To: Cabinet secretary Enviroment
To reduce NEMA lisence fee that recently increased by 100%
We, the undersigned waste entrepreneurs, grassroots waste collectors, and concerned citizens, write to you with deep concern regarding the recent decision by the National Environment Management Authority (NEMA) to increase the annual waste management license fees from KES 40,000 to KES 80,000. This abrupt fee increment has placed an unbearable financial burden on small-scale waste entrepreneurs, threatening their livelihoods and undermining inclusive waste management efforts across Kenya.
Key Concerns:
1. Exclusion of Small-Scale Players: Many grassroots waste collectors who could barely afford the initial KES 40,000 license fee are now completely unable to operate legally under the new KES 80,000 requirement. Some had even hoped for a reduction to KES 30,000 to allow wider compliance.
2. Unintended Growth of Illegal Operations: The drastic increase forces small waste entrepreneurs into illegal operations, which contradicts the government's commitment to structured waste management and environmental protection.
3. Monopolization of the Waste Sector: The fee hike disproportionately benefits large corporations such as Mr. Green and other dominant players in the sector, pushing out small enterprises that relied on these larger companies to purchase waste materials from them. This is killing competition and innovation in the waste management sector.
4. Contradiction with Extended Producer Responsibility (EPR) Programs: With the recent introduction of Extended Producer Responsibility (EPR) through organizations like the Kenya Extended Producer Responsibility Organization (KEPRO), producers such as Coca-Cola, Unilever, Bidco, Brookside, and many more are now mandated to play an active role in waste collection and management. The exorbitant licensing fees contradict this initiative by discouraging community-level waste management, which is critical for the success of EPR programs.
5. Lack of Public Participation and Legal Protections for Youth and Community-Based Organizations (CBOs): The fee increment was introduced without adequate public participation, violating Article 10 and Article 69 of the Constitution of Kenya, which mandate public involvement in environmental governance. This has disproportionately disenfranchised youth-led startups and community-based organizations (CBO)
Why is this important?
Adherence to Legal and Constitutional Protections: We demand that the Ministry of Environment and NEMA adhere to the legal frameworks governing public participation, fair competition, and environmental justice, ensuring that waste management policies do not favor a select few at the expense of youth groups and community-based enterprises.
A thriving waste management sector requires inclusivity, fairness, and accessibility. We respectfully urge the government to reconsider this fee hike to safeguard the livelihoods of thousands of small-scale waste entrepreneurs, support the success of the Extended Producer Responsibility (EPR) initiative, and promote legal, structured waste management in Kenya.
We appreciate your swift intervention on this matter and look forward to your favorable response.
Youth Unemployment in Kenya: According to the Kenya National Bureau of Statistics (KNBS), youth unemployment remains a critical challenge, with over 39% of young people aged 18-34 facing joblessness. The waste management sector provides vital employment opportunities, particularly for marginalized youth. Increasing licensing fees restricts their ability to engage in income-generating activities, exacerbating unemployment and poverty levels.
Youth Unemployment in Kenya: According to the Kenya National Bureau of Statistics (KNBS), youth unemployment remains a critical challenge, with over 39% of young people aged 18-34 facing joblessness. The waste management sector provides vital employment opportunities, particularly for marginalized youth. Increasing licensing fees restricts their ability to engage in income-generating activities, exacerbating unemployment and poverty levels.
Additionally, jobs that have emerged through climate change adaptation, climate innovation, and climate justice align with the theme of the 2023/2024 budget, which emphasized climate justice. Waste management is a key pillar within this framework, and ensuring its accessibility and affordability for grassroots entrepreneurs is critical to achieving the government's sustainability and employment goals.
Violation of Fair Competition Laws: The Competition Act of Kenya seeks to promote fair trade and prevent market monopolization. By imposing exorbitant fees that favor large corporations over small enterprises, NEMA’s new licensing policy violates the principles of fair competition and economic inclusivity.
Violation of Fair Competition Laws: The Competition Act of Kenya seeks to promote fair trade and prevent market monopolization. By imposing exorbitant fees that favor large corporations over small enterprises, NEMA’s new licensing policy violates the principles of fair competition and economic inclusivity.
