World Bank Challenge Regarding Water Hyacinth on Lake Victoria

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Resources Conflict Institute
28th September, 1999
Mr. Harold E. Wackman
Country Director
The World Bank
P O Box 30577

Dear Mr. Wackman,
LVEMP - Mechanical Removal of Water Hyacinth at the Nyanza Gulf Request for
We have addressed a Request for Inspection to the Inspection Panel of the World Bank in the
envelope accompanying this letter.
Pursuant to paragraph 14 of the Inspection Panel`s Operating Procedures, we wish to deliver the
Request to the Panel through your office.
Kindly issue a receipt for the Request as stipulated in the said paragraph 14 of the Operating
Procedures, and transmit the Request to the Panel in the manner provided.
Yours Sincerely,
Michael Ochieng Odhiambo
Executive Director
C.C. Executive Secretary
Inspection Panel
Fax No. 202 - 477 - 6391
Printing House Road, P.O. Box 7150, Nakaru, Kenya Phone: 254-37-44940 Fax: 254-37-212865


Resources Conflict Institute
27th September, 1999
The Inspection Panel
1818 H Street, NW
Washington, DC 20433 USA
We, the Resources Conflict Institute (RECONCILE), acting for and on behalf of persons
in the area known as the Nyanza Gulf of Lake Victoria within the Republic of Kenya, do
present this request for inspection.
1. The communities and individuals we represent are likely to suffer harm as a
result of failures or omissions in the design or implementation by the Bank of
the water hyacinth management component of the Lake Victoria Environmental
Management Project (LVEMP) in Kenya.
Following are the failures or omissions that we believe are the responsibility of the
i) No Environmental Impact Assessment (EIA) has been done on the likely
impact of the method adopted by the Project for the mechanical removal of the
water hyacinth, to wit, the shredding and sinking of the weed to the bottom of
the lake.
ii) The tendering procedure was not sufficiently transparent and serious concerns
raised about how the tender was awarded have not been addressed sufficiently
or at all.
iii) Serious concerns raised by the communities around the lake, whose livelihoods
depend directly on the lake as well as other informed persons about the likely
ecological impact of shredding and sinking the water hyacinth to the bottom of
the lake have not been answered sufficiently or at all.
iv) Little or no regard has been had to the sustainable management of
the water hyacinth in using this method of mechanical removal, as it does not
involve the local communities in its design or implementation.
v) The stated participatory approaches and stakeholder involvement in
the design and management of the project have been totally ignored as the
Project proceeds with this method of removal of the water hyacinth in the face
of and without any regard to the concerns and objections of the affected
2. We fear that these failures and omissions shall result in the following damage
or harm:
i) The Nyanza Gulf is home to fresh water fish and the source of water for
domestic use for these communities, and these will be endangered by the
pollution caused by dumping the weed to the bottom of the lake, thereby
putting at risk the livelihoods of the people who depend on the lake. In this
connection, it is noteworthy that the lake is already heavily polluted by raw
waste discharged into it by neighbouring industries; and further that it is
shallower at the Nyanza Gulf than elsewhere.
ii) In its decomposition, the weed, being an organic material shall make
use of oxygen from the lake, thus reducing or depleting the concentration of
dissolved oxygen in the water. This will endanger the lives of the species of
fish that have little tolerance for reduced oxygen levels. Such fish include the
Nileperch, Tilapia and Dagaa, which are major sources of food for local
communities, as well as the basis of a major export trade of great importance to
the national economy. In this connection, it should be noted that the Tilapia,
Dagaa and haplochromine species of fish breed and nest largely on the
shoreline, which is the area most infested by water hyacinth. Thus, sinking the
weed shall seriously impact on the livelihoods of the local communities.
iii) There is scientific evidence that the water hyacinth is capable of
accumulating heavy metals, phenols, and toxic substances. Thus, sinking and
eventual degradation of the weed shall result in an abrupt increase of toxic
chemicals in the lake, which shall play havoc with the ecosystem.
iv) The decomposition of the water hyacinth will enhance the eutrophication of the
lake at the Nyanza Gulf with serious consequences for the ecosystem, in
addition to the increased likelihood of the regeneration of the water hyacinth.
Moreover, the likely increase of nitrate levels along the shoreline will in turn
increase the likelihood of babies below 5 years of age developing the Blue
Baby Syndrome.
3. We make this request on behalf of the communities living on the shores of Lake
Victoria at the Nyanza Gulf and who depend directly on the lake for their
livelihoods, feeding and trading in its fresh water fish species and using its water for
domestic purposes. These are communities whose livelihoods and well-being shall
be directly affected by the aforementioned impacts.
4. These concerns have been raised with the Bank staff in Nairobi by various people
on behalf of these communities, with little or no adequate response. For our part, we
wrote a Demand letter to the Project Director of LVEMP on 26th July, 1999
requiring him to address these concerns. We informed him that in the absence of an
appropriate response we would file a case in the High Court to obtain an injunction
to restrain LVEMP and Aquarius Systems from shredding and sinking the weed to
the bottom of the lake unless these concerns are addressed and the alternative
methods for the removal and disposal of the weed are taken into account. We
copied the letter to the Bank`s Country Director.
We have never received any response from the LVEMP, Aquarius Systems or the Bank.
Instead, the Bank on 13th August, 1999 convened a 3 - hour meeting at Nairobi which
turned out to be a forum for the Bank, LVEMP and Aquarius Systems to justify their
chosen method of removal of the water hyacinth. At the end of the meeting the Bank
proposed the formation of a Monitoring Group, without any specification as to who
would form or constitute the Monitoring Group nor what its Terms of Reference would
be. In the aftermath of the meeting, the LVEMP, Aquarius Systems and the Bank have
continued with arrangements to do exactly what the communities are so strenuously
opposed to. Clearly therefore, the Bank`s response has been inadequate and has not
addressed the concerns of the communities.
5. In view of this inadequate response, we are still considering the possibility of
filing suit against the Project, the Bank and Aquarius Systems. In the meantime, we
are consulting with stakeholders with a view to ensuring that the project is
implemented in a manner that does not compromise the sustainable management of
this important resource or the livelihoods of these communities.
We believe that the above actions and omissions which are contrary to the Banks policies
or procedures have materially and adversely affected the rights and interests of the
communities on whose behalf we present this request. We therefore request the Panel to
recommend to the Bank`s Executive Directors that an investigation be carried out in order
to resolve the problem.
We have made this Request for Inspection briefly in accordance with your Operating
Procedures. We are however able to provide you with more particulars on request.
Yours Sincerely,
Michael Ochieng Odhiambo
Executive Director
We authorize you to make this Request public.

