strategic environmental assessment (sea) …and biodiversity. this document presents a report on...
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THE REPUBLIC OF UGANDA
STRATEGIC ENVIRONMENTAL ASSESSMENT
(SEA) OF OIL AND GAS ACTIVITIES IN THE ALBERTINE GRABEN,
UGANDA
MINISTRY OF ENERGY AND MINERAL DEVELOPMENT
MINISTRY OF WATER AND ENVIRONMENT
Kampala, September 2013
Page i
Copyright © MEMD 2013
All rights reserved.
The Ministry of Energy and Mineral Development through its Petroleum Exploration and Production
Department (PEPD), in conjuction with the Ministry of Water and Environment through the National
Environment Management Authority (NEMA) initiated and funded the Strategic Environmental
Assessment (SEA) of the oil and gas activities in the Albertine Graben of Uganda, with support from
Oil for Development (OFD) Program a bilateral agreement between Government of Uganda and
Norway under the project, “Strengthening the management of Oil and Gas Sector in Uganda”. The
SEA process was undertaken by an International Consultant, Eco-Management Support supported by
a national consultant, ESIPPS International Ltd
Disclaimer
The SEA report has been prepared and delivered by a team of consultants, under the guidance of the SEA
Steering Committee.
The content of the report reflects the professional judgement and advice of the SEA Team.
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FOREWORD
The discovery of oil and gas resources presents great socio-economic opportunities and benefits for the
Albertine Graben and the country at large. At the same time, the area is of high ecological and biodiversity
significance. This presents various challenges for environmental protection. As stated in the National Oil
and Gas Policy (2008), oil and gas activities must be underataken in a manner that conserves environment
and biodiversity. This document presents a report on Strategic Environment Assessment (SEA) of oil and
gas activities in the Albertine Graben of Uganda. The SEA document presents strategic recommendations
for policies, plans, and programmes that will guide environmental planning and decision making in the
Albertine Graben. The SEA presents a unique opportunity for the country to systematically address
environmental management issues pertaining to oil and gas activities in the Albertine Graben in the
context of sustainable development.
The SEA was initiated under the leadership of the Ministry of Energy and Mineral Development (MEMD)
through its Petroleum Exploration and Production Department (PEPD) and the Ministry of Water and
Environment (MWE) through the National Environment Management Authority (NEMA). The Norwegian
Government provided financial support and technical backstopping. A steering committee comprising
Petroleum Exploration and Production Department (PEPD), National Environment Management Authority
(NEMA), Uganda Wildlife Authority (UWA), Directorate of Environment Affairs (DEA), Ministry of Lands,
Housing & Urban Development (MLHUD), Directorate of Water Resources Management (DWRM),
Department of Fisheries Resources and Uganda Association of Impact Assessors was instituted to guide
the process. The SEA was undertaken and delivered by the SEA consultant team under the guidance of
this Steering Committee.
The process was initiated by a high level scoping meeting in April 2010, followed by another high level
steering committee meeting in November 2010. The official kick off was in March 2012 and since then the
SEA developed through careful analyses and a rigorous consultative and collaborative process. At different
stages (phases) and levels (national, local and regional), various stakeholders were involved in
identification of key issues and recommendations. Further issues and recommendations were drawn from
a scenario analysis process. The SEA was supplemented by Advisory Notes throughout the process. A
typical example was the advice on The Petroleum (Refining, Gas Processing, Conversion, Transportation
and Storage) Bill, 2012 and the Petroleum (Exploration, Development and Production) Act, 2013. For
effective implementation of the recommendations, a monitoring framework has been provided.
This is the first SEA for the oil and gas sector in Uganda and will be a valuable reference at national and
other levels. It is also a beginning of stakeholder partnership framework on concerted implementation of
the recommendations that will guide future plans and decisions regarding sustainable environmental
management of oil and gas activities in the Albertine Graben.
The Ministry of Energy and Mineral Development and the Ministry of Water and Environment would like
to thank all the institutions and individuals that participated in the preparation of this historic document.
We call upon all those who participated and future readers to nurture the initiated partnership on
sustainable environmental management of oil and gas activities in the Albertine Graben and the wider
petroleum sector.
.…………………………………………………………………………………
Hon. Eng. Irene Muloni (MP) Minister of Energy and Mineral Development ………………………………………………………………………………… Prof. Ephraim Kamuntu (MP) Minister of Water and Environment
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ACKNOWLEDGEMENT
The Strategic Environmental Assessment of oil and gas activities in the Albertine Graben is a product
of concerted effort by different individuals and institutions whose contributions are highly
acknowledged. The SEA Team would like to thank the institutions and individuals who were
consulted and whose views greatly provided value to this document as a building block for future
stakeholder partnership on environmental management of oil and gas in the Albertine Graben.
The SEA Team would like to acknowledge the invaluable leadership from the Ministry of Energy and
Mineral Development through the Petroleum Exploration and Production Department for the
successful coordination of the process, most especially Mr. Dozith Abeinomugisha and Ms. Caroline
Korutaro. The Ministry of Water and Environment through the National Environment Management
Authority most especially the Environment Management Pillar Manager Mr. Waiswa Arnold Ayazika
is highly acknowledged. The Steering Committee instituted to guide the SEA process is also highly
acknowledged.
The Steering Committee consisted of the following members:
Mr. Dozith Abeinomugisha (Petroleum Exploration and Production Department, Ministry of
Energy and Mineral Development), Chairman
Mrs. Caroline Korutaro (Petroleum Exploration and Production Department, Ministry of
Energy and Mineral Development), Secretary
Mr. Edgar Buhanga (Uganda Wildlife Authority, UWA)
Mr. Waiswa Ayazika (National Environment Management Authority, NEMA)
Mr. Simon P. Otoi (Uganda Association of Impact Assessors, UAIA)
Mrs. Teddy Tindamanyire (Directorate of Environmental Affairs, Ministry of Water and
Environment)
Mr. Vincent Byendamira (Directorate of Physical Planning & Urban Development, Ministry of
Lands, Housing & Urban Development)
Mr. Aventino Bakunda (Department of Fisheries Resources, Ministry of Agriculture Animal
Industry and Fisheries)
Mr. Emmanuel Olet (Directorate of Water Resource Management, Ministry of Water and
Environment)
The Team finally gives special tribute to the Norwegian Government through the Directorate for
Nature Management, for providing financial support and technical backstopping.
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TABLE OF CONTENT
FOREWORD .................................................................................................................................. ii
ACKNOWLEDGEMENT ................................................................................................................... iii
EXECUTIVE SUMMARY .................................................................................................................. ix
ACCRONYMS .............................................................................................................................. xvi
1 INTRODUCTION .................................................................................................................... 1
1.1 The Geographical Scope of the SEA ......................................................................................... 2
1.2 The Oil and Gas Sector............................................................................................................. 5
1.3 Structure of the SEA Report .................................................................................................... 8
2 THE SEA PROCESS AND METHODOLOGY ............................................................................... 10
2.1 The SEA Approach ................................................................................................................. 10
2.2 Key Issues .............................................................................................................................. 11
2.2.1 Review of documentation ............................................................................................. 13
2.2.2 Evaluation by expert teams/panels ............................................................................... 13
2.2.3 Stakeholder opinions ..................................................................................................... 13
2.2.4 Scenario Analysis ........................................................................................................... 13
2.3 The SEA Phases ...................................................................................................................... 14
2.4 Stakeholder Engagement ...................................................................................................... 17
2.5 SEA Organization and Implementation ................................................................................. 17
3 BASELINE SETTING ............................................................................................................... 18
3.1 The Regional Setting .............................................................................................................. 18
3.2 The Physical Environment ..................................................................................................... 19
3.2.1 Climate ........................................................................................................................... 19
3.2.2 Geology and Soils........................................................................................................... 19
3.2.3 Surface waters ............................................................................................................... 20
3.2.4 Ground Water ................................................................................................................ 23
3.3 The Biological Environment ................................................................................................... 23
3.3.1 Aquatic flora & fauna..................................................................................................... 23
3.3.2 Terrestrial Flora and Fauna ............................................................................................ 25
3.3.3 Protected and Sensitive Environments ......................................................................... 26
3.4 Socio-Economic Environment ................................................................................................ 29
3.4.1 Population and Land Ownership Tensions .................................................................... 29
3.4.2 Livelihoods ..................................................................................................................... 30
3.4.3 Poverty Levels ................................................................................................................ 33
3.4.4 Access to Social Services ................................................................................................ 33
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3.4.5 State of the Environment .............................................................................................. 33
3.4.6 Archaeology and Cultural Heritage ............................................................................... 34
4 LEGAL AND INSTITUTIONAL FRAMEWORK. POLICIES, PLANS AND PROGRAMS .................... 36
4.1 Legal Framework .................................................................................................................. 36
4.1.1 The Constitution of Uganda, 1995 ................................................................................. 36
4.1.2 The National Environment Act, Cap 153, 2000 ............................................................. 37
4.1.3 The Petroleum Supply Act, 2003 ................................................................................... 37
4.1.4 The Petroleum Act, 2013 and Petroleum Bill, 2012 ...................................................... 38
4.2 Regulations ............................................................................................................................ 39
4.3 International and Regional Conventions/Treaties, and guidelines ....................................... 40
4.4 Compliance and Enforcement ............................................................................................... 40
4.4.1 Compliance .................................................................................................................... 40
4.4.2 Enforcement .................................................................................................................. 41
4.5 Institutional Framework and Capacity .................................................................................. 41
4.5.1 General Governance Structure ...................................................................................... 41
4.5.2 Institutional framework for environment management of oil and gas ........................ 44
4.6 Policies, Plans and Programs ................................................................................................. 45
4.6.1 Policies ........................................................................................................................... 46
4.6.2 Plans............................................................................................................................... 47
4.6.3 Programs ........................................................................................................................ 52
5 INTEGRATION OF KEY ISSUES INTO POLICIES, PLANS AND PROGRAMS ................................. 54
6 ASSESSMENT OF STRATEGIC ASPECTS RELATED TO PETROLEUM ACTIVITIES ......................... 72
6.1 Description of the development scenarios ........................................................................... 73
6.2 Petroleum Activities in Environmentally Sensitive and Protected Areas ............................. 76
6.2.1 Assessment of risks and opportunities for current and future petroleum activities .... 77
6.2.2 Recommendations ......................................................................................................... 79
6.3 Co-existence with Other Sectors and Local Communities..................................................... 81
6.3.1 Co-existence with Fisheries ........................................................................................... 82
6.3.2 Co-existence with Tourism ............................................................................................ 84
6.3.3 Co-existence with Local Communities ........................................................................... 85
6.3.4 Co-existence with Cultural heritage .............................................................................. 88
6.4 Institutional Framework and Capacity .................................................................................. 92
6.4.1 Environmental management on a national level .......................................................... 92
6.4.2 Coordination between governmental agencies and district/local level ....................... 94
6.4.3 Capacity building ........................................................................................................... 96
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6.5 Management of Pollution and Waste ................................................................................... 99
6.5.1 Oil spill contingency planning ........................................................................................ 99
6.5.2 Drilling waste and produced water ............................................................................. 103
7 SUMMARY AND TESTING OF RECOMMENDATIONS. MONITORING REQUIREMENTS ............ 107
7.1 Summary and Testing of main Recommendations ............................................................. 107
7.2 Strategic aspects .................................................................................................................. 132
7.3 Differences between the development scenarios .............................................................. 134
7.4 Achievements as compared with SEA Objectives ............................................................... 136
7.5 Performance compared to international best practice ....................................................... 138
7.6 Concluding Advice ............................................................................................................... 139
8 REFERENCES ....................................................................................................................... 142
APPENDIX 1: OVERVIEW OF MAJOR REPORTS PRODUCED IN THE SEA PROCESS ............................... 147
APPENDIX 2: THE PETROLEUM INDUSTRY AND TYPICAL ASPECTS AND IMPACTS .............................. 149
APPENDIX 3: SCENARIO ANALYSIS ....................................................................................................... 163
APPENDIX 4: STAKEHOLDER ENGAGEMENT PROCESS & LOG ............................................................. 184
APPENDIX 5: ENVIRONMENTAL LAWS AND REGULATIONS; INTERNATIONAL AND REGIONAL
CONVENTIONS AND AGREEMENTS AND ADDITIONAL POLICIES......................................... 196
APPENDIX 6: ISSUES REGISTER AND ANALYSIS .................................................................................... 218
APPENDIX 7: KEY ISSUES INTEGRATION MATRIX ................................................................................ 225
APPENDIX 8: DESCRIPTION OF SCENARIO 2 AND 3 ............................................................................. 249
APPENDIX 9: PETROLEUM INDUSTRY IMPACTS IN ENVIRONMENTALLY SENSITIVE AND PROTECTED
AREAS .................................................................................................................................. 256
APPENDIX 10: RESETTLEMENT POLICY FRAMEWORK SUMMARY FOR OIL AND GAS ACTIVITIES
IN AG .................................................................................................................................... 259
APPENDIX 11: THE SEA ORGANISATION .............................................................................................. 263
APPENDIX 12: OUTLINE OF AN INTEGRATED MANAGEMENT PLAN ................................................... 266
APPENDIX 13: COMMENTS RECEIVED FROM STAKEHOLDERS DURING THE VALIDATION PHASE ...... 269
APPENDIX 14: IMPLEMENTATION PLANNING ..................................................................................... 277
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LIST OF FIGURES
Figure 1.1: The status of oil and gas licensing in the Albertine Graben as of Febraury, 2013 ................ 3
Figure 1.2: The wider area with Lake Albert, major roads, district borders and settlements ................ 4
Figure 1.3: The oil supply chain ............................................................................................................... 5
Figure 1.4: Number of wells drilled per year for the period 1938 to 2010 ............................................. 6
Figure 1.5: Wells drilled and discoveries in the Albertine Graben as of February, 2013 ........................ 7
Figure 2.1: The four phases of the SEA process .................................................................................... 11
Figure 2.2: Key Issues as basis for strategic discussion ......................................................................... 12
Figure 2.3: Identification of Key Issues .................................................................................................. 12
Figure 3.1: Tectonic setting of the wider area including the Albertine Graben forming the
northernmost part of the Western arm of the East African Rift System .............................................. 20
Figure 3.2: Bathymetry of Lake Albert................................................................................................... 22
Figure 3.3: Species richness map combining large mammals, birds and woody plants ....................... 27
Figure 3.4: Protected Areas located in the wider study area ................................................................ 28
Figure 3.5: Population in Hoima and Buliisa Districts 2002 – 2012 ....................................................... 29
Figure 4.1: Generic institutional framework for environment management of oil and gas ................. 45
Figure 6.1: Scenario matrix .................................................................................................................... 74
Figure 6.2: A Multi-stakeholder partnership model for the Albertine Graben ..................................... 96
Figure 6.3: Usual tiers for oil spill contingency.................................................................................... 100
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LIST OF TABLES
Table 3.1: Productivity by District for Selected Crops (Yield (MT)/Area (ha)) ....................................... 31
Table 7.1: Key Issues Group 1- Petroleum related activities in protected and Environmentally
Sensitive Areas .................................................................................................................................... 107
Table 7.2: Key Issues Group 2 - Co-existence with Local Communities .............................................. 110
Table 7.3: Key Issues Group 3 - Co-existence with Archaeology and Cultural Heritage ..................... 111
Table 7.4: Key Issues Group 4 - Co-existence with Other Industries and Service Providers ............... 113
Table 7.5: Key Issues Group 5 - Co-existence with Tourism ................................................................ 114
Table 7.6: Key Issues Group 6 - Co-existence with Fisheries ............................................................... 115
Table 7.7: Key Issues Group 7 - Sharing of Revenue and Wellbeing between the National and
Local/Regional Level (Co-operation) ................................................................................................... 116
Table 7.8: Key Issues Group 8 - Discharge and Emissions for the Petroleum Industry ....................... 118
Table 7.9: Key Issues Group 9 - Waste Management .......................................................................... 119
Table 7.10: Key Issues Group 10 - Water Management ...................................................................... 121
Table 7.11: Key Issues Group 11- Oil Spill Preparedness on Land and Surface Waters ...................... 122
Table 7.12: Key Issues Group 12 - Infrastructure Development in the Region and Transportation of
Crude, Products and Construction Materials ...................................................................................... 124
Table 7.13: Key Issues Group 13 - Institutional Capacity Building (Structure and Functions) ............ 125
Table 7.14: Key Issues Group 14 - Capacity of District Local Governments to Manage Environmental
Concerns .............................................................................................................................................. 126
Table 7.15: Key Issues Group 15 - Development of Legislation and Regulations as well as
Standards ............................................................................................................................................. 127
Table 7.16: Key Issues Group 16 - Land Use and Spatial Planning ...................................................... 128
Table 7.17: Key Issues Group 17 – Transboundary and International Issues ...................................... 130
Table 7.18: Key Issues Group 18 - Establishment of Transparent Baseline data and Scientific Basis . 131
Table 7.19: Main recommendations within each strategic aspect ..................................................... 132
Table 7.20: Differences between the development scenarios ............................................................ 134
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EXECUTIVE SUMMARY
The Albertine Graben (AG) in the Republic of Uganda holds oil and gas resources with a large
potential for commercial development. The goal of the National Oil and Gas Policy (2008) is to use
these resources to contribute to early achievement of poverty eradication and create lasting value to
society. The objective is to “ensure that oil and gas activities are undertaken in a manner that
conserves the environment and biodiversity”.
To support and guide the National Oil and Gas Policy, the Government has decided to undertake a
Strategic Environmental Assessment (SEA) for the Albertine Graben (AG). The objective of the SEA is
to ensure that environmental and socio-economic concerns contribute to a balanced and sustainable
development of the oil and gas sector. The SEA covers the entire Albertine Graben with a focuse on
ongoing and planned activities in Exploration Areas 1, 2 and 3A, and the development of a refinery
and potential export of products and crude to international markets.
The potential for petroleum resources in Uganda was mapped as early as 1925 and the first well in
Uganda was drilled in 1938. The first oil discovery was made at Mputa in 2006 and since then several
exploration areas have been earmarked. There are currently, four active Production Sharing
Agreements (PSAs). A total of 88 wells have been drilled, of which 76 have been successful
discovering more than 3.5 billion barrels of oil in place (STOIIP) as of March 2013.
The Albertine Graben is also an area of national and international importance in terms of its
outstanding biodiversity and network of protected areas. The area is relatively sparsely populated by
pastoral and agro-pastoral communities but there are also several urban centers in the wider region.
The SEA is building on a thorough registration and documentation of the baseline setting in the AG
comprising a regional overview, the physical environment, the biological environment and the socio-
economic environment. This has also been the case when it comes to the legal and institutional
framework and relevant Policies, Plans and Programs (PPPs) which have all been registered and
discussed in the SEA.
The National Environment Act, Cap 153, requires that the National Environment Management
Authority (NEMA) consults closely with relevant lead agencies in the process of the SEA. To fulfill this,
NEMA initiated several scoping workshops for the SEA in 2010. These workshops discussed main
potential environmental and social challenges, organization of the SEA work, the kinds of decisions
needed to be taken during the process and the plans that would be subjected to the SEA. The most
challenging concerns were at that time identified as biodiversity loss, land conflicts and trans-
boundary issues.
A Steering Committee for the SEA was appointed and it was decided that the Petroleum Exploration
and Production Department (PEPD) under the Ministry of Energy and Mineral Development (MEMD)
leads the Steering Committee while NEMA coordinates the activities of the SEA. The Steering
Committee developed draft Terms of Reference (ToR) for the SEA activities and these have been the
platform for the SEA work. The SEA is based on international best practice adapted to the specific
Ugandan conditions. A team of national and international consultants cooperated to undertake and
deliver the SEA under the guidance of the Steering Committee.
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The main goals of the SEA were to recommend how to:
Ensure that environmental and sustainability considerations are taken into account during
early stages of decision making and integrate these considerations into laws/regulations and
relevant PPPs; and
Deal with high level environmental strategic aspects in general for the sector and assess
specific future development scenarios in this context.
The formal kick-off meeting for the SEA process took place in Kampala on March 15, 2012, initiating
the inception phase and with the goal of delivering a final SEA Report early 2013. The SEA was
developed during four phases: the screening and scoping (2009 – 2012), the inception, the pre-
assessment and the assessment. Main deliverables in each phase are in that order: the Terms of
Reference, the Inception Report, the Scenario Analysis, and the Resettlement Policy Framework (RPF)
for Oil and Gas Activities in Albertine Graben, the Interim Report and this final SEA Report.
The emerging petroleum sector has a high potential to contribute significantly to Uganda’s economy,
industrialization and poverty alleviation plans. However, as the petroleum resources are located both
within and in the vicinity of environmentally sensitive and protected areas, this poses a particular
challenge to the government, the petroleum industry and the society at large in Uganda.
Safeguarding the environment, community cohesion, community health and safety as well as cultural
heritage is and will be a challenge in light of the fast developing plans. Land acquisition, resettlement
issues and regional security are already under discussion and co-existence challenges, especially with
the tourism industry as well as fisheries and the local society, are already emerging. There is concern
regarding the capacity of the local communities and whether the society can absorb the expected
fast changes in order to take advantage of the benefits.
A systematic approach was developed and followed in order to identify the most relevant and
significant issues of focus for the assessments and recommendations. More than 135 issues were
registered, and these were analyzed and prioritized based on specifically developed significance
criteria. 18 Key Issues Groups were highlighted for further evaluations. The Key Issues were
established after a comprehensive process involving stakeholder engagement, review of
documentation, evaluation by expert teams and a Scenario Analysis. Stakeholder consultation is in
general a key concern for a successful SEA process and wherever practical this was arranged on all
levels. A stakeholder engagement process and log are attached to the SEA.
The Scenario Analysis focuses on the development of a refinery over four sequential phases, each
characterized by activities/key components and related concerns and opportunities. Major concerns
are connected to the development in the Murchison Falls National Park, the large amounts of
workers to be present in the AG during the construction phases and extensive truck transportation of
crude and material on public roads.
A Key Issues Integration Matrix was developed as a tool for dealing with the 18 Key Issues Groups.
The SEA Team identified relevant laws/regulations and PPPs connected to each of the Key Issues and
has engaged connected stakeholders in a comprehensive dialogue on how to deal with the concerns.
Proposed recommendations were developed by the Team prior to the stakeholder discussions and
these were adjusted and supplemented based on the outcome of the consultations. The numbers of
recommendations within each Key Issues Group were typically in the range of 3-20. The 18 Key Issues
groups are:
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1. Petroleum related Activities in Protected and Environmentally Sensitive Areas.
2-6. Co-existence with Local Communities, Archaeology and Cultural Heritage, other Industries
and Service providers, Tourism and with Fisheries.
7. Sharing of revenues between the National and the Local/Regional level (Co-operation).
8. Discharges and Emissions from the Petroleum Industry.
9. Waste Management.
10. Water Management.
11. Oil Spill Preparedness on Land and in Surface Waters.
12. Infrastructure Development in the Region and Transportation of Crude, Products and
Construction Materials.
13. Institutional Capacity Building; Structure and Functions.
14. Capacity of District Local Governments to Manage Environmental Concerns.
15. Development of Legislation, Regulations and Standards.
16. Land Use and Spatial Planning.
17. Transboundary and International Issues.
18. Establishment of Transparent Baseline Data and Scientific Basis.
The most significant recommendations within each Key Issues Group were tested against the
National Oil and Gas Policy (NOGP). The tests were in terms of sustainability and compatibility with
focus on the NOGP coverage of the issue, the NOGP strategy how to deal with the issue and NOGP
proposed actions.
Furthermore, monitoring requirements for the implementation of the recommendations were
proposed with focus on Key Issue identification, monitoring indicators and related responsible
institutions.
In addition to dealing with the integration of the 18 Key Issues Groups into laws/regulations and
PPPs, the SEA also discusses and provides advice on selected strategic aspects related to the
petroleum development. These are:
Petroleum activities in environmentally sensitive and protected areas;
Co-existence with other sectors (fisheries, tourism and cultural heritage) and local
communities;
Institutional framework and capacity;
Management of pollution and waste.
Advice is given on a general basis and the most significant recommendations are listed in the SEA.
The strategic aspects are also discussed in relation to specific development scenarios comprising
development of a refinery and export pipeline, refinery only, export pipeline for crude only and
railway transportation of crude only. The most significant issue is related to the development in the
Murchison Falls National Park which is basically the same for all scenarios. The differences based on
other aspects vary for each scenario but are altogether marginal.
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The concluding advice from the SEA process is the following:
The emerging petroleum sector has a high potential to contribute significantly to Uganda’s economy,
industrialization and poverty alleviation plans. Significant efforts have already been made to use this
opportunity to develop the country. The recommendations of this SEA should be integrated into
national development planning to ensure that environmental and socio-economic concerns are
managed well.
The following points describe the overriding advice based on the recommendation from the SEA
process:
The current planning for development of the petroleum sector has a positive drive. However,
it is recommended to moderate the speed of development to ensure balanced capacity
building amongst relevant institutions, such as NEMA, to manage the sector. Furthermore,
this adjustment would benefit the local district governments and population to adapt to the
new sector.
Activities in areas which are formally designated for ecosystem protection and biodiversity
conservation should be in accordance with the official protection status of the area. As an
example, the National Parks fall into category II of the IUCN classification. The activities
should also ensure maintenance of the status quo of the ecosystem and the biodiversity or
even improving it. Any decision-making regarding potential future petroleum activities in
protected or environmentally sensitive areas need to be based on an Integrated Management
Plan according to the principles outlined in Appendix 12. Therefore the detailed content of the
Integrated Management Plan should be developed and implemented urgently.
Petroleum exploration activities that are already licensed to take place in protected and
environmentally sensitive areas should continue to be based on approved EIAs and
relevant national policies and guidelines such as the National Policy on conservation and
sustainable development of wildlife resources. In addition such activities should follow
international best practice for operations in protected and environmentally sensitive areas.
The legal framework has to be further adapted to the new petroleum sector. An important
element is to further develop the EIA legislation and guidelines according to international best
practice.
Co-existence of the petroleum sector with other sectors is of high importance. The petroleum
industry should proactively train potential local service providers to reach a high local
content. In order to ensure sustainable co-existence with the fisheries, this sector needs
stronger regulation and management. The tourism sector is depending on the preservation of
ecosystem and recreational functions. Mechanisms have to be established to avoid that the
petroleum industry is undermining these values. The sectors should establish common
communication platforms where relevant concerns can be resolved.
Local communities will experience opportunities as well as risks. The capacity to adapt to the
changing framework conditions has to be a key focus and long-term socioeconomic benefits
have to be ensured. A social development plan should therefore be developed. The scenario
analysis reveals the presence of large numbers of workforce, especially during construction
periods and points at significant in-migration. The planning of urbanization and required
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associated infrastructure has to be advanced in line with petroleum development planning to
avoid social tension and lack of capacity of infrastructure.
The Scenario Analysis also reveals that the pressure on public roads is a major concern.
Adequate infrastructure to meet the industry needs while ensuring public road safety has to
be in place.
Selected areas have been designated for industry development and land take is ongoing.
There is concern that resettlement and compensation mechanisms are not adequate.
The SEA advices to implement mechanisms in accordance with international best practice.
The National Oil Spill Contingency Plan is under development. Timely preparation and
implementation including the relevant training is essential.
Waste management has already received increasing attention. Waste management
strategies and facilities covering the existing legacy waste as well as future waste have to be
developed in the very near future in line with international best practice.
Although produced water is not yet a key concern, it requires dedicated attention already
now.
Water management is a major concern. The petroleum industry requires large amounts of
water during their operations and this adds to the pressure on water resources in AG. The
Government should establish water management planning considering the resource needs,
sources and associated environmental impacts.
The National Oil and Gas Policy outlines the spirit of cooperation and the roles of the
Government and the oil industry. The oil industry should be encouraged to take an active role
in developing technology to meet the challenges of ecologically vulnerable areas and reduce
their footprint.
The Government has taken a proactive role in communication with neighbouring states
regarding transboundary issues such as sharing of petroleum reserves across borders with DR
Congo. Further efforts should be made regarding shared oil spill contingency for Lake Albert
and the Nile, fisheries management, security of oil and gas installations, public and border
security.
The National Oil and Gas Policy outlines goals, strategies and actions for revenue
management and transparency. Proper mechanisms and measures should be put in place to
ensure that long-term benefits are created and shared fairly with due consideration of the oil
and gas bearing regions.
Stakeholder engagement is a key principle of the Ugandan government and the SEA builds on
this principle. The disparities in the Ugandan society require attention to ensure that
consultation is meaningful and that information is transparent and easily accessible for
stakeholders. This will contribute to achieving the social license to operate and minimize the
potential for social conflict.
To ensure that the conclusions from the SEA are adequately considered an Implementation
Plan should be developed. This should include the collection of and access to adequate
baseline data. In addition, the SEA should be updated regularly.
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Testing was done to establish whether the SEA and connected recommendations met the objectives
set for the SEA. The result was that all major objectives were met. Testing against criteria set by the
International Association for Impact Assessment (IAIA)) on how to build a good-quality SEA process
according to international best practice was undertaken by the Team and these criteria were met as
well.
An extensive stakeholder engagement program has supported the SEA process. This program which
has engaged individuals, organisations, authorities and others, has initiated good discussions and
added valuable information to the process. The Scoping Workshops in April 2010, the Inception
Workshops in May 2012 and the Validation Workshop in May 2013 have provided valuable feedback
to the assessments.
The structure of the report is presented below:
Chapter 2 explains the SEA process and methodologies used. The cornerstone for the process is the
two-sided objective of the SEA focusing on: 1) how to ensure that environmental and sustainability
considerations are taken into account and integrated into relevant PPPs during early stages of
decision making and 2) how to deal with high level strategic aspects in general and evaluate and
communicate strategic aspects for specific future development scenarios.
Chapter 2 further focuses on the term Key Issues which to a large extent is the basis for the SEA
assessments and the connected stakeholder engagement process. It explains how the Key Issues are
identified and analyzed, refer also to Appendix 6, the Issues Register and Analysis. A Scenario Analysis
presented in a separate report, Appendix 3, discusses which concerns are the most important to
consider during the different stages of the petroleum development. Stakeholder engagement is the
most important part of the SEA and the consultation is explained in Chapter 2.
Another part of the chapter presents the SEA organization and implementation of the process.
Chapter 3 is a short version of the Baseline Setting with focus on regional aspects, the physical -
biological environment and the socio-economic environment. A more comprehensive version of this
chapter can be found in the Inception Report.
The Legal and Institutional Framework is an important basis to understand and be able to integrate
the environmental concerns into the right PPPs. Chapter 4 thus presents the legal framework,
relevant regulations to be aware of, international and regional conventions/guidelines,
compliance/enforcement matters, institutional framework and capacity, and relevant PPPs.
Chapter 5 and 6 present the discussions and analysis made to cover the two-sided objective of the
SEA process. Chapter 5 discusses how to integrate the Key Issues into laws/regulations and relevant
PPPs. The Key Issues Integration Matrix, Appendix 7, has been a crucial instrument during the
analysis. Chapter 6 deals with selected high level strategic aspects on two levels; on a general level
and on a specific development scenario level.
Chapter 7 summarizes the recommendations made and tests whether the SEA process and
conclusions are according to expectations and sustainable development of the sector. It also gives
advice on how to monitor the implementation of the recommendations.
An overview of the reports produced during the SEA process is presented in Appendix 1.
Page xv
Appendix 2 presents typical aspects and impacts related to the petroleum industry.
Appendix 3 presents the Scenario Analysis process and results elaborated according to different
phases.
Appendix 4 comprises the Stakeholder Engagement Process & Log including analysis of the different
stakeholder categories and interests, Methodology and approach used in stakeholder engagement
and outcome of the consultations.
Appendix 5 elaborates environmental laws and regulations; international and regional conventions
and agreements; and additional policies including highlight of the policies that are listed in Chapter 4
but not described in detail.
Appendix 6 presents an issues register and analysis including a comprehensive list of issues, criteria
used and significance rating.
Appendix 7 presents the Key Issues Integration Matrix outlining key issues, Relevant PPPs and
stakeholders, Laws and Regulations, outcome of the consultations and recommendations.
Appendix 8: Description of Scenario 2 and 3, providing information on overall description of oil field
development, overall description of Scenario 2 and 3 and scenario overview matrixes for each
development phase.
Appendix 9 highlights petroleum industry impacts in environmentally sensitive and protected areas,
listing typical primary and secondary impacts related to petroleum activities in environmentally
sensitive and protected areas.
Appendix 10 presents a summary of the Resettlement Policy Framework for Oil and Gas activities in
the AG.
Appendix 11 is the Sea Organisation providing a list of members of the Steering Committee and their
Institutions and members of the SEA Team and their areas of expertise.
Appendix 12 outlines a proposal for Integrated Management Plan (IMP).
Appendix 13 deals with the comments from the stakeholders received during the Validation
Workshop.
Appendix 14 outlines the principles for implementation planning.
Page xvi
ACRONYMS
AG Albertine Graben
AGEMP Albertine Graben Environmental Management Plan
AIA Archaeological Impact Assessment
AIDS Acquired Immune Deficiency Syndrome
API American Petroleum Institute
BAT Best Available Technique
bbls/d Barrels of oil per day
BEP Best Environmental Practice
BMU Beach Management Unit
BOPD Barrels of oil per day
CBD Convention on Biological Diversity
CISCO Coalition of NGOs of Oil and Gas
CNOOC China National Offshore Oil Corporation
CPF Central Processing Facility
CSO Civil Society Organizations
DEA Directorate of Environmental Affairs
DEO District Environment Officer
DFR Department of Fisheries Resources
DN Directorate for Nature Management, Norway
DRC Democratic Republic of Congo
DSIP Development Strategy and Investment Plan
DWD Directorate of Water Development
DWRM Directorate of Water Resources Management
E&P Exploration and Production
EA Exploration Area
EAC East African Community
EAPS East African Petroleum Services Ltd
EIA Environmental Impact Assessment
EIN Environmental Information Network
EIS Environmental Impact Statement
EITI Extractive Industries and Transparency Initiative
EMS Environmental Management System
ERA Environmental Risk Assessment
EWT Extended Well Testing
FEED Front End Engineering Design
FSSD Forest Sector Support Department
GIS Geographical Information System
GKMA Greater Kampala Metropolitan Area
HIV Human Immune Virus
HSE Health Safety Environment
Page xvii
IAIA International Association for Impact Assessment
IFAD International Fund for Agricultural Development
IFC International Finance Corporation
IFPRI International Food Policy Research Institute
IMP Integrated Management Plan
IOR Improved Oil Recovery
IPP Integrated Power Project
IR Inception Report
ITCZ Inter-Tropical Convergence Zone
IUCN International Union of Conservation of Nature
LCV Local Council, level V
LG Local Government
LPG Liquefied Petroleum Gas
m.a.s.l Metres above sea level
MAAIF Ministry of Agriculture, Animal, Industry and Fisheries
MEMD Ministry of Energy and Mineral Development
mEq Milli equivalent
MFNP Murchison Falls National Park
MGLSD Ministry of Gender, Labour and Social Development
MLHUD Ministry of Lands, Housing and Urban Development
Ms Manuscript
MSL Mineral Services Ltd
MT Million Tonnes
MTWA Ministry of Tourism, Wildlife and Antiquities
MWE Ministry of Water and Environment
MUIENR Makerere University Institute of Environment and Natural Resources
NAFIRRI National Fisheries Resources Research Institute
NATOIL Uganda National Oil Company
NCEA Netherlands Commission for Environmental Assessment
NDP National Development plan
NEAP National Environmental Action Plan
NEMA National Environment Management Authority
NEMP National Environment Management Policy
NE-SW North East-South West
NFA National Forestry Authority
NGO(s) Non-Governmental Organization(s)
NINA Norwegian Institute for Nature Research
NOGP National Oil and Gas Policy
NORM Naturally Occurring Radioactive Materials
NOSCP National Oil Spill Contingency Plan
NOx Nitrogen Oxide
Page xviii
NP National Park
NTMP National Transport Master Plan
OPEC Organisation of Petroleum Exporting Countries
OPM Office of the Prime Minister
OfD Oil for Development Program, Norway
OSCA Oil Spill Contingency Analysis
PAPs Project Affected Persons
PAU Petroleum Authority of Uganda
PEAP Uganda Poverty Eradication Action Plan
PEPD Petroleum Exploration and Production Department
PM Particulate Matter
PMA Plan for Modernization of Agriculture
PPP(s) Policies, Plans and Program(s)
PSA Production Sharing Agreement
QA Quality Assurance
RAP Resettlement Action Plan
RBP Regulatory Best Practice
RPF Resettlement Policy Framework
SEA Strategic Environmental Assessment
SC Steering Committee
SOx Sulfur Oxide
SWL Static Water Level
STD Sexually Transmitted Diseases
STOIIP Stock Tank Oil Initially in Place
ToR Terms of Reference
UAIA Uganda Association of Impact Assessors
UBOS Uganda Bureau of Statistics
UGX Ugandan Shilling
UNBS Uganda National Bureau of Standards UNDP United Nations Development Program
UNEP United Nations Environment Program
UNESCO United Nations Educational, Scientific and Cultural Organisation
UNFCCC United Nations Framework Convention on Climate Change
UNRA Uganda National Roads Authority
UPDF Ugandan People’s Defence Forces
UWA Uganda Wildlife Authority
WR Wildlife Resources
Page 1
1 INTRODUCTION
The Albertine Graben in the Republic of Uganda is endowed with oil and gas resources with large
potential for commercial development. The goal of the National Oil and Gas Policy (2008) is to use
the country’s oil and gas resources to contribute to early achievement of poverty eradication and
create lasting value to society. The operational objective pertaining to the environment is to; “ensure
that oil and gas activities are undertaken in a manner that conserves the environment and
biodiversity”. To support and guide this National Oil and Gas Policy, the Government decided to
perform a Strategic Environmental Assessment (SEA) for the Albertine Graben.
