4.11.3 Annual Environmental Audit The Proponent undertakes to carry out regular water abstraction monitoring and also conduct an annual environmental audit of the facility and forward the Audit Report to NEMA. 4.12 Diseases and Disease Vectors of the Project Area The proposed Naretoi Golf Resort area in the Mara basin generally has low potential for vector borne diseases apart from Malaria and Trypanosomiasis vector (Tsetse Fly and Mosquitoes) which are significant. The Proponent will need to provide protection from these vectors e.g. mosquito nets and other forms of protection.

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No sprays (insecticides) shall be allowed within the resort. 4.13 Socio-Economic Environment The main source of livelihood for residents of Naretoi is livestock. The livestock depend on the rangelands that are still open and often, the people move from place to place in search of pasture and water. Livestock provide products and by-products such as milk, meat, blood, hides and skins, which are used for both subsistence and for cash. Due to decreasing rainfall the pastoralists have faced several challenges. During the drought in 2000, the Maasai lost most of their herds thus affecting their main source of income. As a result of frequent loss of herds and influence of modern living, many Maasai have diversified their economic activities to include farming, trade and involvement in tourism and wildlife conservation. The study area falls in Narok District which has a human population of 365,750 persons according to the 1999 population census. Of these 184,231 were males and 181,519 females. According to ‘The Geographic Dimensions of poverty in Kenya’, a document by Central Bureau of Statistics, Narok has a poverty incidence of 52 per cent compared with a provincial average of 48 per cent for Rift Valley.

The proposed project is situated 3 kms from Emarti which is the closest town. If accepted by NEMA, this would form part of a conservancy which would be the northern-most conservancy from the Maasai Mara National Reserve which is about 50 kms south of Naretoi. A separate study shall be conducted for the proposed Conservancy. The proposed resort is expected to generate employment opportunities and increase economic activity in the area including increased tourism interest in Kenya. This is because for the first time, tourists would be able to enjoy the unique combination of enjoying a game of golf in the midst of nature. To the north of the proposed site, there are a number of small-holder farms and cattle rearing families. The resort would provide a ready market for produce, both agricultural and animal, for these farmers and pastoralists.

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4.14 Infrastructure Facilities 4.14.1 Proper infrastructure is essential in ensuring that visitors and service providers are able to offer their services and also enjoy their stay in this remote area. 4.14.2 Telecommunication The area is not well served with a proper communication network. Safaricom network coverage is available, but only in certain areas of Naretoi. Other wireless telephone service providers have not installed communication masts to cover the area probably due to challenges arising from lack of electricity. 4.14.3 Roads The main road leading to the existing Olerai Farm is a murram road that is motorable during the dry season but provides a serious challenge when it rains. It is a government road (C 10).

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Fig. 13: The Proponent has planted thousands of trees (middle distance, behind cultivated area). It is anticipated that these shall provide water-heating services for the rooms, and keep guests warm in cold month.. It shall also be used as building material.

4.14.4 Airstrips Naretoi is served by Ngerende landing strip. This is one of 3 bigger landing strips serviced by Air Kenya, the other two being Kichwa Tembo and Keekorok respectively. These airstrips are also used by KWS to monitor park operations and wildlife movement while also carrying out air surveillance to provide security. Naretoi have a private airstrip which they would like to continue using during operation of the project. 4.14.5 Water The proposed Naretoi Golf Resort intends to provide piped water. Elaborate plans have been made to enable water recycling by as much as 65%, namely through constructed wetlands and the use of biodigesters. Rainwater will be collected as well. The existing potential sources of water for the proposed facility shall be abstracted from the Mara River that passes next to the proposed site. As water is already being abstracted for the ongoing horticultural farming, minor, if any, adjustments will be made at the existing pump house. Included in the design of water provision will be a recycling plant, where grey water from the houses will be recycled, treated by a bio-digester, and used for irrigation. Some of it may be pumped back into the houses, but this would be used just for flushing toilets. This measure would drastically reduce the amounts of water that would otherwise need to be diverted from the river. A separate system shall require the installation of a water treatment works to treat the water for domestic consumption.

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4.14.6 Electricity Supply The area is not served with electricity since there are no power line grids within the vicinity. In the reserve itself, service providers are encouraged to use eco-friendly sources of power to offer tourism services within the game reserve. The options available for this site include hydro-power generation from the abundant waters of River Mara, using solar panels and windmills. The Proponent proposes to explore the possibility of installing a turbine to generate power. Generators are not encouraged due to noise and smoke pollution and will be used only as a last resort. 4.15 Location of Nearest Fire and Police Response Teams The nearest public fire brigade service is that of Narok County Council located more than 80 kms away from the proposed site. Armed KWS guards are located approx. 10 kms away from the site. 4.16 Demographic Characteristics The proposed site is located outside the Maasai Mara National Reserve. Population here is sparse, with Maasai families living in manyattas and houses with distances of several kilometres between them. The nearest lodge is Fairmont (formerly Mara Safari Club), located approximately 10km away, also outside the reserve.

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The project was deemed out side the development moratorium area which was lifted recently by the Chairman of NEMA. The project site is within an agricultural zone, but it intends to contribute 24,000 acres towards the Mara ecosystem and call it Enonkishu Conservancy (see above). The aim of the conservancy is to contribute to the welfare of vulnerable wildlife and their habitat, which is danger of being destroyed. Without this conservancy and project the Mara would loose a potential 24,000 acres of ecosystem. 4.17 Land Tenure The land, on which the proposed Naretoi Golf Resort will be developed, is outside the Maasai Mara National Reserve and within an agricultural zone. It is privately owned by Olerai Farm Ltd. The land for the proposed Conservancy, however, which will be developed alongside the resort, will comprise of land belonging to several Maasai families, all of whom have come together to provide land for conservation purposes and conservation income.