Kenya Chapter
P.O. Box 68, Homa Bay, Tel: 0385-22029
Telefax: 0385-22160/22055
23rd September, 1999
ATT: Mr. Michael Ochieng Odhiambo
Executive Director
Box 7150
Telephone 254-37-44940
Fax 254-37-212865 NAKAR-KENYA

Dear Sir,
This is to register the dispute between the communities living along Lake Victoria and
LVEMP, World Bank and acquarius systems on the intended use of shedding and sinking
method of removal of the water hyacinth from Lake Victoria. Members of the
communities living along the aforesaid Lake are totally opposed to the suggested method
of shedding and sinking and strongly advocates for the weeds to be removed manually.
It is on this note that my organization is being a representative of these communities
would wish to show commitment with them by mandating you to take up the matter for
their benefit.
Ecovic strongly feels that it should not be left out of the inspection team and I don’t mind
being listed in the team. Enclosed please find a photocopy of the letter my executive
committee had written to the Executive Director OSIENALA affirming the same.
Your quick response towards this effort will be highly appreciated. Please kindly
acknowledge receipt.
Your sincerely,
Mary Atieno Amwata
Chairperson Ecovic Kenya Chapter

(Friends of Lake Victoria)
September 28, 1999
Executive Director
Resource Conflict Institute
P O Box 7150
Nakaru, Kenya
Subject: Demand Notice to LVEMP and (World Bank and Aquarius Systems)
OSIENALA ( Friends of Lake Victoria), is a community based organization representing
interest of over 4 million Lake Victoria riparian communities/stakeholders residing on the
Kenya side. OSIENALA was formed with the main objective or restoring Lake Victoria
to its former glory. As you are aware we are opposed to the proposed shredding and
sinking of water hyacinth in Lake Victoria by LVEMP, the World Bank and the Aquarius
systems, and our position on this issue has not changed.
As stakeholder organization, we fully support you for the proposed actions:
1) Demand Notice to LVEMP and (World Bank & Aquarius Systems) and
2) Request for Inspection with the Inspection Panel with World Bank in
Washington, D.C.
This letter, is therefore, to request your organization (RECONCILE) to take up the above
actions without delay for the benefit of the communities who live and benefit from the
We also request that the organization may list our name in the Request for Inspection.
Please, act with haste as they (LVEMP are determined to get ahead with the
proposed shredding and sinking of the water hyacinth.
Your sincerely,
Kinya Muniyirwa
For Executive Director
OSIENALA (friends of Earth)

