While in Kenya for our workshop on Integrated Fire Management in Tsavo, we discussed the draft of the Wildlife Conservation and Management Bill 2025 [pdf]. We realised that wildfire or landscape fire was mentioned only very briefly (restricted to a single statement in one clause) and not in way that seemed to meet with the principles and values laid out in the Preliminary section of the Bill (namely adoption of the use of emerging science and indigenous (traditional) knowledge, participatory and inclusive management and an ecosystem approach). Given that these were topics of discussion in our workshop, and that public consultation on the Bill was ongoing, we felt that we could offer some comments on how the Bill might be improved to better reflect those values (as well as our own).
Below are our comments that we submitted via the Ministry of Tourism and Wildlife’s public participation feedback tool.
We are a group of Indigenous people and local community representatives, academics, and conservation area managers who met together 13-15th May 2025 in Voi, Taita Taveta County. We came together in a workshop to discuss fire management and how Indigenous People and Local Communities (IPLC) and their knowledges can be better represented in contemporary fire governance. Together, we are the ‘IPLC Workshop’. We hereby submit our comments through the undersigned, with our names and organizations annexed to this document.
Integrated Fire Management is needed to meet the guiding values and principles of the Wildlife Act
Landscape fire is recognised scientifically by ecologists as an important component in fire-prone ecosystems1, such as those that compose many of Kenya’s protected areas, non-protected areas, and forests. Fire-prone ecosystems are those ecosystems in which fire occurs regularly and is an essential ecosystem process, influencing biodiversity, carbon and nutrient cycling, and water supplies2,3. These ecosystems extend over the majority of Kenya’s land surface, including grass-dominated savannas, Acacia bushlands and forests. Landscape fire is currently under-considered in much of Kenya’s legislation including the Wildlife Conservation and Management Bill 2025 which seemingly has the same phrasing as legislation in previous Acts (i.e., WCMA 2013). The current attitude towards fire in Kenya’s legislation seems to be exclusionary4 and reactive to large, intense wildfire disasters that result in economic losses, environmental and habitat modification, and large carbon emissions. These unplanned events could be prevented or mitigated with appropriate proactive management of landscape vegetation to foster healthy ecosystems that support wildlife5 while minimizing economic losses. Developing and effectively applying proactive fire management plans would be alignment with legislation in other countries with fire-prone ecosystems around the world and with the commitment in Section 5(1)d of the bill to adopting an “ecosystem approach”.
Fire management plans should be developed that specify appropriate risk assessment and mitigation measures that are appropriate for the jurisdiction and ecological conditions in any given location and time. Plans could adopt an Integrated Fire Management approach6,7, one approach among many options but which aims to produce positive ecosystem outcomes, and which seeks to include and account for Indigenous peoples’ and local communities’ knowledges and practices and ensure transparent communication across all stakeholders adopting the ecosystem approach.
We believe that:
- controlled and prescribed fires to manage vegetation need to be permissible, but regulated, under certain circumstances and that this should be reflected in the Wildlife Conservation and Management Act;
- conservancies, ranches, wildlife corridors (conservation areas) and protected areas need to develop,maintain and implement clear and well-defined integrated fire management plans;
- cultural burning practices of Indigenous people and local communities should be permitted in conservation areas but regulated to avoid damaging wildlife habitat and other assets;
- the enforcement regime for controlling fire should distinguish more clearly between malicious acts of arson and failures to exercise reasonable precautions, like maintaining fire breaks, that result in the spread of fire onto adjoining properties.
Section 5 of the proposed Bill states that the implementation of the Wildlife Act should be guided by values and principles that include (h) the use of emerging science and indigenous (traditional) knowledge, (d) an ecosystem approach, and (b) participatory and inclusive management. However, consideration of fire in the current proposed Bill is limited to a single clause in Section 240 in Part XIX ‘Offences and Penalties’ which does little to meet the guiding values and principles laid out in Section 5. While provision for punishing unauthorised fire use that leads to detrimental outcomes is certainly appropriate, given our statements above we believe that there needs to be a new section of the Bill on ‘Fire in Conservation Areas’ to permit and facilitate more proactive, ecosystem-oriented, integrated fire management that can produce positive outcomes. This section could include:
- Clarity on authority for regulating and conducting fire management within different types of conservation areas (e.g., is a fire within a National Park the responsibility of the County or National Government? What about a fire that starts in one area and spreads into another?)
- Clarity on approval of management plans by different government levels (County and National)depending on jurisdiction (e.g., if prescribed burning is desired in a National Reserve, does authority lie with County or National Government?)
- Clarity on who is responsible for permitting (e.g., should a conservancy apply to County of National Government for a permit? From whom would ranchers, local communities obtain permits to burn culturally or for pasture management?)
Signatories
Amos Chege and James Millington (King’s College London, Leverhulme Centre for Wildfires, Environment and Society) plus 12 others from Taita Ranch Ltd, Management of Arid Zones Initiatives and Development Option (MAZIDO), African Wildlife Foundation, Taita Taveta Wildlife Conservancies Association (TTWCA), Wildlife Research and Training Institute, Kasigau Conservancy Ltd, County Government of Taita Taveta, Boston University, Princeton University, Tsavo Trust, Mgeno Conservancy Ltd
Direction not Destination 