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4.18

Employment Opportunities and Operations The proposed resort is envisaged to provide short-term and long-term employment opportunities. It will also provide direct employment to scores of workmen during the construction phase. During the operations of the facility, there will be opportunity to engage permanent employees (skilled and unskilled) from the local community and elsewhere to provide services under permanent employment. As echoed by the local administration and community, the Proponent is expected to offer job opportunities to the local community so as to generate income for them. There will also be indirect employment from other support activities associated with both construction and operation of the resort.

4.19 Stakeholder Consultations During this EIA Study, various stakeholders have been consulted to obtain their honest opinions and views on the proposed project. 4.19.1 Purpose of Stakeholder Consultation The main purpose of carrying out the stakeholder consultation is to obtain community views and concerns on the proposed project. This is done with the aim of incorporating their contribution into the project development to safeguard the environment and the interest of the local communities who form an integral part of the stakeholders. Secondly, stakeholder consultation is conducted to take the opportunity to elaborate the essence of the project, to inform the community of any potential negative impacts and elaborate on the positive aspects so that an informed decision is made by the stakeholder. 4.19.2 Mode of Stakeholder Consultation Stakeholder consultation was conducted using various modes which included the following:  Interviews and discussion  Stakeholder Workshop meetings  Barazas and group discussions

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 Questionnaire administration where a questionnaire is given to the stakeholder to fill in. The questionnaires distributed to various stakeholders have been included in Annex 4 and minutes of the Stakeholder workshop are included in Annex 5. 4.19.3 Stakeholder Consultation Results Majority of the views obtained during the consultation supported the development of the resort as a positive move that will provide increased tourist accommodation, create employment opportunities and generate revenue which the local administration and local populace would like to benefit from. However, some concerns were noted and suggestions given in order to reduce the potential environmental impacts. These included:  Sound solid waste management through the provision of adequate and secure waste collection bins within the resort area;  Proper construction of sewerage lines and septic tanks for the management of generated sanitary waste;  The developer of the resort to ensure that it blends with the host environment;  Confirmation that the proposed resort site is not within the wild animal migratory routes since this can interfere with the natural existence of the animals thus creating stress and conflict;  Assurance that mitigation measures are instituted to safeguard the most sensitive receptor within the vicinity (Mara River);  Assurance that tourism activities within the area do not affect the harmonious existence of wildlife e.g. lighting of huge open fires at night, playing of loud music at the facility;  Local population to be considered for various job opportunities that shall come up;  Location of facility at safe distance from Mara River Bank;  There should be no introduction of exotic species;  No employment should be given to minors especially ladies as this will promote prostitution;  Lighting should be regulated to reduce impact on animal behaviour;

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 Solid waste should be carried away and the use of bio-digesters explored;  Management of solid and liquid waste generated by the resort should be done through properly constructed facilities and well managed collection and disposal procedures;  Increased noise levels from Tour Van Traffic;  Air pollution emanating from dust during construction and operation phases;  Visual intrusion if project structures do not blend in with the existing environment;  Security provision to staff during construction and operation phases and the tourists who shall be visiting the resort;  There should be Annual Environmental Audit to assess the impact of the resort operations on the environment and timely institution of mitigation measures on any observed impacts;  The Proponent should ensure dispersal of visitors by providing a variety of attractions away from the usual/typical park attractions;  The carrying capacity of the ecosystem should be assessed to ensure that it does not overburden the area and impact on biodiversity;  Where feasible, as much as possible, the local community should be given priority in job opportunities. 4.19.4 Consulted Stakeholders During the field investigations, the Consultants held discussions and interviews with various stakeholders including the following:  Local community and Administration  Water Resources Management Authority (WRMA) – Narok Outpost  County Council of Narok and other departments within the Council  Community leaders Majority indicated that a resort providing 5 houses accommodation, to begin with, is generally within the low end of potential impact to the environment compared to current land uses. As the project expands, it is anticipated that the sheer size of the area will mean impact on the environment will continue to be low. However, they emphasised that the Proponent has to provide the necessary mitigation measures to ensure that the environment is protected from
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potential negative impacts. Their opinions and observations are elaborated in Annexes. 4.20 Analysis of project alternatives During the course of formulating the proposed project, several project alternatives were considered to ensure that the best option of project development was adopted. The project alternatives considered include the following: 4.20.1 Alternative to a Golf Resort Facility The need for a Tourist Golf Resort within the greater agricultural zone near the Mara Area Currently there are no golf courses in Kenya that allow for game viewing at the same time. The proposed resort shall therefore serve to provide additional accommodation outside the National Reserve, thus taking pressure off the reserve itself. It would also offer alternative activities for tourist to engage in other than game viewing, thus relieving some pressure on the game viewing areas. 4.20.2 Alternative to Site Proposed Resort Location The Proponent has for some time now felt that Naretoi should be returned to what it is naturally supposed to be, that is, wildlife terrain. In addition, farming in this area has provided its own challenges, not least among them the difficulty of managing the soil-type for horticulture (black cotton soil). With sweeping, breathtaking, scenic landscapes, wildlife, nature and authentic cultural experiences the Maasai would offer, Naretoi provides an ideal combination of factors necessary for promoting a new kind of tourism in Kenya, i.e. Sports-based Tourism. In addition to golf, polo and equestrian activities would be introduced as alternative sporting activities.