(Friends of Lake Victoria)
September 7th 1999.
OSIENALA, a National NGO based in Kisumu once again wishes to emphasize its stand
on the implication of the proposed shredding and sinking of water hyacinth in Lake
Victoria. As you may be aware, an American firm, Aquarius Systems, won a tender for
the mechanical removal of the hyacinth weed from Lake Victoria. The activity is set to
start this week, despite protests from scientists and some local leaders that the contract
terms be reviewed to include assurance that the weed will be removed and dumped
outside the lake. The proposed shredding and sinking of water hyacinth into the lake will
have untold ecological decay and environmental degradation that must not be allowed in
any civilised society. The following are some of the possible ultimate effects of such an
activity: dissolved oxygen deficiency; eutrophication and toxic chemical threat.
Dissolved Oxygen Deficiency
Being an organic material, the sunk water hyacinth will undergo bacterial decomposition.
Since the bacteria involved require oxygen during decomposition, this oxygen must be
obtained from water. This will lead to the depletion of dissolved oxygen concentration.
Fish species are less tolerant to reduced oxygen level. E.g. Tilapia, Nileperch, Dagaa,
haplochloramine spp. will therefore decline since they depend on this oxygen. Other
species that will manage to survive will have their composition changed as a result of this
reduced oxygen level. It should be noted that Tilapia, Dagaa, and haplochloramine
species have their breeding and nesting grounds in the shoreline. These species are also
the main source of food for the local community since Nileperch is mainly for export.
Water hyacinth mostly infest the shoreline and therefore sinking the weed will severely
affect the most important fish species for the local community, a situation that may
worsen the already serious food insecurity in the region, due to the globalization of Lake
Victoria Fisheries.

Possible Toxic Chemical Threat:
Available scientific evidence shows that water hyacinth has the capacity to accumulate
heavy metals and phenols. The plant can retain within hours for every gram of dry matter
the following amount of substances: Cadmium- 0.67mg, Nickel-0.50mg, Lead-0.176mg,
Magnesium-0.15mg(McDonald, 1975).
It also accumulates the following toxic substances: Tannin-1% in dry matter and 2% in
leaves, Oxalate 0.8%-3.3% in dry matter (Loreo and Bressani, 1982). It is no doubt
therefore the sinking and eventual degradation of the hyacinth en-masse will result to an
abrupt increase of the toxic chemicals in the aquatic environment, a scenario that can
crush the aquatic ecosystem.