The objective of the SEA was to ensure that environmental issues associated with the oil and gas
sector are considered and integrated into laws/regulations, major decisions connected to Policies,
Plans and Programs (PPPs) and specific strategic aspects related to petroleum activities at the earliest
stage in order to achieve the goals of the National Oil and Gas Policy.
The SEA is in accordance with the Ugandan understanding aiming at supporting sustainable
development which defines the environment to comprise the physical environment, cultural heritage
and socio-economic effects caused by petroleum development in the Albertine Graben. Institutional
matters related to infrastructure, spatial planning, and emergency response, capacity building, etc.,
are included where relevant.
The Albertine Graben is a sparsely populated area of national and international importance in terms
of its outstanding biodiversity and network of protected areas. As this area also harbors the country’s
most promising petroleum reserves, this poses a particular challenge for oil and gas industry in
Uganda.
The SEA shall contribute to sustainable use of natural resources and goods derived from the
Albertine Graben by maintaining the structure, functioning and productivity of the ecosystems of the
area as a basis for long term value creation and sustained livelihoods.
The SEA process shall further contribute to a balanced and sustainable development of the
petroleum sector, and shall focus on the following principles:
Ensure public participation to make sure that concerns and expectations are considered in
the decision process;
Ensure that all relevant major issues are addressed at the earliest stages of the oil and gas
development and that advice is given in the process of decision making;
Establish a common understanding and joint baseline for the SEA;
Identify key issues to be dealt with in order to ensure a focused discussion;
Identify environmental related opportunities and risks associated with various scenarios for
the petroleum development and give advice on enhancing opportunities and minimizing
risks;
Outline mitigation and monitoring requirements and objectives that establish best practice
and ensure effective impact management for future oil and gas development;
Use efficient and well developed methodologies for the SEA;
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Establish and implement a transparent SEA process which also ensures predictability for
sustainable involvement of the international oil industry which will in turn apply best
international practices.
1.1 The Geographical Scope of the SEA
The SEA covers the entire Albertine Graben with a focus on ongoing and planned petroleum license
areas, which comprise Exploration Areas 1 (Pakwach Basin), 2 (Lake Albert Basin) and 3A (Semliki
Basin) in addition to the development of a proposed refinery and the transportation of crude from
the petroleum production facilities to the refinery. Figure 1.1 shows the status of licensing in the
Albertine Graben. The SEA is also considering scenarios where all oil production is exported either via
pipelines or railway.
The Albertine Graben forms part of the Western arm of the East Africa Rift System. The Graben is a
unique physiographic region comprising of the rift escarpments, the block of the Rwenzori Mountains
and an extensive graben. The area has several lakes including Albert, Edward and George.
The Albertine area is a landscape of great relief contrast with both the lowest elevation in the
country of about 620 metres above mean sea level and the highest elevation in the country of about
5100 metres above mean sea level on the Magherita peak in the Rwenzori Mountains. The Graben
extends for a total distance of over 500 km with widths averaging 45 km.
The Albertine Graben is one of the most important locations for the conservation of mammals, birds
and freshwater fish in Africa. It has a variety of geological and biological features with complex
ecosystems and high biological diversity. It is a home to many plants and animal species that are
endemic for the region and it is the most important area for bird endemism in Africa. A wide variety
of ecosystems and species are known to exist in the region. The Albertine Graben has got a number
of protected areas.
The Graben is sparsely populated because it dominantly has a hot and dry climate. The majority of
the inhabitants are pastoral and agro-pastoral communities. A number of people live in fishing
villages on the shores of lakes Albert, Edward and George.
Due to the oil development activities in the region, a spiral of urbanization processes is taking place
along the roads in the region. There are several population centres in the area (Figure 1.2) and there
is increased growth of these old towns. The oil exploitation and development activities will most
likely create further urbanization processes.
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(Source: PEPD)
Figure 1.1: The status of oil and gas licensing in the Albertine Graben (as of February 2013)
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(Source: NEMA, 2012)
Figure 1.2: The wider area with Lake Albert, major roads, district borders and settlements
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1.2 The Oil and Gas Sector
The petroleum industry is divided into three levels: upstream, midstream, and downstream which
encompass the main segments of the supply chain. The upstream level includes the exploration,
drilling, and production of crude oil. The midstream level includes the transportation and trading of
crude oil to refineries and refining. The downstream level refers to the distribution and marketing of
crude oil to wholesalers and retailers. Figure 1.3 below illustrates a typical supply chain.
The largest volume of products of the industry is fuel oil and petrol. Petroleum is also the raw
material for many chemical products, including pharmaceuticals, solvents, fertilizers, pesticides, and
plastics. Appendix 2 presents more information about the petroleum industry and typical aspects and
impacts related to the various upstream petroleum activities.
In Uganda, the petroleum potential was first documented by A.J. Wayland in 1925, who mapped oil
seepages at that time. In 1938 the first well, Waki-B1, was drilled in the Butiaba area confirming oil
shows. Since then, petroleum potential of the Albertine Graben was known but it was not until the
1990s that an increased and targeted focus on exploration was initiated.
Figure 1.3: The oil supply chain
By the early 2000s, Uganda was seeking domestic petroleum reserves in response to rising oil prices.
The Albertine Graben has since been subdivided into ten Exploration Areas. The Exploration Areas
include Blocks 1 and 5 located to the north of Lake Albert, Blocks 2, 3A, 3B, 3C and 3D on and around
Lake Albert, while Blocks 4A, 4B and 4C are located around lakes Edward and George in the southern
part of the Graben (Fig. 1.5). Four out of these ten Exploration Areas are currently licensed to oil
exploration companies for exploration, development and production.
In 2002, Heritage Oil and Gas Ltd drilled the first exploratory well, Turaco-1 in Block 3 and two more
wells; Turaco-2 and 3 until 2004. In 2005 Hardman Petroleum Resources Pty drilled the Mputa-1 well
Page 6
in EA 2 and tested in 2006. This well finally provided the break-through and tested a combined total
of 1100 bbl/d. Since then exploration activities have increased significantly (Fig. 1.4) and Uganda is
preparing for managing a petroleum sector.
In 2006, Heritage Oil and Gas Ltd drilled the Kingfisher-1 well in EA3A and estimated Kingfisher
resources to 600 million barrels of crude in place. Heritage's partner Tullow Oil, which had in the
meantime bought Hardman Resources, stated that the Albertine Basin as a whole contained over one
billion barrels. The Kingfisher-1 well flowed over 10,000 bbl/d of oil. The tested oil predominantly
reveals medium crude with an API around 30, a high wax content (16 – up to 30 weight %) and a pour
point around 40° C. These properties imply pumping during production and continuous heating of the
transport infrastructure to ensure flow. Power supply as well as overall energy efficiency are
therefore of key importance to be able to make use of the crude. A consumer for the wax also has to
be considered.
(Source: PEPD, 2012)
Figure 1.4: Number of wells drilled per year for the period 1938 to 2010
Oil exploration and production activities to date indicate that the oil potential in the Graben is
promising. For example, out of the 88 exploration and appraisal wells drilled by to date, 76 were
successful.
In summary the characteristics for the Albertine Graben are:
Total acreage of about 23.000km2
First oil discovery made at Mputa in 2006
20 oil/gas discoveries made to date
More than 3,5 billion barrels of STOIIP (Stock Tank Oil Initially in Place) as of March 2013
Estimated 1 billion barrels of recoverable oil equivalent
4 active Production Sharing Agreements (PSAs)
TOTAL, Tullow, CNOOC hold licenses
Page 7
Four out of ten exploration areas in the Albertine Graben have been licensed to international
oil companies
(Source: PEPD, 2012)
Figure 1.5: Wells drilled and discoveries in the Albertine Graben as of February, 2013
All discoveries have so far been made within the Lake Albert petroleum system while the Rhino Camp
and Lake Edward petroleum systems have not yet been proven.
Significant exploration and appraisal activities are ongoing and CNOOC already holds a conditional
production license for Kingfisher. According to the current planning earliest production is feasible for
end 2016/2017 but various issues have to be resolved in the meantime. These include, among others,
agreement and approval of field development plans, infrastructure and facilities, adequacy of the EIA
process, waste management solutions, capacity and efficiency in various governmental institutions at
various levels to manage the sector properly as well as implementation of adequate oil spill
contingency.
The significant scale of oil discoveries since 2006 drives the expectations of the petroleum resources
contributing significantly to poverty eradication, job and revenue creation. Various alternatives of
petroleum development and use along the value chain are currently under discussion.
Chapter 2.2.4 and 6.1 provides an overview of various potential scenarios and development phases
for upstream and midstream activities. In any case, significant development has to take place in the
Albertine Graben to produce the oil and gas resources and make use of it, whether within Uganda or
for export. Full field development including gathering lines, processing and storage facilities will be
necessary for any of the options.
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This implies significant development and improvement of associated infrastructure such as roads,
waste management facilities, oil spill contingency, medical facilities for emergency response as well
as adequate structuring of the involved governmental institutions and capacity building to manage
the petroleum sector. Land ownership and tenure, compensation and the already started land
speculation have to be tackled to avoid social disruption and corruption. An important aspect is also
the overall security situation within the region, the role of the army, police and potential private
security forces and associated safeguarding of the rights of the local population. Further information
is given in Chapters 5 and 6.
1.3 Structure of the SEA Report
An overview of the reports produced during the SEA process is presented in Appendix 1.
Appendix 2 presents typical aspects and impacts related to the petroleum industry.
Chapter 2 explains the SEA process and methodologies used. The cornerstone for the process is the
two-sided objective of the SEA focusing on: 1) how to ensure that environmental and sustainability
considerations are taken into account and integrated into relevant PPPs during early stages of
decision making and 2) how to deal with high level strategic aspects in general and evaluate and
communicate strategic aspects for specific future development scenarios.
Chapter 2 further focuses on the term Key Issues which to a large extent is the basis for the SEA
assessments and the connected stakeholder engagement process. It explains how the Key Issues are
identified and analyzed, refer also to Appendix 6, the Issues Register and Analysis. A Scenario Analysis
presented in a separate report, Appendix 3, discusses which concerns are the most important to
consider during the different stages of the petroleum development. Stakeholder engagement is an
important part of the SEA and the consultation is explained in Chapter 2.
Another part of the chapter presents the SEA organization and implementation of the process.
Chapter 3 is a short version of the Baseline Setting with focus on regional aspects, the physical -
biological environment and the socio-economic environment. A more comprehensive version of this
chapter can be found in the Inception Report.
The Legal and Institutional Framework is an important basis to understand and be able to integrate
the environmental concerns into the right PPPs. Chapter 4 and Appendix 5 thus presents the legal
framework, relevant regulations to be aware of, international and regional conventions/guidelines,
compliance/enforcement matters, institutional framework and capacity, and relevant PPPs.
Chapter 5 and 6 present the discussions and analysis made to cover the two-sided objective of the
SEA process. Chapter 5 discusses how to integrate the Key Issues into laws/regulations and relevant
PPPs. The Key Issues Integration Matrix, Appendix 7, has been a crucial instrument during the
analysis. Chapter 6 deals with selected high level strategic aspects on two levels; on a general level
and on a specific development scenario level.
Chapter 7 summarizes the recommendations made and tests whether the SEA process and
conclusions are according to expectations and sustainable development of the sector. It also gives
advice on how to monitor the implementation of the recommendations.
An overview of the reports produced during the SEA process is presented in Appendix 1.
Page 9
Appendix 2 presents typical aspects and impacts related to the petroleum industry.
Appendix 3 presents the Scenario Analysis process and results elaborated according to different
phases.
Appendix 4 comprises the Stakeholder Engagement Process & Log including analysis of the different
stakeholder categories and interests, Methodology and approach used in stakeholder engagement
and outcome of the consultations.
Appendix 5 elaborates environmental laws and regulations; international and regional conventions
and agreements; and additional policies including highlight of the policies that are listed in Chapter 4
but not described in detail.
Appendix 6 presents an issues register and analysis including a comprehensive list of issues, criteria
used and significance rating.
Appendix 7 presents the Key Issues Integration Matrix outlining key issues, Relevant PPPs and
stakeholders, Laws and Regulations, outcome of the consultations and recommendations.
Appendix 8: Description of Scenario 2 and 3, providing information on overall description of oil field
development, overall description of Scenario 2 and 3 and scenario overview matrixes for each
development phase.
Appendix 9 highlights petroleum industry impacts in environmentally sensitive and protected areas,
listing typical primary and secondary impacts related to petroleum activities in environmentally
sensitive and protected areas.
Appendix 10 presents a summary of the Resettlement Policy Framework for Oil and Gas activities in
the AG.
Appendix 11 is the Sea Organisation providing a list of members of the Steering Committee and their
Institutions and members of the SEA Team and their areas of expertise.
Appendix 12 outlines a proposal for Integrated Management Plan (IMP).
Appendix 13 deals with the comments from the stakeholders received during the Validation
Workshop.
Appendix 14 outlines the principles for implementation planning.
Page 10
2 THE SEA PROCESS AND METHODOLOGY
The SEA shall contribute to informed decision making by taking into consideration the possible
environmental, cultural heritage and socio-economic effects caused by petroleum development in
the Albertine Graben. The SEA shall document values, assess impacts/conflicts and show how to deal
with challenges. Furthermore, the SEA shall suggest a framework for sustainable use of the natural
resources and goods derived from the Albertine Graben that maintains the structure, functioning and
productivity of the ecosystems of the area as a basis for long term value creation and sustained
livelihoods. Institutional matters related to the petroleum development shall also be considered and
improved.
The specific objectives for the SEA are presented in Chapter 7.4 as part of an evaluation of whether
the objectives are met.
SEA has got increasing attention internationally during the last decade although the process of doing
SEA is known for a longer period of time. The objectives and methodologies are developing rapidly
and there are many good references internationally on interesting SEA literature and performed
processes. A typical characteristic of SEA is, however, that there is no single recipe on how to do SEA
for a specific sector in a specific country.
2.1 The SEA Approach
The SEA approach in Uganda was based on a stepwise process specifically developed for the
Ugandan situation and shall thus contribute to strengthening governance by providing clear and
concise advice to future decisions, either related to laws/regulations and Policies, Plans and
Programs or to specific strategic aspects and future scenarios connected to the development of the
petroleum industry. The advice was provided in the form of advisory notes during the SEA process or
as recommendations in this final SEA report.
An important part of the SEA process was to provide capacity building on petroleum industry related
matters for all directly involved and for the institutions/organizations responsible for the PPPs to be
dealt with during the process.
Public participation was critical for the success of the SEA process and stakeholder consultations
were important in soliciting views and concerns.
The SEA process has been divided into four phases:
Screening and Scoping
Inception
Pre-assessment
Assessment
Figure 2.1 illustrates these steps of the SEA process and presents typical characteristics and the main
deliverables within each phase.
Page 11
Figure 2.1: The four phases of the SEA process
2.2 Key Issues
An important objective of the assessment was to identify Key Issues as basis for the SEA process.
As indicated in Figure 2.2 below, the Key Issues are the basis for two discussions:
1. Ensure that environmental and sustainability considerations are taken into account during
early stages of decision making and integrate these considerations into laws/regulations and
relevant Policies, Plans and Programs (Chapter 5).
2. Deal with high level environmental strategic aspects in general for the sector and assess
specific future development scenarios in this context (Chapter 6).
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Figure 2.2: Key Issues as basis for strategic discussion
It was obvious and necessary to use a systematic approach to reduce the number of issues and focus
the assessment on a limited number of Key Issues.
The SEA has concentrated on using four sources to identify potential issues to be carried on to the
further SEA analysis. A broad analysis and discussion of all the issues has concluded on the most
significant issues, the Key Issues, as a platform for a focused SEA process. The evaluation of
significance is building on how often the issue is highlighted by the four sources shown in Fig 2.3. And
the urgency of the issue related to the SEA process, the duration and extent of impact connected to
the issue and the reversibility of the impact. The Issues Register and Analysis is presented in
Appendix 6. Only the issues within the category of high significance are carried on as Key Issues.
Figure 2.3: Identification of Key Issues
1. Review of
documentation
4. Scenario
analysis
2. Evaluation
by expert teams
3. Stakeholder
opinions
Issues
Evaluation of significance of Issues
Issues Register and Analysis
(Appendix 6)
1. How to ensure that
environmental and sustainability
considerations are taken into
account during early stages of
decision making and how to
integrate these considerations
into laws/regulations and relevant
Policies, Plans and Programs.
2. How to deal with high level
strategic aspects in general and
how to assess strategic aspects
for specific development
scenarios.
Which are the most relevant and
important issues to concentrate the
assessment on?
The Key Issues!
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2.2.1 Review of documentation
Desk identification of relevant issues covered in existing policies, plans and programs (PPPs) related
to the petroleum sector, review of PPPs for other relevant sectors, local community plans, private
industry plans, Environmental Impact Assessments for projects, submissions from interest groups,
None Governmental Organizations (NGOs) plans and statements etc.
2.2.2 Evaluation by expert teams/panels
The scoping/screening process in 2010 provided valuable input to the Issues Register. In 2012, the
Ugandan members of the SEA Team made individual inventories of issues connected to their specific
area of expertise. These inventories are attached to the Inception Report. Amendments to these
issues were made during a reconnaissance trip to the region during the inception phase. Another
input to potential key issues was developed during the field trip which took place during the kick-off
meetings in the inception phase. An inventory of the issues identified during this field trip is attached
to the Inception Report as well.
Valuable input to the Issues Register is delivered by the Norwegian partners to the SEA program and
by the three operating petroleum companies in Uganda.
2.2.3 Stakeholder opinions
Public participation has been critical for the success of the SEA process and stakeholder consultations have been important to solicit their views and concerns about possible issues. Important contributions resulted from the Inception Workshop in May 2012. More information on the stakeholder engagement process is presented in section 2.4 and Appendix 4.
2.2.4 Scenario Analysis
The Scenario Analysis has been used in the SEA as a tool to visualize and analyze a range of “pictures”
of future situations. This methodology is a systematic approach providing a description of activities
related to the different developments over time and connected detailed inventories of concerns and
opportunities at each stage. Three scenarios have been the basis for the SEA:
Scenario 1, a development combining construction and operation of a refinery with
associated power plant and an export pipeline transporting crude oil to markets outside
Uganda.
Scenario 2, with construction and operation of a refinery and a power plant with no export of
crude oil.
Scenario 3, with export of crude oil to markets outside Uganda, either via an export pipeline
or via a railway system for transportation of crude. A small power plant is also constructed
and operated.
As the Government already has advanced plans for a stepwise development of the petroleum
resources and related facilities and infrastructure in the Albertine Graben for creation of revenue, a
phased approach for the scenario analysis has been chosen. This approach focuses on a scenario
developing a refinery over four sequential phases, each characterized by activities/key components
and related concerns and opportunities. The conclusions and issues from the analysis are transferred
to the SEA Issues Register as shown in Figure 2.3.
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Scenario 1 was therefor used as basis for identifying Key Issues as described above. All three
Scenarios have been further analyzed in connection with the assessment of the high level aspects as
described in Chapter 6.
In order to provide a good understanding and input to the issues register, Scenario 1 was analyzed in
detail over four development phases:
Phase 1 (2012 – 2015): Early commercialization
Phase 2 (2015 – 2017): Refinery of 20,000 bbls/d
Phase 3 (2017 – 2022): Refinery of 60,000 bbls/d
Phase 4 (2022 – 2030): Refinery of 120,000 bbls/d
The full Scenario Analysis is presented in Appendix 3.
2.3 The SEA Phases
Screening and scoping (see Inception Report for more details)
The SEA process for the petroleum development of the Albertine Graben was initiated in 2009 by
screening the need and possible objectives for starting an SEA process for the petroleum sector in
Uganda, specifically for the Albertine Graben. The screening process led to a positive outcome and a
platform for the SEA was established securing governmental support from various agencies as well as
the Norwegian Oil for Development Program. This phase established the organization of the SEA
process.
During the process it was also agreed that NEMA coordinates the activities of the SEA while the
Ministry of Energy and Mineral Development leads the process as they own the plans to be subjected
to SEA. Furthermore, it was established that the Steering Committee reports to the Permanent
Secretaries of the Ministry of Energy and Mineral Development and that of Water and Environment.
As the National Environment Act, Cap 153; requires that the National Environment Management
Authority (NEMA) consults closely with relevant lead agencies in the process of SEA, NEMA organized
Scoping Workshops for the SEA in April 2010. A high level workshop took place on April 28, 2010 with
the objective of reaching a common understanding of the need for the SEA. A further scoping
workshop took place on April 29 - 30, 2010. The workshop participants included NEMA and technical
officers from government agencies, civil society and the districts. The objective of the workshop was
mainly to discuss critical issues and plans relevant to the SEA process.
Both workshops were coordinated with the Norwegian Oil for Development (OfD) Program. The most
challenging concerns identified were biodiversity loss, land conflicts and transboundary issues.
Further key issues identified during the Screening and Scoping Phases are reflected in the Issues
Register (see Appendix 6).
A final and approved draft Terms of Reference (ToR) was delivered on June 28, 2011 and this was the
basis for the engagement of the SEA Team.
The Inception Phase (see the Inception Report and the Interim Report for more details)
The Inception Phase included the following activities in chronological order:
A field trip to the most relevant parts of the Albertine Graben to build relations between the
members of the SC and the leaders of the SEA Team and to familiarize with the region and
the ongoing and planned petroleum activities. It also established contact between the
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participants and the oil companies at field level. The field trip took place from March 15 to
18, 2012.
An introductory meeting between the SC and the SEA Team on March 20, 2012.
An internal meeting for the SEA Team on March 21, 2012 with the objective of presenting the
professional background of each of the Team members, building relations between the
participants and establishing the rules and routines for how to work effectively together in
order to deliver what is expected by the SC. The SEA process was discussed and agreed upon
and a comprehensive discussion regarding stakeholder engagement took place. As a result,
the most relevant stakeholders to be invited to the Inception Workshop were identified.
A concluding kick-off meeting between the SC and the SEA Team was held on 22. March
2012. Among other aspects it was decided to undertake a full scenario analysis for the SEA as
an additional scope outside the original ToR.
Consultation took place on March 23, 2012 holding introductory meetings with the oil
companies Tullow Oil and Total.
A final kick-off meeting was held by the SEA Team on March 26, 2012. A detailed work plan
including meetings, deliveries and other events were agreed upon. In addition, the content of
the Inception Report, the break-down of input to the Inception Report into individual work
packages, the request for assistance on GIS and further stakeholder engagement prior to the
Inception Workshop were agreed upon.
A reconnaissance trip for the SEA Team took place on May 8 to 11, 2012. The trip was used to
familiarize the Ugandan members of the SEA Team with the local conditions and current
petroleum installations and activities. Selected consultation took place during this trip with
district authorities in Hoima, Buliisa and Pakwach.
A draft Inception Report was delivered to the Steering Committee on May 7, 2012. The SC
subsequently distributed the draft report to relevant stakeholders.
The SC and the SEA Team had a planning meeting on May 21, 2012 to discuss and prepare
the Inception Workshop.
Two inception workshops were held from May 22 – 24, 2012. The first workshop was
targeting the technical personnel in the various governmental agencies as well as private
sector, Non-Governmental Organisations (NGOs) and Civil Society Organisations (CSO). This
workshop was held on May 22- 23, 2012. The workshop was attended by approximately 90
participants. The draft report was presented and stakeholders commented on the scope and
content as well as work plans for the further SEA.
The second workshop targeted high-level personnel in the various government agencies. This
workshop was a half-day event held on May 24, 2012. The workshop was attended by
approximately 50 participants.
The SEA Team had several meetings after the inception workshop to discuss the conclusions
and agree on the way forward including more detailed discussions about the preparations of
the scenario analysis.
The Inception Phase was concluded after the workshop meetings. The delivery of the
Inception Report was however delayed until July 19, 2012 due to late incoming comments
and a more comprehensive process of completion.
The issues derived during the Inception Phase are included in the Issues Register (Appendix
6).
Page 16
The Pre-Assessment Phase (see the Interim Report for more details)
The Pre-assessment followed directly after the finalization of the Inception Phase and included the
following activities in chronological order:
From June 1 - 28, 2012 the scenario building and analysis took place. A workshop was held in
PEPD during June 18 – 22, 2012 with relevant personnel presenting the various development
plans to provide a picture of the envisaged activities, timelines, concerns, etc.
From June 23 – 27, 2012 sketch maps were developed and a Scenario Analysis of the likely
consequences of the various development stages was undertaken with the entire SEA team.
Meetings were held individually with the oil companies (Tullow Oil, Total and CNOOC) on
June 26, 2012 to present and discuss the outcome of the Scenario Analysis.
A meeting with the SC took place on June 27, 2012 where the Scenario Analysis was
presented and discussed.
Further planning of the SEA program based on the revised schedule was agreed with the
Team and the Steering Committee.
Coordination of activities and budgets between the international consultant and the local
team was arranged.
The local SEA Team held a meeting on July 28, 2012 to discuss the Stakeholder Engagement
Plan.
The pre-assessment phase was concluded by the delivery of the draft Interim Report on September
5, 2012.
The Assessment Phase
This phase involves all activities from delivery of the draft Interim Report to the delivery of the final
SEA report.
The SEA Team had a meeting on September 18, 2012 and agreed on the methodology and
process for finalizing the Interim Report.
The SC presented their comments on the draft Interim Report in a meeting on September 19,
2012 focusing on analysis of PPPs, integration of conclusions from the Inception phase and
the Scenario Analysis, the purpose of the Interim Report etc. The further schedule for the SEA
was also discussed and agreed upon with a draft SEA report delivery in early December, a
validation workshop in mid December and a final SEA report in late January.
The SEA Team had several working meetings from September 20 – 28, 2012 with focus on
developing the Key Issues Action Matrix which was the basis for the comprehensive
Stakeholder Engagement process in October, November and December.
The final Interim Report was delivered on September 30, 2012.
A comprehensive Stakeholder Engagement program was carried out in October 2012. The
main purpose of the meetings was to get feedback on how to integrate the Key Issues into
laws/regulations and PPPs based on the proposals developed in the Key Issues Action Matrix.
The status and challenges were discussed in an SEA Team meeting on October 26, 2012 and it
was decided to develop a Stakeholder Engagement Log (Appendix 4).
In a meeting on October 29, 2012 the SC gave feedback on the Stakeholder Engagement
process. The advice was to make sure that all relevant stakeholders take part in the program
and that the discussions concentrate on the Key Issues identified. The methodology focusing
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on the integration of Key Issues and discussion of specific strategic aspects was adjusted and
agreed upon. In addition, the three development scenarios discussed in Chapter 6 were
presented
A preliminary draft SEA Report was delivered on January 23, 2013.
After a comprehensive review process a final draft was delivered to the SC on April 16, 2013.
This final draft was the basis for the validation workshop which took place on May 23.2013.
The Norwegian Embassy arranged two meetings on May 27th and June 5th with the donor
community in Uganda to present and discuss the SEA.
Based on the comments received during the validation phase, the final draft has been
updated in May/June 2013. Appendix 13 deals with the comments received during the
Validation Workshop.
The final SEA was delivered by the SEA Team to the SC in June 2013.
2.4 Stakeholder Engagement
The stakeholder engagement process was considered as a building block for the multi-stakeholder
partnership recommended in Chapter 6.4. The principle of the partnership is interdependent
engagement of all relevant stakeholders. To achieve this, the stakeholders should be fully involved in
all plans and decisions. A stakeholder analysis was undertaken to determine the stakeholders to be
involved in the SEA process. This resulted in a categorization of key stakeholders including
1) Government (at international, regional, national and district levels);
2) Civil Society (development organizations, NGOS, faith-based organizations, CBOs, etc.);
3) Business and Industry (private enterprises).
The stakeholders that were consulted are presented for each of the key issues in Chapter 5. Further
details on the Stakeholder Engagement process and a log are presented in Appendix 4.
2.5 SEA Organization and Implementation
The SEA process for the Albertine Graben is guided by a Steering Committee (SC) which is chaired by
the Petroleum Exploration and Production Department (PEPD) who is the formal owner of the SEA
process. In addition to PEPD, the SC has members from NEMA, the Ministry of Lands, Housing and
Urban Development, the Uganda Wildlife Authority, the Directorate of Water Resources
Management, the Directorate of Environmental Affairs, the Department of Fisheries Resources and
the Uganda Association of Impact Assessors.
The SEA was undertaken by an SEA Team comprising two international consultants (Team leader and
Team coordinator) and a number of Ugandan local consultants. The international consultant is the
Team leader. Further specifications of the expertise and the specific tasks of the SEA Teams are
included in Appendix 11.
The Netherlands Commission for Environmental Assessment (NCEA) has been engaged by the SC to
undertake Quality Assurance during the Inception phase, on the Interim report and on the final draft
SEA report.
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3 BASELINE SETTING
The baseline setting gives an overview of the current situation in the Albertine Graben against which
recommendations are drawn. It looks at the regional setting, the physical environment, the biological
environment and the socio-economic environment.
3.1 The Regional Setting
The Albertine Graben has unique geomorphological, meteorological and biological features with
complex and fragile ecosystems. The rift catchment area lies in the central plateau of Uganda with an
altitude of about 620 to 5,100 metres above sea level (m.a.s.l). The lowest point in Uganda is Butiaba
fish landing site on Lake Albert (620 m.a.s.l.).
The Albertine Graben area comprises of different physical landscapes, climatic conditions and soils
which in turn significantly influence land use systems in the area including agriculture. Because of its
location in the rain shadow, the Rift Valley zone is mostly dry and hot and hence the area has serious
moisture deficiency problems for agricultural activities especially during critical crop growth periods.
Furthermore, soils on the Rift Valley floor are dominantly sandy with excessive drainage
characteristics, making the moisture deficiency problem arising from low rainfall even worse.
That notwithstanding, like any other rural community, land is an important resource since most
communities are engaged in both crop farming and livestock rearing; 79.1% of the land in the Graben
under agriculture, settlement and other miscellaneous land uses. The dominant cash crops grown on
small scale farms include tobacco and cotton especially in Buliisa, as well as tea plantations. The
dominant food crops include beans, maize and bananas although these crops are also often sold for
cash income.
In terms of population more than 50 percent of the population lie between 0-20 years of age. There
are also slightly more females than males, however, given the increased influx of people from other
regions ever since the oil exploration activities began the population structure changed. In terms of
social infrastructure, road networks have greatly improved, previously most areas in the Graben were
not easily accessible and population was mainly concentrated at landing sites. This is evident from
the opening up of agricultural farms and encroachment into forest reserves in search of firewood and
pasture. Evident is also the expansion of rural growth centres along the Hoima – Kaiso – Tonya Road
which suggests increased investments by local people into the area.
The oil and gas development in the region has triggered population growth within the Albertine
Graben that has put pressure and competition on the scarce land resources. While an estimated 85%
of the rural population depends on land for its livelihood, over 95% are smallholder farmers
cultivating on an average of 2 ha of land. Agriculture is mostly rain-fed and input use is low. As a
consequence, population pressure coupled with low and declining agricultural yields has resulted in
the poorest farmers increasingly farming marginal land that is especially prone to degradation. Yet,
the majority of farmers have limited capital and knowledge to combat land degradation and adjust to
climate variability and change.
In terms of governance, communities in the Albertine Graben respect both informal and formal
modes of governance. Customary systems tend to dominate land ownership and the Bunyoro, Alur
and Acholi Kingdoms are cultural institutions advocating for increased participation in management
of petroleum activities. Based on a scenario analysis and key issues identification and analysis, a
number of areas of interest relate to co-existence of the oil and gas sector with local communities.
Page 19
3.2 The Physical Environment
3.2.1 Climate
The Albertine Rift experiences a sharp variation in rainfall, mainly due to variations in the landscape.
The rift valley lies in the rain shadow and is thus relatively dry with precipitation rates around 850
mm/year while the highland areas on the escarpment experience around 1400 mm/year rainfall,
largely due to orographic influence. The northern part of the Graben has two seasons of high rainfall
(between April – May and August through to October), associated with the passing of the Inter-
Tropical Convergence Zone (ITCZ) over the region.
The Albertine Graben lies astride the equator. The climate is hot with temperatures averaging 27 –
31°C with maxima consistently above 30°C and sometimes reaching 38°C. Average minimum
temperatures are relatively consistent and vary between 16°C and 18°C. The average monthly
humidity is between 60 and 80 percent.
The long-term wind speed records from the East African Meteorological Department (1975) indicate
conditions of moderate to strong or turbulent conditions. The winds increase in the afternoon. Both
wind speed and direction have important implications on the dispersion potential for pollutants
arising from oil and gas activities.
3.2.2 Geology and Soils
Albertine Graben is a Cenozoic sedimentary rift basin developed on the Precambrian orogenic belts
of the African craton. Rifting was initiated during the late Oligocene/early Miocene. Available
geological and geophysical data suggest that the Albertine Graben has undergone substantial
tectonic movements and sedimentary layers of approximately 6 km thickness have been deposited in
fluvial deltaic and lacustrine environments. The rocks are mainly classified as Pre-Cambrian basement
and sedimentary rock formations (PEPD, 2008).
Like the rest of Uganda, the rift flank of Albertine Graben is underlain by some of the world’s oldest
rocks, some of which were formed as long as 3 billion years ago. The Albertine Graben is part of the
East African rift system and forms the northernmost part of its western arm, which runs along the
western border of Uganda with DRC. The area is seismically active resulting in active faults running
NE-SW along Lake Albert (see Figure 3.1). Movements along such active fault zones lead to
earthquakes and dislocation but can also trigger landslides and mass movements depending on the
location. It is important to highlight existing geohazards in order to consider their impact during site
selection and design of various facilities and infrastructure.
Page 20
(Source: PEPD, 2012)
Figure 3.1: Tectonic setting of the wider area including the Albertine Graben forming the northernmost part of the Western arm of the East African Rift System
Ferralitic soils cover a vast part of the catchment. The soils are mainly yellowish-red clay loams on
sedimentary beds. Highly leached, reddish brown clay loams are found in the extreme east of the
Masindi District. There are also dark brown, black loams (Bugangari series) found along the axis of
the warp. These two types of soil are of low to medium productivity. The soils of recent origin that
consist of quartzite debris are found along the escarpment. Their depth depends on the vegetation
cover and land use. They are suitable for coffee and maize (Harrop, 1960). Rivers and valley beds
mainly have grayish-black sands, which are base deficient and acidic. These alluvial soils are of low
productivity.
3.2.3 Surface waters
Aquatic ecosystems considered for this SEA are comprised by Lake Albert, the lower floodplains and
the deltas of the main rivers. The sub-catchments of Lakes Albert-Edward-George that are linked via
rivers Semliki and Kazinga channel respectively.
A large number of rivers and streams, most of them seasonal, cascade down the escarpment to flow
into Lake Albert. The major rivers (permanent and semi –permanent) include the Victoria Nile,
Semliki, Waaki, Wambabya, Waiga, Wisoke, Sonsio and Hohwa. Almost all of them have extensive
floodplains within the rift valley. The seasonal streams and rivers are flooded by runoff from the
Page 21
catchment areas after a heavy rainfall event. The water drains quickly into Lake Albert and the
discharge in the run-off channels ceases. Seasonal rivers include Sebigoro, Kabyosi, Warwire and
Nyamasoga.
River Nile and River Semliki have vast deltas and sprawling floodplains of emergent shoreline
wetlands. The Nile and the Semliki deltas discharge into Lake Albert at the northern and southern
tips, respectively, across extensive shallow zones of the lake (<2 m deep) with a carpet of
predominantly submerged aquatic flora. Rivers Waiga and Waisoke drain upper floodplains of
permanent and semi-permanent wetland within the rift valley and have an extensive lower zone of
swamp forest. The swamp forest fringes Lake Albert and practically merges the floodplains of the two
rivers. Where the escarpment lies close to the lake, affluent rivers into Lake Albert have very short
floodplains (e.g. River Wambambya) or none at all as is the case with River Waki whose floodplain is
at the delta.
The floodplains of inflowing rivers of Lake Albert are a vital storage zone for runoff from the
catchment. Runoff translocates dissolved and particulate nutrients that support aquatic production.
Runoff is also a potential conduit for contaminants such as silt and heavy metals. Floodplains and
large deltas are hence reservoirs and point sources for essential nutrients for fisheries, and could
carry potential contaminants like oil into Lake Albert.
The land-water interface of lakes and rivers are often associated with rich species diversity and high
biological productivity. The biology and ecology of most fish species in Lake Albert is, at some stage in
their life history, linked to the shoreline aquatic environment of the lake. Most fish species use these
shallow sandy/muddy/rocky waters close to the water-land interface as breeding, nursery and
feeding grounds. The shallow deltas of River Nile and River Semliki are reportedly home to juveniles
of almost all fishes in Lake Albert.
While Victoria Nile contributes by far the largest inflow into Lake Albert (about 90%), most of the
water immediately drains out down the Albert Nile located close to the inflow at the northern tip of
the lake. The Nile water does not mix with the largest bulk of Lake Albert. As a result the water
chemistry of the lake is influenced much more by the southern inflow from River Semliki (Talling and
Talling 1965).
Lake Albert
The lake is shallow in its northern and southern parts and along the Ugandan shoreline. It generally
gets deeper in its central part stretching to the DR Congo shoreline. The waters of Lake Albert are
also shared with downstream countries astride River Nile.