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The resort promotes reduced vegetation clearance, given that the Proponent intends to blend the resort with the existing biodiversity while taking the opportunity to rehabilitate the area by planting indigenous trees within the site area. Site Area Accessibility The present site location is close to an existing murram road and can easily be accessed without having to remove vegetation to pave way for new access roads. 4.20.3 Alternative to Design Proposed Resort Construction Design Several options of design have been evaluated and the current adopted design has been considered to blend well with the existing environment.  The proposed resort has been designed to have a maximum of 120 beds for visiting tourists. However the nature of the facility would be to run at much lower occupancy than the current tented camps which would aim to run at a minimum of 30% occupancy. Naretoi would aim to run at a minimum occupancy of 15% due to guests using the facility as second holiday homes. Given that the area proposed for the golf-course and structures around it is 1300 acres, this can generally be considered a low impact facility;  As much as possible, construction materials used will consist of locally available materials;  The roof structure will be constructed using sisal poles and gum pole trusses covered with grass thatching. These selected materials for construction of the Camp are expected to blend with the natural environment and increase the scenic beauty of the site area. 4.20.4 Alternative to Energy Source

Energy Source for the facility The Proponent has indicated that priority for energy source shall be ecofriendly (solar panels or hydropower from an installed turbine in the Mara

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River). This shall significantly reduce smoke and noise pollution that could affect the harmonious habitat/existence of wildlife. This is expected to be an effective and environmentally friendly source of energy (less noise and gas emissions) given the semi-arid climate with plenty of sunshine available, and the presence of a perennial river. This will also guarantee energy supply without interruption. The Proponent has also planted several Eucalyptus trees, at staggered intervals, to ensure a continuous supply of sustainable and planned woodfuel which will be used eventually to provide hot water in the various houses. In cold months this could also be used to warm houses and the club house. Other possible sources of energy include windmill energy which the Proponent is willing to explore. Wind energy is eco friendly, and the Proponent is eager for the resort to be the most eco-efficient and carbonneutral facility in the wider Mara area. However this is not a common energy source in Kenya and the area being remote would increase maintenance costs. Energy source from generators will only be limited to bridging when there is no energy from the principle source due to its elevated noise levels and smoke emission. 4.20.5 The “No Project” alternative The alternative of not having the golf resort constructed would have the benefit that the locality would remain as it is, i.e. a horticultural farm. The Proponent of the resort undertakes to revegetate bare areas through planting indigenous trees and maintaining the landscape, thereby improving the flora of the area. Closely tied to this is the Proponent’s aim of working closely with the Maasai on herd management. This will involve an emphasis on quality rather than quantity of cows, thus giving the land time to heal from serious over-grazing in parts. An improved stock will also mean the cows will be stronger and better able to resist drought.

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The no project alternative will deny tourists the opportunity of enjoying a unique and exciting experience of playing golf in an environment where they can also view game. The Narok County Council will not enjoy revenues earned from the proposed facility, and the Government will also miss out on revenues that would have been earned from overseas guests. 4.21 Project Lifespan and Decommissioning In the event that the Proponent would wish to cease resort operations, the expectation is that the golf course and all accompanying structures would be decommissioned and demolished. This would restore the host environment close to its original state prior to the resort being built, through rehabilitation. The demolition exercise shall involve the following:  Demolish and remove all the concrete works  Demolish and remove all the sanitary utilities (sewerage lines and septic tanks)  Demolish and remove the wooden and roofing materials  Carefully remove all the electrical fittings and associated cables  Ensure proper handling of the demolished materials and have an authorized and guided transportation and disposal system away from the wildlife conservation area. The host environment shall thereafter be rehabilitated and restored to its former state through:  Approved and appropriate landscaping methodology  Planting of indigenous vegetation  Removal of any soils that may have been impacted by oils or fuels for offsite (away from the conservation area) remediation.

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5

POSITIVE AND POTENTIAL NEGATIVE ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES The development of the proposed golf resort at Naretoi would change both the biophysical and socio-economic salient environmental features of the area. During implementation, potential positive and negative environmental impacts are expected to arise from the construction and operation phases.

5.1

Positive Impacts The positive impacts of the proposed development are expected to include creation of employment and generation of income and revenue from the Proponent and tourists using the facility. The other benefits are as outlined in table 1 below: Table 1: Positive impacts of the proposed golf resort and the Justification Ite m 1. Positive Impact The operation of a 24,000 acre conservation area, partnering with the local landowners to protect the environment and valuable species found in the area. Generation of Direct and Indirect Employment and Income Justification With the start and operation of Enonkishu Conservancy 24,000 acres and 200 families will be involved in a partnership to create, expand and protect the Mara ecosystem. The area is in an agricultural zone and this conservancy will bring a new income stream for 1000s of individuals and an ecosystem which tourisms can enjoy.

2.

3.

Provision of Tourist Accommodation and
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The proposed golf resort will create employment opportunities. This will embrace both permanent and temporary staffing. Besides the direct employment by the proposed development, other forms of employment are likely to result from the spill over effects, through indirect services during the construction and operation phases. The employment opportunities will generate income and improve the living standards of the local population and its environs. Provision of luxurious yet rustic and attractive tourist accommodation within its own Enonkishu
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a unique sporting opportunity within The Greater Mara 4.

5.

6.

7.

