Environment Protection Index: A comparative analysis of 3 African countries

This past month, the United Nation’s flagship climate change finance initiative, the Green Climate Fund, encountered a significant setback, which came to a head during the South Korea meeting on how to raise influx of contributions towards the Fund. The Green Climate Fund was created under the United Nations Framework Convention on Climate Change (UNFCCC) in order to funnel up to 100 billion dollars annually from the wealthy nations and towards developing ones, in order to support the latter in tackling climate change through mitigation and adaptation projects. While it was set up by 194 participating nations in 2010, it was given major leverage in 2015, when the Paris Agreement was adopted. The Agreement gave an important role to the Fund in serving the agreement and supporting the goal of keeping climate change below 2 degrees Celsius. It stated that “the push to address loss and damage as a distinct issue in the Paris Agreement came from the Alliance of Small Island States and the Least Developed Countries, whose economies and livelihoods are most vulnerable to the negative impacts of climate change.” The Fund was effectively positioned as the grease with which the Paris Agreement was to be implemented, and on November 4th, 2016, the Agreement entered into full force.

However, the meeting that was held a few weeks back was preoccupied with bureaucratic struggles and debates over how to release the approximately billion dollars’ worth of proposals. The subsequent resignation of the CEO was indicative of the management issues stagnating the effectiveness of the Fund. Developing countries have on a whole taken small progressive steps forward to create better frameworks for environmental regulation and enforcement, but for larger scale changes there was much dependence on the Fund to help translate international cash flows and policies into comprehensive programmes. However, with the helm at stalemate, this means that the burden of fiscal responsibility for climate change will for the time being remain upon the shoulders of the recipient nations, and on piecemeal donations, loans, and investments granted to them by various stakeholders with varied interests.

This leads to the question of how much effort developing nations themselves have put into working towards the goal of staying well below 2 degree Celsius, to demonstrate commitment to utilizing the Fund finances effectively and rapidly. For this analysis, there is a need to look at trends in three Sub-Saharan African countries, which were selected for their regional representation, GDP, and population size. COP21 (colloquially called the ‘Paris Agreement’) Commitments, post-2015 policy shifts, and Environment Protection Index were the main documents sourced for comparison. The following comparisons will highlight the status quo in Kenya, Nigeria, and South Africa.

The Environment Protection Index (EPI), first published in 2002, is a method of quantifying the environmental performance of a state’s environmental policies, and was originally designed to support the targets established under the UN Millennium Development Goals (MDGs).

The EPI has been developed to assess the influence and impact of two policy objectives: Environmental Health and Ecosystem Vitality. The former measures ‘threats to human health’ while the latter measures the availability of natural resources and ‘ecosystem services’. The categories are meant to provide comparable measurements that reflect the existing policies being utilized to address environmental problems.


One noticeable trend between the 2016 and 2018 EPI scores for the four index countries is that all of the scores have fallen across the board. This is in part due the significant changes made in the EPI technical assessment itself. In 2016 and prior, the weightage between Environmental Health (HLT) and Ecosystem Vitality (ECO) objectives was evenly split. However in 2018, a few major changes were made in the weightages, as well as the indicators that were included and excluded. One significant change was to give HLT 40% weightage and ECO, 60 percent.

This is because HLT had almost twice wider spread in its variance than did ECO, and as such, giving a 50-50 weightage split would have given too much influence to HLT’s policy objectives. Secondly, materiality filters – which are used to exclude certain countries from being assessed because they did not meet thresholds for influence – were also adjusted. Post Paris Agreement, for instance, it was agreed that all countries regardless of size or development status were to support reducing emissions. Therefore, the materiality filter was removed from analysis in 2018. Finally, the 2018 EPI reintroduced the category of ‘air pollution’, which was last featured in the 2012 EPI, with SO2 and NOX as the two main pollutants of global concern.

In turn, the HLT objective now gave ‘air quality’ 65% weightage, against 33% in 2016’s EPI, and the ECO objective gave the again-added ‘air pollution’ category 10% weightage. This was also a consequence of the EPI taking the global disability-adjusted life-years (DALYs) analysis into account, which showed that approximately 65% of DALYs around the world were attributable to air quality alone.


