We, the undersigned civil society organisations, express deep concern over the proposed routing of the Lagos-Calabar Coastal Highway through the Stubbs Creek Forest Reserve, a legally gazetted forest reserve in Akwa Ibom State. We are also alarmed at statements from the Akwa Ibom State Government, suggesting that it might pursue de-reservation of Stubbs Creek in order to make way for this project.
BACKGROUND
Stubb’s Creek Forest Reserve is a gazetted forest reserve in Akwa Ibom State. It was established by the colonial government’s Forest Reserve Order No. 45 of 1930. The reserve is considered a biodiversity hotspot, and remains one of Nigeria’s most ecologically significant mangrove-freshwater forest systems.
In addition to the conservation of thousands of species, several of which are either rare or facing extinction, the reserve provides coastal protection, flood control, fisheries breeding grounds, and livelihoods for indigenous and forest-dependent communities. Passing a major infrastructure project through such a fragile ecological zone risks would cause irreversible environmental damage such as large-scale deforestation, disruption of hydrological systems, biodiversity loss, and severe threats to coastal resilience, in addition to social fragility and long-term economic loss.
The current status of Stubbs Creek as a forest reserve imposes a clear duty on government authorities to prevent incompatible land uses that would result in ecological damage. Any infrastructure development within the reserve would therefore be inconsistent with the reserve’s legal purpose and conservation mandate.
OUR KEY CONCERNS
1. The highway can be rerouted, but environmental impacts would be irreversible
As the statutory custodian of Stubbs Creek Forest Reserve, the Akwa Ibom State Government has openly indicated its willingness to permit the Lagos–Calabar Coastal Highway to traverse the reserve. This position necessarily implies the de-reservation of all or part of Stubbs Creek, as required under Volume III, Cap 52 of the Laws of Akwa Ibom State 2022. Re-purposing a forest reserve is a serious decision, and global evidence shows that such downsizing or degazettements have resulted in rapid, often irreversible environmental loss. Under international human rights and environmental norms, such a step must be preceded by meaningful public participation, free, prior, and informed consultation, and access to information. But it is clear in the current instance that routing the project through Stubbs Creek is not unavoidable; neither can due process for de-reservation be meaningfully followed within the timeline of the highway project. In any case, portions of the coastal highway have already been realigned in other locations, demonstrating that alternative routes are feasible when ecological and social considerations are taken seriously.
2. The project risks creating cumulative damage
An abandoned 2017 superhighway project and the ongoing BUA refinery development within the Stubbs Creek have resulted in a wave of unchecked logging and accelerated deforestation, leaving visible ecological scars on the reserve. A 2016 Environmental and Social Impact Assessment (ESIA) report for the BUA Refinery highlighted massive potential negative impacts on the environment and livelihoods of communities that depend on the reserve and committed to a number of measures to address those impacts. To date, we find no evidence that any such mitigation actions have been initiated. Proceeding with this latest project would further compromise an already stressed ecosystem, triggering a cascade of degradation that the forest may never recover from.
3. The project flouts environmental law
Section 20 of the 1999 Constitution of the Federal Republic of Nigeria (as amended) mandates environmental protection, requiring all levels of government to “improve the environment and safeguard the water, air and land, forest and wildlife of Nigeria.” The Environmental Impact Assessment (EIA) Act No. 86 of 1992 mandates that projects likely to have significant environmental impacts undergo thorough and public environmental impact assessment before approval and any land-altering activities. Allowing the coastal highway project pass through such an important ecosystem clearly contradicts Nigeria’s constitutional objectives. Evidence from the Federal Ministry of Environment indicates that the Environment and Social Impact Assessment (ESIA) process for the coastal highway within the Stubb’s Creek only began in January 2026, well after approvals and public announcements regarding the highway alignment. Approving or advancing the project before completing a comprehensive ESIA undermines the legal intent of the Act and raises serious questions about transparency and due process.
4. The issue at hand goes beyond legality
The state government has relied on the Land Use Act 1978 which, without a dispute, establishes its administrative power over the reserve. But the issue in question goes far beyond legality. What is at stake is the reduction of complex communal rights to a question of who holds title, thereby ignoring the reality that lawful control does not equal social licence and the imperative of managing fragility. Also at stake is the pursuit of development choices that violate Nigeria’s international commitments on climate and biodiversity, and the cost of failure to properly account for environmental and climate impacts in an already vulnerable context. The Niger Delta today faces threats that are strikingly similar to those confronting small island nations, including rising sea levels, coastal erosion, salination, flooding, and ecosystem collapse. Mangrove systems and wetlands, which the Stubbs Creek typifies, are among our strongest natural defenses against these impacts. Sacrificing them for short-term infrastructure choices would not only be shortsighted but also violate the principle of intergenerational equity. That a forest identified by colonial authorities nearly a century ago as worthy of permanent protection is now being positioned for sacrifice on the altar of “infrastructure” reflects a dangerous approach to development that prioritises brick, mortar, and asphalt over socio-ecological dimensions.