The morphometry of the Lake was initially recorded by Verbeke (1957) and was more recently
followed up by Evans (1997) and Carp et al (2007). Lake Albert lies between 1°N and 2°N at an
elevation of 615 m. The lake is approximately 170 km in length and 40 km wide. Along the faults, the
bottom of the lake drops sharply to depths of 40 m in Uganda waters and over 50 m on the Congo
side of the lake to the maximum recorded depth of 58 m near the escarpment. Lake Albert has a
surface area of 6,800 km2 (Verbeke, 1957) and a mean depth of 25 m. The depth profile of Lake
Albert is presented in Figure 3.2. Deposition by deltas of the major inflowing rivers at the north and
south end of the lake has created gentle slopes with water depths of less than 2 m close to delta
boundaries. Relatively recent faulting (in geological timescales) along the North Toro-Bunyoro Fault
and the Butiaba Fault has created a shelf that stretches along the northeast shoreline between
Butiaba and the Kaiso-Tonya spit. This shelf is the only extensive area of waters less than 30 m deep
away from the major northern and southern deltas.
Page 22
(Source: NEMA, 2010)
Figure 3.2: Bathymetry of Lake Albert
Thick sedimentary layers have been deposited in the lake basin since its origin including the famous
Kaiso fossil beds. Sedimentation near the Semliki discharge has led to a shallow underwater bar
projecting into the lake, dividing the main deep-water area near the western escarpment from a
subsidiary deep groove or canyon near the eastern (Uganda) shore. The lake water is often rather
turbid with fine, silt material in suspension.
The water of the Victoria Nile is much less saline than that of Lake Albert. It has therefore been
possible to demonstrate by conductivity measurements that even in times of floods the river water
does not affect the lake beyond about 10 km from the north end. The Victoria Nile thus serves to
maintain the level but has no other influence on the water of the lake except at its northern end
though its rate of flow is considerably greater than that of the Semliki.
The lake is well known for its frequent, severe storms and strong currents that displace and destroy
fishing gears especially gillnets. Accounts on the lake by Worthington (1929a, 1930), Verbeke (1957),
and Van Deren (1957) suggest a slight thermal stratification with wind induced mixing usually
extending to all the depths sampled. More recent data from occasional limnological monitoring at
irregular intervals during the 1990’s by scientists from the National Fisheries Resources Research
Institute (NaFIRRI) summarized in Mugidde et al. (unpublished MS) suggest that thermal stratification
may be more persistent.
Page 23
Challenges and data gaps:
The trans-boundary character of the water resources of the Albertine Graben with both the
Democratic Republic of Congo and the downstream countries astride River Nile poses
significant challenges in relation to oil spill management planning;
Spatial and temporal data on hydrodynamics of Lake Albert and Lake Edward are virtually
unknown;
There is no available data on the ambient air quality around the Graben which will make
future detection of change difficult.
3.2.4 Ground Water
The static water level (SWL) which is the depth below ground level or the level of the water table in a
well when there is no operational pump, varies over the entire Albertine Graben with levels ranging
from 1m to over 70m. SWL gives an indication on how easily ground water can be contaminated; the
shallower it is the more susceptible to contamination it is but this also depends on sediment
conditions, e.g. permeability. Depth to bedrock is virtually homogeneous in this area, with only
14.50% of the soils being deep and 60.48% of them very shallow.
3.3 The Biological Environment
3.3.1 Aquatic flora & fauna
Wetland flora
Prominent wetland flora is comprised by emergent, floating and submerged categories of
macrophytes plus the microscopic, mostly epiphytic algae.
In the Albertine Graben, the emergent aquatic macrophytes cover the floodplains of some rivers e.g.
River Wambabya. They plug deltas of some rivers such as the Nile and River Semliki and form narrow
fringes along the banks of most rivers flowing into Lake Albert. They also fringe parts of the shores of
Lake Albert. A special case of emergent wetland is the swamp forest reported to cover most of the
merged lower floodplains of River Waiga and River Wisoke in Buliisa District. Floating macrophytes
are comprised by free-floating plants and rooted ones. On Lake Albert floating macrophytes are
associated with shallow sheltered environments provided by the usually narrow strips of emergent
aquatic flora. Rooted submerged macrophytes occur in shallow waters. In Lake Albert extensive fields
of submerged macrophytes form the transition between the deltas of River Nile and River Semliki
and the open lake. Other fields of submerged macrophytes are known to occur on the shallow
inshore shelves along the lake shore but very little is known about their distribution and spatial
extent.
Wetland flora is vital to the structure and functioning of floodplain and fringing wetland ecosystems
associated with Lake Albert. These wetland biotopes are believed to offer the principle food-web
fabric that supports most of the major fisheries of the lake. The biggest historical fish landing beaches
on Lake Albert on the Ugandan side are developed at river mouths. Such settlements include
Wanseko, Bugoigo, Butiaba/Waaki and Kaiso/Tonya.
Page 24
Algae comprise a diverse and ubiquitous array of microscopic water plants. They constitute an
extensive plant community of the water column - the phytoplankton. Algae and the higher aquatic
plants are the primary producers of food in the aquatic environment. The benthic microscopic algae
are not described in Lake Albert even though they can be important food sources for fishes feeding
on shallow bottom areas in African lakes (Hecky and Hesslein 1995). Evans (1997) provides a species
list, the spatial and seasonal distribution of phytoplankton species, and their biomass in Lake Albert
(Uganda) for the period of 1961-1962.
Aquatic fauna
Information from NAFIRRI indicates the presence of micro-invertebrates across all depth ranges with
a greater species diversity in the sheltered shallow waters (< 7 m). This depth zone had abundant
micro-invertebrate fauna.
The earliest information on macro-invertebrates in Lake Albert, reported in Worthington (1929),
indicated a lake-wide distribution of Mollusca but with clear preference for the sheltered and shallow
waters (< 7 m) which had 13 species. Other unspecified macro-invertebrate fauna including a mix of
insect species and prawns were also found in this depth zone. Five species of Mollusca were
recovered from the relatively shallow wave-affected intermediate depth zone (7 to 20 m) while seven
species were identified in the deep open waters (> 20 m).
Abundance of Zooplankton is highly seasonal with a profound minimum in abundance of all taxa
between June and August. This is also a period of reduced phytoplankton abundance (Evans, 1997)
and likely indicates a minimum in phytoplankton primary production under light limitation.
Zooplankton is favourite food for very young fish. Its abundance in the sheltered inshore zone would
be strongly associated with presence of fish fry.
Fish fauna
The fish fauna of Lake Albert and the River Nile below Murchison Falls is diverse with respect to both
the taxonomy and size range of component species. The earliest checklist of the fish fauna of Lake
Albert was generated by Worthington (1929). It was later updated by Greenwood (1966) and Holden
(1967). Lake Albert and its contiguous waters host at least 55 species classified into 14 families. There
are at least 10 fish species endemic to Lake Albert. Murchison Nile registered 11 Families with 25
species while the Albert Nile had 20 species belonging to 10 Families. Haplochromines appear to be
most abundant largely in sheltered inshore areas, especially in the lagoons. They are also found along
rocky shorelines of the lake (Worthington, 1929) but these have not been adequately surveyed. Lates
niloticus, one of the largest freshwater fishes, and the endemic Neobola bredoi, one of the smallest
commercially exploited fish species, are both native here.
Characterization of the fisheries of Lake Albert according to generalized ecological considerations
identified three zones:
- The lower floodplains and deltas of major rivers including Victoria Nile, Semliki, Muzizi and
Wassa plus the shallow inshore lake fringe less than 7 m deep. This zone contains biodiversity
hot spots and is a recognised breeding, nursery and refugia ground for almost all fish species
in Lake Albert. It is also vital fishing ground attracting a large number of fish landing sites
(see Figure 3.3);
- The intermediate depth zone (7 to 20 m) includes the steeper shoreline sections with rocky
underwater cliffs or in the vicinity of the spits steep sand slopes (Worthington 1929). No
Page 25
information on representative invertebrates and fish fauna were found in the literature,
forming a serious knowledge gap;
- The deep open water zone (>20m) covers the largest portion of the lake but it is perhaps the
least known in terms of its ecology and recent faunal composition and distribution. This
water zone is coming under intense exploitation with more efficient but sometimes illegal
fishing gears and methods encouraged by the escalating demand for fish. Because of the
threat of over fishing, the endemic Lates macrophthalmus species has been placed on the
IUCN Red List as “endangered” highlighting the need for special conservation efforts.
Worthington (1929) noted that only one mollusk was found as living specimens at depths
greater than 40 m. The most abundant invertebrates occupying this zone are the
microcrustacean zooplankton.
Major data gaps include:
Lack of detailed biodiversity inventories of the floodplains and lakeshore;
Lack of economic valuation data for floodplain wetlands of the Albertine Graben;
Temporal and spatial data on hydrodynamics of Lake Albert are virtually unknown;
No recorded information on critical nursery or feeding areas for different fish species;
No seasonal studies of fishes which would allow for identification of fish habitat preferences
and spawning grounds; and
Lack of recent flora and fauna data for the intermediate and the deep zones of Lake Albert.
3.3.2 Terrestrial Flora and Fauna
The Albertine rift is incredibly species rich. It is the richest area in vertebrate species on the African
continent. The area has 14% of all African reptiles (175 species), 19% of Africa’s amphibians (119
species), 35% of Africa’s butterflies (1300 species), 52% of all African birds (1061 species), 39% of all
African mammals (402 species), 14% of Africa’s plants (5,800 species) and over 400 fish species. The
reptile and amphibian groups have, however been poorly collected in the rift and the numbers are
expected to increase with more work. Of these, 35 mammal species are considered highly threatened
by extinction (Critically Endangered, Endangered or Vulnerable as classified by IUCN criteria), 25 birds
species, 16 amphibian species and 40 plant species are also considered highly threatened. So far 34
endemic mammals, many of which are small mammals, 41 birds, 16 reptiles, 34 amphibians and 117
butterfly endemic species have been identified in the region. Mismanagement of any part of the rift
would be a threat to survival of some of these species.
The Ugandan section of the Albertine Rift is the richest biodiversity area in Uganda. Figure 3.3
provides information on areas of high species richness. The delta area of Murchison Falls National
Park stands out as an area of very high species richness. The Rothschild giraffe (Giraffa
camelopardalis), with its highest population occurring in Murchison Falls national park, and the
Uganda Kob (Kobus thomasi) have been identified by Colin Groves and Peter Grubb (2011) as new
species. Rothschild giraffe is already classified as Endangered by IUCN. Kabwoya wildlife reserve,
Budongo and Bugoma forest reserves also have very high species richness. In the waters of Lake
Albert, the southern part of the lake, the area around Kabwoya wildlife reserve, Kaiso-Tonya
community wildlife area and Butyaba area show high fish diversity.
Page 26
Natural Vegetation
The vegetation of the area can broadly be classified into forest, savannah, grassland and swamps.
The main functions of vegetation include providing water catchments, food and biodiversity storage,
climate modification and being a good ecological indicator (NEMA, 1998; Plumptre et al. 2003).
Management of the forest resources is carried out by the Central Government under National
Forestry Authority (NFA), the cultural institutions (Bunyoro, Alur and Acholi Kingdoms), Nyabyeya
Forest College and private ownership. The natural forests have over time been degraded due to
pressure on land. Human activities such as deforestation and wetland degradation have had a great
influence on the natural vegetation cover. Causes of land degradation include timber cutting, clearing
land for agriculture and settlement, over grazing and extraction of other resources e.g. honey, rattan
and fuel wood (Masindi District Environment Profile, 2005).
Challenges to resource management include lack of adequate surveys of amphibians, reptiles and
small mammals, low coverage of flora and fauna surveys outside protected areas, lack of focused
conservation plans for biodiversity outside protected areas, and low funding for the environment and
natural resources sector both at the national and the district level, which results in inadequate
monitoring of the natural resources especially by the districts officers. This is all compounded by the
fact that most of the petroleum deposits have been discovered within or close to protected areas.
3.3.3 Protected and Sensitive Environments
While protected areas are designated areas protected by law, sensitive environments may have
similar ecological value but without official protection status.
The Albertine Graben is an area of national and international importance in terms of its outstanding
biodiversity and network of protected areas. It is extremely rich in species. It has a high number of
endemic species as well as endangered and threatened species (as classified by IUCN). The high
diversity of habitats and species occurring in the Albertine Graben is also reflected by the fact that
seventy percent (70%) of all protected areas in Uganda are located in the Graben. Of the ten (10)
National Parks, seven (7) occur within the Albertine Graben. There are also twelve (12) Wildlife
Reserves, thirteen (13) Wildlife Sanctuaries and five (5) Community Wildlife Areas. The Graben also
has a high number of forest reserves (see Figure 3.4 ), many of which host endemic plants and animal
species. Most of the viable oil and gas deposits have been discovered within or adjacent to protected
areas.
The specific protected areas where petroleum resources have been found are Murchison Falls
National Park (including the Murchison Falls Albert Delta Ramsar site), Bugungu Wildlife Reserve,
Kabwoya Wildlife Reserve, Kaiso-Tonya Community Wildlife Area and the Ramsar site along River
Nile. Budongo and Budoma Forest Reserves occur in areas where infrastructural developments that
will support the oil industry will occur.
The definition of an environment as sensitive has been based on fragility of an ecosystem or
vegetation type, its function or services, species richness and presence of endemic or threatened
species, and its ease of recovery. Sensitive environments within the study area include deltas and
other wetlands, riverine forests, animal breeding areas and forests. Such areas may be within or
outside protected areas. Monitoring challenges are related to the lack of sufficient and up-to-date
baseline information, which would be a baseline tool for monitoring change in levels of
fragmentation and degradation.
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(Source: NEMA, 2010))
Figure 3.3: Species richness map combining large mammals, birds and woody plants of the study area
Water bodies (River Nile, Lake Albert, and the smaller rivers that either feed into Lake Albert or are
tributaries of River Nile) and the associated wetlands are specific sensitive areas that occur in the
area. They are recognized as breeding, nursery and refugia grounds for almost all fish species. The
areas are also vital fishing grounds. The intermediate depth zones and deeper open waters are not
well researched and significant data gaps exist for the entire lake environment.
A large number of rivers and streams cascade down the escarpment to flow into Lake Albert,
however, most of them are seasonal and are fed by heavy rains in the catchment areas. Major rivers
can be permanent or semi-permanent. They include the Victoria Nile, Semliki, Waaki, Wambabya,
Waiga, Wisoke, Sonsio and Hohwa. Almost all of them have extensive flood plains within the rift
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valley and have created significant erosion features including gullies or gorges cutting into the
escarpment. Some, such as the River Nile and the Semliki have not only created flood plains but also
deltas and associated wetlands, which are features of high ecological value. In general, the land-
water interface is rich in species diversity and high biological productivity, e.g. the Lake Albert
shoreline ecosystems of sandy to sandy-clayey or boulder beaches, fringing wetlands and deltas, and
the rocky cliffs. Wetland flora is vital to the structure and functioning of floodplain and fringing
wetland ecosystems, which are principle food-web systems for the fish resources.
Sensitive areas that will be impacted are the River Nile area in Block 1 and in wetlands, especially the
spit on Lake Albert. Each of these areas has unique characteristics. Typical expected primary and
secondary impacts are given in Appendix 9.
The area where oil resourcess has been discovered has the highest mammal biodiversity (NEMA,
2010) in the whole of the MFNP. The area is also surrounded by water, making it an ideal watering
point for wildlife during the dry season. The boundary between Kabwoya and Kaiso-Tonya is River
Hohwa, which is the major water source for wildlife found in these two protected areas, especially
during the dry season. The riverine forest along River Hohwa also serves as a corridor for wildlife that
access Lake Albert. The delta area of MFNP is also major destination or resting place for migratory
birds.
(Source: NEMA, 2010))
Figure 3.4: Protected Areas located in the wider study area
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3.4 Socio-Economic Environment
This section focuses on 4 districts of Hoima, Buliisa, Amuru and Nwoya because they span the area of
consideration. It is important to note that Amuru, Nwoya and Buliisa districts are quite new.
Consequently there is little or no data on their key socioeconomic issues. In the following section a
discussion on the district’s population and land ownership tensions, livelihoods, poverty and income
levels, access to social services and the state of the environment is presented.
3.4.1 Population and Land Ownership Tensions
This section discusses the population, population growth rates, and population densities in the three
districts. This is then followed by a discussion on the identified land ownership pressures in the
recent past.
There are no recent statistics on population, however, population estimates from 2002 are used to
project the annual district population. SKRIP (2010) shows that the average population density in the
region is 129 persons/km2. This shows that the area is sparsely populated, and land ownership
struggles are not based on land scarcity per se, but rather the competition for arable/fertile land and
the cultural sentiments attached to communal or customary law governed land. 10.5% of the
population lives in urban areas and the population density is approx. 55 persons/km2. Human
population in Hoima district was estimated at 343,480 and the population growth rate at 4.7% in
2002.
The population of Buliisa district was estimated at 88,700 in 2010. The population growth rate is
estimated at 4% in Buliisa district. The district is primarily rural and most people in the district are
either pastoralists or subsistence agriculturalists. The discovery of oil is expected to lead to more
diversification of activities across the region. The population figures in the two districts appear in
Figure 3.5 below. There are no population figures for Buliisa before 2010 as it is a new district.
However, the figure shows high population growth rate for Hoima.
(Source: amended after SCRIP, IFPR, 2010)
Figure 3.5: Population in Hoima and Buliisa Districts 2002 – 2012
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The insecurity in the DRC and in South Sudan, as well as the porous borders of the country and the
government resettlement policy leads to large influxes of refugee populations into the districts.
International Alert (2009) shows that some refugees have successfully managed to settle and engage
in business (trading, fishing and farming), however there are varying degrees of resentment from the
natives. For example, there is growing discontent among the Banyoro and Bakiga settlers
(International Alert, 2009). This however has not yielded any major clashes.
Within the local communities in Amuru and Nwoya, previous episodes of war, food insecurity, long
years of displacement, and land conflicts are seen as the key factors likely to spark off tensions
(International Alert, 2009). Indeed this study predicts that the discovery of oil in these areas and the
influx of new investors both in the oil sector and other sectors will exacerbate the pressures on the
land distribution tensions.
There is no single model to explain the population dynamics of the two districts. However, it is very
plausible to expect a rapid population increase in these areas once oil production commences. This
will of course be a result of newcomers seeking profits, jobs and markets. Such an influx of people
requires these districts to draw up plans or to revise the existing ones to incorporate the demands
from increased settlements e.g., health and education infrastructure demand as well as the need for
increased policing.
3.4.2 Livelihoods
The major activities in the area are: crop farming, livestock husbandry, fishing, hunting, lumbering,
commerce (mainly dominated by trans-boundary trading) and by provision of recreational services
(tourism). There is also sizeable land area of protected areas and National Parks.
Agriculture
The main economic activity in Hoima, Buliisa, Nwoya and Amuru districts is agriculture. This is mainly
in form of food production, although fishing in Lake Albert also contributes significantly to the
economy of Hoima district.
Rain fed agriculture dominates activities in the area, though in some areas irrigation is practiced in
the growth of sugar cane. Agriculture production in the area is characterized by low mechanization
and it is dominated by small holder farmers who depend on subsistence agriculture for their
livelihoods (UBOS, 2007). The average farm size ranges between 0.5 and 2 acres. Fishing and tourism
are also significant contributors to the economy.
The major food crops in these districts are bananas, cassava, sweet potatoes, Irish potatoes, maize,
beans, peas, groundnuts, millet and sorghum. The district of Amuru dominates in the production of
sorghum, ground nuts, beans, peas and millet. Hoima produces more bananas, cassava and sweet
potatoes. The productivity variation for the four districts for the major crops is given in the table
below (Nwonya was curved out of Amuru and is therefore included in the Amuru data).
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Table 3.1: Productivity by District and Selected Crops (Yield in MT/Area in ha)
Crop
District
Bananas Cassava Sweet
Potatoes
Maize Sorghum Millet Ground
nuts
Hoima 1.81 4.19 4.54 3.77 0.81 0.74 0.95
Buliisa 0.90 5.72 3.86 7.24 0.89 0.40 1.27
Amuru - 5.89 3.09 2.87 1.56 1.63 1.29
Source: UBOS (2010)
The figures in Table 3.1 show that Amuru district has the highest productivity for cassava and ground
nuts. Hoima has the highest productivity for sweet potatoes. Buliisa district has the highest
productivity for maize. The variations in productivity may be linked to improved seed and fertilizer
use, but also to variations in soil quality.
The major cash crops in Hoima district are tobacco, maize, beans, cassava and vegetables. It is
reported that coffee production is declining due to disease and neglect resulting from low export
prices (IFAD, 2009).
The major identified constraints to agricultural production in the area are: decline in soil fertility; high
costs of improved seeds; subsistence mindset of farmers; poor post harvest technologies;
inappropriate storage systems; poor access to markets and market information; pests and crop
diseases and price volatility; and insecure land tenure (TRIAS, 2010).
Fisheries
The main fisheries for the region are on lakes Albert, Edward and George. In addition, the region has
numerous small water bodies where fish is caught. There is also considerable investment in
aquaculture. Fish catches from Lake Albert were estimated at 56,500 MT and valued at UGX 351
millions in 2010.
The current trend in the fisheries variables is not very different from that on the other lakes and
rivers in the country. Catches from Lake Albert have steadily declined. The factors behind this decline
are:
steadily increasing fisher population in the area;
increasing use of illegal fishing gears;
weak enforcement of regulations;
increasing fish demand and markets across the border; and
open access to fish resources (MAAIF, 2010).
The increasing number of fisher folk in the last 10 years is explained by limited availability of
employment opportunities outside the fisheries, and the lucrative business. Consequently catch per
unit of effort has been steadily declining, and hence clear signs of fish stock declines in the Lake.
The Informal Fish trading with the DRC was estimated at 53% of the regional catches (UBOS Report
on Informal trading) with a value of USD 36.3 mio. Fisheries are important as a source of
employment, income and food security in the region. However, the fisher folk here are mainly
threatened by Schistosomiasis due to the environmental health of the lake (Dunne et al., 2006). The
most affected towns are Paida, Booma, Bugoigo and Walakuba, on Lake Albert.
Although fish is possibly the most socio-economically valued aquatic resource in the Albertine
Graben, current fishery exploitation and management practices are unlikely to promote sustainable
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fisheries. Further, current oil and gas exploration and the proposed development and production of
the resource in the Albertine Graben is likely to be accompanied by increased demand for fish
leading to enhanced fishing pressure and to detrimental impacts on fish habitats in the event of
environmental contamination.
Navigation on Lake Albert
Lake Albert provides key navigation routes for passengers and cargo between the region and the
DRC. The transport sector is dominated by small vessels and ferries. These are licensed by the district
fisheries officials. However, due to the failure for the authority to make routine checks on the safety
conditions of vessels plying the Lake, accidents of vessels capsizing are common. Data on such
incidents and the implied losses of life and goods is, unfortunately, not readily available.
Forest resources
The region has considerable proportions of the country’s moist and semi-deciduous forests where
the ironwood (Cynometra alexandri) is the dominant species (Eggeling, 1947). The major forests here
are Bugoma in Hoima district and Budongo forests in Masindi.
Forests provide a spectrum of services to households and firms in the region. These include provision
of timber, fuel wood energy, grounds for hunting and gathering of wild and medicinal plants and
ecological services. The source of energy for rural households is predominantly fuel wood.
According to Banana and Turiho-habwe (1997) forest foods make a critical contribution to the food
supply in Hoima and Masindi districts. The consumption of forest foods is, however, decreasing
rapidly due to the rapid degradation of forest resources, erosion of indigenous knowledge and the
influence of western cultural values.
The rapidly rising population and demand for energy, the insecurity of land tenure coupled with the
ever increasing demand for fire wood for tobacco curing has led to the rapid reduction of the native
forests (Sejjaka, 2004). Banana and Turiho-habwe (1997) indicate that the main causes of forest loss
in Hoima district are clearing for agriculture, logging for timber, pit-sawing, charcoal and firewood
production. While the national rate of deforestation is estimated at 2.7% per annum (Mclennan,
2008), there is no information on the estimated deforestation rates in the districts of Hoima and
Buliisa.
There is, however, considerable private investments in plantation forests, mainly dominated by the
pine species. Thus as the hectares under native forests are dwindling, expansive coverage of hills with
pine trees is widespread in the districts.
Tourist Attractions and Tourism
The Albertine Graben is known for its high biodiversity. Bird watching, game hunting, butterfly
watching and water sporting are some of the activities carried out in AG. The protected areas in the
AG have large populations of Chimpanzees, Warthogs, Antelopes, Impalas, Buffalos, Hippopotamus,
various species of monkeys and a range of other mammals. The biggest of the protected areas in the
region is the Murchison Falls National Park. The highest concentration of wildlife in the park is found
in the Buliji circuit, a peninsula between Lakes Albert and Victoria. The park is bordered by two
Wildlife Reserves (the Karuma Wildlife Reserve (720 km2) and Bugungu Wildlife Reserve (748 Km2).
The Budongo Forest Reserve found south of the park has about 600-700 chimpanzees. According to
(SCRIP,IFPRI, 2010) the current entry fees to Murchison Falls National Park ranges from 7,500 to
10,000 shillings for a resident to gain entry for two to three nights excluding camping and other costs.
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Park entry fees for non-residents are up to 50% higher. The proportions of entry fees from tourism
activities accruing to the district authorities and the local communities are not readily available. It is
worthwhile to note that the study area has a number of heritage sites (mainly the Bunyoro-Kitara
Kingdom).
3.4.3 Poverty Levels
According to UBOS (2010), the poverty headcount ratio for the mid-western region (including Hoima,
Masindi and Buliisa) is 25.3%. The poverty headcount ratio at the national poverty line (% of
population) is 24.5%. This shows that the percentage of individuals estimated to be living in
households with real private consumption per adult equivalent below the poverty line for these
districts exceeds the national average. Thus poverty is high in the region.
It is widely believed that oil exploration and production will lead to social, cultural, economic and
environmental changes in the region. Further the native people have a lot of expectations about the
sharing of the oil benefits.
3.4.4 Access to Social Services
There is generally low access to basic social services in the region (SCRIP,IFPRI, 2010). Access to safe
water is high in Hoima district, with an estimated 77.5% of the rural population having access to it.
However, safe water sources are not uniformly distributed in terms of population coverage due to
the general topology of the area and population distribution. In areas where water is scarce, such as
Buseruka, Bugambe and Kigorobya sub-counties, members of those communities (mainly women and
children) have to walk long distances to get water. Access to safe water sources is lower in Buliisa
(53%).
Literacy rates in these districts are generally low. It is estimated that on average an approximate of
37.1% of the population aged 6 years and above have never attended school, with females
dominating. School enrollment has recently increased following implementation of the Universal
Primary Education (UPE) Policy, although the drop-out rate still remains high, again with girls
dominating. The illiteracy rate in Hoima district is high, about 44% of people older than 10 years.
There are a total of 188 primary schools, 32 secondary schools, and one college at Butera. SCRIP,
IFPRI, 2010).
SCRIP, IFPRI (2010), shows that Hoima has one hospital (government-aided and referral) and 37
health centers. With a total of 290 beds, the number of persons per bed ratio is 1,204.
3.4.5 State of the Environment
The area of consideration is well known for its biodiversity sanctuaries, forest reserves national parks
and protected areas. Due the rapid population growth through natural birth and cross border and
cross district immigration, there is increasing encroachment on forest reserves and protected areas.
It has been widely agreed that many of the causes of environmental degradation stem from either
the lack of institution of property rights or poorly instituted property rights over environmental
resources. This creates a situation where private agents’ actions impact either negatively or positively
on other individual’s well-being and environmental resources. The externalities at issue in these
districts include deforestation, soil erosion, and the pollution caused by pesticides and other harmful
inputs (Ssejaka, 2004).
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In the Masindi-Hoima area increased tobacco growing has led to the rapid increase in the
deforestation rates. Many of the farmers engaged in the growing of the crop are squatters who clear
big chunks of land under natural vegetation, use little fertilizer inputs, and practice shift cultivation
(Ssejaka, 2004). Deforestation rates are further exacerbated by the rising demand for wood fuel for
use in the curing of tobacco. Reports of severe soil erosion are evidenced in Ogen (1993).
Deforestation and the loss of habitats for the eastern chimpanzee have led to human-wildlife conflict
(JGI/UWA, 2002). There are frequent incidences of crop raids leading to immense losses of crop
output and sometimes human injuries and loss of life (McLennan, 2008).
NEMA (2010) reported widespread poaching and sedimentation of the water bodies as other forms
of environmental management problems in the region.
The main identified sources of environmental degradation are: climate change, soil erosion and
sedimentation of water bodies, deforestation, rapid population increase due to search for prime
rangelands, new settlements for war refugees from within the country and across borders, over-
fishing, wetland conversion, invasive species and wide spread poaching of wild life.
3.4.6 Archaeology and Cultural Heritage
The AG holds a number of important cultural heritage and historical sites (like Fort Magungu in
Kilyango village in Buliisa district), burials and graves as well as paleontological sites.
Since 1965, 41 new paleontological sites have been identified in the AG. Four Pleistocene localities
are found in the region of Nkondo, a site for paleontological findings as well as mammalian fossils. A
site at Hohwa River is also rich in fossils. Kaiso site at the eastern shore of Lake Albert and south-east
of Ndondo is very important for paleontological research as it holds plant fossils of about 2.5 mio and
fossilized horns of the extinct long-horned Buffalo of about 2.6 million years age.
In the 19th century the state was mainly supported by cattle pastoralist and small stock husbandry
together with substantial cultivation places. In addition trade in several key commodities like salt and
iron were probably important in the maintenance of the centralized authority. The first Babito King
Isingoma Mpunga Rukidi is traditionally credited with the development of iron and salt industries of
Bunyoro Kitara kingdom. Kibiro salt was an important component in the Bunyoro economy. In the
pre-historical economy, the region and Kibiro in particular provide insight into the origins of salt
economy and cultural relationships of some people who formed part of that state.
The archaeology of the AG is unique in western Uganda. The iron-using agriculturalists of the last
millennium left behind good stratified deposits of material culture in terms of iron slag, pottery, salt
pans, etc.
Today, the Kingdom of Bunyoro-Kitara is the remainder of a once powerful empire of Kitara that
included present-day Masindi, Hoima, Kibale, Kabarole and Kasese districts and also parts covering
present-day Western Kenya, Northern Tanzania and Eastern Congo. Related to the kingdom there are
heritage sites like Mparo tombs, Katasiiha fort and cultural site, Kabalega’s forts in different parts of
the oil region, Buhimba fort, Kijura cultural site in Masindi, Karuzika-Hoima Palace, Kihande in
Masindi, Kibiro hot spring, Waraga tombs and Nyabweya.
Traditional sites comprise palaces and living culture (traditional beliefs and practices, cultural trees
and shrines). Palaces are included in this definition as they were re-instituted by the 1993
reinstitution of traditional assets. The area is not only occupied by the Banyoro, but also other tribes,
most of them having migrated into the area during the Congo wars and northern insurgence (1986 to
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2003). Just like other traditional people in different parts of Africa, the inhabitants of the area had
their small gods which they used to worship in the forest and hill in different parts of the region.
These tribes include Acholi, Lango, Alur, Bangungu and the Baluli. Some of these have been
assimilated into the early inhabitants hence use the Alur, Runoyo or Lugungu language as medium of
communication.
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4 LEGAL AND INSTITUTIONAL FRAMEWORK. POLICIES, PLANS
AND PROGRAMS
This chapter presents the current legal and institutional framework on environmental management
in Uganda with specific emphasis on oil and gas exploration and production in the Albertine Graben.
The current Policies, Plans and Programs by the government with regard to oil and gas exploration,
production and eventual management and implications to environment management in the Graben
are also described.
The initial framework for environment management of oil and gas activities in Uganda was provided
in the National Oil and Gas Policy (2008). The policy has one of the key principles as the “Protection
of the Environment and Biodiversity”. A corresponding objective is “To ensure that oil and gas
activities are undertaken in a manner that conserves the environment and biodiversity”. It should be
noted that the existing laws on environmental protection, such as the National Environment Act,
1995, the Uganda Wild Life Act, 2000, the National Forest and Tree Planting Act, 2003, the Water Act,
1997, the Fisheries Act and their respective regulations, were developed without oil and gas
discoveries in consideration as they were formulated earlier. Yet, the discoveries have been made in
an area that is rich in biodiversity and ecologically sensitive.
However, the inadequacies in the aforesaid legislation have been acknowledged. This calls for urgent
reformation and review so as to harmonize and improve the legal framework. Efforts are also needed
on harmonizing the legislations with the current global and national developments with focus on best
practices including Health, Safety and Environment (HSE) standards in this rather nascent yet pivotal
oil and gas sector.
More details about relevant environmental laws and regulations, international/regional
conventions/agreements are presented in Appendix 5.
4.1 Legal Framework
The legal framework on environmental management in Uganda is provided for in a series of laws,
including the constitution of Uganda (1995), as well as other principal and subsidiary legislation.
The overall objective for the legal framework is to provide measures necessary to protect and
preserve the environment from abuse, pollution and degradation as well as to promote
environmental awareness. It is also geared towards achieving sustainable social and economic
development, by ensuring that natural resources are harnessed and exploited in a balanced and
sustainable manner for the present and future generations. This is explicitly provided in Article 245 of
the Constitution of Uganda and also features as objective No. 27 in the national objective and
directive principles of state policy in the constitution. The next sections present a brief account of the
salient provisions of some of the relevant legislations that are expected to have a bearing on the SEA.
4.1.1 The Constitution of Uganda, 1995
The constitution of Uganda is the principal legislation in the country from which all laws, regulations
and institutional policies derive validity. According to Article 254 of the constitution, parliament is
given express mandate to pass legislations that are meant to preserve and protect the environment
from abuse. Articles 244 and 26 of the Constitution of Uganda, 1995, also vests ownership and
control of petroleum in or under any land or waters into the government. This means that the
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government has a paramount right of ownership over petroleum except that where such petroleum
deposits are discovered in a private person’s piece of land, the government will be obliged to
adequately compensate the affected land owner before taking over his or her land. Such
compensation is assessed in accordance with the valuation principles laid out in Section 78 of the
Land Act (Cap 227) briefly explained in Appendix 5.
In the Albertine Graben, compensation, livelihood restoration and resettlement are affecting co-
existence of oil and gas activities with local communities. As the Constitution provides, land take for
petroleum activities in the Graben should involve regulated compensation and livelihood restoration
as well as adequate planning and sensitization of communities. Emphasis should be on the tools and
methods in resettlement action planning so as to ensure that communities have no fears of unfair
compensation.
4.1.2 The National Environment Act, Cap 153, 2000
The National Environment Act is the principal law on environmental management in Uganda. It
establishes the National Environment Management Authority (NEMA) as the overall body, charged
with the management of environmental issues and provides for sustainable management of the
environment. The Authority, in consultation with the lead agencies, is empowered to issue guidelines
and prescribe measures and standards for the management and conservation of natural resources
and the environment. The Act provides for environmental monitoring and impact assessment;
environmental audit; environmental restoration orders and improvement notices; environmental
easements; environmental performance bonds; licensing and standard setting; use of economic and
social incentives; civil and penal sanctions, including community service, among others. It establishes
the Policy Committee on Environment; the National Environment Fund and a collaborative
framework with lead agencies and other stakeholders in environmental management.
The main gap regarding enforcement and compliance to environmental standards by the Oil and Gas
sector is inadequate support by the current licenses and Permits to the application of “Polluter Pays
Principle”.
Although this Act provides for environmental protection, it does not specifically address the issues
related to oil and gas exploration, production and transportation. NEMA does not also have adequate
capacity to deal with the peculiar environmental challenges posed by the discovery of oil and
petroleum in the Albertine Graben. The National Environment Act, Cap. 153 is, therefore, one of the
legislations that are undergoing review to ensure that oil and gas activities are provided for.
4.1.3 The Petroleum Supply Act, 2003
This Act provides for the supervision, monitoring, importation, exportation, selling and distribution of
petroleum products. It also vests in the minister responsible for the petroleum sector supervisory
powers over all dealers in petroleum products. The key objectives of this Act is the need to ensure
that petroleum supply in Uganda is adequate, economical for dealers and consumers, as well as the
need to strengthen government capacity to regulate the petroleum sector among others. The Act
also provides for a Commissioner of PEPD, who, together with the technical staff under him, to carry
out petroleum exploration promotion, initiate petroleum legislation and monitor oil companies’
compliance with existing laws, regulations and agreements.
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This act is to superseded by the new petroleum legislations and any environmental matters that arise
are provided for as discussed in section 4.1.4
4.1.4 The Petroleum Act, 2013 and Petroleum Bill, 2012
"The new Petroleum Act (Exploration, Development and Production) enacted in 2013 repeals the
Petroleum (Exploration and Production) Act, 1985 as revised in 2000 which successfully guided the
sector through the initial promotion efforts and subsequent licensing of international oil companies
that led to the discovery of commercial oil reserves in 2006. "
The Petroleum Act provides for the promotion, licensing and exploration of petroleum in the country,
but following the Oil and Gas Policy of 2008, the Government embarked on a new law (the Petroleum
Bill 2012) which was passed by parliament. The Petroleum (Exploration, Development and
Production) Act, 2013 was assented to by the President on the 21st March, 2013 and commenced on
5th April, 2013 while the Petroleum (Refining, Gas Processing, Conversion, Transportation and
Storage) Bill, 2012 is awaiting accentuation by the President.
According to the Oil and Gas Policy, a new Act is to, among other things, include provisions for the
development and production of natural gas; bring on board international best practices in areas like
Improved Oil Recovery (IOR) together with Health, Safety and Environment (HSE) standards; provide
a harmonious relationship with the proposed law on management of petroleum revenues; provide
for National participation as an effort to enhance value creation by oil and gas activities; and provide
for a more competitive licensing process.