COP21 Commitment: A reduction in emissions of 30% by 2030 relative to a business-as-usual scenario of 143 MtCO2e. This commitment is subject to financial and technological international support, and does not rule out use of international market mechanisms.

Kenya, with a population of approximately 48.5 million people in 2016, has the 8th biggest economy in the continent, and the 4th biggest in the Sub-Saharan region . Kenya’s EPI scores rose sharply between 2014 and 2016, but then fell again due to the re-assessment of the indicators themselves in 2018; this alludes to the significance of air pollution in the country, based on the re-weighing of the EPI indicators and the addition of the ‘air pollution’ category under ECO, which in turn has a greater weightage this year as compared to in 2016. In fact, it was recently found that Nairobi’s pollution is approximately 30 times worse than in London, and the issue is compounded by the fact that many of the country’s vehicles run on diesel, which has higher risks of inducing cancer and internal organ damage in humans .

While Kenya has gone further than most African countries in trying to eradicate plastic bags – it took Kenya three attempts over 10 years to finally pass the ban in August, 2017 - its regulations for air pollution and waste management are still inadequate to handle the influx of materials injected into the environment. Kenya has a National Environment Policy that was adopted in 2013, as well as Air Quality Regulations passed by the National Assembly in 2014. However, the National Environment Management Authority (NEMA), which is charged with enforcing the policies through a system of strict licensing and penalties , had not implemented them comprehensively. In addition, the 2013 Policy contains messaging on air quality but does not assign quantitative targets to the Government’s proposed actions. The 2014 Regulations are more technical, assign quantitative limits, and are prescriptive in regards to how to carry out various air quality tests; however, given that they were drafted prior to the Paris Agreement, do they not reflect the urgency and immediate actions that were committed to in the assembly.

One area where Kenya has become a leader, however, is in utilizing geothermal power to generate electricity. In 2015, 47 percent of Kenya’s electricity was from steam, and approximately 35 percent came from hydropower generation. According to KenGen, Kenya’s Electricity Generating Company, Kenya has the potential to generate more than 10,000 megawatts (MW) of geothermal energy ; currently, the demand just exceeded 1,600 MW. However, lack of funding from international markets, poor governance, and corruption have proven to be significant barriers for expansion. It is feasible that Kenya’s large and growing investment in geothermal power has offset some losses from its regression in other categories, mainly air pollution and climate & energy.


COP21 Commitment: Unconditional 20% reduction in emissions by 2030, compared to business-as-usual levels. This could increase to 45%, conditional on international support. The commitment includes plans to end gas flaring and install 13 gigawatts of off-grid solar, as well as improving energy efficiency by 30% by 2030.

Based on current statistics, emissions are projects to reach 900 million tons of CO2 by 2030 under the business-as-usual scenario, and Nigeria had pledged a reduction of these emissions by 20% independently of international community financing; in that, it committed to reducing approximately 180 million tons of CO2 by itself without support of mechanisms such as the Green Climate Fund. However, in line with other proposals submitted to UNFCCC, Nigeria’s own does not elaborate on how key stakeholders, including the government, can work together to achieve the ambitious promise. As of 2016, Nigeria was yet to have any climate change specific law enacted by the National Assembly and while the country adopted several environmental and sectoral policies, their enforcement is limited . In 2012, the Nigeria Climate Change Policy Response and Strategy was adopted, with its focus being to raise the capacity of nation to adapt to climate change, but its influence and success is hard to determine given that the country is still in its nascent stages of adapting the policies into action. However, there are positive impressions made due to Nigeria currently investing in low-carbon electrification and its cities currently developing resilience strategies; Lagos, one of Nigeria’s largest cities, already has a climate change policy and action plan in place .

One major setback for Nigeria, in terms of its ranking using the EPI indicator framework, is gas-flaring. The country is among the top 10 globally in terms of wealth of oil and gas resources, which means that this sector is one of the main sources of greenhouse gas emissions in Nigeria – the predominant source being gas flaring, which is the practice of burning off natural gas that accompanies crude oil withdrawal. In fact, oil companies in the country flare over 313 million standard cubic feet of gas annually, which contributes approximately 16.5 MtCO2e annually . While the practice has been illegal for over three decades now, monitoring and enforcement has been very poor; the government has committed to implementing a new multi-stakeholder strategy which is currently under development.