OUR CALLS TO ACTION
We therefore call on:
The Federal Ministry of Works to immediately reroute the Lagos–Calabar Coastal Highway away from Stubbs Creek Forest Reserve and its buffer zones; publicly disclose alternative alignments that avoid protected areas and sensitive ecosystems; and ensure that all project decisions comply with the EIA Act 1992 and robust international safeguards
The Federal Ministry of Environment to mandate and publicly release a cumulative ESIA for all existing and proposed projects affecting Stubbs Creek Forest Reserve, assessing combined impacts and enforce full compliance with environmental and forest protection laws by applying the precautionary principle, including a halt to land clearing or construction within the reserve where credible cumulative impact assessments and safeguards are absent; and guarantee transparent public participation and independent oversight by convening open consultations and appointing an independent review mechanism to scrutinise ESIA findings, mitigation claims, and accountability for ecological damage and restoration; and
The Akwa Ibom State Government to unequivocally affirm the protected status of Stubbs Creek Forest Reserve and refuse any land allocation or right of way approvals that permit construction within the reserve; actively engage the Federal Government and host communities to secure a lawful, environmentally responsible, and conflict-sensitive alignment for the coastal highway that respects both statutory protections and indigenous rights; and protect the rights and safety of communities and civil society actors advocating for environmental protection.
CONCLUSION
We urge both the Akwa Ibom State Government and the Federal Government of Nigeria to act responsibly and decisively to prevent irreversible damage. Rerouting the coastal highway away from Stubbs Creek Forest Reserve is not only feasible; it is necessary, lawful, and responsible.
True development must not come at the cost of ecological collapse and heightened climate vulnerability. Protecting Stubbs Creek is not an obstacle to development; but rather an investment in climate resilience, environmental justice, and the long-term wellbeing of present and future generations in Akwa Ibom State and the wider Niger Delta.
SIGNED;
1. 21st Century Community Empowerment for Youth Initiative
2. Accountability Lab, Nigeria
3. Abuja School of Social and Political Thought
4. Africa Network for Environment and Economic Justice (ANEEJ)
5. African Centre for Leadership, Strategy & Development (Centre LSD)
6. African Centre for Media & Information Literacy (AFRICMIL)
7. Amnesty International Nigeria
8. Borno Coalition for Democracy and Progress (BOCODEP)
9. BudgIT Foundation
10. Center for Fiscal Transparency and Public Integrity
11. Centre for Democracy and Development (CDD)
12. Centre for Community Empowerment in Conflict and Peacebuilding – Kaduna
13. Centre for Democratic Research and Training (CRDDERT)
14. Centre for Global Tolerance and Human Rights
15. Centre for Information Technology and Development (CITAD)
16. Centre for Journalism Innovation and Development (CJID)
17. Centre for Social Centre for Justice Reform
18. Centre for Transparency Watch
19. Civil Society Legislative Advocacy Centre (CISLAC)
20. CLEEN Foundation
21. Community Life Project (CLP)
22. Conscience for Human Rights and Conflict Resolution (CHRCR)
23. Connected Development (CODE)
24. Corporate Accountability and Public Participation Africa (CAPPA)
25. Elixir Trust Foundation
26. Emma Ezeazu Centre for Good Governance and Accountability
27. Environmental Rights Action
28. Environmental Rights Action/Friends of the Earth, Nigeria (ERA)
29. Falana and Falana’s Chambers
30. #FixPolitics
31. Global Rights
32. Good Governance Team
33. Green Concern for Development (GREENCODE)
34. Health of Mother Earth Foundation (HOMEF)
35. Human and Environmental Development Agenda (HEDA Resource Centre)
36. Human Rights Social Development and Environmental Foundation
37. INVICTUS AFRICA
38. Kebetkache Women Development & Resource Centre
39. Lawyers Alert
40. Media Initiative for Transparency in Extractive Industries (MITEI)
41. Media Rights Agenda
42. Mothers and Marginalized Advocacy Centre (MAMA Centre)
43. Nigeria Network of NGOs
44. Open Society on Justice Reform Project
45. Order Paper
46. Organization for Community Civic Engagement (OCCEN)
47. Partners West Africa
48. Peace Point Development Foundation 49. Policy Alert
49. Praxis
50. Prisoners’ Rehabilitation and Welfare Action (PRAWA)
51. Procurement Observation and Advocacy Initiative
52. Resource Centre for Human Rights and Civic Education (CHRICED)
53. RULAAC – Rule of Law and Accountability Advocacy Centre
54. Say NO Campaign – Nigeria
55. Say No Campaign
56. Sesor Empowerment Foundation
57. Social Action
58. Socio-Economic Research and Development Centre
59. Socio-Economic Rights and Accountability Project (SERAP)
60. State of the Union (SOTU)
61. Tax Justice and Governance Platform
62. Transition Monitoring Group (TMG)
63. West Africa Civil Society Forum (WASCSOF)
64. Women Advocate Research and Documentation Centre (WARDC)
65. Women in Media Communication Initiative (WIM)
66. Women in Mining, Nigeria
67. World Impact Development Foundation
68. Yiaga Africa
69. Zero Corruption Coalition (ZCC)
70. West Africa Civil Society Institute (WACSI)