Conservancy. A game of golf is expected to attract high-end, big spending niche tourists looking for additional excitement to the normal game drives currently offered by the Mara. Eased pressure on The development of the proposed golf resort shall the Mara National provide increased accommodation to cope with Reserve through the ever increasing number of tourists visiting the provision of Maasai Mara National Reserve in an area where alternative there is NO current tourism so no additional accommodation off pressure. This will take pressure off the National the reserve Reserve as the country continues to promote The Great Migration as one of the new wonders of the world. Provision of a The proposed resort shall have a swimming pool recreation facility in addition to the golf course. Other facilities being proposed include an equine facility, polo facilities and a rugby pitch. Guests to the facility will also have the opportunity to view wild animals that come close to the resort area. Contribution to  There shall be increased government revenue Government collection through payment of gate fees by Resources (KWS tourists that shall be seeking accommodation at Maasai Mara Naretoi and who wish to drive to the Reserve; National Reserve  The development and running of the proposed Gate Fee Collection) golf resort shall result in payment of the necessary licence fees and levies by the Proponent to KWS and the Local Authority of Narok;  The Proponent is expected to pay a fee to NEMA for the EIA Licence of 0.05% of the total cost of the Project is USD15m. Improved landThe Proponent has documented through the scaping and structural architectural drawings, and a specially sculpturing of golf appointed golf architect, that the majority of the course and houses materials shall be obtained locally and the that blend with the structures shall be made to blend with the local environment environment and improve the scenic beauty of the area.

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5.2 5.2.1

Potential Negative Impacts Potential Impacts of Construction Activities The main construction activities that will affect the environment of the proposed resort include:  Excavation and disturbance of soils and geological formation  Construction activities and shaping of the proposed golf course facilities and other activities associated with civil works including construction of drainage lines and sewerage septic tanks:  Domestic sewerage waste from the construction camp  Water demand for construction personnel and activities  Site Construction Waste  Dust Emission  Noise from construction machinery  Fossil Fuel Emission (Smoke Emission from construction machinery and Generators when in use)  Oil waste from vehicles and machinery  Security for the construction personnel  Malaria Health Risks to Construction Personnel  Proximity of proposed resort to Mara River  Effects of construction activities to wild animal environment.

5.2.2

Potential Impacts from Operation Activities Expected impacts once the golf resort is complete and operations begin include the following:  Domestic sewerage waste from the houses, club house and staff houses  Solid waste from the houses, club house and staff houses  Smoke emissions from tour vans, site operation vehicles and generator  Noise from machines (generators), tour vans and other vehicles visiting the resort  Provision of security for tourists and resort personnel  Malaria Health Risks for resort personnel and tourists  Oil waste from vehicles and machinery  Increased water demand for resort operations (domestic consumption and watering the greens – though this will be done using recycled water)
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 Effects of resort operation activities to wild animal environment Table 2 below forms part of the Environmental Management Plan and identifies the possible negative impacts and proposed mitigation measures.

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Table 2: Negative Impacts of the proposed golf resort and the Proposed Mitigation Measures Ite m 1. Activity Resort facilities Negative Impact Design Blending with the natural Environme nt Soil erosion, siltation, flooding and collapse of excavated areas Mitigation Measures Responsibili ty  Olerai Limited  Golf Architect  Architect Timing Before Construct ion Cost (Kshs) 6,000,00 0/=

2.

Soil Excavatio n

The resort facilities have been designed and the proposed construction materials shall be evaluated following the Ministry of Public Works building codes and approved to comply. Majority of the materials to be used shall ensure the finished structure blends in with the natural environment. During site preparation (excavation) for construction and  Olerai shaping of the golf course the Proponent and contractor Limited undertake to ensure that:  The Contractor understands the preferred construction process by ensuring that the existing features that are  Contractor supposed to be incorporated in the construction and golf course design are not excavated or removed  The site preparation process is done with utmost care to ensure that excavation is done systematically and carefully without raising dust and creating unpleasant heaps of soil  The Contractor undertakes to rehabilitate any degraded environment especially the reconstructed/redeveloped part of the area.

During 5,000,00 Construct 0/= ion and Operation Phases

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Ite Activity m

Negative Impact

Mitigation Measures  The degraded environment especially excavated areas prone to soil erosion will be rehabilitated in-situ (as the construction progresses) to avoid soil being washed down gradient and into the Mara River  Any loose soils are compacted to avoid any wash off  All disturbed areas are well landscaped to improve on visual intrusion  Storm water drainage lines are well constructed to reduce incidences of ponding and flooding. This also encourages groundwater recharge. This is in line with the provision of Public Health Act, Cap 242 The process of rehabilitation (planting of indigenous plants to improve scenic beauty of site area) is carried out where possible when construction is in progress to avoid siltation and soil wash off.

Responsibili Timing ty

Cost (Kshs)

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Ite Activity m 3. Drainage and Sewage Lines Constructi on

Responsibili Timing ty Olerai Limited management and the Contractor will ensure  Olerai During proper construction of sewerage and drainage lines in the Limited Construct project area. Carry out proper landscaping and filling ion depressions at the time of construction and immediately  Contractor after. This is to avoid creating breeding ground for malaria vectors.(This is in line with the provision of Public Health Act, Cap 242) 4. Constructi Accidents Olerai Limited and the Contractor will ensure:  Olerai During on and  The implementation of safety measures and emergency Limited Construct Activities Occupatio plans to contain accident risks associated with vehicle ion by nal Risks transport, operation of any sophisticated machinery and Contractor  Contractor other related activities. Personnel  Emergency response plans/procedures including details (phone numbers and location) of the nearest dispensaries, hospitals and the Proponent’s site manager will be provided to the Site Foreman / Site Manager for action in case of any accidents during construction.  All staff is trained in the use of any unfamiliar machinery and equipment that may pose danger to the user before they are allowed to use it. Particularly important is the provision of protective clothing, helmets, dust masks etc. 5. Workers Public During  Attention will be paid to sanitation on the site by  Olerai
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Negative Impact Ponding Risks

Mitigation Measures

Cost (Kshs) 50,000,0 00/=

100,000/ =

20,000,0

ECOPLAN Ltd.