In addition, in 2016, the WHO found that four of the worst cities in the world for air pollution were in Nigeria. For example, one growing Sothern Nigerian city, Onitsha, recorded 30 times more than the WHO’s recommended levels of PM10 . Some of the main contributors identified was the reliance on using solid fuels for cooking (a new indicator added to the HLT objective under the EPI framework), burning waste, gas flaring, and traffic pollution, according to the WHO.


COP21 Commitment: South Africa plans to take a peak, plateau, and decline (PPD) approach to tackling emissions. It aims to peak between 2020 and 2025, plateau for approximately a decade and then initiate falling emissions. Emissions during 2025-2030 will be in the range of 398-614 MtCO2e, compared to the 461MtCO2e generated in 2000.

South Africa’s currently policy-based projects are estimated to reach emission levels of 606 MtCO2e in 2020, which is a 74% increase from 1990 levels. Given that the nation’s economy relies heavily on the mining and heavy industries, it has been historically on trend for South Africa’s emissions to steadily increase. In addition, energy consumption in the industrial and building sectors largely relies on electricity that is produced using high carbon sources such as domestic coal. In fact, in 2015, 92% of South Africa’s electricity was generated from coal, and over 30% of South African gasoline and diesel needs are covered by liquefied coal .

The nation had developed a National Development Plant (NDP) which provides a 2030 vision on sustainable development, including eliminating poverty and reducing inequalities. The same vision was delineated in the 2011 National Climate Change Response Policy (NCCRP), which contains various sectoral plans for addressing the costly sources of electricity in the country . It is also currently planning on introducing a carbon tax covering fossil fuel combustion emissions, industrial processes and product use emissions, and fugitive emissions (e.g. fugitive emissions from coal mining). The proposed Carbon Tax Bill was introduced in parliament earlier in 2018, after two years of debate and consultation; the final draft is expected to be completed by the end of 2018. The Tax bill is thought to also be accompanied by a package of tax incentives and revenue recycling measures that will support minimizing the impact of the first phase of the policy, which is focused heavily on taxation alone.

In addition to the growing health problems due to water pollution, land degradation and pollution due to solid waste, air pollution is killing 20,000 South Africans every year , according to the World Bank’s 2016 estimates. Therefore, due to current trends, in most part due to the country’s heavy reliance on coal and petroleum, emission loads are to continue increasing, and the hope is that the carbon tax will provide the first line of relief once implemented.


According to the 2016 African Economic Outlook report, the human cost of air pollution is ‘abnormally high’ in Africa, where an estimated 246,000 premature deaths in 2013 were caused by ambient particulate matter pollution . In 2016 itself, long-term exposure to air pollution contributed to the deaths of 6.1 million people – with strokes, heart attacks, lung disease, and lung cancer causing many of them. It is also now the fourth-highest cause of death worldwide, with the majority of deaths recorded in developing countries .

Therefore, it makes sense that the EPI scores for the profiled Sub-Saharan African countries fell from the 2016 levels, given that the 2018 EPI indicator framework gave more weightage to air quality, while also including the new category of ‘air pollution’, which measured the emissions of toxic gases into the environment. In addition, given that the 2018 EPI framework relied on DALY data, which is traditionally information aggregated for informing public health interventions, it is also sensible that the EPI’s HLT objective is by majority informed by the quality of air in a country (65% weightage under 2018 EPI framework, versus 33% weightage in 2016’s framework).

In conclusion, even if developing countries have made substantial progress in other categories such as water and sanitation, and agriculture, if air pollution is not addressed in a significant way and urgently so, there is high risk of the country falling down the ranks in comparison to its neighbors and global leaders, and thus failing to reach its 2030 commitments made as part of the Paris Agreement.

swathi Author – Swathi Manchikanti,,
MSPH International Public Health,
Johns Hopkins University