The new Act will also take recognition of the Petroleum Supply Act (2003), and adequately relate to
the emerging issues of the midstream petroleum sub-sector (i.e. oil and gas transportation,
processing and refining).
(i) The Petroleum (Exploration, Development and Production) Act, 2013
The objective and principle of the Act is to give effect to article 244 of the Constitution; to regulate
petroleum exploration, development and production; to establish the Petroleum Authority of
Uganda; to provide for the establishment of the National Oil Company; to regulate the licensing and
participation of commercial entities in petroleum activities; to provide for an open, transparent and
competitive process of licensing; to create a conducive environment for the promotion of
exploration, development and production of Uganda's petroleum potential; to provide for efficient
and safe petroleum activities; to provide for the cessation of petroleum activities and
decommissioning of infrastructure; to provide for the payment arising from petroleum activities; to
provide for the conditions for the restoration of derelict lands; to repeal the Petroleum (Exploration
and Production) Act, Cap 150; and for related matters. The Act came into force on 5th April, 2013.
(ii) The Petroleum (Refining, Gas Processing, Conversion, Transportation and Storage) Bill,
2012.
The Act is to give effect to article 244 of the Constitution; to regulate, petroleum refining, gas
processing and conversion, transportation and storage of petroleum, to promote policy formulation,
coordination and management of petroleum refining, gas processing and conversion, transportation
and storage; to provide for third party access to infrastructure; to provide for an open, transparent
and competitive process of licensing by the Minister responsible for petroleum; to provide for health
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and safety environment; to provide for cessation of petroleum activities and decommissioning of
petroleum facilities and infrastructure and to provide for related matters.
The SEA Team reviewed the Bills and prepared recommendations in form of advisory notes for
strengthening environmental provisions. It is expected that with coming into force of the two bills,
the Legal framework in this sector will become strengthened.
4.2 Regulations
Besides principal legislations, otherwise called Acts of parliament, there are also a number of
subsidiary legislations (regulations) which equally affect environmental protection in the oil and gas
sector in Uganda. One of the key regulations is The Petroleum (Exploration and production)(Conduct
of exploration operations) Regulations, 1993.
The Petroleum (Exploration and production)(Conduct of exploration operations) Regulations, 1993.
These are a set of regulations currently guiding the conduct of operations in the upstream petroleum
sub-sector. There is need to revise these regulations in order to take into consideration the global
improvements in technology over the recent past together with the increasing concern for
environmental conservation and sustainable development. This will include implementation of
international best practices for flaring during flow testing of oil and gas wells. The improved
regulations will also better address the operations and activities undertaken during the development
and production of oil and gas. The activities to be regulated under the upstream petroleum sub-
sector shall include exploration, development and the production of oil and gas. The new regulations
will be in harmony with those for midstream (refining and transportation) and downstream
(petroleum products distribution, marketing and sales) petroleum activities.
There are several other regulations that are of particular relevance to environmental protection in
the oil and gas sector. These are presented in Appendix 5.
Other Regulations
In connection with the review process for the National Environment Act, Cap. 153 Act, the following
regulations are also under review:
Regulations and Audit
Effluent discharge
Noise regulations
Waste management
New regulations are being formulated on “Air Quality”. The “Oil Spills Liability” draft is currently
updated and “Oil Spill Contingency” is being drafted. New guidelines will be prepared on “Waste
Management”.
Existing guidelines that are relevant for environment management:
Physical Planning Regulations, 2011
Guidelines to the Physical Planning Act 2010
National Physical Planning Standards and Guidelines, 2011
Regulations and guidelines on waste management are particularly overdue and the process for their
development needs to be expedited.
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4.3 International and Regional Conventions/Treaties, and guidelines
Uganda, just like many other states, is an active player in regional and international environment
matters. According to the Ministry of Energy and Mineral Development (MEMD, 2010), there are
already existing frameworks for regional cooperation in petroleum matters through the Committee
on Energy of the East African Community of which Burundi, Kenya, Rwanda, Tanzania and Uganda are
members. Harmonizing policies, laws and fiscal framework for the oil and gas sector is one of the key
matters being worked on by this committee.
Since 1990, Uganda has also had an Agreement of cooperation with the Democratic Republic of
Congo. This agreement was amended in January 2008. Under this arrangement, Uganda has made
available to DRC data and information in the public domain and has invited representatives from DRC
to the data room to view data that are not in the public domain to allay any fears that Uganda may
be doing something that may jeopardize the interests of DRC.
More agreements will probably be executed with other neighboring countries to more specifically
cater for oil and gas exploration and production.
At the international scene, Uganda is a party to several international treaties as explained in Appendix 5.
4.4 Compliance and Enforcement
4.4.1 Compliance
Compliance monitoring has been undertaken for purposes of detecting violations, supporting
compliance to specific conditions in the laws, regulations and various permits, providing evidence for
enforcement response and building compliance statistics.
Compliance monitoring takes various forms namely self-monitoring, inspections, citizen complaints
and area monitoring. Specifically for oil and gas activities, compliance monitoring started in the mid-
1990 and increased in the mid-2000 when oil and gas activities intensified. The companies involved in
oil and gas exploration and production use indicators related to environmental resources such as
water or degrade these resources through the various activities they carry out such as discharge of
effluent from their operations, disposal of drilling cuttings etc.
Strategically, oil exploration and production companies are required to carry out self-monitoring and
submit their data to the various environmental agencies on a quarterly basis. Inspections are carried
out by the regulators but these are sometimes not well coordinated and harmonized. In addition, due
to limited financial and human resources, the frequency of monitoring has been quite low,
sometimes once every quarter. Announced and a few unannounced inspections have been
undertaken, single and multi-disciplinary teams of Officers have carried out monitoring of compliance
involving also districts’ key technical staff.
Observations from the SEA Team reveal that compliance monitoring remains a challenge at district
level given the rigor required for monitoring and level of sensitivity of the sector. As proposed earlier
a compliance monitoring system can be strengthened and staff at local government level given sector
specific tools to enable them to adequately monitor activities. Further description of relevant
monitoring tools is presented in Appendix 5.
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4.4.2 Enforcement
The following tools are used by the regulators namely National Environmental Management
Authority (NEMA), Uganda Wildlife Authority (UWA), Petroleum Exploration and Production
Department (PEPD), Directorate of Water Resources Management (DWRM). These are listed below
and described in Appendix 5:
National laws and policy instruments
Permits
Production Sharing Agreements (PSA)
Field operations plans
National Park Management Plans and regulations
Inspection
Reporting
Delegated Authority
Self-Regulation
4.5 Institutional Framework and Capacity
The institutional framework and capacity for the oil and gas sector is considered in the SEA as a
mechanism that will influence the management of the petroleum resources and activities with crucial
implications to the environment. The Government has underlined the importance of the institutional
capacity issue through a national program on “Strengthening the management of the Oil and Gas
sector in Uganda”. The purpose of the program is: “To put in place institutional arrangements and
capacities to ensure well-coordinated and results oriented Resource management, Revenue
management, Environmental management and HSE management in the oil and gas sector” in order
to contribute to the achievement of the objectives of the National Oil and Gas Policy. Objective 9 of
the NOGP is specifically relevant to environment management and the SEA, that is, “to ensure that
oil and gas activities are undertaken in a manner that conserves the environment and biodiversity.
Objective 8 provides a framework to support the development and maintenance of national
expertise. Institutional capacity is to be built for both the authorities and national entrepreneurs and
the oil companies operating in the country which are expected to contribute to this effort and in the
transfer of technology.
4.5.1 General Governance Structure
The Policy direction for the petroleum sector is the responsibility of the Ministry of Energy and
Mineral Development (MEMD). However, Government’s institutional reform policy of Regulatory
Best Practice (RBP) recommends separate institutions for policy, regulation and the
business/commercial aspects of the oil and gas sub sector. Therefore, while MEMD handles the
policy aspects, new institutions will be set up to handle the regulatory and business/commercial
aspects. The regulatory functions will be handled by the Petroleum Authority of Uganda (PAU) while
the business/commercial aspects will be handled by the Uganda National Oil Company (NATOIL). The
roles and relevance to environment management of oil and gas of the State, the Ministry, the new
institutions as well as other institutions of Government and Civil Society are discussed in the next
paragraphs.
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The role of Parliament
According to the National Oil and Gas Policy, the specific role of parliament in Uganda’s petroleum
sector is to enact petroleum legislation, to enact the proposed legislation for the management of
petroleum revenues and to monitor performance in the petroleum sector through policy statements
and annual budgets. The key challenge will be the capacity of parliament to ensure that
environmentally streamlined legislation and policies are enacted and adequately financed.
The Ministry Responsible for Oil and Gas
The mission of the Ministry is: “To promote, develop, strategically manage and safeguard the rational
and sustainable utilization of energy, petroleum and mineral resources for economic and social
development. Currently MEMD will continue to play all the roles of Government for the oil sector
including policy making and implementation, regulation of the sub-sector and managing the
commercial/business aspects until the new institutions are established. For more efficient
management, of the sector, the policy recommends establishment of the Directorate of Petroleum.
The Directorate of Petroleum
Among the roles of the Directorate, the following are considered relevant for environment
management:
Initiating, developing and implementing oil and gas policy
Submitting draft legislation to Parliament
Issuing Petroleum Regulations
Proposing Petroleum Administration
Negotiating, endorsing and administering PSA’s
Approving Plans for Field Development
Approving data management systems
Recommending the option to exercise state participation in development and production of oil
and gas
Ensuring dissemination of information on oil and gas activities.
The relevant Department for petroleum affairs is the Petroleum Exploration and Production
Department, PEPD.
The Petroleum Authority of Uganda (PAU)
An authority shall be put in place to regulate the different players in the sub-sector. The specific roles
of the PAU that are specific to environment management include:
Proposing and implementing Regulations
Assisting in proposing and implementing petroleum legislation
Assisting in proposing and implementing oil and gas policy
Assisting in negotiating and administering PSAs
Assessing Plans for Field Development
Assessing tail-end production and abandonment
Ensuring that licensees uphold laws, regulations, rules and contract terms
Ensuring Health, Safety and Environmental standards in oil and gas operations
Ensuring appropriate implementation of petroleum legislation
Assisting in the acquisition of data for use in promoting unlicensed areas.
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The SEA concern is capacity for the authority to streamline environmental issues into development
and implementation of the legislation and regulations and ensuring that appropriate environmental
data is part of the database supporting licensing areas.
The Uganda National Oil Company (NATOIL)
The NATOIL will handle the national commercial interests in the sub sector, e.g. state participation in
the licences and marketing the country’s share of oil and gas production received in kind. The SEA
concern is capacity to integrate eco-labeling to flagship Uganda’s best environmental practices in oil
and gas production.
Other Government Ministries and Agencies
As provided in the policy, the SEA considers the roles of Government stakeholders including
Ministries that are responsible for policies relevant to oil and gas, and operational/managerial
agencies dealing with implementation and regulation. The SEA considers the following as crucial:
National Environment Management Authority (NEMA) is responsible for approving environmental impact assessments and reports for mining projects.
The recently formed Uganda Chamber of Mines and Petroleum and relevant groupings that may come in place will constitute the main stakeholders of institutional framework for the development of the sector.
Other key ministries and agencies that comprise the institutional framework are presented in
Appendix 5.
Civil Society and Traditional/Cultural Institutions
These have a role in advocacy, mobilization and facilitating dialogue with communities. A major issue
is the capacity of Civil Society and Cultural Institutions in undertaking this role.
Business /Private sector
The NOGP recognizes the role of the private sector on the basis of the contribution to the
development of an oil and gas sub sector through investment in productive sectors of the economy,
development of new economic and social infrastructure, increasing power generation capacity and
the general enhancement of energy security through production and refining of oil. This is seen to be
in line with Uganda’s Poverty Eradication Action Plan (PEAP) that focuses on promoting private-
sector led economic growth.
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4.5.2 Institutional framework for environment management of oil and gas
Institutional Framework defined under the NOGP
The institutional framework provided in the NOGP provides wider designates NEMA and UWA for
specific roles that cater for environment managment. NEMA is designated for the following roles:
Co-ordinating the processes of environmental impact assessments for oil and gas activities.
Carrying out, alongside other stakeholders, environmental monitoring and audits of oil and
gas activities.
Ensuring and monitoring compliance of oil and gas activities with environmental guidelines.
Issuing guidelines for strategic environmental assessment.
Harmonizing national performance standards in the oil and gas sector on environmental
sustainability with international standards.
The role of Uganda Wildlife Authority is defined as follows:
Monitoring compliance of oil and gas activities to regulations governing operations in wildlife
protected areas.
Harmonizing national and international performance standards on wildlife protected areas
Monitoring the impact of oil and gas activities on wildlife protected areas.
Participating in evaluation of Environmental Impact Assessments (EIA) and environmental
audits for oil and gas activities.
Issuing consent to undertaking petroleum operations in wildlife protected areas.
Environment Management Pillar
The Government instituted an environment management pillar as one of three pillars for the
management of oil and gas in the country. The environment management pillar comprises
institutions with a mandate to manage the impact of oil and gas activities on the environment and
biodiversity and whose heads form the strategic level monitoring team. The institutions include:
National Environment Management Authority (NEMA), Directorate of Water Resources Management
(DRWM), Directorate of Environmental Affairs (DEA), National Forestry Authority (NFA), Uganda
Wildlife Authority (UWA), Department of Fisheries Resources (DFR), and Ministry of Lands Housing
and Urban Development (MLHUD).
A multi-sectoral technical team was also instituted at national level to inspect oil exploration
activities on a quarterly basis. The team includes the following institutions: NEMA, PEPD, UWA,
DWRM, NFA, Fisheries and Department of Occupational Health and Safety.
However, environment management of oil and gas requires a multi-sectoral approach involving
institutions that have been designated as resource and revenue management pillars, as well as the
institutions that have been highlighted for the governance of oil and gas. The multi-sectoral
institutional structure for environment management is illustrated in Figure 4.1.
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Figure 4.1: Generic institutional framework for environment management of oil and gas
The main challenge with the institutional framewok is the capacity of the environment management
pillar institutions in fulfilling their mandate to manage the impact of oil and gas activities on the
environment and biodiversity. The details of capacity issues and recommendations are provided in
Chapter 6.4.
4.6 Policies, Plans and Programs
This chapter presents an overview of Policies, Plans and Programs (PPPs) to be considered when Key
Issues are identified (see Chapter 2 for more details) and further assessment of how to link these to
existing laws/regulations and PPPs is undertaken.
PPPs provide the context for the SEA and they are the key subjects of the assessment for
environmental consequences. In broad terms, the policies to be considered in the Albertine SEA are
the proposed government actions and options at the highest level. A policy, unlike a law, is an outline
of what government hopes to achieve and the methods and principles it will use to achieve them. It
states the goals of the institution, mostly, the ministry. A policy document is as such not a law but it
often identifies new laws needed to achieve its goals. In Uganda, there are several policies related to
environmental protection, such as the National oil and gas Policy, 2008, the National Environment
Protection Policy, the Water Policy etc. On the other hand, plans and programs prescribe options and
measures for carrying out a proposed course of action for a particular policy sector. A number of
plans and programs have been prepared for the oil and gas sector. Here below is a brief account of
some of the most relevant policies to the oil and gas sector that are relevant for the SEA process.
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4.6.1 Policies
THE NATIONAL OIL AND GAS POLICY FOR UGANDA (NOGP, 2008)
Consideration for environmental management is entrenched in the fourth Principle of the NOGP,
which is “Protection of the environment and biodiversity”. It integrates an operational objective
(objective 9) pertaining to the environment which is to: “ensure that oil and gas activities are
undertaken in a manner that conserves the environment and biodiversity among the 10 objectives of
the National Oil and Gas Policy. However, the National Oil and Gas Policy focuses more on upstream
and midstream activities, and provides complementary action on downstream issues from the Energy
Policy of 2002.
Concerning environmental management, the NOGP focuses on institutional framework aimed at
addressing environmental and biodiversity issues, capacity, as well as monitoring the impact of oil
and gas activities, promoting self-regulation and environmental restoration. Further, the NOGP
recommends the upgrading of environmental and biodiversity legislation to address oil and gas
activities, strengthen institutions with a mandate to manage the impact of oil and gas activities on
biodiversity and, to develop physical master plans, environmental sensitivity maps and oil spill
contingency plans for the oil and gas producing region and any transport corridors.
The policy also assesses the following likely environmental impacts of oil and gas activities on the
environment: energy use (clean energy for human health and reduction on dependence of biomass
energy), air, and water and land pollution and infrastructure development. The use of the “Polluter
Pays Principle” in pollution control and management is also encouraged in this policy.
In addition, the NOGP provides for revenue sharing in which each district is to receive 7% of the
revenues generated from its extracted deposits. These funds will be a constant amount which is
exchange rate immune. The resources are strictly for use in the development of the respective
district social and economic infrastructure. The basis for determining the percentage that goes to
districts is not clear. However, the idea is to keep a bigger percentage of the revenues at the center
(MPFED, and is held in trust) such that at the end of the extraction period, the center can use the
funds to support continued social and economic development in the districts. The draft public finance
bill takes this issue further.
The main challenge with the revenue sharing provision, however, is managing the different
expectations from the various stakeholders. For example, the Bunyoro kingdom’s demand is 15%.
With time also the expected increase in population and other economic influences such as inflation
acerbate the challenges of revenue sharing and bear on stakeholder participation and relations.
The NOGP also provides for institutional arrangements for management of various aspects of oil and
gas sector, including those for managing environmental aspects.
THE NATIONAL ENVIRONMENT MANAGEMENT POLICY (1994)
The National Environment Management Policy provides for the institutional structure as well as
policy measures for environmental management in Uganda. The overall goal of the policy is
sustainable social and economic development, which maintains or enhances environmental quality
and resources productivity on a longer-term basis that meets the needs of the present generations
without compromising the ability of future generations to meet their own needs. The specific
objectives of the policy are to:
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Enhance health and quality of life of all Ugandans and promote long-term sustainable
economic development through sound environmental and natural resources management
and use.
Integrate environmental concerns in all development-oriented policies, planning and
activities at national, district and local levels, with participation of the people.
Conserve, preserve and restore ecosystems and maintain ecological processes and life
support systems, including conservation of national biodiversity.
Optimize resource use and achieve sustainable level of resource consumption.
Raise public awareness to understand and appreciate linkages between environment and
development.
Ensure individual and community participation in environmental improvement activities.
This Policy sufficiently addresses general requirements for environment management but by treating
environment as a crosscutting issue, certain aspects of environmental management e.g.,
management of extractive industries in national parks is not adequately addressed. The policy does
not also sufficiently provide for mechanisms needed to mitigate environment degradation in areas
where oil exploration and production will take place.
However, in order to address the challenges of integrating environmental concerns in all policies,
plans and programmes the Strategic Environment Assessment Steering committee was created in
order to increase understanding of sector specific environmental concerns in the planning of line
ministries. This team recommends that a social and environment management system be developed
and implemented for sustainability. The aim would be to discuss different mitigation options,
indicators and the need for compliance incentives where applicable. Additional relevant policies are
included in Appendix 5.
4.6.2 Plans
The SEA is addressing the key strategic plans according to consultations with relevant stakeholders.
Plans which are not highlighted are also important and should be further followed up in the
implementation of the SEA.
NATIONAL DEVELOPMENT PLAN (NDP) 2010
The NDP is the overarching framework for national development planning. The NDP 2010 outlines
strategic actions for improving public sector management and administration including oil and gas.
The plan emphasizes establishment of new and strengthening the existing regulatory agencies within
government to ensure proper and efficient regulation in critical sectors including oil and gas industry.
The NDP also emphasizes specialized human resource training to be carried out for personnel in key
sectors including the Oil and Gas to so that the skills gaps are addressed in order to enhance
efficiency and productivity in existing and emerging sectors of the economy.
OIL AND GAS SECTOR DEVELOPMENT AND INVESTMENT STRATEGY/PLAN (2010)
The plan is part of the program by the Uganda Government through MEMD and the Government of
Norway Strengthening the Management of the Oil and Gas Sector in Uganda. The investment plan is
a live document which can be updated annually in the event that the expected results do not
materialize or new, promising opportunities emerge. Investments planning will focus on three
thematic areas approved for the program:
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Preparing a detailed integrated field development plan
Developing an oil and gas utilization plan
Preparing technical and economic feasibility studies for prioritized investment requirements.
BASIN WIDE DEVELOPMENT PLAN
Following significant exploration success in 2009 and the progress made in forming a new aligned
partnership, the focus is now on delivering an accelerated development program. The oil industry is
working with the Government of Uganda on clearly defining the phases of development. Phase 1 is
already under way.
Lake Albert Phase 1: This involved the development in Block 2 of the Nzizi gas field, to fuel a regional
thermal power station, and the Mputa oil field for industrial consumption within Uganda.
An extended well testing program was planned to support development planning of Kasamene and
subsequent fields. This program, which focused on gathering essential dynamic production data and
testing proposed production systems, commenced in mid-2010, starting with the Kasamene field. The
crude oil produced from the testing operations will be used to supply fuel to local industrial users and
provide the first domestically produced oil in sub-Saharan East Africa following other Sub-Saharan
countries as South Sudan, Nigeria, Gabon, Republic of Congo, Equatorial Guinea, Côte d’Ivoire, Chad,
Cameroon, and Angola. The appraisal drilling and well testing will be complemented by in-fill 2D and
3D seismic acquisition.
Beyond Phase 1: The first objective of the new proposed partnership was to agree on a Basin Wide
Development Plan that will encompass the production of the northern and southern fields via an
integrated infrastructure. A refinery will be developed to supply the national and regional demand. If
there is any excess crude, an export option may be considered. The plan is not yet available.
MANAGEMENT PLANS FOR PROTECTED AREAS
The various protected areas in the AG have general management plans, some of which are outdated.
There is therefore a need to update or develop new management plans. In cases where oil
development is approved, such plans have to be updated to consider the sensitivity and values of the
protected area as well as the aspects and impacts from oil activities.
The process of updating Management Plans for areas such as Murchison Falls National Park,
Maramagambo Forest Reserve and Queen Elizabeth National park to consider aspects related to oil
and gas is currently underway.
OIL SPILL CONTINGENCY PLAN
Oil spill contingency planning will provide guidance on national oil spill responses and actions
including a risk analysis of the oil and gas activities and stakeholder sensitization. It will provide a
comprehensive framework to guide mitigation efforts. The petroleum activities in Lake Albert region
are being undertaken in a sensitive ecosystem. River Nile which runs towards Sudan is an
international resource. In addition, oil transportation activities may involve oil spills/accidents, which
will need a comprehensive framework to guide mitigation efforts. The National Oil Spill Contingency
plan is being developed and is expected to be in place in 2013.
PLANS FOR DEVELOPMENT OF AN OIL REFINERY AT KABAALE
A refinery covering an area of 29 km2 is planned at Kabaale village, Buseruka sub-county, Hoima
District for an initial capacity of 20,000 barrels per day which will subsequently be expanded to
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60,000 bbls/d and finally 120,000 bbls/d or even 180,000 bbls/d if demand for the products exists.
This follows establishment of commercial quantities of oil and gas deposits in the area east of Lake
Albert and the Nile Delta north of Lake Albert in the Districts of Hoima, Buliisa and Nwoya. As the
crude has a pour point around 40°C and a high wax content, it requires heating to keep the oil in
liquid state. The refinery feasibility study (2011) has therefore recommended that the refinery should
be constructed close to the producing oil fields to avoid lengthy and costly pipeline transportation
and to optimize the value from the oil resources.
As a result of the refinery planning significant infrastructure developments will be carried out in the
project area. This will require construction of roads, pipelines and development of construction
camps and settlements. An environmental baseline study is to be commissioned to ensure that any
significant environmental and social aspects are considered during the Front End Engineering Design
(FEED) phase and that the identified issues are integrated in the early planning stages of the project
and serve as a basis against which future impacts can be measured or monitored.
PLANS FOR TRANSPORT OF OIL FROM THE FIELDS TO THE REFINERY
A feasibility study for the development of pipelines and storage facilities for crude oil and gas in
Uganda was finalized in January 2012. The study evaluated the commercial feasibility of two crude oil
pipelines and associated storage facilities to transport crude oil from a northern and southern central
processing facility to the central refinery including required pump stations, block valves and pigging
facilities. Scenarios also included gas and oil transportation from additional fields. The crude oil
properties require permanent heating of the oil pipelines as part of the design to ensure continued
flow. As the northern and southern central processing facilities are more or less defined, there are
not many options regarding pipeline routing.
PLANS FOR DEVELOPMENT OF A PETROLEUM BASE AT BUTIABA
A private developer, the East African Petroleum Services Ltd. (EAPS) has proposed to construct and
operate a petroleum base at Butiaba. EAPS is a company set by the Norwegian NorSea Group and the
Ugandan logistics operator Mineral Services Ltd. (MSL Logistics) aiming to provide warehousing,
repair, drilling waste treatment and disposal, water treatment and sewage, laboratory services,
emergency preparedness, storage and transportation among others. Construction of the base is
underway but is not yet decided which facilities will be established at the base and what services are
finally offered as not all approvals have yet been obtained.
NATIONAL WATER QUALITY MANAGEMENT STRATEGY (2006)
The strategy aims to provide direction for water quality management in Uganda in terms of strategic
targets, actions and implementation plan and possible funding requirements. The strategy has its key
principle and policy related objective to link the water quality monitoring objectives with a set of
environmental values given in Clause 4.3.3 of the National Water Policy, 1999, national and
international commitments and national environmental responsibilities. The integrated monitoring
and assessment framework that the strategy presents addresses basic ambient monitoring ,
operational and affluent monitoring, preventive measures as well as a data management framework
that can benefit the processes of addressing water resources management in the Albertine region.
NATIONAL TRANSPORT MASTER PLAN (2008-23)
The National Transport Master Plan including a Transport Master Plan for Greater Kampala
Metropolitan Area (NTMP/GKMA) is a 15-year strategy framework for development of the transport
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sector involving overall planning of the medium-term economic and social development of Uganda. It
is a comprehensive long-term plan for the whole sector, covering investment needs, and a whole
transport framework including policy and strategy; the institutional, legal and financial framework;
and other relevant aspects, including land and environment, stakeholder interests, and capacity
building. The long term view of the sector envisions the Rail Transport Sub-Sector beyond 2023,
with a possibility for a Kampala-Nakasongola-Gulu, with a branch off to the oil fields in the Albertine
catchment area and possible electrification of the network in total or in part. The plans include
expanded air transport. Therefore, there is need to take into account the influence of these plans
on future oil and gas activities and the socio-economic as well as ecological implications.
The strategy recognizes that environmental protection will be a critical factor in infrastructure
development. One of the key aspects of the draft strategy and policy paper is to ensure that all
transport development projects are subject to environmental impact assessments (EIA’s) approved
by the National Environmental Management Authority.
THE ENVIRONMENTAL MONITORING PLAN FOR THE ALBERTINE GRABEN 2012-2017
Uganda has prepared an environmental monitoring plan for the Albertine Graben to cover a period
between 2012 and 2017. The plan was prepared under an established environmental monitoring
program in the Albertine Graben covering ecological and societal issues as part of management
actions in connection with the planned activities of oil and gas exploration. The program is funded by
the Norwegian Government under the Environmental Management Pillar of the Uganda oil for
development program. NEMA is the lead agency in Uganda for developing and managing the
monitoring program, including the process of establishing it. The process has been highly
participatory and started with a scoping workshop attended by various major stakeholders in April
2011. The Norwegian Institute for Nature Research (NINA) was contracted by the Directorate for
Nature Management, Norway, to facilitate the workshop (Thomassen & Hindrum, 2011).
The new monitoring plan for the Albertine Graben provides a framework with indicators based on
valued ecosystems services that would enable different stakeholders assess performance of the
sector, however, a Social and Environment Management System needs to be developed under PEPD
to further enhance ongoing interventions while bringing on board all stakeholders and addressing
coordination issues.
Other plans that have a bearing on environment management of oil and gas include:
Strategic Plan for the Northern Albertine Rift of Uganda 2011 – 2020
This Strategic Plan includes the landscape from Murchison Falls National Park in the north to the
Toro-Semliki Wildlife Reserve in the south. It focuses on improving livelihoods of rural
populations outside protected areas, forest planning outside protected areas and integration of
conservation and protection measures for forests, wetlands and biodiversity.
Uganda Association for Impact Assessment Strategic Plan 2010 – 2015
The objective and priorities of the Strategic Plan is to advocate for environmentally sustainable
practices, develop and share public opinions on Environmental Impact Assessment, participate
in international fora and implement methods and standards of knowledge and skills for people
seeking to become members of the association.
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THE RESETTLEMENT ACTION PLAN (RAP) FOR THE REFINERY AREA
The main objective of the RAP is to develop a framework for managing the loss of economic activities
and livelihoods through compensation or resettlement from the site of the local people. Government
undertook a feasibility study on the development of a refinery in the country. The study which was
carried out by Foster Wheeler Energy Limited, a UK Engineering firm was completed in September
2010 and approved by Government in April 2011. The study confirmed that developing a 60,000
barrels/day refinery in the country was a viable venture with post tax rate of return of over 30% and
payback period of 2.2 years. The study undertook a comparative analysis of a crude pipeline to the
Mombasa. The waxy Ugandan crude would require having the pipeline continuously heated for the
entire length thus making it very expensive.
The study also analysed six possible locations for the refinery that included two areas around the
Lake Victoria shores, Majanji in Busia, Nakasongola and, Biiso and Kabaale in Hoima district. Kabaale
parish was chosen as the most suitable location for the refinery because of its close proximity to the
oil fields in the Albertine Graben, the availability of a large source of water (Lake Albert), its fairly flat
terrain and sparse population. With this, there was need to prepare a RAP for the Kabaale area. The
RAP is expected, among others, to consult all stakeholders especially the affected people about their
concerns on the proposed land acquisition, prepare a social impact analysis, raise awareness about
the project and its consequences, and measure current property and socio-economic status of the
Project affected persons.
PHYSICAL DEVELOPMENT PLAN FOR THE ALBERTINE GRABEN REGION (TO BE PREPARED)
Following the declaration of the Albertine Graben as a special planning area, the Ministry of Lands,
Housing and Urban Development (MoLHUD) has embarked on the development of a regional physical
development plan for the area. The process which is supported by DFID through the World Bank is at
procurement stage. The plan is to address the following:
Actions and alternatives for the present and future land use development that will stimulate
development in the region and developed detailed development proposals and implementation
strategies.
Alternative spatial development concepts illustrating broad land use concept, settlement
development strategies, key environmental management strategies and the primary internal
transportation network; all derived from an inventory and assessment of the environmental, socio-
cultural, economic opportunities, existing problems/constraints and potential components of the
spatial system of the Albertine Graben
Basic environmental scoping exercise to determine any significant adverse impacts that are likely to
arise from implementation of the proposals and formulate mitigation measures as required.
The plan will guide locations and structures of industries, infrastructure, agriculture, housing,
environmental conservation and other activities that will arise as a result of oil and gas development.
There is already infrastructural boom and population increase in Bunyoro as more people pour in the
region in anticipation of opportunities that will accrue from oil exploration.
Given the ecological sensitivity of the area, the physical development plan should in general integrate
ecological principles and should specifically focus on the land use planning within protected and
environmentally sensitive areas.
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FAST TRACKING URBAN PLANNING AND DEVELOPMENT OF SELECTED AREAS IN THE AG
While the Physical development plan will provide an overall planning framework to guide activities in
the Albertine Graben, some urban areas and settlements in the region are fast expanding. This has
warranted fast tracking physical development planning for selected areas including Buliisa, Butiaba,
and Sebigoro.
UGANDA WILDLIFE AUTHORITY OPERATIONAL GUIDELINES FOR OIL AND GAS EXPLORATION AND
PRODUCTION IN WILDLIFE PROTECTED AREAS (DRAFT).
The guidelines were developed to complement the Sensitivity Atlas, the Strategic Environmental
Assessment (SEA), Environmental Impact Assessments (EIAs), various regulations and policies
relevant to petroleum developments in order to ensure minimal negative impacts on the
environment.
The purpose of the guidelines is to ensure that the oil and gas activities do not negatively impact on
the integrity of the protected areas. The guidelines were formulated to guide the operations of oil
companies within wildlife protected areas including dual management areas and are categorised
under four major themes; Operations and coordination, Infrastructure, Tourism and Ecosystem
health. The guidelines emphasises that the all oil and gas operations within wildlife protected areas
shall be conducted in line with the provisions of the Act and where the guidelines contradict the EIAs,
the guidelines shall take precedence. The key objectives of the guidelines include: To minimize long
and short - term negative impacts of oil and gas developments on the integrity of protected areas
and associated ecological processes; to minimize potential negative impacts of oil and gas
development activities on tourism; to guide, coordinate and regulate activities of oil companies
within protected areas; and to enhance awareness and appreciation of conservation among the oil
companies.
MURCHISON FALLS NATIONAL PARK, KARUMA WILDLIFE RESERVE AND BUGUNGU WILDLIFE
RESERVE (MURCHISON FALLS PROTECTED AREA) GENERAL MANAGEMENT PLAN (2012-2022)
The purpose of the plan is to successfully conserve Murchison Falls Protected Area (MFPA) and
address the increasing level of human demands and limited natural resources. It is important that a
management plan be developed. The purpose of the plan is to guide management in making
decisions for the sustainability of the Protected Area. With the minimal resources, the plan will help
management to prioritize the activities and locate resources to the most critical areas. In addition,
the plan will contribute to the general management of the area. This plan therefore identifies the
desired future conditions (management objectives) of MFPA during the 10-year period (2012-2022)
and presents strategies to enable the PA managers achieve this objective.
4.6.3 Programs
STRENGTHENING THE MANAGEMENT OF THE OIL AND GAS SECTOR IN UGANDA’ S PROGRAM
The program is between the Norwegian Ministry of Foreign Affairs and the Government of the
Republic of Uganda under the Ministry of Energy and Mineral Development. The program started in
July 2009 has a lifespan of five years and is expected to end in June 2014. The overall objective of the
program is to contribute to the achievement of the goal of the National Oil and Gas Policy of Uganda
which is: “To use the country’s oil and gas resources to contribute to early achievement of poverty
eradication and create lasting value to society”.
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The purpose of the program is: “To put in place institutional arrangements and capacities to ensure
well-coordinated and results oriented Resource management, Revenue management, Environmental
management and Health, Safety and Environment management in the oil and gas sector” in order to
contribute to the achievement of the objectives of the National Oil and Gas Policy.
The program is implemented under the three pillars of Resource Management, Revenue
Management and Environment Management. Each of the pillars is headed by a Pillar Manager and
each Pillar Manager has a counterpart on the Norwegian side referred to as a Resource Manager. The
Pillars and the entire program are coordinated by a Program Coordinator in Uganda who also has a
counterpart in Norway. The Pillars are coordinated and supported at Program Management level by
the Program Secretariat (MEMD, 2012)
TRAINING PROGRAMS
The Ministry of Energy and Mineral Development has worked with the Ministry of Education and
Sport to introduce training programs in petroleum-related fields to build national skills and expertise.
These programs would help the country to build a team of trained scientists to manage and monitor
oil production. In 2009, Makerere University started to offer a Bachelor of Science in Petroleum
Geosciences degree; and in March 2010, the Uganda Petroleum Institute at Kigumba began offering
diploma and certificate courses. The ministry of Energy and Mineral Development has also sent
students abroad for degrees in petroleum-related fields (Mugyenyi and Twesigye, 2010).
ASSESSMENT OF THE NEEDS TO ESTABLISH AN ENVIRONMENTAL LABORATORY IN PEPD
Done by GEUS of Denmark; assessment of the needs to establish an environmental laboratory in
PEPD to analyse the effects of possible oil spills or pollution from petroleum activities. The project
was financed from Danish trust funds with UNDP and apart from laboratory needs; the TOR included
capacity building in terms of training courses for staff at PEPD. The purchase of proposed new
equipment was not part of this activity. However, preparations for such procurement (elaboration of
specifications and identification of possible donors) were included. The GEUS/UNDP project ended in
2005.
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5 INTEGRATION OF KEY ISSUES INTO LAWS/REGULATIONS;
POLICIES, PLANS AND PROGRAMS
As already described in Chapter 2, this chapter is focusing on how to ensure that environmental and
sustainability considerations are taken into account during early stages of decision making and how
these considerations are integrated into relevant Policies, Plans and Programs.
The Key Issues identified (Chapter 2) represent the environmental and sustainability aspects to be
considered. The Key Issues are sorted into 18 groups to make the further assessment more
structured. For each of these groups, relevant Policies, Plans and Programs are identified for
consideration in integration of the aspects. To ensure an effective engagement with
people/organizations connected to the respective aspects, a thorough registration of stakeholders
was carried out. Preliminary recommendations prepared by the SEA Team were presented to the
stakeholders as basis for a good and relevant discussion about how to integrate the Key Issues into
the relevant PPPs.
In the following sections, the conclusions from the stakeholder engagement process and the
subsequent recommendations made by the SEA Team are presented for each Key Issues Group. The
relevant PPPs, stakeholders and laws/regulations as well as the outcome of the stakeholder
consultations are covered in Appendix 7, the Key Issues Integration Matrix.
Key Issues Group 1: Petroleum related Activities in Protected and Environmentally Sensitive Areas
Key Issue.
Why is the Key Issue relevant?
1. Consideration of biodiversity loss, also aquatic. Footprint.
Considerable petroleum activities are taking place in protected and environmentally sensitive areas.