Ite Activity m Health (Potential spread of HIV/Aids amongst workers)

Negative Impact Health Risks to workers during constructio n and operation (HIV/Aids Education Health of Awareness Tourists )

Responsibili Timing ty providing clean water and proper house-keeping. Effective Limited Construct wastewater management (provision of sanitary facilities) ion and (This is in line with the provision of Public Health Act, Operation Cap 242)  Contractor  Provision of biodigesters, constructed wetlands and septic tank facility to avoid impacting the environment and especially the Mara River as the nearest sensitive receptor (This is in line with the provision of Public Health Act,  Naretoi Golf Resort Cap 242)  Provision and use of mosquito repellent nets (This is in Manager line with the provision of Public Health Act, Cap 242  Conducting HIV Aids awareness campaigns among employees regularly (yearly) Health of  Over the counter medicine for use in case of sickness to Tourists staff and tourists  Emergency response plans/procedures including details (phone numbers and location) of the nearest dispensaries, hospitals to be provided to the Resort manager and also be available to tour guides for action in case of tourists falling sick while on visit to the resort

Mitigation Measures

Cost (Kshs) 00/=

Routine Activity

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Ite Activity m 6. Construct ed wetlands and installatio n of biodigesters Water abstractio n from Mara River to supply adequate water for Workers and Tourists

Negative Impact Increased Water Demand

Mitigation Measures

Responsibili Timing ty The construction and operation of the proposed Naretoi  Olerai During Golf Resort shall require the provision of adequate water. Limited Construct To this end, bearing in mind sensitivities surrounding the ion and Mara River, the Proponent shall have constructed wetlands Operation and biodigesters incorporated into the project design to  Contractor enable recycling of most of the water to be used in the project (as much as 65%). Currently the site area is supplied by water from the Mara which is abstracted for irrigation purposes. Olerai Limited shall ensure that a water abstraction permit from the Water Resources Management Authority Offices in Narok is valid and up-to-date for its proposed activities. Olerai Limited shall then ensure that during construction and operation:  The water abstracted from the river is treated (full chemical and bacteriological analysis is done) to establish if it is fit for construction and domestic use.  There is proper management of water usage. Avoid unnecessary wastage  Installation of a reservoir water tank and water conserving taps that turn-off automatically when water is not being used. Avoid unnecessary wastage
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Cost (Kshs) 1,800,00 0/=

ECOPLAN Ltd.

Ite Activity m

Negative Impact

Mitigation Measures

Responsibili Timing ty

Cost (Kshs)

 Recycling of water used in the swimming pool  Recycling of water used on the greens  Recycling of water used for gardening  Recycling of water for flushing toilets in the houses and club house 7. Resort Solid and  Special attention shall be paid to the handling and disposal Constructi Liquid of all solid waste generated during construction and on and Waste operation phases. A reputable solid waste handler will be Operation Generation contracted to regularly collect solid waste for appropriate disposal following the Local Authority Guidelines. There will be adequate provision of strategically placed waste bins all over the compound to ensure that there is no idle litter that can be accessed by baboons (This is in line with the provision of Public Health Act, Cap 242)  Non-usable solid waste materials generated during the construction shall be transported for appropriate disposal in Narok.  Due to the proximity of the resort to the Mara River, the Proponent undertakes to provide well constructed sewage lines all draining into septic tanks that shall be regularly emptied by an exhauster.  All waste receptacles shall be at least 50m away from the

 Olerai Limited

During 100,000/ Construct = per ion and month  Contractor Operation Phases  Naretoi Golf resort Manager  Waste Collection Firm

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ECOPLAN Ltd.

Ite Activity m

Negative Impact

Mitigation Measures Mara River bank Staff education on the importance of sound environmental management through proper handling and disposal of generated waste due to the fragile environment where the resort will be located

Responsibili Timing ty

Cost (Kshs)

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ECOPLAN Ltd.

Ite Activity m 8. Noise Generatio n and Air Pollution

Negative Impact Noise, air pollution from machines/g enerators and dust generation during resort constructio n and operation

Mitigation Measures

Responsibili Timing ty  Olerai Construct Construction  Relatively high noise levels are expected in the area Limited ion and Operation during the construction phase. Noise control measures will be implemented at the site area if the noise levels  KWS exceed 85 dBA for a continuous 8 hours. In addition, protection against the effect of the noise exposure among  Contractor the workers should be effected.  Sound levels reaching the inner ear may be effectively attenuated by the use of protective devices, such as  Naretoi earplugs and earmuffs. Appropriate selection of Golf Resort machinery would minimise noise pollution. The Manager contractor is expected to minimise (preferably avoid altogether) the use of explosives during the excavation process  Construction Supervisors shall be encouraged to sensitise construction workers to switch off engines of vehicles or machinery not being used  Sensitise vehicle drivers to avoid hooting or revving of engines.  Ensure construction machinery is kept in good working condition. Spraying of water during construction to reduce dust emissions
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Cost (Kshs) 100,000/ = per month

ECOPLAN Ltd.

Ite Activity m

Negative Impact

Mitigation Measures Operation  Ensure that all generators are attenuated and heavy duty equipment is insulated or placed in enclosures to minimise noise pollution.  Alternative energy source to replace generators to reduce fossil fuel emission  Quiet Energy sources like solar power will be preferred over the use of generators that cause air pollution and produce excess noise which is not favourable for the wildlife habitat environment  Drivers entering the Naretoi area shall be expected to control the speed of their vehicles (approx. 30km/hr) to reduce dust emission and other risks including the risk of knocking wild animals  The resort shall have controlled noise levels from the various entertainment centres  Drivers will need to be instructed to desist from hooting unnecessarily. Olerai Limited shall be required to put up sign posts within the resort area issuing instructions to drivers on speed control and discouraging unnecessary noise generation from vehicles.

Responsibili Timing ty

Cost (Kshs)

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ECOPLAN Ltd.

