Mr Leboo Ole Morintat AG, County Secretary Nairobi City County P.O Box Nairobi. 30 th November 2017, Dear Mr.

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1 Mr Leboo Ole Morintat AG, County Secretary Nairobi City County P.O Box Nairobi 30 th November 2017, Dear Mr. Morintat, RE: MEMORANDUM ON THE DRAFT COUNTY INTEGRATED DEVELOPMENT PLAN County planning is a key aspect of the development process. Proper planning ensures that counties use limited resources wisely to address the unlimited needs of the citizens. Under Schedule 4 of the Constitution of Kenya, the responsibility of county planning and development is vested in county governments. County governments are thus expected to decide before hand what will be their short, medium and long-term priorities. Section 104 of the CGA requires the county to plan and indicates that: a county government shall plan for the county, and no public funds shall be appropriated outside a planning framework developed by the county executive committee. The purpose for preparation of the Plan (CIDP) is to enable allocation of scarce resources to priority projects and programmes as determined by the people and political manifestos of the government of the day. Whereas we acknowledge the effort by the County Government of Nairobi in the development of CIDP and appreciate the opportunity presented for the members of the public to input into the document, we hereby after critical analysis of the various sectors and subsectors wish to bring to your attention the following key concerns: Key observations 1. Lack of access to information: The County government has not availed implementation report of CIDP to the public 2. Lack of adequate and meaningful public participation in the CIDP process: Insufficient notice given for public participation during the CIDP sub county forums. The notice given to the public to present written submission was not well publicized 3. Source of funds: The draft CIDP fails to avail information on project funding sources. The county should consider clearly indicating the source of funds for the proposed projects for effective monitoring and evaluation by the public 4. Urban Planning: The CIDP draft indicates obstacles to county planning to include Nairobi National Park, Kibera Slum to Ngong Forest, Nairobi Central Station, KRC land in Makadara, Airbase and rivers within informal settlement, which should not be the case.

2 CIDP Sector Analysis: Trade Sub-Sector Both CIDP and envision the establishment of markets for wholesale and retail trade, with an objective of reducing unemployment levels within the county. The development priorities for the sub-sector for the next five-year period between are: Promotion of trade development and market services through construction of new trading market facilities Rehabilitation of markets Development of business incubation centers Provision of loans and capacity building of MSMES Licensing and fair trade practices Key Analysis Highlights 1) Inadequate clarity on specific project targets under trade development programme. 2) Failure to cost mega projects and programmes under the trade sub-sector. 3) Criteria used for cost projections on MSMEs raises concerns/is not clear. 4) Inappropriate prioritization under trade licensing programme. There is indisputably a challenge/s with the county s licensing system. Limited legal framework and strategy towards effective revenue collection by the county remains wanting and hence the county should consider prioritization towards the realization of effective and efficient licensing regime. 5) Contrasting information with respect to county revenue generation through market CESS. According to the draft CIDP, trade development and market services is envisaged to contribute towards generation of revenue for finance and economic planning sector. The county has currently stopped collection of revenue inform of CESS from small scale traders thus the statement is untrue and misleading. 6) There is evidenced a few cases of double prioritization as well as funding of projects Questionable projects funding Status of City Park market in Parklands remains indeterminate. In the CIDP, the project was not prioritised. However, the implementation report revealed that a total of Kshs. 120 million was spent on reconstruction of city park project with the market planned to have been completed in a span of 3 years. Pointedly, the same market has been prioritised for construction in the draft CIDP with project proposed to be implemented in 1 year. Imperative to note is that the project is not costed. There is also no clarity/information on the status of the project from the draft CIDP Lack of

3 update on the status of implementation of the aforementioned market project raises accountability and transparency concerns. The county should therefore, provide information on the status of implementation of the project in question as well as accountability on previous resource allocation to the same. Draft County Integrated Development Plan End term review report of the county integrated development plan (CIDP) Veracity on Makina market project prioritization and implementation information In a bid to create ideal working space for traders, the county through the first CIDP prioritized Makina market for construction of more stalls/modern markets and renovation. A review of the end term report by the county on the implementation of county integrated development plan (CIDP) indicates that Kshs 42 million was spent on face-lifting of Makina market. The draft CIDP reveals an additional amount totaling 42 million set to be spent on the same market under the theme rehabilitation of market for efficiency in trading. Considering the contrasting revelation around the aforementioned market project, we recommend that the county provide accurate information on the status of implementation of the project in the previous CIDP as well as accountability on previous resource allocated to the project in question Violation of CIDP Legal Framework Section 104 (1) states that a county government shall plan for the county and no public funds shall be appropriated outside a planning framework developed by the county executive committee and approved by the county assembly. Section 108 (4)(a) of the County Government Act stipulates that, a resource mobilization and management framework shall be reflected in a county s integrated development plan and shall at least include the budget projection required under the law governing county government finance management. Whereas the county has largely adhered to the legal framework above, there is considerable number of trade/market projects and programmes that have