2. Attention on sites with international conservation status.
Petroleum activities are taking place within sites of international conservation status (e.g. Ramsar sites and
Biosphere reserve) which may attract international condemnation. Uganda is a signatory to international
conventions.
3. Impacts on wildlife population and movement.
Wildlife is sensitive to external activities and infrastructure. Further pressure from petroleum activities has
potential to severly impact on wildlife.
4. Sensitive aquatic resources such as deltas, shorelines
Aquatic habitats notably floodplain wetlands, deltas, vegetated shorelines and shallow inshore belts (< 6 m
deep) are essential and sensitive breeding, feeding and nursery sites, rich in aquatic biodiversity.
5. Coexistence with wildlife.
Due to the high human population in the Albertine Graben, wildlife is mostly restricted to protected areas.
Wildlife going outside protected areas results in human-wildlife conflicts and is often killed. Petroleum
activities, which are known to have a large footprint, will compete for space within these areas.
6. Operations within the protected areas.
There are rules and regulations that govern management of protected areas. Petroleum activities will to a large
extent affect animal behavior and survival, and cause reduction in protected area value.
7. Pollution and disappearance of endemic species.
The Albertine rift is a global center for species endemism. It harbors more endemic mammals, birds and
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amphibians than any other region on the African continent. It also has high plant endemism. Any further
disturbing activity in this area is a potential threat to these animals and plants.
8. Habitat fragmentation due to construction works
The existing protected areas are either just enough or require connectivity in order to maintain viable
populations of the existing wildlife species. Further fragmentation may be a threat to some species.
Fragmentation is often associated with introduction of invasive species. It also opens up pristine areas for
encroachment.
9. Environmental monitoring of operations in sensitive areas
Environmental monitoring is a crucial tool for baseline understanding and measurement of impacts and
mitigating measures. Current environmental monitoring is influenced by availability of funds. There is higher
need for more planned and regular monitoring in order to pick up any changes.
Recommendations:
There is a need to review laws and regulations regarding protected areas and their protection
status due to the fact that economic activities such as petroleum developments were not
envisaged when designing the existing laws and regulations. This review has to take into
consideration the extraordinary environmental value of the protected areas and the risks
represented by the petroleum activities. A good example is the extensive petroleum activities
taking place in the Murchison Falls National Park.
The same principles as for the protected areas should be applied for the environmentally
sensitive areas in order to safeguard their ecosystem functions. Environmentally sensitive
areas are those identified in the Environmental Sensitivity Atlas which will be updated
regularly.
Future petroleum activites not yet licensed shall be based on the Integrated Management
planning recommended to be developed in the near future (see chapter 6.2).
The Uganda Forest Policy should be revised to include oil and gas issues, and a timeline should
be set to complete the forest regulations and guidelines for EIA in forest developments.
The Toro-Semliki Management Plan needs to be reviewed to comprehensively address oil and
gas issues.
Valuation of ecosystem services should be established.
Procedure of forest valuation needs to be reviewed. Government valuer only considers
merchantable timber. A cost also needs to be attached to other values of the forest in
question e.g. ecosystem services, biodiversity value and carbon sequestration. This will either
cause oil companies to label certain parts of the forest as extremely sensitive in that no
activities should be carried out in them or be more careful when carrying out activities in such
areas.
Tree planting and support to tree resource management is essential and should also be
considered as part of corporate social responsibility.
Companies should consider supporting local forests as a way of payment for carbon
emissions.
When preparing an EIA for any oil and gas activity, there is need to incorporate
transportation impacts related to that activity.
Local Government needs to develop standards for Environment Officers’ operations.
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The wetlands policy, regulations and standards need review to incorporate oil and gas issues
and the wetlands specific laws need approval by Parliament.
The wetland map needs to be updated.
The Fisheries Act and the National Fisheries Policy should be reviewed to include oil and gas
issues, and lacking fishery control instruments should be put in place.
Fish breeding areas should be clearly mapped out and gazetted.
There is need to consider the writing of one overall EIA for wells and/or other infrastructure
that may be within the same locality so as to capture the cumulative impact of the activities
other than writing an EIA for each well or piece of infrastructure.
Institutions should endeavor to include international standards such as ISO, the Aichi Targets
(United Nations, 2010) etc. into regulation drafting to ensure that petroleum companies
adhere to accepted international standards that are possibly above existing Ugandan law.
Since this is just the beginning of oil and gas exploration in Uganda, very sensitive areas can
be either avoided completely or not explored until technologies that would minimize
degradation of such landscapes have been developed.
Natural resource management institutions and PEPD should develop a harmonized stand on
critical environment issues to avoid scenarios where fear of economic cost that could be
incurred overides conservation concerns.
Key Issues Group 2: Co-existence with Local Communities
Key Issue.
Why is the Key Issue relevant?
1. Compensation, livelihood restoration, resettlement.
Agricultural Production is the mainstay of over 90% of the population in the Graben and as petroleum activities
are undertaken in the area, land taking is common. While there are legal instruments that govern
compensation and livelihood restoration, adequate planning and sensitization of communities on the tools and
methods in resettlement action planning is needed to ensure that communities have no fears of unfair
compensation. Compensation guidelines and procedures are today not known by the affected persons.
2. In-migration at a larger scale. Large workforce.
In addition to a large workforce of 5.000 – 10.000 the extensive activities in the region will attract people
looking for jobs and opportunities. This increased activity and population will lead to social tensions/disruption.
Previously, the Graben was not as heavily populated as it is today, especially around the fishing villages, and as
such, the facilities will not be able to meet the service demands of an increased workforce.
3. Socio-economic issues incl. education, health, social patterns, adaptation capacity etc.
Opening up of roads and related infrastructure has attracted a huge number of people that have opened up
land for agriculture and have settled in the area. This has escalated the demand on existing social
infrastructure. Although the income levels are likely to increase, the disparity in living standards will remain.
4. Land rights and tenure, land conflicts and speculation.
Customary land ownership is the predominant land tenure arrangement, however, petroleum activities are
triggering speculation and high transaction costs for attaining titles, resulting into tension amongst community
members that require a unique understanding of land issues and guidance on how to handle compensation
packages from untitled land amidst increased cost of living.
5. Consultation with cultural and traditional institutions. Indigenous knowledge.
In the recent past, officials from the cultural institutions have expressed concern regarding land use issues and
revenue sharing, moreso, on the need to protect cultural heritage within the Graben and where possible,
adequate compensation handled in the event that activities are unavoidable. Indigenous (traditional)
knowledge could add value to ecosystem understanding and planning of petroleum activities in the region.
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6. Impacts on population dynamics in the region. Urbanisation.
The petroleum activities will escalate the urbanization process in the region. The local population and
immigrants will be attracted to settle in existing and new centers which will lead to management challenges
related to physical and social infrastructure. Additionally, if not well planned, increased numbers of people
pose a threat on existing wildlife resources with increased poaching and encroachment into protected areas in
search of fuel wood, water and agricultural land; and even new settlements in environmentally sensitive areas.
7. HIV/AIDS.
The increased petroleum activities with large numbers of workforce and new inhabitants from outside will lead
to social changes accompanied by increased social vices like alcoholism and increased spread of HIV/AIDS.
8. Involvement of locals in new job market.
While the petroleum industry has a lot of employment opportunities for skilled and semi-skilled workers, low
literacy levels and limited vocational training means that most local people may not be able to getting jobs. In
addition, this new job market could drain the existing sectors of skilled capacity.
9. Relations between indigenous communities and petroleum industry.
Petroleum activities are associated with a lot of social changes that indigenous communities may not be able to
understand including how to get employment opportunities and adequate compensation for land as well as
related environmental and social impacts. The need for the sector to build trust within indigenous communities
is underscored.
10. Recreation and amenity facilities offered by the environment.
There are a lot of ecosystem values attached to environment at the moment and there is need for adequate
planning to ensure that such amenities and facilities are considered when it comes to implementation of
petroleum activities. At the same time it is a fact that local communities do not always see this value.
11. Increase of costs of living.
With the opening up of the Graben and increased demand for goods and services, cost of living is likely to
increase. Salaries will be raised for certain groups but for those not directly involved with the new sector, this
will lead to a difficult situation.
12. Large challenges for the districts to prepare for new settlements. Infrastructure.
While the Graben has been declared as a planning area, the planning of the petroleum activities is ahead of the
district plans to provide the necessary physical and social infrastructure.
13. RAP reports not followed up.
Resettlement Action Plans (RAPs) in other sectors have so far not been adequately implemented. The new
sector is expected to handle this better including grievance management and livelihood restoration.
14. Methodology for sensitization valuation to be improved.
People do not fully understand the RAP process due to lack of adequate sensitization. This leads to frustration
and refusal to accept offered valuation.
15. Disruption of existing livelihoods.
Agriculture and fisheries are the mainstay of most of the population in the Graben. The introduction of the new
petroleum sector will change their livelihood by offering jobs and opportunities moving the focus away from
existing conditions.
16. Expectation management.
Different stakeholders have different expectations from the petroleum related activities and there is need to
ensure that these expectations are managed well before any activities start.
17. Local deliveries of goods and services.
Refer to the description in Group 4.
18. Informal and traditional administrations worked before. What now?
There are informal groups/structures such as clans, traditional healers, pastoral and fishing groups having a role
in the districts today. These structures are already under threat and introduction of the new petroleum sector
could worsen this situation. In addition we have the Kingdoms with structured administrations.
19. Ownership to land required by the petroleum industry.
There is no clear system for acquiring land by oil companies from the owner. This is leading to unnecessary
disputes and misunderstanding.
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General observations from the stakeholder consultations reveal that regarding land issues to date,
land remains an important productive asset to communities within the Albertine Graben. However,
the challenges with land issues stem from the inconsistencies in the land law and rights that
individuals have over land. While titled land is the most secure form of land tenure, transaction costs
make it expensive for rural communities to gain access to this service.
Recommendations:
Local communities will experience opportunities as well as risks. The capacity to adapt to the
changing framework conditions has to be a key focus and long-term socioeconomic benefits
have to be ensured. A social development plan should therefore be developed. The scenario
analysis reveals the presence of large numbers of workforce, especially during construction
periods and points at significant in-migration. The planning of urbanization and required
associated infrastructure has to be advanced in line with petroleum development planning to
avoid social tension and lack of capacity of infrastructure.
Generally, legal framework for land administration exists. Training materials and sensitization
materials for land acquisition are available at the Ministry of Lands, Housing and Urban
Development. The ministry needs to be allocated a budget to translate information into local
languages in the Albertine Graben. Also, district land boards need to be trained.
The Land Administration Department should be more involved in issues of resettlement action
planning instead of only dealing with the office of the Chief Government Valuer.
On issues of social development, including communities coping with the growing sector, a
comprehensive development programme similar to Northern Uganda Social Action Fund or
the Nile Basin programme should be established to address issues of:
HIV/AIDS
Co-existence of agricultural systems with the oil and gas sector
Community infrastructural planning programmes including social and economic
infrastructure
Conflict resolution
Expectation management
Alternative Income Generating Activities
Education and awareness on management of social issues: The Ministry of Gender, Labor and
Social Development has all the policies and guidelines in place, but the linkage to other
sectors such as the petroleum sector should be strengthened.
On planning for growing economy, a census should be carried out in order to determine
numbers of population to serve. Furthermore, related budgets should be allocated to local
governments.
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Key Issues Group 3: Co-existence with Archaeology and Cultural Heritage
Key Issue.
Why is the Key Issue relevant?
1. Archaeology and cultural heritage.
In the recent past, there has been increased awareness on the need to integrate concerns relating to
archeology and cultural heritage. As petroleum activities are being undertaken, care has to be taken to ensure
that such sites are not affected.
2. Awareness about and coexistence with cultural heritage.
Refer to point 1.
3. Inclusion of cultural institutions in the petro strategies. Capacity building.
Recommendations:
The Historical Monuments Act should be expeditiously amended to capture specifically all
matters that concern cultural heritage in the country. This will go a long way in giving the
principle legislation a face lift matched by the rest of the world.
The sanctions and penalties enforced/ administered on transgressors and perpetual offenders
of cultural heritage property should be revised, strengthened and possibly increased.
The government should increase on the number of gazetted sites and areas of historical significance in the AG.
It is important to strengthen links and partnerships with law enforcement agencies to handle
cases of destruction of National Monuments and heritage at large. Local policing capacity
under the community leadership should be established.
It is advised that Uganda should readily adopt more International Treaties and Conventions
concerning Cultural Heritage. There are several international instruments that Uganda has
not yet ratified and transposed into national law.
An Archaeological Impact Assessment Study (AIAS) should be given priority and legal backing
by making it mandatory that all future projects to develop any land in the country should
undertake such investigations and study.
To ensure an increase of awareness and safeguard cultural heritage focus should be given to
providing relevant infrastructure.
There should be massive awareness campaigns carried out throughout the country by lead
agencies in the country and other government bodies geared at making the public aware of
the importance of their cultural heritage and appreciate it in a positive way.
Strengthening Institutions at a local level is yet another essential element. This involves
support to the local committees in terms of training for simple formal
organizational/management skills to effectively manage the different cultural heritage
objects in their locality. This includes developing their lobbying skills.
It is further recommended that the local authorities should be encouraged to establish by-
laws and regulations that would prevent the destruction cultural aspects and their
consequent preservation and management. This will reduce the reliance on the central
government to come with effective policies and laws providing for the same.
To develop management/co-ordination of institutions at a regional level. Two institutions are
recommended: a body of the community themselves and a support or service organization
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which would serve as a focal point for conservation activities and provide technical service
and research functions and advocacy.
Long-term funding for Institutions involved in the promotion, protection and conservation
should be secured.
Values placed on monuments and by local communities as well as uses and regulations should
be reconciled with other values and practices such as biological research and ecotourism.
Key Issues Group 4: Co-existence with Other Industries and Service Providers
Key Issue.
Why is the Key Issue relevant? Petroleum activities as catalyst for other service/industry development.
Normally the petroleum activities offer large opportunities for developing connected service/industry. This
development requires proper planning.
Recommendations:
The petroleum industry should be required to offer capacity building programs for existing
and potential new businesses with the aim of preparing them for delivery of goods and
services to the petroleum industry in good time before any activities take place. This is to
make the potential local companies competitive at international levels.
The Government should develop local infrastructure supporting the involvement of local
companies.
The Government should plan for extra energy resources and provide services (whether by
private Companies or public) such as sewage and storm water management for extended or
new urban centres.
The Government needs to plan for the uncommon hazardous wastes from industries such as
refineries, petrochemicals that will come in AG.
Alternative means of transport need to be developed and include railway, air transport and
water transport to make businesses competitive.
Key Issues Group 5: Co-Existence with Tourism
Key Issue.
Why is the Key Issue relevant?
Co-existence with tourism.
Tourism is currently the second highest earner of foreign exchange. It is also expected to outlive oil activities if
well managed. It should therefore not be sacrificed in the process of extracting oil.
Oil exploration and production may disturb wildlife habitats leading to reduced breeding and feeding grounds,
declining numbers/diversity and the eventual migration of wildlife to other areas or even across the border into
DRC. This has implications for
(i) the value of the park(s) to visitors;
(ii) human safety for communities in the fringes of the park(s)
(iii) returns to investment and employment in tourism sector in the areas and
(iv) the local economy if oil is extracted from this region and fruits being experienced/invested elsewhere.
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Recommendations:
There should be regulations on the maximum acceptable disturbance levels of oil and gas
activities taking the tourism sector views into consideration.
Activities in areas which are formally designated for ecosystem protection and biodiversity
conservation should be in accordance with the official protection status of the area.
The oil and gas exploiting firms must ensure minimum disturbance to the circuits, and
alternative circuits should be developed by the oil firms to replace the ones out of use due to
exploration activities.
Key Issues Group 6: Co-existence with Fisheries
Key Issue.
Why is the Key Issue relevant?
1. Co-existence with fisheries.
Petroleum activities focusing relatively short term benefits, could threaten fishery resources, which are
inherently renewable if sustainably exploited.
2. Fish prices high due to competition on salaries.
Petroleum activities lead to increased demand for fish resulting into higher fish prices which are not affordable
by local people. This situation could be positive for the fishermen.
Recommendations:
Develop regulatory frameworks to operationalize the Fisheries Policy (2004).
Develop plans and programs to:
map critical breeding, nursery and feeding grounds for major commercial fish species;
identify year class recruitment strategies; and model population dynamics of major
commercial fish species for management purposes,
track and mitigate impacts of pollution from petroleum activities on the aquatic
environment and fisheries;
map the hydrodynamics of major lakes in the AG for input into the oil spill contingency
plan;
promote sustainable aquaculture and other viable non-capture fisheries in the AG as a
relief measure to fishing pressure on lake fisheries.
Develop and operationalize an effective oil spill contingency plan for the AG.
Strengthen strategies and plans for water resources assessment, monitoring and allocation to
multiple uses with particular focus protecting sensitive aquatic ecosystems in the AG.
Strengthen the multi-institutional approach to fisheries administration and management,
setting clear mandates and modes of interaction and coordination amongst the key
institutional actors namely the Centre (DFR), District Local Governments and community
representatives for example BMUs.
Formalize and strengthen inter district dialogue, coordination and collaboration to enhance
management and development of fisheries and other natural resources in the AG.
Address international Transboundary challenges to fisheries management in AG lakes.
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Key Issues Group 7: Sharing of Revenues and Wellbeing between the National and the Local /
Regional level. Co-operation
Key Issue.
Why is the Key Issue relevant?
1. Revenues to the benefit of local communities and future generations.
Benefit sharing has been one of the instruments used in managing some of the public natural resources where
law enforcement is costly for government (forests, national parks, etc). The aim is to reduce illicit activities
(poaching, deforestation) and to build local stewardship for the resources.
2. Lack of collaboration between local and central government. Also influencing budgets.
For the Petroleum sector, Sharing of revenues here is proposed as means of reducing the discontent that is
likely to develop if oil is extracted from this region and fruits being experienced/invested elsewhere. Situations
of rioting, perhaps destruction of oil infrastructure can be avoided if the communities in the areas where
extraction is taking place realize “a fair share of the cake”.
Recommendations:
Develop a flexible revenue sharing mechanism, taking into account not only the size of the
petroleum production and population size, but the impacts of the oil activities on the
alternative sources of income for the districts.
There is need for a discussion with the stakeholder districts to explain to them why the
proposed percent is the ideal share.
Revenue shares should be inflation adjusted (indexing) to reduce the risk of loss of the real
value of the funds.
Give districts the autonomy to spend the money on priority projects with the central
Government playing a supervisory role.
Advise district planning authorities on investment in projects in which both the current and
future generations will benefit from.
Revise revenue share incomes so as to minimize the value loss due to inflation.
Ensure that the oil revenue based funding/support to the districts will be sustained in the
period after the oil extraction era.
Key Issues Group 8: Discharges and Emissions from the Petroleum Industry
Key Issue.
Why is the Key Issue relevant? Air emission, and risk of soil and groundwater pollution
Petroleum activities by nature create emission to air as well as liquid and solid discharges. Activities throughout
the petroleum value chain (from exploration, appraisal, production, construction activities, transportation of
produced crude/gas as well as goods and manpower, refining, etc.) cannot be undertaken without emissions
and discharges.
Activities are planned to take place on land and offshore (lakes). Within each phase there are extensive
impacts, especially in areas with sensitive ecosystems and these impacts need to be understood, mitigated and
monitored.
Refineries are complex systems of multiple linked operations. The involved operations depend on the crude
refined and the range of refinery products. Refinery age, location, size, variability of crude and product slates
and complexity of operations all influence on operating configurations and different air emission point counts.
This results in differences in quantities of air pollutants and the selection of appropriate emission management
approaches.
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Air emissions of a refinery include fugitive and volatile organic components and combustion products. Primary
hydrocarbon emissions from piping systems fugitive leaks, product loading, storage tanks and wastewater
collection and treatment. Combustion emissions come largely from heating process streams, chemical reaction
promotion, steam provision and power generation.
Recommendations:
As the Albertine Graben is of national and international importance in terms of its outstanding
biodiversity and network of protected areas, special care has to be taken with respect to
emissions and discharges, incl. potential related pollution.
The area is relatively sparsely populated by indigenous pastoral communities but there are also
several urban centers in the wider region. It is highly likely that the population numbers and
distribution will change rapidly with the petroleum developments.
To safeguard the ecosystems and their value to people, the following is recommended regarding
pollution prevention:
Develop air, noise, vibration and discharge regulations incl. average thresholds and peak
limits over periods of time in line with international standards. Special limits shall be
considered for protected and sensitive areas. Occupational health exposure limits shall be
defined and monitored.
Develop national benchmarks/ threshold limits of defined pollutants using established land
use zoning categories (residential, agricultural, industrial, etc.) to safeguard environmental
quality and public health.
Specific recommendation regarding air emissions are:
Development of national air quality standards to protect public health and
environmental quality. Standards may be concentration limit values for specific
averaging periods or number of times a limit value is exceeded.
Long-term analysis of ambient air quality shall be undertaken by the authorities using
suitable parameters including dust to provide a baseline for later air quality
modeling.
Air emission dispersion modeling shall be undertaken for the refinery and IPP to
understand the local meteorology and dispersion factors.
Facilities shall be designed and built based on BAT and BEP. Well established
commercially available control equipment, designs, principles or practices that are
technically and economically applicable, shall be used.
The EIA of a facility (IPP, refinery, etc.) shall include a full emission inventory and a
plan for regular measurements of key pollutants to be reported to the relevant
authorities.
Auditing personnel shall be fully trained for performing their task. A buddy system of
authority personnel and senior specialist might be most beneficial in the early
phases for training and consistency purposes.
Emission reduction measures shall consider:
Specific emission control equipment for emission reduction shall be implemented (leak
detection and repair program, low emission type valves and pump seals, leakless
technology, etc.).
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Storage tank design shall consider emission reduction in line with stored product
characteristics (fixed vs. floating roof tank types, vapor recovery, etc.).
As loading to rail cars, tank trucks, etc. is a large source of fugitive air emissions,
vapor control has to be considered (submerged or bottom loading, vapor balance
systems, vapor recovery, etc.).
Fugitive air emissions from refinery waste water shall be controlled (minimize waste
water generation, reduce hydrocarbons entering waste water system, reduce
air/water interface area, heat exchanger leak detection program, etc.).
Reduce process vent emissions (e.g. recycle and reuse discharged material, vapor
recovery) for the refinery.
Prefer flaring over venting where feasible.
Implement refinery flare minimization plan as part of the overall EMS and consider
flare gas recovery.
Reduce fuel consumption by applying energy efficiency conservation measures.
Consider co-generation opportunities.
Combustion processes shall be controlled to minimize emission of Sox, NOx and
particulate matter.
Key Issues Group 9: Waste Management
Key Issue.
Why is the Key Issue relevant?
1. Management of pollution and waste
Compared to common industrial development, Petroleum activities are known to have the potential to pollute
the environment (land and water resources) and wastes from petroleum activities require skilled and controlled
management. There are no adequate waste facilities in the region today.
Some wastes from petroleum activities are categorized as hazardous requiring special/ unique treatment and
disposal.
For the first time in Uganda, petroleum activities are taking place in the lake and have to be considered in terms
of pollution and waste management.
2. Waste management. Regulations and guidelines missing.
Existing waste management regulations and guidelines do not cover the new petroleum sector activities.
3. Identifying and regulating transporters and waste facility operators.
Systematic selection of waste transporters and waste facility operators do not exist for the new petroleum
sector activities. In addition the required regulations/guidelines, expertise and capital investments are not
locally in place.
4. Transportation of waste. No control.
The existing regulations for waste transportation are not adequate for the new petroleum sector activities
petroleum activities. In addition there are no regulations/guidelines on what kind of equipment is applicable.
Recommendations:
Strengthen existing waste management regulations to cover aspects of the new petroleum
sector and make new guidelines. Potential transboundary issues need to be handled.
Strengthen existing regulations related to transportation of wastes and make new guidelines
for transporters and waste facility operators.
Adequate infrastructure to handle the new petroleum generated waste needs to be developed
prior to further activities in the region.
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To avoid conflict of interest oil companies (producers of waste) should not act as waste
handlers or waste management companies. Independent third party companies regulated by
NEMA should undertake the waste management.
Key Issues Group 10: Water Management
Key Issue.
Why is the Key Issue relevant? 1. Pollution of surface waters and aquifers. Water management.
Surface water and groundwater is to a large extent consumed untreated by the local communities. Waste,
emissions, discharges and potential oil spills from petroleum activities on the lakes/rivers and on land could
therefore have serious pollution impacts on the water resources and the ecosystem. This is also a
transboundary issue of high importance.
2. Freshwater management.
There will be definite increase in water demand for domestic and industrial purposes. Water allocation for
different uses will therefore be a big challenge.
3. Need monitoring plan on district level for water resources.
There is already a monitoring plan in place for the different resources in AG which is new and yet to be
implemented. Baseline data on water resources is not fully available making proper monitoring difficult.
Recommendations:
Review of the National Water Policy, Act and associated abstraction, use and discharge
regulations to incorporate standards relating to oil and gas activities.
Re-equip the National water quality laboratory in Entebbe to ensure oil and gas testing
capability.
Capacity building for relevant staff to handle the oil and gas issues.
Provision of equipment for water quality and quantity monitoring.
Need for improving on staffing.
Capacity building for monitoring oil related parameters.
The mandate of the water officer should clearly include water for domestic, institutional and
industrial use and not domestic & institutional only.
Create a central database, regularly updated, for information accessible to central and local
governments.
There is need to review and integrate petroleum development related water resource issues in
the annual local government rural water and sanitation workplan in the districts of the AG .
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Key Issues Group 11: Oil Spill Preparedness on Land and in Surface Waters
Key Issue.
Why is the Key Issue relevant?
1. Oil spill contingency planning, on land and surface waters.
The current management of oil spills on land and on surface waters in the country is inadequate. With
significant increase in petroleum activities in AG, professional handling of this issue is extremely important, not
only for Uganda, but also in an international context specifically related to the river Nile and the lakes in the
region. The Scenario Analysis is clearly concluding that there will be tremendous increase of road traffic
specifically truck transportation of oil leading to extensive risk of oil pollution on land.
2. Knowledge about movement of spilled oil
There are no operational oil spill models available in Uganda today. Oil spill models are normally based on
meteorological data, knowledge about oil characteristics, understanding of oil movement and behavior in
different media on land and in surface waters etc. Such input data is not fully available today.
3. Existence of necessary public infrastructure to meet the petro development.
The existing public infrastructure is in general not adequate for the current state of the Uganda Economy. This
infrastructure (roads, harbors, railways, water supply etc) is vital for oil spill contingency response in addition to
specific oil spill contingency infrastructure such as oil spill contingency equipment, storage facilities etc.
Recommendations:
A functioning NOSCP has to be in place including resources and equipment being available,
personnel fully trained and communication lines tested and fully functioning prior to large
scale development activities.
In case relevant input data for the environmental risk assessment, oil spill contingency
analysis and subsequent NOSCP is missing, these gaps shall be filled as soon as possible.
This plan should be coordinated with public infrastructure development plans and should be
the basis for provision of specific oil spill response equipment, training needs, etc.
There is a need to coordinate efforts between the NOSCP and establishing waste
management procedures/facilities and the development of new public infrastructure.
All relevant stakeholders need to be involved in developing the oil spill contingency plan
among which are:
Fire brigade of Uganda Police,
Department of Disaster preparedness in OPM,
Uganda Peoples Defense Forces (UPDF).
Key Issues Group 12: Infrastructure Development in the Region and Transportation of Crude,
Products and Construction Materials
Key Issue.
Why is the Key Issue relevant? 1. Infrastructure needs.
Key observations from the Scenario Analysis for the Graben (carried out by the SEA Team) suggest that there is
need to develop petroleum related infrastructure to meet the needs of the sector. For example it is expected
that trucking of oil from Extended Well Testing (EWT) to consumers and also trucking of oil from Central
Processing Facility (CPF-1) in phase 1 will increase transportation needs tremendously.
2. Existence of necessary public infrastructure to meet the petro development.
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Refer to point 1.
3. Transportation systems. Infrastructure.
Existing transportation system (roads, airways, railways, water transport) is very inadequate and was not
designed with petroleum activities in mind. Transportation of oil related goods requires adequate
infrastructure. There are also high chances of environment degradation e.g. due to spills and opening up new
areas to construct additional transportation infrastructure. According to the Scenario Analysis, the road
transportation of oil, pipes, building material etc will be extensive.
4. Transportation of crude and materials.
Refer to point 3.
Recommendations:
Cooperation of the petroleum sector and the Ministry of Works and Transport, UNRA and
local governments should be strengthened to ensure that the needs of the petroleum sector
are integrated in the overall infrastructure planning and budgeting. UWA should be involved
in the planning to ensure concerns regarding protected areas and sensitive habitats are
considered.
Alternative transportation means should be developed and include railway, air and water
transport.
All infrastructure associated with oil and gas development should be subject to integrated
ESIA.
Key Issues Group 13: Institutional Capacity Building. Structure and Functions
Key Issue.
Why is the Key Issue relevant?
1. Institutional capacity regarding petro sector.
The petroleum industry in Uganda is relatively young and the institutional framework is not yet fully
established.
2. Inadequate local capacity to review oil and gas EIAs and do audits.
The oil and gas industry is attracting various developments that require EIA and environmental audits. However
there is limited capacity amongst the regulators to review EIAs, make audits and monitor performance of oil
and gas projects.
3. Capacity building for national and local governments.
Reference is made to no.1.
Recommendations:
Effort shall be made to train NEMA staff and other relevant supervisory agency staff to scrutinize and review EIAs related to the petroleum sector.
Both, new institutions to be established and existing ones require awareness, training and infrastructure for handling their mandate in managing the petroleum industry.
Establish a panel of experts on rational basis who should be appointed periodically to review EIS of the Oil and Gas sector.
Increase the capacity of line ministries and lead agencies to review EIAs on oil & gas .
Ensure capacity and adequately staff and budget ministries that regulate the petroleum sector, such as Ministry of Tourism, Wildlife and Antiquities; NEMA; MEMD; Ministry of Finance and Planning; Ministry of Justice; Labour; Education; etc .
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A framework of monitoring of oil and gas activities as provided for in the National Oil & Gas policy should be done. Thereafter monitoring protocols to be developed.
More independent environment inspectors should be appointed by NEMA to effectively inspect the Oil & Gas activities to be effectively managing the environment.
A thorough stakeholder engagement process should be part of the EIA in line with international best practice such as IFC.
Capacity building shall include CBOs and other civil organizations.
Key Issues Group 14: Capacity of District Local Governments to Manage Environmental Concerns
Key Issue.
Why is the Key Issue relevant?
1. Strengthen environmental concerns at district level. Awareness building.
District officers should carry out planning, day-to-day monitoring of the environment and build environmental
awareness. They are unfortunately often not informed of ongoing activities and also not well equipped
(technically) to carry out the monitoring. The introduction of the new petroleum sector will make this situation
worse.
2. Lack of adequate baseline data is restricting effective monitoring. Only compliance monitoring done today.
Existing environmental data is mainly for protected area and some of it does not have full coverage of the areas
of interest. It will therefore be impossible to know when a resource had been degraded. The districts do not
have access to all relevant existing environmental baseline data relevant for the petroleum sector.
3. Need inter district cooperation on water management.
The Albert Water Management Zone was established one year ago with the intention to manage water
resources including the AG. The districts are not yet actively taking part in this management structure.
4. District budgets on environmental management.
There are inadequate district budgets for environment management, which limits implementation of
environment plans.
5. Understaffing at district level.
Although the districts have an organizational structure, many positions are vacant. The limited available staff
lacks capacity to effectively perform the full range of duties. This results in inadequate management and
monitoring of the resources. The introduction of the petroleum industry will make this even more challenging.
6. District officers are overlooked by the petro industry.
Petroleum industry receives most of their instructions from the central government. The central government
does not keep the district administrations up-to-date on what instructions have been given out. So the industry
acts independent of districts yet the districts are mandated to monitor activities carried out in their districts.
Recommendations:
Environmental managment should be given high priority when preparing district budgets.
More skilled personnel should also be recruited at the districts to fill vacant posts in the
environment and natural resources fields. A specific program should be developed and
implemented for capacity building on environmental management related to the oil and gas
sector in the AG.
Both, new institutions to be established and existing ones, require awareness, training and
infrastructure for handling their mandate in the industry. This can be achieved by
strengthening cooperation between the petroleum industry, PEPD and local governments
(districts).
There is need for improved coordination between the districts and the relevant central
Government departments and the information flow channels should be clearly outlined and
followed.
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Environmental and socio-economic data available at central Government departments and
agencies should be available to the districts. Extra data should be collected to fill any gaps.
The district officers need to be actively involved in the planning process so that they know
what to monitor. What is planned for would also be used as justification for a more realistic
budget.
The district local government should be actively involved in the activities of the Albert Water
Management Zone.
There is need for improved coordination between the districts and the relevant central
Government departments and the information flow channels should be clearly outlined and
followed.
More district officers need to be given opportunity to train in aspects of the petroleum industry
that are relevant to their fields of operation.
Operationalize the communication strategy of oil/gas to avail information to the district.
Key Issues Group 15: Development of Legislation and Regulations. Standards
Key Issue.
Why is the Key Issue relevant? 1. Transfer of EIA when operatorship change
Each company has their own understanding of baseline conditions in the actual area. They have their company
specific experience and they have their individual standards when it comes to environmental management.
Taking over an EIA which is not yet approved should trigger an update under the responsibility of the new
operator.
2. EIAs are too generic. Standard controls are used more than specific mitigation measures.
EIAs are project and location specific addressing impacts on the ecosystems in the area of influence. EIAs which
are too generic do not cover the relevant concerns in each case.
3. Policy guidance and legal safeguard for the petro industry missing.
Most of the relevant laws and regulations were put in place prior to exploration and production of oil and gas in
Uganda. Therefore there is lack of specific guidance to the new oil and gas sector.
Recommendations:
More focus should be on waste specific to oil and gas in terms of generation , treatment and disposal.
There is a need to review the existing EIA regulations and develop sector specific standards
and guidelines for the petroleum sector.
Assess whether the existing laws and regulations are punitive enough.
Develop regulations on occupational health and safety for the oil and gas sector.
Classification of wetlands needs to be reviewed to enable regulations.
To strengthen the competence among the environmental practitioners connected to the new oil and gas sector, there is a need to review and update the existing regulations for this expert group.
Develop legislation and guidelines for ocuupational health and safety of workers.
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Key Issues Group 16: Land Use and Spatial Planning
Key Issue.
Why is the Key Issue relevant?
1. Land use and Physical/spatial planning.
In addition to the oil and gas exploration and production infrastructure in the Albertine Graben, the region is
expected to experience increased social economic infrastructure and settlements, conservation and related
activities such as research and tourism. Spatial planning is, therefore, considered to be of key importance to
allow for co-existence with existing activities and agriculture. There are issues of tenure, compensation
schemes, displacement and resettlement, which are acerbated by lack of proper demarcation and or titling of
the communal lands. Challenges to public regulation of land are evident, including the formal/statutory and
informal/customary system of land administration as well as an efficient land registry system.
The Ministry of Lands, Housing and Urban Development is commissioning a Physical development Plan for the
AG region but the process is overdue considering the pace in the growth and dynamics of the oil and gas sector.
This calls for expeditious process for development and implementation of the planned physical development
plan. Considering that the AG hosts vulnerable biodiversity resources and is an internationally recognized
biodiversity hotspot, the planning process should apply an ecological approach to spatial land use planning.
2. Need for urbanization policy.
The population in the Albertine Graben has been relatively low and urbanization low due to the hot and dry
conditions on one hand and on the other hand, accessibility challenges posed by the rift landscape. However,
the increasing oil and gas activities are bound to increase population and settlements, leading to unplanned
expansion of the existing fishing villages and the towns. Urbanization is also taking place along the road system
in the region. This process is likely to intensify due to oil production activities in the region. The growing
urbanization will pose new environmental changes if it is not well planned. Yet, there is limited policy guidance
for urbanization despite general reference to minerals and petroleum in the Uganda National Land Policy.
Recommendations:
Ministry of Lands, Housing and Urban Development shall expedite the process for the
development of the AG regional physical development plans with emphasis on ecological land
use planning to cater for the various sensitive areas.
Ministry of Lands, Housing and Urban Development needs to urgently initiate development of
the Urbanization Policy as recommended in the National Land Policy in order to provide
sufficient guidance for the comprehensive orderly planning and sustainable development in
the AG.
Key Issues Group 17: Transboundary and International Issues
Key Issue.
Why is the Key Issue relevant? 1. Conflicts with international environmental agreements.
Uganda has signed several international and regional international conventions/treaties of relevance to the
petroleum development in the Graben such as the United Nations convention on biological diversity (1992), the
Ramsar convention (1971), the convention concerning the protection of world cultural and natural heritage
(1972), the convention on migratory species (1979), the African convention on the conservation of nature and
natural resources and the convention on the protection and use of trans-boundary water courses and
international lakes. The development plans for the petroleum resources in Murchison Falls National Park is an
example which needs to be considered in this context. The new sector may lead to serious violation of these
conventions/treaties.
2. Security Issues and regional emergency response.
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A number of attacks are threatening the borders to DRC. This instability is increasing due to petroleum
discoveries in the rift on both sides of lake Albert where most of the oil has been discovered. The border cuts
straight through the lake.
Security is also an internal problem in Uganda due to for example the complex land disputes related to the
petroleum industry with complaints about none transparent processes and insufficient compensation leading to
instability, public anger and riots.
Recommendations:
Security planning shall include consideration of the roles and responsibilities of the police,
military and private security companies. Security of local communities as well as economic
activities shall be the key focus. Planning shall be based on transparency and dialogue with
the relevant stakeholders.