Ite Activity m 9. Security and Fire

Negative Impact Risk of fire and site security

Mitigation Measures

Responsibili Timing ty Protecting the Site from a fire outbreak will be achieved  Olerai During through sound engineering, reliable operations, written Limited constructi operating procedures, trained employees, good preventive on and and predictive maintenance techniques and commitment to  Naretoi Operation safety. Olerai Limited shall provide fire fighting equipment Golf Resort during the construction and operation phases of the resort Manager and also ensure that the following are done:  Install and maintain fire fighting equipment and  Contractor machinery  Sensitise the workers on fire risks and the use of fireproof materials  Provide emergency numbers at strategic points  Portable fire fighting equipment is located at strategic points  Provision of security during the construction and operation phases  Ensure that all workers have access to communication facilities for quick emergency response

Cost (Kshs) 100,000/ = per month

10. Resort Mara River Olerai Limited management will ensure that:  Naretoi During Routine Constructi and  No domestic or any other hazardous waste is disposed of Golf Resort Construct Site on and Groundwat at the site or the nearby river water body Manager ion and Operatio
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ECOPLAN Ltd.

Ite Activity Negative m Impact Operation er Pollution

Responsibili Timing Cost ty (Kshs) Operation n  A riparian reserve distance of 30 meters away from the river water body will be observed to avoid pollution and  Contractor protect the resort from any potential flooding. In addition Naretoi have acquired a 100m reserve designated across the river along the course of the site to protect the river  Naretoi Golf Resort ecosystem as it passes through the project site.  Machinery and used oil from vehicles is not released to Manager the ground through the provision of mode of collection and appropriate disposal.  Clear instruction to machine and vehicle servicing personnel on this provision should be made available. In line with the provisions of the Water Act, 2002 and Public Health Act Cap242 11. Vehicle Increase in Olerai Limited management will ensure that:  Olerai During Routine and vehicle and  All drivers comply with traffic regulations such as speed Limited Construct Site Human human ion and Operatio limits (30km/hr or less) during construction and operation  Naretoi Presence traffic  Workers and tourists are well informed about the danger Manager Operation n during of straying beyond the resort area as there is risk of  Contractor constructio encountering wild animals. n and operation 12. Resort Degradatio Maintain existing trees and plant more indigenous species  Olerai During Routine
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Mitigation Measures

ECOPLAN Ltd.

Ite Activity m Constructi on and Operation

Responsibili ty to rehabilitate the resort environment and improve the Limited scenic beauty of the area.  Naretoi  Ensure rehabilitation of exposed and over-grazed areas by Manager planting indigenous grass and through pastoralist  Contractor sensitisation on herd management  Carry out regular watering and maintenance of the trees that have been planted. 13. Presence Unnecessa Olerai Limited shall be expected to provide dim lighting to  Olerai of resort ry Bright avoid creating unnecessary attraction to game animals Limited within the or Flood during the night.  Naretoi vicinity of Lights Manager the within the Turning off all unnecessary lights at night to avoid  Contractor MMNR resort area unnecessary attraction of wild animals during the night. 14. Presence Effect of The proposed site for the permanent golf resort has been of resort resort on carefully considered to ensure that:  Olerai within the Wildlife,  The wetland area within Naretoi is avoided Limited vicinity of Disturbanc MMNR e of wildlife movement pattern 15 Park Ecosystem Carry out an Environmental Audit after the first year of

Negative Impact n of existing Vegetation

Mitigation Measures

Timing

Cost (Kshs) Construct Site ion and Operatio Operation n

Construct Routine ion and Site Operation Operatio n

Before Approval for Resort Construct ion

Routine Site Evaluati on

During
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Routine

ECOPLAN Ltd.

Ite Activity m Ecosyste m

Negative Impact Carrying Capacity

Mitigation Measures

Responsibili Timing ty operation to assess effects emanating from the emergence of  Olerai Operation the resort in order to enhance any positive impacts while Limited s of the immediately addressing negative impacts. Camp  Naretoi Mandatory Annual Environmental Audit that will evaluate Golf resort any changes in the ecosystem (flora and fauna). Manager  Audit Report to evaluate animal behaviour patterns resulting from presence of the golf resort and also record  Environme ntal any improvements noted in fauna rehabilitation. Consultant

Cost (Kshs) Site Evaluati on

200,000/ = per Audit

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ECOPLAN Ltd.

6

ENVIRONMENT MANAGEMENT PLAN The Environment Management Plan (EMP) is an important process of ensuring project sustainability and environmental protection. Whereas efforts are usually made to develop mitigation measures for a proposed project, it is during the operation lifespan of the project that actual impacts are noted or experienced. It is therefore important to integrate in the environmental impact assessment process, an environment management plan that includes the monitoring of the progress of mitigation measures being implemented while also monitoring the project for any new negative impacts that were not earlier considered or anticipated.

6.1

Environmental Monitoring Plan Environmental monitoring is an important integral part of the environmental project management process. It rationally completes the process that begins with:  Establishing the environmental baseline condition  Carrying out the environmental impact assessment  Implementation of mitigation measures, and finally  Monitoring the success of those measures.

6.1.1

Sound Environmental Monitoring Environmental 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 resort, once it starts operating, should at least include the following parameters:

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ECOPLAN Ltd.