Decomposition of the sunk water hyacinth will increase the nutrient load in the Winam
Gulf of Lake Victoria, which is a very rich fish breeding and spawning area. Such as
increase will stimulate algal growth. As more and more salts of nitrogen and
phosphorous increase, more is taken up by both epiphytic and planktonic algae in the
aquatic ecosystem. This will result in an increase in their mean biomass and productivity,
but with a decline in diversity of species intolerant to low light, higher dissolved solids or
competition. This effect will completely alter the aquatic ecosystem leading to a
complete disruption of the otherwise natural life. The consequences of this may be shortterm
or long term far reaching. Due to this kind of magnitude of eutrophication and given
the fact that seeds of water hyacinth can survive for several years, it will not be a matter
of time for the water hyacinth to rejuvenate even more. Further more, if nitrate levels in
the shorelines could increase considerably, then babies below 5 years of age using such
water can develop a condition referred as a Blue Baby Syndrome.
Recent scientific evidence on effects of water hyacinth on phico-chemical characteristics
in the lake indicates that standing water hyacinth in the lake adversely alters phicochemical
characteristics of the water, how about if the weed was to be shredded and
dumped in to the lake to decay? The following would happen: Hypolinnectic oxygen
would be nil, higher amounts of ammonia nitrogen would be released into the water in the
ensuring reactions, addition of soluble organic matter to water would increase levels of
electrical conductivity, total dissolved solids, calcium hardness, magnesium
concentration, phosphate concentration and reduced pH. All these would have untold
deleterious effect on the biodiversity in the lake not to mention its effect on the water
quality for domestic and livestock purposes.
It is for this reason that OSIENALA wishes to let scientists and environmentalists know
that by allowing the planned shredding and sinking of water hyacinth, they are showing
total disregard to the ecology and hence the people who depend on this lake for their
livelihood. We hope the American Company ( Aquarius Systems) knows well the
consequences of eutrophication for cases of Lake Moss and Lake Washington which
occurred in America not too long ago are still very fresh in our minds. It is also clear that
in the United States, Environmental Protection Agency (EPA) would not allow such an
ecologically disastrous activity to be undertaken in their water bodies. We also doubt
whether the World Bank and GEF managers would sponsor such an activity “ in their
respective countries”. One therefore fails to understand why these well- informed
institutions should support this unorthodox activity, in a poor country that will not be able
to handle the consequences. Let us not commit a mistake, which the future generation
will find hard to forgive.
In conclusion, we would like to make the following recommendations: First, we demand
that and Environmental Impact Assessment (EIA) for the proposed activity be released to
all stakeholders. Second, for sometime now, water hyacinth has been subjected to a
biological control using weevils and so far a significant degree of success has been
achieved. Shredding and sinking the water hyacinth will also destroy the weevils.
OSIENALA believes that the biological control though results into the sinking of the
weed, is a much slower process that allows a natural re-adjustment of ecological system
and is therefore more environmentally friendly. It should be given a chance. Further
more this methodology has been successful in other countries such as Sri Lanka,
Australia, Namibia, Botswana, New Guinea, so why should we now doubt its success in
Lake Victoria. Third, water hyacinth is a symptom to the problem of pollution.
Pollution control measures should therefore be put in place as a long-term solution.
While as a short-term measure economic utilization of water hyacinth should be

Yours sincerely,
Obiero Ong’ang’a
Executive Director

26th July, 1999
Dr. J. B. Ojiambo
Project Co-ordinator
Lake Victoria Environmental Management Programme
P. 0. Box 30126

Dear Sir,
Removal of Water Hyacinth
We write to you in connection with the planned mechanical removal of the water hyacinth
from Lake Victoria, on the Kenyan side. We have read the article by Hon. Peter Anyang
Nyong`o (Sunday Nation, July 25, 1999) raising concerns about the planned dropping of
the weed at the bottom of the lake. We think his concerns are serious, and his arguments
sufficiently weighty to warrant serious consideration.
We are a public interest environmental law organisation, and one of our objectives is to
use the legal process and the legal system in Kenya to protect the environment and
promote the sustainable management of natural resources. It is clear to us that the
concerns raised by Hon. Nyong`o touch on the sustainable management of Lake Victoria
and its resources; a matter that is central to the survival of the people who depend on the
lake and its resources for their livelihoods.
In the premises, we should like to add our voice to that of Hon. Nyong`o and to demand
an assurance from the LVEMP and all concerned that the concerns raised shall receive
due consideration and alternative methods of disposal of the weed shall be looked into.
We are copying this letter to the World Bank`s Country Director as well as the Inspection
Unit in Washington, and to the concerned ministries of the Kenya government. We
request for a copy of the environmental impact assessment report on this project so that
we too can verify the process followed in determining the best method for removing and
disposing of the weed.
We put you on notice that unless we receive an appropriate response within 10 days
hereof that the matters raised herein are being given due consideration, then we shall take
legal action to restrain you from your intended course of action. In this connection we
hasten to draw your attention to the fact that the Environmental Management and
Co-ordination Bill currently before Parliament recognizes the precautionary principle
which is defined by section 2 thereof as "the principle that where there are threats of
damage to the environment whether serious or irreversible, lack of scientific certainty
shall not be used as a reason for postponing cost-effective measures to prevent
environmental degradation".
This is a tacit recognition by the government of a major principle of sustainable
development that seeks to ensure that we are better safe than sorry.
Yours faithfully,
Michael Ochieng Odhiambo
Executive Director
The Permanent Secretary
Ministry of Environmental Conservation
P.0. Box 67839
The Permanent Secretary
Ministry of Natural Resources
P.0. Box 30126
The Country Director
The World Bank
P.0. Box 30577
The World Bank Inspection Unit
World Bank Headquarters 1818, H Street NW
Washington DC 20433
U. S. A
The Provincial Commissioner
Nyanza Province
P.0. Box 1814 KISUMU
Hon. Peter Anyang Nyong`o
P.0. Box 57103
The Executive Director
P.0. Box 30552
The Press NAKURU

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