Any plans and activities which could be in conflict with international conventions/treaties,
need to be assessed by the Government with the view of identifying potential breach of the
agreements and possible consequences.
Transboundary challenges related to fisheries management and oil spill contingency planning in AG lakes shall be addressed.
The government plans of mapping and demarcating of the border as per 1956 between Uganda and DRC should be fast tracked.
Key Issues Group 18: Establishment of Transparent Baseline Data. Scientific Basis
Key Issue.
Why is the Key Issue relevant?
1. Strong scientific basis for decisions.
While environmental assessments (such as EIAs) form the basis for approval of projects or activities deemed
likely to have significant impacts on the environment, baseline data are not always adequately verified in terms
of transparency and scientific methods used.
2. Focus on trend analysis as to baseline conditions.
Changes in baseline conditions over time are inevitable. Using static baseline information will lead to biased
environmental and socio-economic assessments.
Recommendations:
Set appropriate qualifications plus regular awareness refresher instruction on environmental
assessment practitioners and EIS reviewers.
Provide for independent verification of environmental baseline data for transparency and
conformity to scientific methodology; and periodic updates to establish adequacy of baseline
information. The establishment of a “Clearing House” for baseline data should be initiated.
Require appropriate capacity building of relevant technical staff at District local Governments
in the AG to enable them meet the challanges of environmental assessment and monitoring
with particular reference to oil and gas exploration, development and production.
The existing Environmental Information Network (EIN) needs better support and more
publicizing to ensure that acquired data is adequately stored and accessible to the public.
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6 ASSESSMENT OF STRATEGIC ASPECTS RELATED TO
PETROLEUM ACTIVITIES
This chapter comprises an assessment of strategic aspects related to future petroleum activities.
The assessment is an in depth discussion of some of the most challenging high level strategic aspects
which are:
Petroleum activities in environmentally sensitive and protected areas
Co-existence with other sectors and local communities
- fisheries
- tourism
- local communities (social issues, economic issues including benefit creation and land use,
livelihoods and compensation
- cultural heritage
Institutional framework and capacity
- environmental management on a national level
- coordination between governmental agencies and district/local level
- capacity building
Management of pollution and waste
- oil spill contingency planning
- drilling waste and produced water
The assessment is based on three development scenarios, namely:
Scenario 1, a development combining construction and operation of a refinery with
associated power plant and an export pipeline transporting crude oil to markets outside
Uganda. This Scenario was used as basis for identifying Key Issues and has already been
described in Chapter 2.2 and Appendix 3. It should be noted that Phase 1 Scenario – Phase 4
Scenario are describing four phases of Scenario 1 as explained in Appendix 3.
Scenario 2 with construction and operation of a refinery and a power plant with no export of
crude oil.
Scenario 3 with the export of crude oil to markets outside Uganda. This involves the
construction and operation of an export pipeline (Option a) or construction and operation of
a railway system for transportation of crude (Option b) to Mombasa. A small power plant is
also constructed and operated to produce electricity for the public grid.
While Scenario 1 is already described in detail in the Scenario Analysis in Chapter 2.2 and Appendix 3,
Appendix 8 provides an overall description of Scenario 2 and 3.
The assessment of the scenarios is carried out with a focus on these concerns:
Pacing and siting of infrastructure /activities
Cumulative effects
Choice of technology
Mitigation measures
Emergency response and security
Infrastructure needs
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6.1 Description of the development scenarios
Discussions are ongoing regarding which developments are reaching the objectives of the National
Oil and Gas Policy in the best way and are most favorable for Uganda. The three scenarios have
therefore been developed to paint a picture of the potential future situation in the country when
exploiting the petroleum resources in place. The assessment of potential benefits and impacts of
each scenario allows identification of key differences between the scenarios and a high level
comparison.
All scenarios are divided into four phases over a timeline from today to 2030. The phases are:
Phase 1 from today to end 2015
Phase 2 from end 2015 to end 2017
Phase 3 from end 2017 to end 2022
Phase 4 from end 2022 to 2030
It is worth noting that the activities in the oil and gas fields are assumed to be similar for all three
scenarios which all require the oil and gas fields to be developed to either feed the refinery or to be
exported, or both.
Appendix 8 provides a short description of the field activities, an overall description of Scenario 2 and
3, and a high level qualitative assessment of selected indicators for the three scenarios during the
specific phases. These indicators represent the most relevant aspects considered in the SEA. At this
strategic level of planning a more detailed analysis would not add value.
The scenario matrix below presents a summary of the activities for each scenario during the four
phases and reflects the differences between the scenarios based on the more detailed evaluations
made in Appendix 8. The selected indicators are, among others, basis for the assessment of risks and
opportunities for the scenarios in Chapters 6.2 to 6.5.
It should be noted that the scores within each selected indicator is reflecting the outcome of the
evaluations as an average for the specific scenario over the four phases. The scores are only
indicating the differences between the scenarios within each selected indicator.
The production levels stated in the following figure refer to Appendix 3 (Scenario Analysis) and
Appendix 8 (Description of Scenario 2 and 3).
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Four color shades of red (highest to lowest) are used to visualize the outcome of the evaluations.
Highest Lowest
Scenario 1 Refinery and export pipeline
Scenario 2 Refinery only
Scenario 3a Export pipeline
Scenario 3b Railway export
Development phases Phase 1 (2013-2015) - Infield infrastructure
- 3D seismic in National Park - Integrated Power Plant (IPP) - Oil trucking from EWT - Building of construction/supply bases - Road construction - Refinery construction - Trucking of material/pipes/modules
- Infield infrastructure - 3D seismic in National Park - IPP - Oil trucking from EWT - Bases - Road construction - Refinery construction - Trucking of material etc
- Infield infrastructure - 3D seismic in National Park - IPP - Oil trucking from EWT - Bases - Road construction
- Infield infrastructure - 3D seismic in National Park - IPP - Oil trucking from EWT - Bases - Road construction
Phase 2 (2015-2017) - Infield infrastructure - IPP - Extension of bases - Trucking of oil from EWT - Refinery 20.000 bbls/d - Refinery extension - Trucking of products from refinery - Trucking of material etc
- Infield infrastructure - IPP extension - Extension of bases - Trucking of oil - Refinery 20.000 bbls/d - Refinery extension - Trucking of products - Trucking of material etc
- Infield infrastructure - IPP - Extension of bases - Trucking of oil from EWT - Trucking of oil produced, 20.000 bbls/d
- Construction of export pipeline - Trucking of material etc
- Infield infrastructure - IPP - Extension of bases - Trucking of oil from EWT - Trucking of oil produced, 20.000 bbls/d - Construction of railway - Trucking of material etc.
Phase 3 (2017-2022) - Infield infrastructure - IPP - Construction of product pipeline and gas pipeline - Trucking of material etc - Refinery 60.000 bbls/d - Refinery extension - Construction of oil export pipeline - Rehab./construction of railway
- Infield infrastructure - IPP - Refinery 60.000 bbls/d - Refinery extension - Trucking of material etc - Extension oil pipeline to refinery - Construction of product pipeline and gas pipeline
- Infield infrastructure - IPP - Construction of gas fired power plant and LPG plant
- Export of oil in pipeline - Construction of gas pipeline - Trucking of material etc
- Infield infrastructure - IPP - Construction of gas fired power plant and LPG plant - Export of oil on railway - Construction of gas pipeline - Trucking of material etc
Phase 4 (2022-2030) - Infield infrastructure - Large IPP - Construction/operation of gas fired power plant and LPG plant - Refinery 120.000 bbls/d - Export pipeline 180.000 bbls/d - Pipeline transport of products and gas - Petrochemical industry - Uganda hub
- Infield infrastructure - IPP - Construction/operation of gas fired power plant and LPG plant - Refinery 300.000 bbls/d - Pipeline transport of products and gas - Petrochemical industry - Uganda hub
- Infield infrastructure - IPP - Operation of gas fired power plant and LPG plant
- Export of oil in pipeline, 300.000 bbls/d
- Pipeline transport of gas towards Kampala
- Uganda hub
- Infield infrastructure - IPP - Operation of gas fired power plant and LPG plant - Export of oil on railway, 300.000 bbls/d - Pipeline transport of gas towards Kampala - Uganda hub
Selected indicators Disturbance of sensitive and protected areas
- refinery/pipelines/railroad High/medium Medium M edium/low Medium
- petroleum field activities High High High High
Conversion of land
Waste volumes
Workforce presence - construction High/medium High Medium Medium
- operations Medium/high Medium/high Low Medium/low
Pressure on local communities
Creation of benefits and jobs
- benefits x x x x
- skilled workforce High/medium High/medium Medium/low Medium/low
- unskilled workforce High/medium High Medium/low Medium
Road usage and trucking of:
- goods/equipment High/medium High Medium Medium
- refinery products Medium/low Medium/low NA NA
- oil from EWT Medium Medium Medium Medium
Risk of accidents - construction High/medium High Medium Medium
- operations Medium Medium Low Medium/low
Institutional capacity needs
Figure 6.1: Scenario matrix
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These are the main differences for the three development scenarios during the four phases:
Phase 1
High level construction activities for Scenario 1 and 2 create similar levels of positive and negative
effects. Effects related to Scenario 3, both negative and positive, are a bit lower as the large scale
construction activities of the transportation infrastructure (tank farm and pipeline or railway) start
only in the next phase. Nevertheless, some construction is similar for all four scenarios, e.g. CPFs,
gathering lines, roads, supply bases, etc.
Phase 2
The high level of construction activities requires a large construction workforce present in the region
for all Scenarios. For Scenario 3 the pressure on local communities besides the oil field activities is
more temporary and transitional due to the linear construction spreads for the pipeline or railway
moving onwards. The disturbance of protected and sensitive areas is also high for all scenarios as oil
field activities are ongoing and construction takes place.
Phase 3
Large scale construction activities are ongoing for Scenario 1 and 2 to expand the refinery. However,
construction is also ongoing for both Scenario 3 options due to the construction of the gas fired
power plant and the LPG plant. The trucking is reduced for Scenario 3, especially regarding petroleum
products. Also the disturbance of protected and sensitive areas is reduced for Scenario 3, especially
for the export pipeline option as the pipeline corridor has been reinstated and habitat fragmentation
is therefore limited. On the other hand, workforce opportunities for skilled and unskilled labor are
also lower.
The risk for accidents during operations is low for the export pipeline, medium for the railway due to
the higher risk of human error and sabotage and high for Scenario 1 and 2 for the same reasons. Also
the pressure on local communities is lower for Scenario 3, largely because the linear infrastructure of
railway or pipeline requires a more temporary presence of workforce.
Phase 4
Construction activities have been finalized for Scenario 1 and 3 while extension of the refinery is
under construction for Scenario 2. The construction workforce and presence in the area is thus
reduced for Scenario 1 and 3. The need for operational workforce is lower for Scenario 3 than for the
other Scenarios, both skilled and unskilled. The need for trucking is on low levels for Scenario 3, while
Scenario 2 is still having higher requirements for road usage.
The risk for accidental events during operations is significantly higher for Scenario 1 and 2 than
Scenario 3. This is due to the refinery installations being prone to third party interference or human
errors while the pipeline is buried, requiring low maintenance and having a lower risk for sabotage.
The risk for the railway option is higher than for the pipeline option as railway is prone to third party
interference or human error during operations.
The overall socio-economic benefits will be higher for Scenario 1 and 2 than for Scenario 3 if
managed well. However, Scenario 3 will have lower environmental effects due to less industrial
activity in the area.
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6.2 Petroleum Activities in Environmentally Sensitive and
Protected Areas
It is the responsibility of the Government of Uganda to formally designate areas for ecosystem
protection and biodiversity conservation and to avoid activities that compromise their ecological
integrity. The Government shall also regulate activities in environmentally sensitive areas in general
to secure their biological value. The petroleum companies shall on their side develop appropriate
responses and systems to manage their business activities in areas of high environmental value
according to regulations, international best practice and company standards. If the Government
decides to open up for petroleum activities in highly sensitive hotspot areas, both parties have a clear
responsibility of doing whatever possible to minimize the impacts on the environment.
Petroleum activities in the Albertine Graben may result in negative primary and secondary impacts
on environmentally sensitive and protected areas.
Primary impacts are normally directly connected to the area of influence of a project/activity and can
often be mitigated when projects incorporate sound operational management and biodiversity
conservation practices from the earliest stages of project development.
Secondary impacts do usually not result directly from project activities but are the result of the
project presence. Such impacts may reach outside project or license boundaries and are not limited
to a project’s life cycle. Secondary impacts may often result from high level (government/district)
decisions and the actions of nearby communities in response to a project’s presence, rather than
from the operational decisions and activities of project connected people. It is therefore often
difficult to identify the origin of such impacts.
Secondary impacts are often caused by human population changes in an area and new/additional
activities resulting from project development such as roads, settlements, harbors and power
generation. Petroleum development in Albertine Graben will attract people who hope to get jobs or
to use the business opportunities created by the project’s need for goods and services. This in-
migration is encouraged by local or national governments, making secondary impacts a particularly
sensitive political issue. Due to the character of the secondary impacts, the petroleum industry is not
always in a position to control or influence these.
Typical onshore/waterway impacts related to petroleum activities in environmentally sensitive and
protected areas similar to those in the Albertine Graben are presented in Appendix 9. The most
significant impacts are related to onshore seismic activities, land take and presence in general,
construction of roads and pipelines, traffic, produced water, oil spills and secondary impacts related
to in-migration.
When it comes to primary and secondary impacts from operations in the environmental sensitive
parts of the lakes, these are mainly related to seismic surveys, drilling operations, installation of
platforms/artificial islands, pipeline laying, operations and supply activities. Typical aspects and
possible impacts are:
Acoustic disturbances of marine organisms
Damage and fragmentation to habitats from anchoring, maneuvering vessels and
construction/presence of infrastructure
Short-term, local disturbances to marine organisms from noise and vibrations
Short-term disturbance to wildlife from emissions, noise and light
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Local damage to flora and fauna
Damage on ecosystems from waste, produced water and spilt oil
Adverse impacts on habitats outside of project area from siltation caused by operations
Increased pressure on fishing by none fishermen
Although avoiding, minimizing and mitigating the negative impacts should be the priorities when
environmentally sensitive and protected areas are influenced by petroleum activities, companies
might take the opportunity to benefit biodiversity in and around project sites. Offsetting of residual
impacts is also an alternative action.
The condition of the environmentally sensitive and protected areas has a direct influence on the
tourism industry which is the second highest earner of foreign exchange in Uganda. Petroleum
activities in such areas are therefore directly influencing on the success of developing Uganda as an
eco-tourism major player in East-Africa. This sensitive co-existence between two major sectors is
demanding strong leadership from both parties supported by governmental pro-active management.
The infrastructure associated with petroleum activities may have various negative impacts on
tourism if not well managed. Such impacts could, for example be an increase in the number of roads
and vehicles in the area, which could lead to increased road kills of wildlife, the infrastructure at the
drilling sites and the associated lights may scare away wildlife while at the same time reducing the
aesthetic value of the protected area. The construction of petroleum associated infrastructure also
often increases fragmentation of the landscape, which may cause animals to move away from the
known good viewing sights. A combination of such impacts may contribute to reduction in revenue
derived from tourism.
6.2.1 Assessment of risks and opportunities for current and future petroleum activities
Opportunities
Petroleum activities are associated with a variety of developments. Many of these, in addition to
serving the petroleum industry, create new opportunities of development of the area where the
petroleum activities are taking place. Some of the major developments that are likely to be beneficial
are listed below:
The different stages in the petroleum industry development will require high numbers of
both skilled and unskilled labor. Some of this labor may be sourced from the region. This may
reduce the extractive pressure the local communities exert on resources from the protected
areas. It will also provide an alternative source of income other than depending on the
natural resources extraction. It may also reduce the level of conflict over resource extraction
between the local communities and the protected area management.
Infrastructure: This includes roads, markets and housing. With better roads, access to the
area will be improved. This may enable local communities to access markets to sell their
goods and also get resources that do not exist in the area. The roads may also provide the
protected area managers better coverage of monitoring activities.
The local communities will have a wider market for their produce because of the increased
population in the area resulting from the high number of workers recruited by the industry.
Organized communities will be able to boost their production potential e.g. through growing
crops that will be on demand other than depending on the limited natural resources like fish.
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With the population increase and good road infrastructure, various service providers e.g.
accommodation (hotels and housing estate companies), transport sector, the health sector
and supplies sector (bigger shops and supermarkets) will extend their services to the region.
Future enhancement of protected area value due to good restoration and support to
protected area management. After the establishment of the oil wells and connecting
infrastructure, areas will be restored. Enforcement of the mitigation and restoration plans,
improved protection from poachers and management lessons learned throughout the high
activity period will provide a better basis for improved management of the protected areas.
Risks
Petroleum Activities require large areas and a large labor force. They are known to have a high
footprint due to the many activities and infrastructural developments associated with the industry.
Where the activities are located within the protected or sensitive areas, primary impacts may be
great. Secondary impacts are also likely to be exaggerated due to the magnitude of the petroleum
activities. Major risks include:
Fragmentation of protected and sensitive areas. The protected area system in the graben is
either just adequate for some species or already too small for the survival (maintenance of a
viable population) of some species e.g. mammals. Further fragmentation of these areas
through construction of roads, pipelines and other associated infrastructure will threaten the
survival. Seismic lines, a feature expected to be of temporary nature, sometimes persist for
years because communities or other people carrying out activities in the protected area keep
using them. For some of the animals (especially mammals and birds), an open place is a
major barrier that prevents them from accessing resources on the opposite side of the open
space.
The high labor force associated with the petroleum industry will result in high human
population increase. This increases competition for space between wildlife and the people,
trampling of the landscape, demand on the natural resources. Human-wildlife conflict may
also increase because of the animals moving away from where activities are taking place to
community areas.
Invasive species may be introduced especially along the roads, areas where camps are set up
and field sites where workers spend a lot of time.
Wildlife population may decline due to various causes. Roads and other infrastructure like
seismic lines and openings for pipelines may be used by poachers to access areas that were
originally not accessible and therefore a refuge for wildlife. Machinery used in seismic activity
may kill or maim slow moving wildlife. Increased vehicle numbers and reckless driving may
lead to increase in road-kills and stress of wildlife. Stress may in turn lead to reduction in
reproduction, a common feature with some animal species e.g. Kobs.
Soil and water contamination, especially with heavy metals, may occur during the
exploration, appraisal and drilling stages, and during the transportation of the petroleum
products. Oil spills that occur may contaminate local habitats, especially waterways, water
table and ground surface, which would in turn affect both flora and fauna.
Petroleum activities in protected areas will cover all parts of the areas of interest leading to
opening up of areas that were not often or had never been accessed by humans. This is a
disturbance to both vegetation and wildlife. If the activities are not well managed, it will lead
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to the degradation of such areas and the protected areas in general. EIAs are prepared for all
activities taking place in the protected and in sensitive areas. If the mitigation measures are
not well implemented, the areas may be degraded.
Protected area devaluation leading to reduction in income from tourism. Most of the tourists
that come are interested in seeing wildlife in the wilderness. The high petroleum
infrastructure will reduce or fragment such wilderness area, which may cause reduction in
numbers of tourists.
The extensive earth works during the oil fields development stage will have a number of
impacts e.g. burying of sensitive habitats, increased erosion and disturbance of below ground
biodiversity. If field development activities are not carried out in a suitable climatic window,
the impacts may even be greater.
6.2.2 Recommendations
1. Petroleum activities in environmentally sensitive and protected areas
Activities in areas which are formally designated for ecosystem protection and biodiversity
conservation should be in accordance with the official protection status of the area. As an
example, the National Parks fall into category II of the IUCN classification. The activities
should also ensure maintenance of the status quo of the ecosystem and the biodiversity or
even improving it. Any decision-making regarding potential future petroleum activities in
protected or environmentally sensitive areas need to be based on an Integrated Management
Plan according to the principles outlined in Appendix 12. Therefore the detailed content of the
Integrated Management Plan should be developed and implemented urgently.
Petroleum exploration activities that are already licensed to take place in protected and
environmentally sensitive areas should continue to be based on approved EIAs and
relevant national policies and guidelines such as the National Policy on conservation and
sustainable development of wildlife resources. In addition such activities should follow
international best practice for operations in protected and environmentally sensitive areas.
Petroleum companies who are taking part in petroleum developments in environmentally
sensitive and protected areas shall build their involvement on a Framework for ecosystem
protection and for integrating biodiversity into their activities. The Framework shall focus on
these principles:
The Framework shall address the ecosystem/biodiversity aspects as covered by the
respective Integrated Management Plan and shall be approved by the Government prior to
any activities.
The companies shall integrate ecosystem/biodiversity considerations into their
Environmental Management Systems (EMS) at corporate and project level. The EMS shall
focus on performance more than just following a strict process.
Companies shall take a pro-active approach on ecosystem protection and biodiversity
conservation and shall develop plans for avoiding, minimizing and mitigating impacts rather
than focusing on offsetting residual impacts. Pro-active engagement could be to;
strengthen creation and management of sensitive/protected areas, support for scientific
research/assessments, initiate and support campaigns to save endangered species, share
baseline information on biodiversity, support environmental education and awareness
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building, support capacity building in national/regional agencies, support for conservation
easements and to support for integrated conservation and development.
Development and use of technology shall go beyond the general objectives of cost efficiency
and shall have a prevailing focus on minimizing environmental impacts.
Contingency plans shall be developed and implemented in order to ensure no harm to the
environment independent on cause and complexity of the accidental event.
Ecosystem protection and biodiversity conservation shall be an integrated and focused part of
Environmental Impact Assessments for projects in environmentally sensitive and protected
areas based on these principles:
Implement an ecosystem approach according to the IMP.
Ensure that secondary impacts are considered and that cumulative impacts are taken
into consideration according to the IMP.
Differentiate between impacts on ecosystem-species-genetic levels and respond with
applicable preventative and mitigating actions.
Develop proper ecosystem/biodiversity indicators for planning and monitoring purposes.
Assess and respond to the interaction between environmental and social concerns.
Questions of concern are; does the activity lead to biological loss on population level or
the chance of loss of habitats/ecosystems; does the activity surpass the maximum
sustainable produce, the carrying capacity of a habitat/ecosystem or the acceptable
disturbance levels of a resource/population/ecosystem; does the activity lead to changes
to the access/rights over biological resources, etc.
New conservation and land use planning methods should be considered and tools should be
selected to deal with the trade-offs between different interest groups where environmentally
sensitive and protected areas are under threat. Such tools should provide opportunities for
objective and transparent planning to avoid conflicts by offering open access to data and
relevant stakeholder involvement on all levels.
2. Evaluation of future development scenarios
All three scenarios have a high disturbance of protected and environmentally sensitive areas
in phase 1 (today – end 2015). This is mainly due to petroleum field activities involving
extensive seismic surveys in and around the Murchison Falls national park. There is no
available IMP today and the companies are thus planning and operating on a piece by piece
basis without being able to ensure an integrated approach, development/use of best
available technology and assessing/responding to the cumulative impacts.
It is thus strongly recommended to postpone any further activities in Murchison Falls until an
IMP is developed with the involvement of the companies based on the general principles
outlined under Section 1 above. The ongoing seismic surveys should be narrowed to an
absolute minimum and stopped immediately if the parallel monitoring demonstrates serious
negative effects on the ecosystem/biodiversity.
The high disturbance is ongoing for all scenarios until after 2022 mainly due to the fast field
development and operations in Murchison Falls. More available time is therefore essential for
the planning and development of environmental friendly solutions/technology, and it is
therefore recommended to moderate the speed of the development in Murchison Falls to
allow for Integrated Management Planning.
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There is an extensive need for land for all scenarios. For Scenario 3a the permanent land take
is restricted to the land for compressor/heating stations. In addition, there will be user
restrictions with respect to a narrow corridor for operational maintenance and safety. The
other scenarios require a permanent ownership to the land.
From a socio-economic point of view, Scenario 1 and 2 offer large opportunities for value
creation.
In the case of a slower exploitation speed, scenario 3a has lower flexibility than 3b as to
receiving oil production from a less steep production profile. This scenario would require a
longer period of road trucking of oil before the production levels can economically justify
building an export pipeline. Railway transportation is more flexible as to stepvice oil
production.
Scenario 3a with export through an oil pipeline is the most favorable scenario based on a full
speed field development.
As the field developments and primarily the Murchison Falls development is the dominant
reason for the environmental disturbance, it is from an ecosystem protection and biodiversity
conservation point of view more important to take the necessary time to optimize solutions in
and around the park than choosing a scenario with lesser disturbance on other factors. In
addition to above, sequencing of activities should be assessed. However, as production takes
place for a long time, the feasibility of sequencing production scenarios appears limited.
6.3 Co-existence with Other Sectors and Local Communities
Following the scenario analysis and in relation to co-existence with Other Sectors and Local
Communities this section is a presentation of issues and impacts relating to the fisheries, tourism,
other industry/service providers, local community issues including benefit creation, land use,
livelihood restoration and compensation, cultural heritage and water management. Regarding
regulatory framework, social issues are addressed by line ministries including Ministry of Gender
Labor and Social Development, Ministry of Lands, Housing and Urban Development, Ministry of
Health, Ministry of Agriculture, Animal Industry and Fisheries and Ministry of Health amongst others.
Environmental legislation is meant to ensure that resources are used sustainably. Since this affects
social aspects, such as opportunities to improve the livelihoods, general wellbeing and increased
access to social and economic infrastructure, coordination between the relevant ministries is
essential. A number of concerns have emerged during the SEA process which have to be addressed at
strategic level:
Socio-Economic Benefits
Fisheries Management
Occupational Health and Safety Issues and HIV/AIDS
Urbanization and Public Health Issues
Increased demand for social infrastructure
Public Disclosure and sensitization on impacts related to petroleum development activities
within all sectors (agriculture, health, gender, land issues, infrastructural planning e.t.c)
Land issues including adequate compensation planning and livelihood restoration in the
event the personal properties are affected
Building of community capacity to enable participation in the petroleum related activities
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Building capacity for monitoring mitigation measures including addressing coordination
failure
Finally the need for a regional social development plan to address the vulnerability contexts
of communities closest to the oil resource
It is expected that if these key concerns are addressed, then project specific Environment Impact
Assessment and environmental and social management plans will adequately integrate values for
different ecosystems services in the assessments and mitigation planning. This section gives a brief
overview of the related impacts identified within the different sectors during the petroleum
development activities and recommendations on how they can be addressed.
6.3.1 Co-existence with Fisheries
Potential environmental impacts on fisheries due to petroleum exploration, development and
production in the Albertine Graben include marked increase in demand for fish that would translate
into unsustainable fishing pressure if unmitigated; and pollution (with oil and gas contaminants) of
sensitive surface water habitats where fish breed, nursery, feed and shelter. The boost in economic
benefits due to rise in fish sells at inflated prices would be short lived, giving way to unsustainable
fisheries.
Petroleum activities can be associated with serious degradation of aquatic environments through
physical damage and chemical pollution connected to construction works and transportation as well
as exploration drilling and production from platforms located in the lakes . Such serious damage has
so far not come to light. Yet stockpiling of waste products of exploratory drilling for oil and gas (that
could contain contaminants detrimental to the environment) close to surface waters pauses
significant potential risk to aquatic resources including fisheries.
This section outlines the baseline setting for fisheries in the AG focusing on how critical fish habitats
and fisheries could be impacted by petroleum exploration, development and production.
Recommendations for high level mitigating interventions towards co-existence of sustainable
fisheries and petroleum activities in the AG are proposed.
Current Situation
Reports from the AG indicate that petroleum activities are already influencing the rise in cost of fish
due to rising demand for fish mainly by unskilled employees in the industry able to pay more for fish.
Higher prices attract more investment into the fishing industry. New internal job seekers are also
attracted into the fishery. The use of illegal and destructive fishing gears like monofilament gillnets
and small hooks become attractive because they are cheaper and have higher catch rates. This
scenario was reported to be already in place. Fisheries management capacity is inadequate to
counteract it effectively. The result is enormous increase in fishing pressure and the reported
uncharacteristic reduction in catch rates per fishing unit. Low catch rates were particularly evident
for more popular commercial fishes such as Nile perch, Nile tilapia and tiger fish, signaling
overfishing.
Degradation of sensitive fish habitats and resources due to physical and/or chemical impairment
inflicted by contaminants from exploration of relevant oil and gas exploration, development and
production in the AG was not identified during the engagement with the stakeholders. Possible
environmental contaminants are expected to be associated with the high oil waste volumes released
during field operations. Contaminants would also be released into the environment by large
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accidental oil spills and through refinery effluents. Presence of low level environmental
contamination cannot be ruled out because there is no effective ongoing pollution monitoring in
surface waters.
Future Prospects
Demand for fish will increase further during Phase 1 (2013-2015) in tandem with the expected need
for casual labour during heightened seismic activity especially in the Murchison Falls national Park.
Such labour is likely to be required most during Phase 2 (2015 to 2017) during pipeline construction
works and similar activities. The growing demand is expected to spur fish production and generate
revenues to a limit. If use of destructive fishing gears is firmly controlled by fisheries administration,
fishery production will peak and begin to decline under sustainable management. Unmitigated the
fishery could collapse rendering the speculative investment a major loss.
The risk of large oil spills leading to contamination of the aquatic environment and fisheries resources
will be greatly enhanced by the onset of large scale oil and gas production and movement likely in
phase 3 Phase 3 (2017-2022). Mitigation of the likelihood of serious contamination of sensitive
habitats for fisheries will depend on timely development and operationalization of effective oil and
gas waste management plan and strategy; and a comprehensive oil spill contingency plan.
The Challenge of Transboundary Harmonization
This challenge is complicated further by the lack of harmonized fishing regulations in the Trans-
boundary fishery on Lake Albert. Intensive Trans-boundary use of undersize gears especially hooks on
long lines is reportedly threatening the survival of Lates macrophthalmus.
Recommendations
1. Petroleum activities and interference with fishery interests
Coordinated and more effective enforcement of management regulations of the fisheries in
the region is essential and should be strengthened in order to ensure sustainable fisheries.
A coordination forum between the fisheries and the petroleum industry should be created in
order to effectively discuss and resolve coexistence issues on a mutual basis. Representatives
from authorities or others could be invited when necessary.
2. Evaluation of future development
Today to end 2015 (Phase 1)
According to scenario analysis the demand for fish obtaining today is expected to increase
further during the rest of this phase in tandem with the expected unskilled workforce need for
casual labour during enhanced oil field activities such as the extensive 3D seismic acquisition
in the Murchison Falls national Park. The growing demand is expected to spur fish production
and generate revenues to a limit. If use of destructive fishing gears is firmly controlled by
fisheries administration, fishery production will peak and begin to decline under sustainable
management. Unmitigated the fishery could collapse rendering the speculative investment a
major loss. During this phase the risk of accidental environmental contamination of sensitive
aquatic habitats will be high due to the high volumes of oil waste in the AG, and to the
trucking of oil from extended well testing through the AG to the consumers.
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End 2015 – end 2017 (Phase2) and end 2017 – end 2022 (Phase 3)
The size of unskilled workforce required is expected to be larger in Phase 2 than during Phase
1 due to the need for more labour to lay infield pipelines for channeling oil from production
wells to the local Central Processing Facilities (CPFs) and for menial labour for the
construction of the oil refinery. The risk of environmental contamination due to accidents
involving trucks carrying oil from EWT will be enhanced by those trucking refinery products.
Successful mitigation of serious contamination of sensitive habitats for fisheries arising from
accidental oil spills will depend on timely development and operationalization of effective oil
and gas waste management plans and strategies; and on comprehensive oil spill contingency
plans.
6.3.2 Co-existence with Tourism
The Uganda Wildlife Policy (2000) was developed before the oil exploration era. There have not been
major revisions of the policy to incorporate the activities of the oil and gas sector. However, UWA
has developed guidelines to ensure that the oil and gas sector activities do not injure their interests
of protecting and conserving biodiversity. For example, UWA has ensured that the oil pipelines pass
through the less sensitive areas of parks and reserves. Further, pipeline disturbances of the wildlife
habitats will only be short-run. The major concern is how to deal with the pollution damages to the
wildlife and the health of their habitats.
The Uganda Tourism Policy (2003) was also developed before the oil exploration era. The concern for
this group of stakeholders is the disturbance to wildlife habitats. The observation is that there are
specific circuits where the chances of seeing animals are high. A number of these circuits have been
taken over by the oil exploration activities. Thus there has been a reduction in access to wildlife
viewing. The consulted person suggests that the oil and gas exploiting firm must ensure minimum
disturbance to the circuits, and alternative circuits should be developed by the oil firms. This will
internalize the external disturbances of oil activities. The other concern was that of waste disposal
versus the health of the protected areas. The consulted officer emphasized the need for the oil
exploiting firms to employ technology that ensures minimal ecosystem disturbances.
Risk and Opportunities for the Tourism Sector
The opportunities that may accrue from the oil and gas sector to the tourism sector include:
Provision of resources for the development and improvements of the tourism sector
Provision of alternative sources of energy, reducing the demand on biomass fuel and
consequently having positive impacts on forests and biodiversity conservation. Increased
number of tourists both international and domestic ones leading to a boost in revenues from
tourism activities.
Increased marketability (advertisement) of the regions tourist resources, and therefore a
positive impact on employment in the sector and revenue to tourism operators.
If the oil extraction activities are conducted carefully with minimal damages to the
environment, the area will become a demonstration for sustainable exploitation/co-
existence of oil operations within protected areas. This can be another centre of attraction
for tourism and for educational demonstrations.
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Oil and gas operations may be a threat to the tourism sector if:
Air and water quality deterioration due to oil production reducing the number of visitors due
to the scare of health damages.
Deterioration of wildlife ecosystem health leads to changes in the wildlife grazing
arrangements, breeding capacity, and migration patterns.
Presence of oil infrastructure in areas where tourists want to view wildlife and undisturbed
ecosystems.
New diseases outbreaks take place when inhabitants (wildlife) of certain zones of the parks
and reserves are pushed into other areas as a result of habitat fragmentation by the oil and
gas activities.
Influx of new settlers close to the parks and national reserves making it necessary to increase
the amount of resources allocated to parks management and the curbing poaching.
Recommendations:
There should be regulations on the maximum acceptable disturbance levels.
Activities in areas which are formally designated for ecosystem protection and biodiversity
conservation should be in accordance with the official protection status of the area.
6.3.3 Co-existence with Local Communities
Given the nature of environment in the Albertine Graben makes communities vulnerable to a
number of issues. Previously, a hard to reach area, the area had limited coverage of social services
including schools, health centres and roads. With recent developments, settlements are influenced
by changes in population due to migration of people in search of labor or business opportunities. This
results in increased demand for safe water coverage and latrine coverage, adequate health facilities,
education facilities as well as increased demand for food and means of production including land.
General observations relating to the petroleum activities is that there is general increasing social
infrastructure in the Graben due to the presence of oil companies including roads, health centres,
services like banks, petrol stations, microfinance institutions for example in Buliisa which was
previously hard to reach and community intervention projects like sensitization for HIV/AIDS by
companies. Furthermore, some community members have been able to get jobs and therefore able
to add capital to their traditional production systems like agriculture. The key strategic opportunities
within the communities include:
Employment of locals in petroleum related activities
Increased access to social infrastructure
Growth in local economy as a result of demand for services and products for those
participating in petroleum activities
General knowledge and awareness about petroleum activities and increased participation in
governance issues amongst local government staff and communities.
The key challenge observed so far include immigrations and its related challenges. Specifically:
Petroleum activities attracted members within the local communities that were mainly land
speculators which created fear of loss of land or unfair compensation
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Regarding community health and safety, location of some fields are located within
community areas companies and this exposes them noise related impacts, on its part, Bulisa
is updating its land use plan in order to address these challenges.
The land use plan should be able to address issues of urbanization, sanitation and community
health issues that are a menace in the area.
On HIV/AIDS companies have been sensitizing communities however; local governments
need to come on board.
On land issues, so much has been ongoing including the fear for unfair compensation given
the trend in the region. Community members always refer to their experience with other
sectors like Rural Electrification Agency, Uganda Electricity Transmission Company Limited
and Uganda Roads Authority in addition to the land acquisitions at district level. Major
concern was that most land was customary land tenure which may not attract high
compensation rates. Although there is a land administration system in the county, it has not
been followed by most stakeholders. Area land committees have rarely been involved in land
transactions aside from signing forms; yet, they have the tools and mandate to be involved in
sensitization and solving disputes. District land boards have only began updating
compensation rates given the demand from petroleum related land acquisition process and
the presence of the Land Administration Department at the Ministry of Lands, Housing and
Urban Development has equally had limited presence in the land acquisition processes in the
sector. Furthermore, while Uganda’s national land laws provide for compensation of
property and disturbance allowance, utilization of international principles of best practice
including:
o Adequate sensitization of potentially affected persons so that they are able to make
informed decisions
o Clear guidelines on identification of potentially affected persons for project specific
activities. For example within the roads sector, there is standard when it comes to
land acquisition which includes 30m or 50m road reserve that is acquired by
Government for utilities. Petroleum related standards need to be developed and
communicated to stakeholders including the buffer required for an oil field, refinery,
pipelines amongst others.
On agriculture and food security issues, crop production is predominant in the Graben in
addition to livestock rearing. Most production systems are still traditional in nature; farmers
would benefit more from improved farming methods so as to cope with increasing crop
production in a water stressed area.
On interaction with natural resources, encroachment in protected areas in search of
firewood, grazing and agricultural land is common. The social development programme
proposed by Ministry of Gender Labor and Social development should include coping
strategies including energy saving technologies, adoption of alternative income generating
activities so that increased demand for resources is managed. Access to safe water will
ensure that communities have access and secondly they do not have to depend entirely on
unsafe water sources.