 Collection and analysis of relevant environmental data of the site including:  Maintenance status of drainage and sewerage facilities  Evaluation of the type and quantity of solid waste generated at the resort  Evaluation of the type and quantity of liquid waste generated at the resort  Evaluation of noise and other effects emanating from the resort on wild animal behaviour within the vicinity of the resort  Evaluation of the type of energy used and its effect on the immediate environment  The amount of water consumed and how the waste water is efficiently handled and disposed of  Seasonal variation of the presence of disease vectors (mosquitoes)  Effects of Vehicular and Human Traffic on wildlife  Identification of unexpected environmental impacts  Formulation of counter-measures to mitigate against the unexpected negative impacts while comparing them with actual impacts as identified during the assessment. Responsibility: Olerai Limited/Naretoi Resort Manager Timing: During Construction and Operation Phases 6.2 Internal Audit (Environmental Operation Survey) In order to sustain a healthy environment in the project area and its environs and to ensure that minimal negative impact is imparted on the resort ecosystem, the management should undertake to monitor the quality of the environment as a routine practice. Monitoring will involve measurements, observation, evaluations, assessment and reporting on variables once the resort becomes operational. It shall therefore be useful for the resort operator to institute internal environmental audits (Environmental Operational Survey) as this will assist in improving operations of the facility and protecting the environment. Components of the Environmental Operation Survey may include evaluation of the following:

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ECOPLAN Ltd.

1. Solid Waste Management on a regular basis through having the staff of the resort (Resort supervisor) estimate the quantity of solid waste generated at the resort (from the private residences, the club house and staff houses) on a daily or weekly basis. This will assist the resort operator to provide adequate solid waste storage facilities before it is collected for disposal away from the resort. 2. Condition of the Sewerage Systems (Sewerage Lines and Septic Tanks) on a regular (daily) basis to ensure that any failures are noted early enough for maintenance to be carried out. 3. Due to the distance of the proposed resort from the nearest medical centre, the resort management is to ensure availability of standard over the counter drugs e.g. painkillers, malaria drugs and a well stocked first aid kit. 4. The resort is to ensure that at any one time it has one of its staff members capable of administering first aid prior to any afflicted person being transferred to a medical institution for treatment. 5. Taking note of the water consumption trend to be able to provide adequate water and also stop any wastage or carry out surveillance on leakages. 6. Seasonal variation of the presence of disease vectors (e.g. mosquitoes) since this shall assist the resort to advise tourists on potential dangers of getting malaria and what precautionary measures are appropriate while being accommodated at the golf resort. 7. Evaluation of fire fighting equipment by having a relevant maintenance team check it regularly and test its functionality. 8. Provision of appropriate and polite posters within the area guiding the residents and staff in various aspects of environmental protection including:  No throwing of litter apart from at designated areas to ensure that wild animals like baboons that might encroach on the resort do not scavenge on them  Do not feed wild animals  Do not go beyond this point without assistance or escort for safety reasons  Early reporting to the resort management of any unusual health feelings (e.g. some persons may not know the symptoms of malaria until they are very sick).

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ECOPLAN Ltd.

The above information is vital for the smooth running of the facility and environmental monitoring. Olerai Ltd is encouraged to ensure that the resort manager is able to monitor all activities and keep records for review by KWS and other Authorities. Responsibility: Olerai Limited and Naretoi Golf Resort Manager Timing: During Construction and Operation Phases

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ECOPLAN Ltd.

7

CONCLUSIONS AND RECOMMENDATIONS The Proponent’s wish is to have a unique, Eco-friendly project. This will be possible only after re-building the environmental damages that the farm has done over the last 12 years. Every element of service delivery must demonstrate the clear intention to reduce the ecological footprint of the project. It is imperative that the development and the operators embrace principles of environmental sustainability and social responsibility seeking a ‘high-end, low impact’ project. With the formation of the Enonkishu Conservancy the Olerai project would be increasing the important Mara ecosystem by 24,000 acres. This project would be funding the protection of game and the natural habitat; moreover the leases to the local landowning community would sustainably contribute to an increase in local incomes and give the Mara Ecosystem and wildlife a further 24,000 acres to its shrinking area. Water recycling will be a fascinating design development. Each house can be provided with its own septic tank and radial arm soak-away system. This will work well, and the radial arms will need rebuilding every 5 to 10 years, depending upon usage. A number of constructed wetlands will be constructed to accommodate the entire development. The advantages here would be that the resulting substantial waterscapes could be used to dramatic visual advantage. The end results would encourage wildlife and birdlife into the new wetlands with obvious advantages: game viewing, bird hides and fishing.

7.1

Conclusion It is quite evident from this study that the construction and operation of the proposed golf resort would bring numerous positive impacts locally, nationally and indeed to the region. Potential negative effects in the project area also exist, hence the need for mitigation measures. The effects, both positive and negative, are listed below:

7.1.1

Positive Effects  Resort Structures that blend in with the environment  Generation of direct and indirect employment and income
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ECOPLAN Ltd.

 Provision of tourist accommodation off the Maasai Mara National Reserve  Provision of diverse recreational facilities in a unique setting  Contribution to government resources (Maasai Mara National Reserve) Gate Fee Collection and NEMA EIA Licence Fee  Improvement of the site area biodiversity. 7.1.2 Potential Negative Effects Although the proposed development will have positive effects there are negative environmental implications that are associated with its implementation. The potential negative impacts of this project include:  Loss of topsoil and siltation during construction  Visual intrusion  Ponding risks  Accidents and occupational risks  Public health risks  Increased water demand  Waste generation  Noise and air pollution  Fire risks  Water pollution and  Increased traffic. Fortunately many of these are confined to the construction phase of the project. 7.2 Project Evaluation for Recommendations The Proponent (Olerai Limited) has ensured that the upcoming project is located at an appropriate site and is environmentally sound through the following:  The Contractor undertakes to rehabilitate any degraded environment especially the reconstructed/redeveloped part of the area.

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ECOPLAN Ltd.