4 not been costed. We hereby recommend that the county strictly adheres to the legal framework and standards set out in the in the CGA and relevant legal frameworks governing planning in the county. Water and Sanitation sub-sector The strategic objective by the county on water and sanitation remains appealing: To enhance environmental sanitation through provision and management of public toilets; to improve access to water and sanitation services to all county residents and particularly those in the informal settlements; to reduce non-revenue water to world class standards. However, there is evidenced a generic concern under the subsector as: 1. There is failure by the county to provide location of proposed projects hence raising transparency and accountability concerns. The county should therefore endeavor to indicate location of proposed water and sanitation programmes to be undertaken within the five-year period of CIDP implementation. 2. Extensive use of technical terminologies in naming various projects and repetition of similar projects with different cost that makes it difficult for ordinary citizens to establish/understand what exact projects have been prioritised. Both naming and location of projects under the sub-sector should remain simple and easily understandable to the public who are the ultimate beneficiaries. Health Sector The draft does not provide data under the health sector. It also does not clearly address the issue of county health, services and building the capacity of community health workers. Education Sector Under the education sector, there are no clear targets of what the county government intends to achieve. It is not clear what criteria the county executive uses to prioritize projects, for example, CIDP proposes construction of two polytechnics in Dagoretti South whereas Dagoretti North does not have any polytechnics and none has been proposed for construction in the draft CIDP Solid Waste Management Sub sector Solid Waste Management falls under the Environment, Water, Sanitation and Garbage pillar that also doubles up as one of the pillars for prioritization by the government of the day. Issues identified in solid waste include, poor garbage collection system, inadequate dumping sites, inadequate waste collection equipment and trucks. The proposed strategies to solve these are; implement the solid waste management plan, develop and enforce environmental standards, integrate environmental issues in county development planning, improve garbage collection system, increase/ expand sewerage system, procure adequate waste collection, equipment and trucks, recruit more environmental officers, provide alternative dumping

5 sites, promote recycling of solid waste campaign, leverage on technology in solid waste management, enforcement and policing of environmental regulations, increase public education and awareness on environment. The CIDP was reviewed against the CIDP to identify gaps and issues for advocacy as indicated in the table below. Priority projects and programmes in CIDP Develop and commission of one new dumpsite in Ruai (New Sanitary Landfill) at KShs 14 B. Increase garbage collection from 50% to 80% in the entire county involving Privatize garbage collection by 30%. No costing. Training garbage collectors and CBOs on proper solid waste management. Procure more trucks for garbage collection Reduce no. of illegal dumpsites. No costing. Collection and transportation plan for the entire County involving procurement of trucks and equipment at Kshs 5 B Final disposal plan in Dandora involving improvement of Dandora site at Kshs 14 B. Environmental education and public sensitization targeting 85 CBO s (5 CBOs per constituency) at Kshs 10 M Priority Projects and programmes in CIDP Installation and servicing of 23,500 litter bins at Kshs 94 m Expand the waste collection fleet for an effective and efficient waste collection by procuring 74 side loader trucks at Kshs 520 m; 17 RC Trucks at Kshs 340 m; 14 tippers at 140 m; 55 trucks at Kshs 550 m; For an increased efficiency of the dumpsite operations, procure 4 excavators Kshs 158 m; 2 bulldozers at Kshs 100 m; 2 compactors at Kshs 100 m; To increase the efficiency of the dump site operations, procure 3 back hoes at Kshs 42 m; To enhance supervision, procure 3 station wagons at Kshs 19.5 m; 3 pickups at Kshs 7.5 m; and21 vehicles at Kshs 84 m; 148 assorted skips at Kshs 74 m; 30 refuse skip loaders at Kshs 300 m; Remarks Installation of litter bins around the city is a new initiative. It is not indicated where exactly these litter bins will be situated. Disposal facilities not costed. It is not clear what the fate of the Dandora dumpsite is. In the previous CIDP it was to be decommissioned and a new dump site identified. It was reported that KAA had objected to development of a new dumpsite at the proposed Ruai site. The priorities dwell so much on what the county will do but leaves out the role of other stakeholders.

6 Dandora dumpsite for material recovery facility and City wide for 3R at Dandora dumpsite andcity wide at Kshs 426 M. Plastic project involving recycling. For enhanced resource recovery, procure 17 bailing machines at Kshs 85 m; 3 pressure washing machines at KShs15 m; for an increased turnaround time of refuse trucks, undertake grading Accesses with Hardcore, rehabilitate drains, complete workson J. Osogo Rd, Install Weighbridge at KShs2750 m; For real time information on Vehicle routing and scheduling in solid waste collection system, real time data on actual weights delivered at dump site, fit trucks with GPS and install CCTVS and systems at KShs54 m; 1 weigh bridge for Accurate weighing of waste Delivered at KShs40 m; Build 50 Material Recovery Facilities at Kshs 200 m; decommission dumpsite and Establish waste treatment plant at Kshs 20 m; Develop 53,100 disposal facilities

7 The lnstitute for Social Accountability KHRC C KENYA RIGHTS HUMAN COMMISSION TRANSPARENCY INTERNATIONAL KENYA National Taxpayers Association pesa zetu,haki yetu Putting People First ECONOMIC & SOCIAL RIGHTS CENTRE (Hakijamii) I N U KA Ni Sisi! I PF INSTITUTE OF PUBLIC FINANCE {\HERAF East Africa Tax Governance Ne'Bwor Health Rights Advocacy Forum

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