On conflict resolution and managing of grievances, perceptions differ on how conflicts within
communities on land issues, grievances with petroleum related stakeholders can be handled.
Although the local council system is in place and can be used, they should be supported by
technical staff and also district land boards as well as area land committees.
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Recommendations
1. Petroleum activities in general
On the whole, social mitigation measures mainly require strategic interventions as they are indirect
impacts of petroleum related activities.
It is recommended to moderate the speed of development to ensure balanced capacity
building amongst relevant institutions, such as NEMA, to manage the sector. Furthermore,
this adjustment would benefit the local district governments and population to adapt to the
new sector.
Project based risk assessment is undertaken within EIAs and project specific EIAs follow
indicators in the Environmental Monitoring Plan for the Graben because that is the tool that is
currently used by stakeholders for monitoring. Cumulative impacts, which are beyond the
developer, should however be addressed in order to see the overall influence on the
communities.
Resettlement action plans should be based on international best practice in order to improve
the level of trust .
Develop a specific sector compensation framework including guidelines for valuing natural
resources; in the case of forests current compensation rates at the district are used for specific
trees but in the case of aquatic resources, these have to be developed.
An example of best practice for managing resettlement in line with the IFC Performance Standards is
given in Appendix 10.
2. Evaluation of future development scenarios
In addition to the current situation, the team has also assessed the petroleum related development
scenarios. Within the socio-economic setting, the first phase for all scenarios appears to have a lot of
infrastructural related activities which are likely to benefit communities within the Graben in terms of
job opportunities, increased access to social services, better planned development as more planning
for the Graben is being undertaken by lead agencies including Ministry of Lands, Housing and Urban
Development for land use and spatial planning, Uganda National Roads Authority amongst others.
However, key challenges include physical presence in community areas and land acquisition for
petroleum related infrastructure. High demand for accommodation and food could mean that local
communities may become food insecure if they sell all their food in the market and leave less for their
consumption. Other related issues include the spread of HIV/AIDS, demand for infrastructure, and
limited financing from Central Government to enable districts cope with these changes.
Phase 2 suggests that there will be high level of construction activities requiring a large construction
workforce present in the region for all scenarios. It is expected that 5.000 – 10.000 workers will move
to the Albertine Graben considering that the extensive activities in the region will attract people
looking for jobs and opportunities. This increased activity and population will lead to social
tensions/disruption. Previously, the Graben was not as heavily populated as it is today, especially
around the fishing villages, and as such, the facilities will not be able to meet the service demands of
an increased workforce. For scenario 3 the pressure on local communities besides the oil field
activities is more temporary and transitional due to the linear construction spreads for the pipeline or
railway moving onwards. This means that significant impacts relating to compensation and land
acquisition will be along pipelines and roads. Adequate sensitization is needed for such structures to
ensure that communities are aware of the different infrastructural related activities.
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Considering that Phase 3 will be characterized by large scale construction activities for scenario 1 and
2 to expand the refinery, impacts on communities are limited as many within the refinery environs will
have been compensated and relocated. However, construction is also ongoing for both scenario 3
options due to the construction of the gas fired power plant and the LPG plant meaning that more
land needs to be acquired. There is need to ascertain total land take vis-à-vis productive land so to
make an informed decision on the vulnerability of communities. The risk for accidents during
operations is low for the export pipeline, medium for the railway due to the higher risk of human error
and sabotage and high for scenario 1 and 2 for the same reasons. Also the pressure on local
communities is lower for scenario 3, largely because the linear infrastructure of railway or pipeline
requires a more temporary presence of workforce.
In the case of phase 4 where construction activities have been finalized for scenario 1 and 3 while
extension of the refinery is under construction, scenario 2 will have less employment opportunities for
locals because the construction workforce and presence in the area is thus reduced for scenario 1 and
3. The need for operational workforce is lower for scenario 3 than for the other scenarios, both skilled
and unskilled and they are likely to experience a high cost of living; communities need to be prepared
for this phase. The risk for accidental events during operations is significantly higher for scenario 1
and 2 than Scenario 3. This is due to the refinery installations being prone to third party interference
or human errors while the pipeline is buried, requiring low maintenance and having a lower risk for
sabotage. In the case of communities, oil spill contingency planning is key in order to ensure that they
do not become vulnerable. The overall socio-economic benefits will be higher for scenario 1 and 2
than for scenario 3 if managed well. However, scenario 3 will have lower environmental effects due to
less industrial activity in the area.
In conclusion, an evaluation of the scenarios for the phases, it can be concluded that in the case of co-
existence with local communities short term impacts are more severe within the first phases and
hence the need to prepare the communities to cope with the development opportunities and
challenges in the region.
6.3.4 Co-existence with Cultural heritage
Cultural Landscapes
The project area is mostly in the national Game Park and reserve. It is mostly covered by forest and
savannah vegetation thus a habitat for wild game and flora. It is located at the riverbank of the great
river Nile which harbours some historical sites like the top of the falls which was a crossing point for
the Bunyoro kings to the north and back when need arises, just like other African people in different
part of Africa, the inhabitants of the area had their small god which they used to worship in the forest
and hill in different parts of the region. However most of such cultural activities have long been
abandoned by the local people who prefer Christianity which was brought by the colonial master
leaving behind only memories and traces like at fort Bugungu in Kilylango village.
Cultural groups within the project areas
The areas is not only occupied by the Banyoro, other tribes are also settled in the area in fact the
other tribes are so diverse and have settled in the area gradually most of them having migrated into
the area during the Congo wars and northern insurgence between 1986 to 2003. These tribes include
Acholi, Lango, Alur, Bangungu and the Baluli. Some of these have been assimilated into the early
inhabitants hence use the Alur, Runoyo or Lugungu language as medium of communication.
Baseline indicators
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Living heritage site means places where people practice cultural traditions like performing
rituals e.g., coronation sites, cleansing.
Historical sites; The historical forts in the region like fort Magungu in Kilyango village found in
Bulsia district form part of the archaeology and history of the place which need to be
assessed and documented in the right way.
Burials/ graves means a place of internment and this includes the content, headstone or
other marker that may be used like a plant.
Palaeontological sites. The Albertine region covers the districts of Masindi, Bulisa and Hoima.
41 new fossil localities are believed to have been recorded in the Albertine region by 1965.
Four Pleistocene localities were located of which yielded stone artifacts for example in the
regions of Nkondo and one at Hohwa River where abundant fossils were collected at the site
on the southern banks. Nkondo paleontological site is the most studied in the region, the site
is found 12 km south of Kaiso on the Eastern shore of Lake Albert. It is important as the
paleontological site for the mammalian fossils.
Kaiso site is also found on the Eastern Lake shores of Albert and is found in the South eastern
side of Ndondo. It has been very important for paleontological research where plant fossils
have been discovered of about 2.5 million years ago and fossilized horns of the extinct long-
horned Buffalo of about 2.6 M.a. Most of the above give the back bone activity of site and
monument section.
Archaeological and historical sites; Ethno-archaeological sources indicate that during the
19th century, the state was mainly supported by the cattle pastoralist and small stock
husbandry together with substantial cultivation places. In addition trade in several key
commodities like slat and iron were probably important in the maintenance of the
centralized authority.
The first Babito king Isingoma Mpunga Rukidi is traditionally credited with the development
of iron and salt industries of Bunyoro Kitara kingdom. Historical sources show that during the
late 19th century, Kibiro salt was important component in the Bunyoro economy. In the pre-
historical economy, the region and Kibiro in particular could provide insight into the origins of
salt economy and cultural relationships of some people who formed part of that state which
Buliisa is definitely a component.
Iron smelting and salt production sites; Whereas Iron production was a wider activity in the
region, salt production was more within the Lake Albert basin. It is believed by the local
people that Kibiro salt producing village demonstrates a traditional salt producing technology
which has sustained its people for over eight hundred years and continues to do so. The
archaeology of Albertine rift has been considered by researchers as unique in the western
Uganda, the iron-using agriculturalists of the last millennium left behind good stratified
deposits of material culture in terms of iron slag, pottery, slat gardens and many others
which can be studied and kept in the record for the future generations.
Bunyoro kingdom Today the Kingdom of Bunyoro-Kitara is the remainder of a once powerful
empire of Kitara. At the height of its glory, the empire included present-day Masindi, Hoima,
Kibale, Kabarole and Kasese districts; also parts of present-day Western Kenya, Northern
Tanzania and Eastern Congo. That Bunyoro-Kitara is only a skeleton of what it used to be is
an absolute truth to which history can testify. Related to the kingdom there are so many
heritage sites like; Mparo tombs, Katasiiha fort and cultural site, kabalega’s forts in different
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parts of the oil region, Buhimba fort, Kijura cultural site in Masindi, Karuzika-Hoima Palace,
Kihande in Masindi, Kibiro hot spring, Waraga tombs and Nyabweya.
Traditional sites/ intangible (palaces and living culture)
For the purposes of this report, traditional sites comprise palaces and living culture. One should note
that palaces may be included in the living culture as they were re-instituted by the 1993 reinstitution
of traditional assets. Living culture meaning traditional beliefs and practices that are living and can be
passed on to future generation. Cultural trees and cultural shrines were therefore placed under living
culture. The area is not only occupied by the banyoro, other tribes are also settled in the area
gradually most of them having migrated into the area during the Congo wars and northern
insurgence (1986 to 2003). Just like other traditional people in different parts of Africa, the
inhabitants of the area had their small God which they used to worship in the forest and hill in
different parts of the region Distraction, site abuse of the ritual places, Clan cemeteries and family
graves may be exposed, culturally sensitive trees may be cut if care is not taken from the start.
Archaeological materials
Archaeological assemblages are classified as small bones, small and medium-sized pottery scatters,
stone artifacts, iron smelting sites and other features that are historic information. These sites may
be impacted by the oil activities indirectly or directly if the project comes into contact with the
material.
Assessment of risks and opportunities for current and future petroleum activities
1. Excavations - of the road and for materials like marram (gravel) will lead to total distraction
of the archaeology and other cultural resources found in the soils like burials. This impact is
likely to happen during the construction phase.
2. Vibration from equipment and vehicles -This poses threat to the physical fabric of the
pottery, iron slag, furnaces, tuyeres and the bone remains which are already under threat
from the natural causes and by vehicles using the road. This impact is likely to run from the
construction phase to the operational phase.
3. High Humidity and oil spillage - The consequence of high humidity and moisture is the
deterioration of the material culture fabric. The archaeological materials are made of
different fabrics and react differently to sudden change some cannot withstand high
moisture content. This may happen when the cultural materials get exposed due to different
project activities.
4. Encroachment - There is likely to be an expansion of both human settlements and
agricultural land use, which will ultimately have an impact on the aesthetic values of the
sites. Human traffic, also poses a threat to the sites. The major consequences of
encroachment are the destruction of the physical site and its related values.
5. Poor drainage may cause erosion which will damage and also lead to the exposure of
archaeology in the project area. It may also cause water logging which will directly impact on
the archaeological materials buried in the soil negatively.
6. Theft of Cultural property; Movable physical cultural properties may be impacted on by the
project as the incoming workers may provide ready markets for the cultural resources.
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7. Interference/ abuse of the spiritual life; the intangible life of the region may not be easily
understood by the project workers who may end doing wrong things in spiritual related
areas.
Physical cultural property contingency planning
At the moment there is insufficient cultural/ archaeological data base and information of potential
risks associated with potential oil activities in the Albertine Graben and related project locations due
to the fact that most impacts takes place only when the project activities like excavations get in
contact with the archaeological or cultural sites.
Recommendations
The identification and mapping of all heritage resources in the area affected.
An assessment of the significance of such resources in terms of the heritage assessment
criteria, which needs to be clearly stated with reference, or prescribed.
An assessment of the impact of development on such heritage resources.
An evaluation of the impact of the development on heritage resources relative to the
sustainable social and economic benefits to be derived from the development.
The results of consultation with communities affected by the proposed development and
other interested parties regarding the impact of the development on heritage resources.
If heritage resources will be adversely affected by the proposed development, the
consideration of alternatives.
Plans for mitigation of any adverse effects during and after the completion of the proposed
development.
Development of Chance Find procedure, to take care of any cultural materials which may be
missed during the assessment phase and discovered during the implementation phase.
Cultural sites and human remains:
Acquisition, maintenance of and access to cultural sites must be in a manner that provides
appropriate respect for and recognition of legitimate concerns of people intimately involved
with such site, while accommodating the needs of other legitimate users.
Acquisition, use of and access to culturally sensitive sites and human burial should take into
account (above and beyond the usual criteria) the ongoing feelings of the community of origin
for such site concerning its appropriate use. At all times, attempts should be made to avoid or
reconcile conflicts between the oil projects and responsible custodian of such a site.
Concluding recommendations
The "archaeological heritage" is that part of the material heritage in respect of which archaeological
methods provide primary information. It comprises all vestiges of human existence and consists of
places relating to all manifestations of human activity, abandoned structures, and remains of all kinds
(including subterranean and underwater sites), together with all the portable cultural material
associated with them.
Heritage consultants or the Uganda Museum should compile guidelines which should spell
out procedures to be followed by projects in the event that any heritage resources are
disturbed and discovered during the project. A cultural heritage programme aimed at
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orienting and empowering the personnel who will be working on exposed projects should be
put in place prior to commencement of work.
Development projects constitute one of the greatest physical threats to the cultural and
archaeological heritage. It is the duty of developers to ensure that archaeological heritage
impact studies are carried out before development schemes are implemented. Development
schemes should be designed in such a way as to minimize their impact upon the cultural
heritage.
6.4 Institutional Framework and Capacity
This chapter is focusing on the following strategic aspects:
- Environmental management on a national level
- Coordination between governmental agencies and district/local level
- Capacity building
6.4.1 Environmental management on a national level
The Albertine Graben warrants special measures to safeguard the environment and ecosystem
integrity because of its significance as the most species rich eco-region for vertebrates in Africa, high
tourism potential and at international level identified as a biodiversity hotspot with a very sensitive
biodiversity area. At national level, the Government of Uganda has instituted environment
management structures for oil and gas sector including establishing a regulatory framework and
strengthening institutional framework including monitoring infrastructure as well as skills training in
relevant disciplines for nationals in the new sector. Each of these structures is, however, still evolving
as the oil and gas activities also evolve through the different stages of exploration and forthcoming
development.
Establishment of regulatory framework for the sector
The 1995 Constitution of the Republic of Uganda is the primary instrument for environmental
management in Uganda. The constitution provides for promotion of sustainable development and
public awareness of the need to manage land, air, and water resources in a balanced and sustainable
manner for the present and future generations. Environment issues in the oil and gas exploration and
development are mainly regulated through the National Environment Act – Cap 153 and related
regulations on water, air, land, and promotion of the protection of biological diversity. It has,
however, been recognized that existing legislation, guidelines and policies for petroleum operations
and the existing legal framework in other sectors need to be updated as well. Recognized also is the
need to develop new regulations, guidelines and standards relevant to the new oil and gas sector.
The 2008 National Oil and Gas Policy (NOGP) provides for environment protection and biodiversity
conservation. The policy includes an objective “To ensure that oil and gas activities are undertaken in
a manner that conserves the environment and biodiversity”. The policy has set strategies pertaining
to environment management mainly focused on ensuring availability of the necessary institutional
and regulatory framework to address environment and biodiversity issues relevant to oil and gas
activities; ensuring capacity building for the necessary manpower to monitor the impact of oil and
gas activities on the environment and biodiversity; obligating oil companies and their
contractors/subcontractors to use internal control/self regulation and best practices in ensuring
environmental protection and biodiversity conservation; and requires oil companies and any other
operators to return all operational sites to their original condition as an environmental obligation.
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Following the Oil and Gas Policy of 2008, the Petroleum, Exploration and Production Act 1985 and
(revised in 2000) which provided for promotion, licensing and exploration for petroleum in the
country is to be superseded by new legislation, that is the Petroleum (Exploration, Development and
Production) Actl, 2013 and the Petroleum (Refining, Gas Processing and Conversion, Transport and
Storage) Bill, 2012.
Recommendation:
This SEA process has reviewed the bills and proposed amendments through advisory notes
aimed at strengthening environment management in the new legislation. Following this
precedent, it is imperative that effective environmental safeguards are stipulated in the
regulations and guidelines that will be developed following both the petroleum and relevant
environmental legislation.
Strengthening regulatory infrastructure
This analysis reflects international precedents on proper management techniques and best
environmental practice that if applied can eliminate and or mitigate many if not all potential
environmental impacts. In addition to the international environmental conventions, recognition is
also accorded to international guidelines and relevant international standards. While recognizing that
individual companies are committed to self regulation through own policies and codes, Government
regulation and enforcement is still the cornerstone for environment protection. The Government of
Uganda in partnerships with the Norwegian Government is implementing a program on
strengthening state control and management of the Oil and Gas sector. On the area of Environmental
Management the program focuses on the following;
Environment Impact Assessments (EIAs) for all development projects;
Strategic Environmental Assessment (SEA) for the Albertine Graben;
Environmental and biodiversity related policies put in place/ reviewed with respect to oil and
gas including biodiversity off-sets;
Existing Acts reviewed, recommendations drafted and presented for approval;
Reviewing and where necessary preparing new Management plans for protected areas: The
general management plans in some of the protected areas where oil production will take
place need to be reviewed to take into account oil exploration activities;
Relevant sector plans for the AG updated taking the oil and gas issues into consideration;
An environmental monitoring system for the AG for monitoring changes in the environment
before, during and after the extraction of oil and gas in the Albertine Graben;
Development of environmental regulations and standards relevant to the oil and gas sector;
Strengthening Hazardous waste management system;
Strengthening a framework for compliance monitoring and enforcement of the oil and gas
industry;
Developing and operationalizing a National oil spill contingency plan;
Developing an HSE supervisory strategy and plan;
Establishing the AG as a special planning area and undertaking a Physical Development Plan
for the AG.
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An institutional framework for the above areas of focus is through the Environment Management
Pillar composed of National Environment Management Authority (NEMA) that spearheads the pillar
management. The environment pillar was established under the NOGP to contribute towards
ensuring that oil and gas activities are undertaken in a manner that conserves the environment and
biodiversity.
NEMA is also coordinating an environment information network (EIN) which will play a key role in the
monitoring program for the AG. EIN was established in 2001 with the main objective of enhancing
the capability of key data producers in the environment sector to exchange and share information in
compatible formats at minimal time and cost. All the key data holders are organized in the EIN and
the data management framework for the AG EMP will be part of this framework (NEMA, 2012).
Through the Monitoring plan for the AG, the EIN has set targets for strengthening data management
for planning and decision making in the AG including hosting an environmental data clearing house at
NEMA. The new targets build on previous efforts on a Sensitivity Atlas for the Albertine Graben which
was also prepared under the auspices of the EIN.
Recommendation:
Critical for effective performance of environmental management is the coordination of the
various institutions involved. The key area of cooperation is currently on quarterly monitoring
of impacts but oil and gas being a new sector, the capacity of the institutions to perform this
task in a coordinated manner is limited. The roles and responsibilities by the institutions need
further clarification as capacity of the different institutions in monitoring is strengthened.
6.4.2 Coordination between governmental agencies and district/local level
The ultimate responsibility for environmental management in the country is vested in the Ministry of
Water and Environment (MWE). The mandate is executed through the ministry’s directorates and
agencies. These include the Directorate of Water Resources Management (DWRM) responsible for
Integrated Water Resources Management (IWRM) activities such as monitoring, assessing, planning,
allocating and regulating water resources, whereas the Directorate of Environmental Affairs (DEA) is
concerned with environmental policy and carries out its mandate through three agencies; National
Forestry Authority (NFA), Uganda Wildlife Authority (UWA) and National Environment Management
Authority (NEMA). NFA has a mission to “Manage Central Forest Reserves on a sustainable basis and
to supply high quality forestry-related products and services to government, local communities and
the private sector, while UWA (under the Ministry of Tourism, Trade and Industry) has a mission to
conserve, economically develop and sustainably manage the wildlife and Protected Areas of Uganda
in partnership with neighboring communities and other stakeholders for the benefit of the people of
Uganda and the global community. UWA ensures that oil exploration activities in protected areas
such as Queen Elizabeth, Murchison Falls National parks and the various Wildlife Reserves are carried
out in a responsible manner. However, NEMA is the principal agency in Uganda charged with the
responsibility of coordinating, monitoring, regulating and supervising environmental management in
the country including coordinating the activities between institutions to ensure environmental and
biodiversity protection during oil exploration activities.
A multi-institutional Environment Monitoring Committee has been put in place and is composed of
representatives from DWRM; NFA, PEPD, UWA, Fisheries Resources Department (FRD), DEA and
District Environmental Officers ( DEOs). The monitoring is at three tiers; the executive level,
technical/ operational level and field based monitors. NEMA together with other Government
institutions such as PEPD, UWA and NEMA have staff based in the field to monitor the oil exploration
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activities. Both UWA and NEMA have appointed full time officers to monitor oil exploration activities
whereas PEPD monitors are also monitoring technical aspects. There is a multi-sectorial technical
team composed of NEMA, PEPD, UWA, DWRM, NFA, Fisheries and Department of Occupational
Health and Safety that inspects oil exploration activities on a quarterly basis. The heads of these
institutions form the strategic level monitoring team. The District Level Monitoring Team is also in
place and is composed of the technical staff of the local governments in the AG.
Monitoring to ensure compliance with the environment regulations is a collective responsibility for
all stakeholders. Therefore the monitors work in close consultation with community members, civil
society and the local district leaders through the District Environment Officers. Regular sensitization
meetings are carried out in order to gain understanding of the process and listen to community
concerns, and be able to monitor the activities basing on knowledge.
Risks and opportunities for environmental coordination between governmental agencies and
district/local level in the AG
Although the roles and responsibilities in the environment management of oil and gas is spelled out
clearly in the framework of the Environmental Pillar under the NOGP, operationalization is still a
challenge due to limited capacity in expedition a slow pace in understanding and operationalizing of
the new institutional roles . The institutions still require understanding of the roles and how the new
sector roles interact in the new oil and gas sector without duplication and conflict. NEMA has been
spearheading the coordination of environmental monitoring in terms of programmatic and financial
aspects but the sustainability of this role will be a challenge especially as petroleum activities
increase in the downstream stages. A functional compliance monitoring and enforcement framework
that is proposed to help streamline harmonize compliance monitoring by the different Government
Lead Agencies still requires financial and human resources to operationalize.
The current coordination efforts, however, present an opportunity for strong partnerships amongst
the stakeholders that are beneficial for environmental management in the oil and gas sector. The
E&P Forum/UNEP (1997) builds on Agenda 21 objective to illustrate a multi-stakeholder partnership
in which the commitment and genuine involvement of all social groups is key in moving from
positions of confrontation, dependence or isolation to positions of mutually agreed and understood
interdependence for sustainable development. Therefore, the linkages and roles within the multi-
stakeholder partnership for the AG may take the form that integrates government efforts with civil
society, business and industry in a coordinated structure as shown in Figure 6.2.
Recommendations for environmental coordination in the AG
In the short term, NEMA will still require to spearhead the coordination of environmental
monitoring program until the institutions are fully equipped to participate. For NEMA to
effectively undertake the coordination role, it requires capacity in terms of increased financial
and human resources to fulfill this role.
A multi-stakeholder partnership for the AG should be instituted to integrate government
efforts with civil society, business and industry in a coordinated structure (Figure 6.2). To
effect the partnership model, awareness building will be required from national to local level
and defining of roles and responsibilities reflecting multi-pronged interdependence.
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Figure 6.2: A Multi-stakeholder partnership model for the Albertine Graben (modified after E&P/UNEP, 1997)
6.4.3 Capacity building
To make environmental programs effective, a wide range of capacity building initiatives within
relevant institutions in terms of human and infrastructural resources are required. Key of these have
been outlined at international level by E&P Forum/UNEP, (1997) and include capacity to undertake
baseline surveys; development of environmental policies; legislation and regulatory framework ;
environmental inspections; monitoring and enforcement; continuing ability to manage assessments
and other approval and review functions; service infrastructure such as specialized water, power and
waste services; laboratories; public emergency response systems; transportation systems and local
service industries.
Risks and opportunities related to capacity building
A key capacity building concern is the uncertainty of the dynamic and long term petroleum value
chain as well as establishing and building up of new institutions. However, the National Oil and Gas
Policy provides a framework for appropriate resource management systems and procedures in line
with the National Development Plan (NDP) mainly through setting up of relevant institutions and
capacity building in the country (MEMD, 2010). Through the NOGP, the Government further assures
significant training and other capacity building efforts to be undertaken in order to enable the
established institutions to effectively carry out their different mandates.
The NOGP objectives to “Ensure capacity building for the necessary manpower to monitor the impact
of oil and gas activities on the environment and biodiversity”, is being implemented through the
program on “Strengthening the Management of the Oil and Gas Sector in Uganda”. The Program
which is a joint partnership between the Government of Uganda and that of Norway aims to
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strengthen the state’s administration and management of the oil and gas sector in Uganda through
the following strategies:
Relevant institutions to get extensive training in management of the environmental
component of petroleum operations. Exposing as many Ugandans as possible to various
disciplines of oil and gas including management.
Skills training have been planned for the environment management pillar institutions
including seminars, workshops and tailor-made courses to accelerate this capacity building.
There will also be visits to producing areas elsewhere to gain experiences.
Formal education and training for both diploma and masters programs in petroleum
economics, law, accounting, auditing and taxation have commenced using government
support for capacity building.
Setting up a petroleum technical institution to initially cater for the relevant vocational
training in the sector.
Review the structures of the Ministry of Finance, Planning and Economic Development as
well as structures for all stakeholder institutions under the respective pillars to cater for
creation of either departments or units within respective areas to specifically handle the
requirements of the oil and gas sector with an aim to ensure continuity and sustainability of
the activities of the sector.
Other capacity building support is from the oil industry where the companies are supporting formal
training on oil and gas in partnerships with universities /tertiary institutions both in the country and
abroad. The World Bank has also supported petroleum related environment activities through its
environmental capacity building program to NEMA.
Despite the various efforts, there are still capacity building gaps and opportunities. A capacity needs
assessment for the environmental information network institutions that have been coordinated by
NEMA presents resource/logistical as well as human capacity needs in the following areas:
Aquatic and Ecological involving environmental/biological assessments, fish catch assessments,
fisheries frame surveys, wetland fisheries resources assessments, and fish biology studies. A
field station is planned to be established on L. Albert to provide research facilities for the
various institutions.
Terrestrial Biodiversity Assessment involving aerial surveys and ground counts, vegetation
mapping, ground truth and sensitivity analysis. Oil monitoring units are proposed to be
established in Murchison Falls National Park, Kabwoya and Queen Elizabeth National Park.
Physical assessments including soils, air and water. There is need for expert knowledge on
specifications on technical equipment.
Society: Socio economic Surveys on food, water and sanitation, health, energy, infrastructure,
education, livelihoods and culture. The population and housing census, demographic and
health survey. Another gap that the EIN should consider is availability of a detailed settlement
map for spatial planning and assessments including scenario analysis
Business and Management: Tourism surveys, fish market Information, agricultural trade
information, transport surveys, forest product trade information, and trends in production of
construction materials. EIN will coordinate with other initiatives e.g. the local content by PEPD
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Clearing House involving information management and coordination. Although the clearing
house is not a theme, it has been given importance because it is going to support the
dissemination of all products of the AG EMP.
Most of these efforts are, however, still to be effected at all levels due to the following barriers:
Lack of timely established National and Local content to guide comprehensive national
participation in oil and gas activities: The national and local content require be legislating
and planning in order to ensure that comprehensinve local capacity is built to contribute to
and participate in the oil industry operations.
Barriers to recruitment at district and local level where inspection and monitoring is
important: Many of the stakeholder institutions are seeking to deploy at district level but a
host of barriers have not enabled this.
Recommendations on capacity building
Urgent recruitment should be undertaken at district levels in the AG of key vacant positions
such as Labor officers, Community development officers, physical planners and at each
municipality, Urban Planners
Review of the concluded capacity needs assessment should be undertaken once the national
and local content plan and legislation are in place. The review should be done to ensure
capacity building and participation of all line sector personnel that is required at national,
district and local levels in handling oil and gas services
By the wide spatial and temporal implication of environmental impacts of oil and gas, there is
need to co-opt more institutions in the EIN to include societal agencies that were not
previously included. The new EIN institutions will require special attention on harmonizing
with EIN principles and data management infrastructure
Sustaining established databases and future updates in the framework of the EIN requires
long term investment in institutional infrastructure and human capacity for the relevant
government agencies. This requires that Government prioritizes data and information
management for oil and gas sector in the framework of the National Development Plan and
National Budget through concerted effort with the resource mobilization pillar with an aim for
sustainability.
Fast-track capacity building of non-state institutions and agencies such as the small and
medium business enterprises and environmental practitioners in order for them to participate
effectively in the new oil and gas sector service delivery.
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6.5 Management of Pollution and Waste
Pollution from petroleum activities may derive from routine activities as well as from accidental
events and can be small and localized to large scale and even trans-boundary depending on the type
of pollution, its extent, the potential for pollution migration and other factors. Pollution in the strict
sense includes all emissions and discharges deriving from the full range of petroleum and associated
activities. However, it is acknowledged that industrial activities cannot be undertaken without certain
levels of e.g. air and noise emissions, liquid and solid waste creation as part of the planned activities.
Unplanned pollution, however, includes for instance chemical, fuel or diesel spills as well as oil spills. Proper management and implementation of stringent procedures for handling of hazardous
chemicals, materials and wastes will reduce the probability of pollution as well as its potential extent
and severity of impact to ecosystems and people. The risk of accidental events can also be reduced
through the use of adequate technology, implementation of sound management practice and
personnel focus and attention. Nevertheless, there is a remaining risk for accidental events and one
of the worst cases is a large oil spill. This section therefore focuses on oil spills and drilling/oily waste
management as both may have severe negative effects on the existing ecosystems and their
supporting functions for the local population and other industry sectors.
6.5.1 Oil spill contingency planning
Currently there is insufficient knowledge about the environmental risks associated with potential oil
spills in the Albertine Graben and beyond. The trans-boundary nature of such spills, the fact that the
catchment drains into the River Nile which flows towards Sudan north of Lake Albert and the border
with DR Congo being situated within Lake Albert requires oil spill contingency planning that
addresses trans-boundary effects. Historic data on failure, oil properties, climate, local meteorology
and environmental sensitivities are important factors in assessing the risk, behaviour, fate and
potential consequences of spilled oil.
The largest volumes of crude oil are likely to be discharged as part of a major blow-out during drilling
of exploration and production wells, oil pipeline rupture in a gathering pipeline or a potential export
pipeline, tank farm or processing spillages and spillages during loading or unloading of crude oil e.g.
to or from trucks, road tankers or railway. Discharge points for an oil spill may therefore vary widely
but include aquatic catchment areas (streams, rivers, lakes) and inland terrestrial environments.
The Oil for Development (OfD) Program currently supports the development of an Environmental
Risk Assessment (ERA) and subsequent Oil Spill Contingency Analysis (OSCA) that shall form the basis
for a National Oil Spill Contingency Plan (NOSCP) for Uganda. The ERA will be a preliminary
assessment based on the current and planned petroleum exploration, production and transportation
activities, potential spill incidents and characteristics, oil behavior, migration and spreading vectors
and impact receptors. Risk mitigation measures are divided into preventive (probability reducing)
measures and consequence reducing measures (contingency). Probability and consequence
classifications for human health and safety, environment and socio-economic factors will lead to
establishment of acceptance criteria. Risk mitigation measures may reduce risk from an unacceptable
to acceptable level.
The OSCA will be based on the results of the ERA and will establish potential spill scenarios, the
required legal basis and response capacity, response contingency including organization, equipment
and procedures for an adequate response system at national, regional and local level for
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governmental bodies as well as operating companies. The final NOSCP has the objective to ensure
timely response to spills or the threat of a spill by detailing a tiered management mechanism that
includes preparedness, response, reporting and communication, policy, legal and institutional
analysis as well as administration and implementation mechanisms of the NOSCP.
Tiered Preparedness and Response is a structured approach that allows potential oil spill incidents to
be categorized in terms of their potential likelihood and severity, and the capabilities that need to be
in place to respond. Figure 6.3 below illustrates the linkages between size of spill, proximity to
operations and respective tier.
Large spill
Medium spill
Small spill
Tier 3
Tier 2
Tier 1
Proximity to operations
Figure 6.3: Usual tiers for oil spill contingency
Tier 1 considers smaller, operational-type spills that may occur at or near an operator own facilities
as a consequence of its own activities. The operator is responsible to provide resources to respond at
this Tier. This usually includes purchase of response capacity from a commercial service provider
specialized in oil spill response.
Tier 2 considers a larger spill in the vicinity of an operator’s facilities where resources from other
companies, industries and possibly government agencies can be called in on a mutual aid basis to
fight a spill.
Tier 3 considers larger spills where substantial further resources will be required to control the spill.
Support from national or even international cooperative stockpile may be necessary.
The fundamental components of preparedness and response are consistent across all tiers of
capability:
spill assessment and notification
management framework and roles and responsibilities
response strategies
equipment
response personnel
training program for all stakeholders
exercises to test and practice the arrangements
escalation and integration for people, equipment and other resources
There are four main types of factors each influencing the way response capabilities are designed and
built; operational factors, baseline factors, response capability factors and legislative factors.
The process of defining the tiers of capability and the boundaries between them is part of a wider
risk management strategy; ensuring that all potential risks are as low as practicable and taking
measures to mitigate the residual consequences.
Examples of factors influencing the response capability needed: 37
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Operational factors Baseline factors
Probability and frequency of a
spill occurring
Spill volume
Oil type
Impact of the spill on operations
Feasibility for adequate response
Proximity of spill to operations
Climate, weather and operating conditions altering fate and
behavior of oil or influencing response operations
Proximity to sensitive environments
Proximity to socio-economic resources
Response capability factor Legislative factors
Tier 1 resources
Availability and capability of
regional Tier 2 options
Access to Tier 3 support
Political stability and culture
Legal requirements regarding response actions or performance
criteria
Influences of national, regional or local authorities
Subscription to designated Tier 2 or Tier 3 support
Assessment of risks and opportunities for current and future petroleum activities
Current petroleum activities
Current exploration and appraisal drilling activities are undertaken by commissioning project-specific
oil spill contingency services by the individual operators. The operators have established a mutual aid
agreement amongst themselves to provide for larger disasters where the individual oil spill
contingency provisions would be insufficient. However, despite the acknowledged sensitivity of the
ecosystems in the region, the vulnerability of wetlands, catchment areas and Lake Albert as well as
the dependency of the local population on the ecosystem services, there is a lack of coordinated
effort above Tier 1 as well as a lack of full scale ERA for planning purposes. In case of a major blow-
out, current resources for oil spill response are likely to be insufficient.
Future petroleum activities
The scale of planned activities ranging from large scale drilling (exploration, appraisal and
production), to storage facilities as well as transportation of crude and processing with possibly
transportation of refinery products requires the establishment and implementation of a full scale
tiered response mechanism. The foreseen fast-track developments and lack of current capacity in
terms of equipment, manpower, coordinated efforts between national, regional and local levels and
training above Tier 1 provisions requires a key focus on oil spill contingency. Low education levels and
the prevailing social structures in the Albertine Graben region require immediate attention regarding
recruiting local manpower, training, reporting lines and coordination amongst relevant institutions
and across the various levels of institution hierarchy.
Recommendations
1) General recommendations
OSCP for sensitive or protected areas shall be based on the following principles:
No activities shall be allowed prior to comprehensive oil spill preparedness being in
place in sensitive or protected areas, e.g. the Murchison Falls or other protected areas,
the Nile crossing, drilling in Lake Albert or wetland areas, trucking of oil and supply
activities in the lakes/Nile systems.
The petroleum industry should establish a joint approach to oil spill response to establish
efficient use of resources and effective spill intervention.
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The development of the NOSCP and the underlying ERA and OSCA shall be undertaken based
on the following principles:
The likely lack of relevant information as input to the ERA, OSCA and subsequently the
NOSCP, requires a streamlining of development planning with the progress of the oil
spill contingency planning and implementation activities. A functioning NOSCP has to
be in place including resources and equipment being available, personnel fully trained
and communication lines tested and fully functioning prior to large scale development
activities. Delays in the current work under the OfD program and its implementation
shall be reflected in the overall development planning.
OSCP has to include consideration of equipment selection and use, use of chemicals,
containment method as well as clean-up and disposal of contaminated materials and
restoration of affected areas. There is therefore a clear link to the establishment of
appropriate waste management procedures and facilities. The development of the
NOSCP and waste management regulation and facilities planning shall be developed in
a coordinated effort.
The scenario analysis undertaken as part of the SEA and any potential updates shall
inform the ERA, OSCA and NOSCP. Information exchange between the SEA Team and
the consultants working on the ERA, OSCA and NOSCP is essential to develop a
streamlined approach. Agreed risk acceptance criteria have to be established as a basis
for decision-making.
Once the NOSCP is in place, regular exercises are vital during the implementation and
later phases to train the response personnel to cooperate efficiently and make complex
decisions under stressful circumstances. Plans, equipment and systems have to be
tested and improved. Roles and responsibilities of the different parties (government,
industry and other) have to be properly reflected.
Budgets for undertaking regular exercises and replacing/adapting equipment have to
be made available by the government and industry.
Oil spill response planning shall be an integral part of Environmental Impact Assessment:
A project-specific ERA shall be part of an EIA for projects with the potential for
significant negative impacts to be submitted for approval to NEMA.