 The degraded environment, especially excavated areas prone to soil erosion, will be rehabilitated in-situ (as the construction progresses) to avoid soil being washed down gradient  Compaction of any loose soils as construction progresses to avoid soil wash off  All disturbed areas are well landscaped  The process of rehabilitation is implemented at the time of construction to avoid siltation and soil wash-off  Construction of a proper drainage system in the project area through landscaping and filling depressions at the time of construction and immediately thereafter  The implementation of safety measures and emergency plans to contain accident risks associated with vehicle transport, operation of machinery and other related activities  Emergency response plans/procedures including details (phone numbers and location) of the nearest dispensaries, hospitals, KWS Offices and the Proponent’s site representative will be provided to the Site Foreman / Manager of the resort for action in case of any accidents during construction and during operation  The contractor’s staff members are trained in the use of any unfamiliar machinery and equipment that may pose danger to the user before they are allowed to use them. Particularly important is the provision of protective clothing, helmets and gloves  Special attention will be paid to sanitation on site by providing clean water, sanitation facilities and proper house-keeping. Effective wastewater management as guided by the Local Authority shall be adhered to  Appropriate sewerage line connection to the septic tank system as provided for in the plans is followed  Special attention will be paid to the disposal of solid waste. A reputable solid waste management firm shall be contracted to regularly collect construction and domestic solid waste for appropriate disposal away from the area  All solid waste receptacles and septic tanks for sanitary waste containment shall be located at least 50m away from the Mara River Bank  Sound levels reaching the inner ear may be effectively attenuated by the use of hearing protective devices, such as earplugs and earmuffs. Appropriate selection of machinery would minimise noise pollution. Use
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ECOPLAN Ltd.

  

 

    

of explosives or loud machinery shall not be allowed during the construction and operation of the resort Construction vehicles and machinery operators shall always be asked to switch off engines of vehicles or machinery not in use to reduce air/noise pollution. Ensure that the construction machinery is kept in good condition to reduce noise generation Construction and tour drivers shall be instructed to avoid hooting especially when passing through the wildlife dispersal areas Spraying of water during construction work to reduce dust emissions shall be encouraged The Proponent and contractor shall ensure that all generators and equipment is insulated or placed in enclosures to minimise ambient noise levels The construction work shall be restricted to daytime only to ensure safety and avoid attracting wild animals There shall be proper management of water resources through prudent usage. Unnecessary water wastage shall be avoided. Installation of water conserving taps that turn-off automatically when water is not being used. Acquisition of fire cylinders and installation and maintenance of fire fighting hoses Sensitisation of the workers and tourists alike on fire evacuation plans for the facility Electrical Area classification design/drawing will be done and all electrical fittings will comply with the design Potable fire fighting equipment shall be located at strategic points where they can be easily accessed The proprietor shall ensure that at least one of the workers is trained in First Aid Administration.

7.3

Project Recommendation The proposed development will enhance biodiversity of the area, attract golfing tourists, utilize less water than irrigation, create employment for the local people, improve and enhance the livelihoods of the community and in addition diversify tourism thus minimizing the pressure on the Maasai Mara Reserve. Nationally the government will benefit through increased tourism revenues.

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ECOPLAN Ltd.

This project is therefore considered environmentally acceptable, important, timely, strategic and beneficial in taking pressure off the main reserve, and in providing convenient, luxurious tourist accommodation within a comfortable driving distance to the Maasai Mara National Reserve. On the basis of the fact that the project is environmentally sound with minimal negative impacts that can be mitigated, it is recommended that the project be approved subject to compliance with the proposed mitigation measures and Environment Management Plan (EMP). This project once operational will significantly contribute towards achievement of the Vision 2030 which aims to increase tourist beds by 2012.

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ECOPLAN Ltd.

APPENDICES

Annex 1: Annex 2: Annex 3: Annex 4: Annex 5: Annex 6:

Water Abstraction Permit Ministry of Tourism Golf Promotion Booklet Information on Biodigesters CPP (Consultation and Public Participation Questionnaires administered to various officials) Minutes of several planning meetings with community elders Approval letters  District Physical Planner approvals  Fairmont Mara Safari Club  Enonkishu Conservancy  Ministry of regional development  WWF Title Deed Architectural Masterplan Project Budget

Annex 7: Annex 8: Annex 9:

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ECOPLAN Ltd.

PEOPLE CONTACTED DURING THE EIA STUDY In addition to the site reconnaissance visits and evaluation, the following persons were consulted with regard to the execution of the proposed Naretoi Golf Resort Environmental Impact Assessment Study:            The Proponent The Project Architect The Golf Architect Min. of Tourism officials NEMA officials Several Narok South District Officials Member of Parliament for Narok South KWS officials Neighbouring tourist facilities Community leaders Ministry of Regional Development Authorities

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ECOPLAN Ltd.

REFERENCES ACTS-UNEP, 2001. The Making of a framework Environmental Law in Kenya. Acts press, Nairobi, Kenya. Environmental Management and Coordination Act (EMCA) No. 8 of 1999 Environmental Management and Coordination (Water Quality) Regulations, 2006 – Legal Notice No. 120 Environmental Management and Coordination (Waste Management Regulations, 2006 – Legal Notice No. 121 Environmental Management and Coordination (Fossil Fuel Emission Control) Regulations, 2006 – Legal Notice No. 131 Vision 2030, Government of Kenya National Atlas of Kenya, Fourth Edition (1991). United Nations Environment Programme (UNEP). 1996. Environmental Impact Assessment: Issues, Trends and Practice. 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.

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ECOPLAN Ltd.

World Bank. 1991. Environmental Assessment Sourcebook. Volume III. Guidelines for Environmental Assessment of Energy and Industry Projects. Environment Department. Technical Paper No.154. Draft Maasai Mara Integrated Management Plan GOK Wildlife conservation and management Act EIA/EA regulations, 2003 GOK Tourism Policy Kenya “Undiscovered Golfing Destination…” information from the Internet

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