NEMA personnel shall have to be familiar with international ERA approaches to be able
to evaluate the submissions. Capacity building has to be considered for this purpose.
NEMA shall have sufficient manpower and skill to manage the EIA submissions in an
effective and professional manner.
2) Evaluation of future development scenario
As the need and level of activity for oil field development (exploration, appraisal and
production drilling, operation of gathering lines and CPFs, etc.) is similar for all three
scenarios, all of them require adequate and full-scale oil spill contingency planning at all
established tiers.
Scenario 3a has a low probability for a pipeline rupture and associated oil spills as export
pipelines, if properly routed and constructed to international standards, have very low failure
rates as shown by long-term statistics, if sabotage can be controlled. However, the export
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pipeline has least flexibility as it cannot be operated below its minimal operating pressure and
volume for flow assurance reasons. Should extended transportation by other means, e.g.
trucking be required, the risk picture would be much higher.
Scenario 3b in comparison has a much higher accident probability. This is largely related to
loading and unloading activities but also to the higher risk of third party interference such as
accidents at road crossings, animal or people interactions, etc.
Scenario 1 and 2 have a similar risk picture related to oil spills as the refinery is the more
critical part. Furthermore, spills of refinery products transported by truck have a fairly high
probability due to road conditions, potential interference with local people and animals,
especially when crossing populated areas and driving habits. Spills of refined products such as
diesel or kerosene also have a higher environmental impact.
In summary it is important that the oil spill contingency planning, including at a national level
with implementation of Tier 3 is implemented in line with development planning. Any delay in
the development and implementation of the NOSCP and potential Tier 2 provisions has to be
reflected in the progress of development.
6.5.2 Drilling waste and produced water
Generally, during oil and gas activities different waste types are generated. These include anything
from household wastes to hazardous wastes such as batteries, paints, solvents, lubricants,
transformers, medical waste, and sludge from storage tanks, etc. This chapter, however, focuses on
drilling waste and produced water only.
Drilling waste predominantly includes drill cuttings; fluid retained by cuttings, excess drilling or
completion fluid, excess cement slurry and drilled solid cement. Furthermore, waste water (oily and
non-oily), garbage and potential hydrocarbons from production testing will occur.
There are currently two groups of drilling wastes to consider:
a. Legacy waste from previous drilling operations in the AG
Analyses of legacy waste stored in the intermediate waste storage facilities indicate certain
levels of heavy metals. These levels may be related to drilling or cementing fluids used in the
operations or could be related to the drilled rock. Solutions have to be identified for final
disposal of these well defined wastes. Care should be taken to not create cross-
contamination with other waste that has no elevated heavy metal levels.
b. New waste created from current or planned drilling operations waste volumes will be
significant with additional drilling of planned wells. If the heavy metals in the legacy waste
were related to the use of drilling and/or cementing fluids, there is a possibility that new
drilling waste generated will have better properties. However, hydrocarbon content and
potential other components require attention and solutions have to be identified in any case
for regulated final disposal of such waste.
Produced water
Produced water is a special waste that will become an increasing concern especially during the later
stages of hydrocarbon production. Oil and gas reservoirs have so-called formation water that
typically lies underneath the hydrocarbons or is trapped in the reservoir rock. Furthermore, to
achieve maximum oil recovery additional water is often injected into the reservoirs to help force the
oil to the surface. Both the formation water and the injected water are eventually produced along
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with the hydrocarbons. As the field becomes depleted the produced water content of the oil
increases.
Produced water normally has a reservoir specific composition that may include amounts of downhole
production chemicals and treatment and workover chemicals from the production process, dissolved
inorganic salts, dispersed oil droplets, dissolved organic compounds, heavy metals, dissolved gases
(particularly hydrogen sulfide and carbon dioxide), bacteria, dispersed solid particles as well
radionuclides (Naturally Occuring Radioactive Materials, NORM) . The particular concentrations of
these components can vary over an extremely wide range.
The treatment of produced water is a major cost factor in oil and gas production. Furthermore,
produced water has several properties that are often not well understood and ignoring them
complicates the treatment. These include the potential build-up of mineral scales being formed, solid
hydrocarbon deposition (paraffin formation) and changes in pH. Contact with air may result in
deposition of iron compounds and elemental sulfur. Problems associated with produced water
therefore may include plugging of disposal wells by solid particles and suspended oil droplets,
plugging of lines, valves, and orifices due to deposition of inorganic scales, corrosion due to acid
gases and electrochemical reactions of the water with piping and vessel walls, and growth of bacteria
that plug lines and valves or result in the formation of harmful products.
Due to its harmful composition produced water must be either re-used or disposed of adequately. It
can be used as a source of water for injection for reservoir pressure maintenance or enhancement.
If re-use is not an option, produced water is disposed of after treatment or injected underground. If
re-injection is not an option, standards for produced water disposal have to be determined by the
regulator.
Considering the above, pollution from produced water can be minimized by typically these
techniques:
Minimizing produced water volumes close to the source;
Produced water re-injection for pressure maintenance or injection into a separate structure;
Use of environmentally friendly chemicals for scale inhibition, corrosion control, and
flocculants; and
Produced water treatment.
Assessment of risks and opportunities for current and future petroleum activities
The management of waste holds opportunities as well as risks. Risks are related to insufficient waste
management with associated environmental pollution and public health effects. Inadequate waste
management regulations or regulatory enforcement, poor treatment and disposal technologies,
inadequate waste handling and transportation may lead to such effects. The current lack of suitable
waste management regulation and the related current storage at intermediate waste storage sites
increase the risk.
Opportunities are related to business opportunities for waste transporters and facility operators.
Both can create a significant number of long-term jobs and will create the necessary skill basis.
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Recommendations
1) General recommendations
Develop waste management regulation for legacy waste as well as future waste, both liquid
and solid, based on international categorization of waste.
Focus shall not only be given to drilling wastes but to all kinds of hazardous or toxic waste
generated throughout the value chain. This also includes for instance sludge from storage
tanks or pigging, cementing surplus, incinerator ash, batteries, transformers, medical waste,
mercury, paints, solvents, filters, coolants, etc.
Develop regulatory frameworks for waste management operators for different waste types
incl. licensing, auditing, revoking, chain of custody documentation, site management and
transportation, occupational health standards, etc.
Develop capacity within relevant institutions such as NEMA, Local Governments, DWRM and
others regarding waste matters.
Facilitate development of central waste treatment and disposal facilities in accordance with
international standards. All options (biological, thermal, chemical and physical methods) shall
be assessed.
Central facilities will reduce land take and establish clear ownership of waste and liability. On-
site burial shall be an exception to avoid future legacies.Facilities shall have the capacity to
receive contaminated soil and sediment derived from potential oil spill clean-up activities. The
siting of such facilities shall consider the tectonic setting and risk of geohazards.
Maximum allowable discharge levels/discharge thresholds of specific components in waste
for disposal on land incl. heavy metals, salts, hydrocarbons, etc.
Definition of national benchmarks/threshold limits of defined pollutants in soil using
established land use zoning categories
Establish accredited laboratory facilities to monitor and analyze waste compositions
EIAs submitted by project developers shall include a full inventory of chemicals used as well as
an inventory of all wastes produced. Consideration shall be given to least toxic chemicals and
the internationally accepted waste hierarchy (avoid – minimize – reuse – recycle – dispose, in
this order). MSDS sheets shall be submitted as part of the EIA.
Regarding produced water
The formation of scale and possible levels of NORM shall be monitored to avoid cross-
contamination with radionuclides and ecosystem and public health impacts
A solution shall be identified for produced water as a special waste type. It shall be analyzed
for its contents (e.g. hydrocarbons, heavy metals, NORM, mineral salts, solids and organic
and anorganic components). Options shall consider quantities forecasted, components,
receiving environment and potential dispersion factors. All disposal options (discharge with
pre-treatment, evaporation and salt disposal, injection, etc.) shall be evaluated.
Regarding oily waste from oil spills, see key issue no. 11 and related recommendations.
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In Uganda waste management is regulated under the National Environment Act 153 of 1995 and the
Waste Management Regulations (1999). The National Environment Management Authority (NEMA) is
the institution responsible for waste management in its supervisory and co-ordination and
monitoring roles through lead agencies. Other institutions which directly have a role to implement
waste management regulations include Local Governments, Districts, Cities, Municipalities and Town
Boards. These, however, deal with ordinary wastes.
It was noted during the SEA process that current Waste Management Regulations 1999 are
inadequate to manage E&P drilling wastes and produced water. As a result, Uganda’s Waste
Management regulations 1999 are undergoing review to incorporate wastes related to oil and gas
activities. In addition, guidelines for managing drilling waste are being developed. Further policies,
laws and regulations that should undergo review regarding waste considerations include:
The National Environment Policy (1994), Environmental impact assessment regulations (1998),
Environment (Audit) regulations, 2006, The National water Policy (1998), The Water Act Cap153
(1988), Water resources regulations, Effluent discharge regulations , Local Government Act (1997),
Wildlife Policy 1999, and Wildlife Act Cap 2000 (2000), Waste water discharge regulations.
It is recommended that during review of the above policies, laws, regulations and guidelines,
concerned stakeholders should ensure that their reviews are coordinated.
It is also recommended to use expert advice to incorporate international best practice.
Of particular importance is the recently enacted Petroleum (Exploration, Development and
Production) Actl 2013. Waste management is one of the issues in the Act.
It is recommended that final version of clause(s) on waste management is assessed to
determine its implications. If found inadequate, amendments should timely be made.
2) Recommendations related to future development scenarios
The volume of drilling waste created is the same for the three scenarios as exploration and
production will take place in a similar way for all scenarios. Also the amount of produced
water is similar for all scenarios
The total amounts of hazardous waste is higher in Scenario 1 and 2 in comparison to Scenario
3 due to the creation of refinery waste incl. sludge, filter wastes, etc.
Although such waste is not considered as drilling waste, appropriate waste management
facilities as well as waste regulation and adequate handling is vital. The same applies to
sludge from pigging, tank farms, etc.
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7 SUMMARY AND TESTING OF RECOMMENDATIONS. MONITORING
REQUIREMENTS
The goals of this chapter are to:
summarize the recommendations given in Chapter 5 and 6
test whether the recommendations are sustainable and compatible with the NOGP
propose monitoring requirements for the implementation of the recommendations
check whether the SEA is meeting the objectives
check whether the SEA is performed according to international best practice
present concluding advice
7.1 Summary and Testing of Main Recommendations
Based on the results of Chapter 5, this section highlights the recommendations considered to be the
most significant within each Key Issues Group and tests them against the NOGP in terms of
sustainability and compatibility. Tables 7.1 to 7.18 present the results of the evaluations and rank
them according to priority. The ranking is given in numbers and similar numbers indicate equal
priority. Other recommendations given in Chapter 5 are however also valid and should be
implemented to further develop the petroleum sector in Uganda. Furthermore, monitoring
requirements of the implementation of the recommendations are proposed.
The below tables refer to the issue, strategy and actions of the NOGP relevant for each Key Issues
Group.
Table 7.1: Key Issues Group 1- Petroleum related activities in protected and Environmentally
Sensitive Areas
Main Recommendations
1.There is a need to review laws and regulations regarding protected areas and their protection status due to the fact that economic activities such as petroleum developments were not envisaged when designing the existing laws and regulations. This review has to take into consideration the extraordinary environmental value of the protected areas and the risks represented by the petroleum activities. A good example is the extensive petroleum activities taking place in the Murchison Falls National Park.
The same principles as for the protected areas should be applied for the environmentally sensitive areas in order to safeguard their ecosystem functions. Environmentally sensitive areas are those identified in the Environmental Sensitivity Atlas which will be updated regularly.
1. Future petroleum activites not yet licensed shall be based on the Integrated Management Planning recommended to be developed in the near future.
2. The Uganda Forest Policy should be revised to include oil and gas issues, and a timeline should be
set to complete the forest regulations and guidelines for EIA in forest developments.
3. The wetlands policy, regulations and standards need review to incorporate oil and gas issues and
the wetlands specific laws need approval by the Parliament.
4. The Fisheries Act and the National Fisheries Policy should be reviewed to include oil and gas
issues, and lacking fishery control instruments should be put in place.
NOGP Issue
Many of the areas with a potential for hydrocarbon production coincide with areas of important
biodiversity like national parks, water bodies, and game and forest reserves among others. Due
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conside ration will therefore be necessary to ensure harmony between developing the petroleum
resources and conservation.
NOGP Strategy
Objective 9: to ensure that oil and gas activities are undertaken in a manner that conserves the
environment and biodiversity.
- Ensure availability of the necessary institutional and regulatory framework to address
environment and biodiversity issues relevant to petroleum activities.
- Ensure the presence of necessary capacity and facilities to monitor the impact of petroleum
activities on environment and biodiversity.
- Require oil companies and their contractors/subcontractors to use self regulation and best
practices in ensuring environmental protection and biodiversity conservation.
- Require oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
Consideration of using finite resources to create lasting benefits to society.
The activities of the current generation shall not put a burden on future generations and resources
shall be used to inter-generation equity.
There shall be a neatly balance between environment, human development and biodiversity for
mutual benefit and survival.
The NOGP shall contribute and promote sustainable development.
It is the responsibility of the licensed oil companies to protect the environment where they work or
any areas in the country impacted by their operations while the government shall legislate, regulate
and monitor compliance.
NOGP Actions
Upgrade relevant environment and biodiversity legislation to address oil and gas activities.
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
environment and biodiversity.
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridors.
Sustainability and Compatibility Testing
The NOGP is broad and conservation of the environment and biodiversity are objectives clearly
stated. The protection of forest resources, wetlands and fisheries can be seen as part of the overall
environmental protection goals.
The NOGP does not specifically mention protected and sensitive areas. Uganda holds numerous
protected areas of various protection statuses and there has been reason for such designations. This
includes biodiversity and endemism aspects as well as environmental conservation and such
considerations shall be considered in the petroleum sector planning.
The NOGP states that there shall be a balance between environment, human development and
biodiversity for mutual benefit and survival.
Industrial activities shall only be allowed as an exemption in protected areas and only in case no
significant negative impacts can be identified as a key principle of EIA best practice.
Biodiversity assets are renewable and, if managed well, can provide continued support to economic
and human development.
The SEA provides recommendations on how to consider environmentally sensitive and protected
areas and biodiversity
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Proposal for monitoring Key Issues Group 1
Issue Monitoring indicators Responsible Institutions
Consideration of environmentally
sensitive and protected areas
Management systems
Consideration in integrated
management plans
NEMA, PEPD, UWA and
other relevant
institutions
An environmental monitoring plan for
the Albertine Graben has been
developed for the period 2012 – 2017
(AG EMP). It covers VECs of aquatic
and terrestrial ecosystems,
physical/chemical sampling of soil, air
and water, societal parameters and
business and management aspects.
Implementation of this monitoring
plan has to be followed up in
accordance with the plan.
The indicators, data collection
and analysis described in the AG
EMP shall be used for
monitoring.
The data collected shall be
managed through the EIN in line
with its key objectives to create
a publicly available, efficient and
transparent platform.
NEMA,
NaFIRRI/DFR,
NFA,
DWRM, DWD
Wetlands Management
Dept.
Physical Planning Dept.
Surveys and Mapping
Dept.
and other relevant
institutions
Link requirements for project specific
monitoring by oil companies with the
requirements of the AG EMP and
incorporate the data.
Delivery of monitoring results by
oil companies as an EIA
requirement to be used as input
for EIN.
NEMA
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Table 7.2: Key Issues Group 2 - Co-existence with Local Communities
Main Recommendations
1. Local communities will experience opportunities as well as risks. The capacity to adapt to the
changing framework conditions has to be a key focus and long-term socioeconomic benefits
have to be ensured. A social development plan should therefore be developed. The scenario
analysis reveals the presence of large numbers of workforce, especially during construction
periods and points at significant in-migration. The planning of urbanization and required
associated infrastructure has to be advanced in line with petroleum development planning to
avoid social tension and lack of capacity of infrastructure.
1. Social development investments: On issues of social development including communities coping
with the growing sector a comprehensive integrated development program similar to Northern
Uganda Social Action Fund or the Nile Basin program should be established to address issues of:
HIV/AIDS
Co-existence of agricultural systems with the oil and gas sector
Community infrastructural planning programs including social and economic infrastructure
Conflict resolution
Expectation management
Alternative income generating activities
2. Education and awareness on management of social issues: The Ministry of Gender, Labor and
Social Development has all the policies and guidelines in place, but the linkage to other sectors
such as the petroleum sector should be strengthened.
3. Strengthening land administration systems: Generally, the legal framework for land
administration exists through land communities at district level. Training materials and
sensitization materials for land acquisition are available at the Ministry of Lands, Housing and
Urban Development. The Ministry requires a budget to translate into local languages in the
Albertine Graben and the district land boards need to be trained.
NOGP Issue
Co-existence with local communities is not mentioned explicitly in the NOGP.
NOGP Strategy
Objective 10 supports mutually beneficial relationships between all stakeholders by recognizing and
promoting the different roles of the state, the oil companies and other stakeholders
NOGP Actions
Carrying out consultations with stakeholders especially in the oil and gas producing areas
Sustainability and Compatibility Testing
The NOGP only mentions mutually beneficial relationships between the oil sector and other
stakeholders. The strategies and actions point at general stakeholder consultation but not real co-
existence mechanisms.
Not covered are co-existence mechanisms, sustainable alternative livelihood schemes, inclusive
social development programs and management of in-migration vis-à-vis local communities. The
livelihoods of local communities are already fragile and infrastructure is predominantly poor.
The SEA provides recommendations how to progress co-existence issues with local communities
and avoid social tension.
Proposal for monitoring Key Issues Group 2
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Issue Monitoring indicators Responsible
Institutions
The NOGP does not provide mechanisms for
co-existence with local communities
Co-existence mechanisms PEPD and other
relevant
institutions and
local governments
An environmental monitoring plan for the
Albertine Graben has been developed for the
period 2012 – 2017 (AG EMP). It also includes
consideration of settlement, food, culture and
business parameters. Implementation of this
monitoring plan has to be followed up in
accordance with the plan.
The indicators, data collection
and analysis described in the
AG EMP shall be used for
monitoring.
The data collected shall be
managed through the EIN in
line with its key objectives to
create a publicly available,
efficient and transparent
platform.
NEMA,
NaFIRRI/DFR,
NFA, DWRM,
DWD, Wetlands
Management
Dept.,
Physical Planning
Dept.,
Surveys and
Mapping Dept.and
other relevant
institutions
In-migration Change in settlement and
livelihood indicators and
crime rates over time
Ministry of
Gender, Labor and
Social
Development
Social development Implementation of inclusive
social development programs
Ministry of
Gender, Labor and
Social
Development
Table 7.3: Key Issues Group 3 - Co-existence with Archaeology and Cultural Heritage
Main Recommendations
1. The Historical Monuments Act should be expeditiously amended to include matters related to the
petroleum industry as well as to capture specifically all matters that concern cultural heritage in
the country. This will go a long way in giving the principle legislation a face lift matched by the rest
of the world. Cultural/archaeological impact assessments including baseline surveys shall be
undertaken as part of the EIA process and reviewed by the competent institution.
2. The sanctions and penalties enforced/ administered on transgressors and perpetual offenders of
cultural heritage property should be revised, strengthened and possibly increased so as to serve a
meaningful objective and more applicable.
3. Uganda should readily adopt more International Treaties and Conventions concerning
Cultural Heritage. There are several international instruments that Uganda has not yet ratified and
transposed into national law.
NOGP Issue
Cultural heritage is not explicitly mentioned in the NOGP.
NOGP Strategy
No strategy to safeguard such irretrievable assets is found in the NOGP.
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NOGP Actions
No actions are mentioned
Sustainability and Compatibility Testing
Safeguarding cultural heritage is not mentioned in the NOGP.
Cultural heritage is an important aspect of cultural and national identity. As cultural heritage is
irretrievable once destroyed or severly impacted, safeguards have to be implemented with a focus of
physically avoidance during siting and routing as part of oil and gas activities and associated
infrastructure planning.
The SEA provides recommendations on how to improve consideration of archaeology and cultural
heritage.
Proposal for monitoring Key Issues Group 3
Issue Monitoring indicators Responsible
Institutions
Consideration of physical and intangible
cultural heritage for the oil and gas regions
as well as export options and corridors
Adequate consideration in EIA NEMA, Ministry of
Tourism, Wildlife
and Antiquities
An environmental monitoring plan for the
Albertine Graben has been developed for
the period 2012 – 2017 (AG EMP). It also
includes monitoring of archaeological/
cultural sites. Implementation of this
monitoring plan has to be followed up in
accordance with the plan.
The indicators, data collection and
analysis described in the AG EMP
shall be used for monitoring.
The data collected shall be
managed through the EIN in line
with its key objectives to create a
publicly available, efficient and
transparent platform.
NEMA,
NaFIRRI/DFR,
NFA, DWRM,
DWD, Wetlands
Management
Dept.,
Physical Planning
Dept.,
Surveys and
Mapping Dept.
and other relevant
institutions
Link requirements for project specific
survey requirements and monitoring by oil
companies with the requirements of the
AG EMP and incorporate the data.
Delivery of monitoring results by
oil companies as an EIA
requirement to be used as input
for EIN.
NEMA
Inclusion of physical and intangible
cultural heritage as part of EIA
Inclusion of appropriate
information in EIAs
NEMA
MTWA,
Dept. of
community
development in
affected districts
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Table 7.4: Key Issues Group 4 - Co-existence with Other Industries and Service Providers
Main Recommendations
1. The petroleum industry should be required to offer capacity building programs for existing and
potential new businesses with the aim of preparing them for delivery of goods and services to the
petroleum industry in good time before any activities take place. This is to make the potential
local companies competitive.
2. The Government should develop local infrastructure supporting the involvement of local
companies.
3. The Government should provide relevant public utilities such as sewage or energy for extended
or new urban centers.
NOGP Issue
Co-existence with other industries and service providers is not mentioned explicitly in the NOGP but
indirectly stated as part of national participation.
NOGP Strategy
Objective 7 states optimum national participation by
- promoting the country’s materials, goods and services in oil and gas sector activities
- promoting the country’s entrepreneurs in providing goods and services
- promoting public private partnerships
Objective 8 supports the development of national expertise by
- identifying training skills required for the sector
- utilizing oil and gas activities to support provision of training
- promoting the provision of national goods and services as a way of building national
expertise
- broadening national education curricula
Objective 10 supports mutually beneficial relationships between all stakeholders
NOGP Actions
- Put in place the necessary regulatory framework for national content
- Identify opportunities for national content and plan for its implementation
- Review and expand curricula
- Require oil companies and subcontractors to provide training to Ugandans
Sustainability and Compatibility Testing
The NOGP takes a broad and bold view on optimizing national content but is not specific with
respect to achievable goals and the enhancement of opportunities. Experience has shown that
significant efforts have to be made by the government and oil companies to enable national
industry to participate in the sector. Without targeted, early and continuous training programs on
issues such as HSE, procurement requirements, quality assurance, etc. national content is likely to
be low and restricted to unskilled labor. The implementation of appropriate curricula with adequate
quality is also essential.
In addition to enhancing local content, the SEA provides further recommendations on developing
infrastructure and utilities.
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Proposal for monitoring Key Issues Group 4
Issue Monitoring indicators Responsible Institutions
Securing of adequate level of local
content
Recommendation of on-
going local content study to
be implemented.
Plans for developing infra-
structure and utilities
PEPD and other relevant
institutions
An environmental monitoring plan for the
Albertine Graben has been developed for
the period 2012 – 2017 (AG EMP). It also
includes consideration of water and
sanitation, mineral resources and
construction materials and energy.
Implementation of this monitoring plan
has to be followed up in accordance with
the plan.
The indicators, data
collection and analysis
described in the AG EMP
shall be used for
monitoring.
The data collected shall be
managed through the EIN
in line with its key
objectives to create a
publicly available, efficient
and transparent platform.
NEMA,
NaFIRRI/DFR,
NFA,
DWRM, DWD,
Wetlands Management
Dept.,
Physical Planning Dept.,
Surveys and Mapping
Dept. and other relevant
institutions
Table 7.5: Key Issues Group 5 - Co-existence with Tourism
Main Recommendations
1. See also recommendations for Key Issues Group 1 – protected and sensitive areas as these are
focus areas for tourism.
2. There should be regulations on the maximum acceptable disturbance levels of oil and gas
activities taking the tourism sector views into consideration.
NOGP Issue
Co-existence with other sectors, such as tourism is not mentioned explicitly in the NOGP
NOGP Strategy
Objective 9 supporting conservation of environment and biodiversity which indirectly supports
tourism if well managed.
Objective 10 supports mutually beneficial relationships between all stakeholders by recognizing and
promoting the different roles of the state, the oil companies and other stakeholders
NOGP Actions
Carrying out consultations with stakeholders especially in the oil and gas producing areas
Sustainability and Compatibility Testing
The NOGP mentions mutually beneficial relationships between the oil sector and other stakeholders.
Tourism itself is not explicitly mentioned. The strategies and actions stated point at general stake-
holder consultation but not real co-existence mechanisms.
Tourism is an important economic factor that should not be put at risk due to oil and gas operations.
The SEA focuses on the strong linkage between tourism and environmentally sensitive and protected
areas.
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Proposal for monitoring Key Issues Group 5
Issue Monitoring indicators Responsible
Institutions
Risk of loss of business for tourism sector Co-existence mechanisms PEPD and other
relevant
institutions and
the tourism sector
An environmental monitoring plan for the
Albertine Graben has been developed for the
period 2012 – 2017 (AG EMP). It also includes
consideration of tourism parameters.
Implementation of this monitoring plan has to
be followed up in accordance with the plan.
The indicators, data
collection and analysis
described in the AG EMP
shall be used for monitoring.
The data collected shall be
managed through the EIN in
line with its key objectives to
create a publicly available,
efficient and transparent
platform.
NEMA,
NaFIRRI/DFR,
NFA,
DWRM, DWD,
Wetlands Manage-
ment Dept.,
Physical Planning
Dept.,
Surveys and
Mapping Dept.
and other relevant
institutions
Table 7.6: Key Issues Group 6 - Co-existence with Fisheries
Main Recommendations
1. Develop regulatory frameworks to operationalize the Fisheries Policy (2004).
2. Strengthen strategies and plans for water resources assessment, monitoring and allocation to
multiple uses with particular focus on protecting sensitive aquatic ecosystems in the AG.
3. Strengthen the multi-institutional approach to fisheries administration and management, setting
clear mandates and modes of interaction and coordination amongst the key institutional actors
namely the Department of Fisheries Resources (DFR), District Local Governments and
community representatives for example BMUs.
4. Develop plans and programs to:
map critical breeding, nursery and feeding grounds for major commercial fish species;
identify year class recruitment strategies; and model population dynamics of major commercial fish species for management purposes,
track and mitigate impacts of pollution from petroleum activities on the aquatic environment and fisheries;
map the hydrodynamics of major lakes in the AG for input into oil spill contingency planning; promote sustainable aquaculture and other viable non-capture fisheries in the AG as a relief
measure to fishing pressure on lake fisheries.
NOGP Issue
Co-existence with other sectors, such as fisheries is not mentioned explicitly in the NOGP. However, it
is stated that petroleum activities are likely to improve access to fishing communities and
consequently improved marketing opportunities for fish, while negative effects due to release of gas
may be detrimental.
NOGP Strategy
Objective 10 supports mutually beneficial relationships between all stakeholders by recognizing and
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promoting the different roles of the state, the oil companies and other stakeholders
NOGP actions
Carrying out consultations with stakeholders especially in the oil and gas producing areas
Sustainability and Compatibility Testing
The NOGP mentions mutually beneficial relationships between the oil sector and other stakeholders.
The strategies and actions point at general stakeholder consultation but not real co-existence
mechanisms. Fisheries, at subsistence level as well as on an economic scale, are important for
Uganda and shall not be put at risk.
The likely increase in demand on fish and access to markets requires stringent regulation of the
fisheries sector.
The SEA goes beyond the focus of the NOGP and provides recommendations on improving the
knowledge basis on the fisheries sector and co-existence.
Proposal for monitoring Key Issues Group 6
Issue Monitoring indicators Responsible Institutions
Risk of loss of income or
livelihoods on fisheries.
Co-existence mechanisms. PEPD and other relevant
institutions and the
fisheries sector
An environmental monitoring
plan for the Albertine Graben has
been developed for the period
2012 – 2017 (AG EMP).
It also includes consideration of
fisheries parameters.
Implementation of this moni-
toring plan has to be followed up
in accordance with the plan.
The indicators, data collection
and analysis described in the AG
EMP shall be used for monitoring.
The data collected shall be
managed through the EIN in line
with its key objectives to create a
publicly available, efficient and
transparent platform.
NEMA, NaFIRRI/DFR,
NFA, DWRM, DWD,
Wetlands Management
Dept., Physical Planning
Dept., Surveys and
Mapping Dept.
and other relevant
institutions
Table 7.7: Key Issues Group 7 - Sharing of Revenues and Wellbeing between the National and
Local/Regional Level. Co-operation
Main Recommendations
1. Develop a flexible revenue sharing mechanism, taking into account not only the size of the
petroleum production and population size, but the impacts of the oil activities on the alternative
sources of income for the districts.
2. Revise revenue share incomes so as to minimize the value loss due to inflation.
3. Give districts the autonomy to spend the money on priority projects with the central
Government playing a supervisory role.
NOGP Issue
Consideration of using finite resources to create lasting benefits to society.
The activities of the current generation shall not put a burden on future generations and resources
shall be used to inter-generation equity.
Efficient resource management promotes efficient revenue management by ensuring that
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petroleum revenues are used to boost balanced growth and sustainable development. Revenues
shall be used for durable investments like infrastructure development and other activities which
contribute to lowering the cost of doing business in the country.
High standards of transparency and accountability include simple and easily understood financial
reporting principles. The public sector aims to maximize returns to the society both for current and
future generations.
NOGP Strategy
Objective 6 states ensuring the collection of the right revenues and use to create lasting value to the
society by
- Identifying and documenting the different sources of revenues
- Publishing the revenues received regularly
- Ensuring equity, fairness and transparency in the use of revenues
- Utilizing revenue to support strategic areas such as education, research, infrastructure
development, etc.
- Putting in place a sustainable asset in form of a petroleum fund
- Taking into account the interests of local governments and stakeholders and sharing of
royalties in accordance with the Constitution
NOGP Actions
Put in place a law to regulate the payment, sharing, use and management of revenues
Put in place the necessary institutional framework for revenue collection and management
Participate in the processes of the Extractive Industries and Transparency Initiative (EITI)
Sustainability and Compatibility Testing
The NOGP is fairly explicit in its strategy and actions on revenue management and the
implementation is crucial to avoid social tension. The society is considered as a whole and no
differentiation is made between national and local/regional level.
The SEA provides recommendations supporting this policy.
Proposal for monitoring Key Issues Group 7
Issue Monitoring indicators Responsible
Institutions
The NOGP strategies and actions for
revenue management shall be
implemented
Timely implementations of strategies and
actions mentioned.
Relevant
institutions
Role of civil society and local
governments to oversee revenue
management
Involvement of CSOs, NGOs and local
governments in discussions on revenue
sharing discussions.
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Table 7.8: Key Issues Group 8 - Discharge and Emissions for the Petroleum Industry
Main Recommendations
1. Develop air, noise, vibration and discharge regulations incl. average thresholds and peak limits
over periods of time in line with international standards. Special limits shall be considered for
protected and sensitive areas. Occupational health exposure limits shall be defined and
monitored.
2. Develop national benchmarks/ threshold limits of defined pollutants using established land use
zoning categories (residential, agricultural, industrial, etc.) to safeguard environmental quality and
public health
3. Establish accredited laboratory facilities to monitor and analyze emissions and discharge from the
petroleum industry.
NOGP Issue
Protection of the environment and biodiversity. Due consideration will be necessary to ensure
harmony between developing the petroleum resources and conservation.
NOGP Strategy
Objective 9: to ensure that oil and gas activities are undertaken in a manner that conserves the
environment and biodiversity.
- Ensure availability of the necessary institutional and regulatory framework to address
environment and biodiversity issues relevant to petroleum activities.
- Ensure the presence of necessary capacity and facilities to monitor the impact of petroleum
activities on environment and biodiversity.
- Require oil companies and their contractors/subcontractors to use self regulation and best
practices in ensuring environmental protection and biodiversity conservation.
- Require oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
The activities of the current generation shall not put a burden on future generations.
There shall be a neatly balance between environment, human development and biodiversity for
mutual benefit and survival.
The NOGP shall contribute and promote sustainable development.
NOGP Actions
Upgrade relevant environment and biodiversity legislation to address oil and gas activities.
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
environment and biodiversity.
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridors.
Sustainability and compatibility testing
The NOGP is broad and conservation of the environment and biodiversity are objectives clearly
stated.
The management of emissions and discharges related to routine operations of the petroleum sector
is not mentioned specifically. Furthermore, public as well as occupational health is not mentioned.
The SEA provides recommendations regarding regulations and laboratory infrastructure.
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Proposal for monitoring Key Issues Group 8
Issue Monitoring indicators Responsible
Institutions
Regulations Air, noise, vibration and discharge
regulation.
Occupational health exposure limits and
monitoring requirements.
Land use zoning categories and asso-
ciated threshold limits for pollutants.
NEMA and other
relevant institutions
Monitoring laboratory Establishment of laboratory facilities.
Accreditation to international standards.
NEMA
An environmental monitoring
plan for the Albertine Graben
has been developed for the
period 2012 – 2017 (AG EMP).
It includes physical/chemical
sampling of soil, air and water
as well as health parameters.
Implementation of this
monitoring plan has to be
followed up in accordance with
the plan.
The indicators, data collection and
analysis described in the AG EMP shall
be used for monitoring.
The data collected shall be managed
through the EIN in line with its key
objectives to create a publicly available,
efficient and transparent platform.
NEMA, NaFIRRI/DFR,
NFA, DWRM, DWD,
Wetlands Management
Dept., Physical Planning
Dept., Surveys and
Mapping Dept.
and other relevant
institutions
EIA Requirement for full emission and
discharge inventory for EIA.
Monitoring of EIA forecasts against real
discharges and emissions.
NEMA
Table 7.9: Key Issues Group 9 - Waste Management
Main Recommendations
1. Develop waste management regulation for legacy waste as well as future waste, both liquid and
solid, based on international categorization of waste
2. Develop regulatory frameworks for waste management operators for different waste types incl.
licensing, auditing, revoking, chain of custody documentation, site management and
transportation, occupational health standards, etc.
3. Facilitate development of central waste treatment and disposal facilities in accordance with
international standards. All options (biological, thermal, chemical and physical methods) shall be
assessed. Central facilities will reduce land take and establish clear ownership of waste and
liability. On-site burial shall be an exception to avoid future legacies. Facilities shall include
capacity for contaminated soil and sediment as part of potential future oil spill clean-up activities.
NOGP Issue
Protection of the environment and biodiversity. Due consideration will be necessary to ensure
harmony between developing the petroleum resources and conservation.
NOGP Strategy
Objective 9: to ensure that oil and gas activities are undertaken in a manner that conserves the
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environment.
- Ensure availability of the necessary institutional and regulatory framework to address
environment and biodiversity issues relevant to petroleum activities.
- Ensure the presence of necessary capacity and facilities to monitor the impact of petroleum
activities on environment.
- Require oil companies and their contractors/subcontractors to use self regulation and best
practices in ensuring environmental protection.
- Require oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
The activities of the current generation shall not put a burden on future generations.
The NOGP shall contribute and promote sustainable development.
NOGP Actions
Upgrade relevant environment legislation to address oil and gas activities.
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
environment and biodiversity.
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridors.
Sustainability and Compatibility Testing
The NOGP is broad and conservation of the environment and biodiversity are objectives clearly
stated.
Waste management is mentioned under impacts and supports the review, updating and
implementation of waste disposal standards together with the establishment and enforcement of the
necessary monitoring, evaluation and control mechanisms.
The SEA is focusing on the lack of appropriate waste management regulation and appropriate
facilities.
Proposal for monitoring Key Issues Group 9
Issue Monitoring indicators Responsible Institutions
Regulations Waste management
regulation.
NEMA and other relevant institutions
Waste facilities Central waste treatment and
disposal facilities following
international standards
NEMA and other relevant institutions
Waste operators Audit requirements
Compliance monitoring.
NEMA and other relevant institutions
An environmental monitoring plan for the Albertine Graben has been developed for the period 2012 – 2017 (AG EMP). It includes physical/chemical sampling of soil, air and water as well as health parameters. Implementation of this monitoring plan has to be followed up in
The indicators, data collection
and analysis described in the
AG EMP shall be used for
monitoring.
The data collected shall be
managed through the EIN in
line with its key objectives to
NEMA, NaFIRRI/DFR, NFA, DWRM, DWD, Wetlands Management Dept., Physical Planning Dept., Surveys and Mapping Dept. and other relevant institutions
Page 121
accordance with the plan. create a publicly available,
efficient and transparent
platform.
EIA Requirement for full inventory
of liquid and solid waste
volumes by waste type
NEMA
Table 7.10: Key Issues Group 10 - Water Management
Main Recommendations
1. Review of the National Water Policy, Act and associated abstraction, use and discharge
regulations to incorporate standards relating to oil and gas activities.
2. There is need to review and integrate petroleum development related water resources issues in
the annual local government rural water and sanitation work planning in the districts of the AG.
3. Create a central database, regularly updated, for information accessible to central and local
governments.
NOGP Issue
Protection of the environment. Due consideration will be necessary to ensure harmony between
developing the petroleum resources and conservation.
NOGP Strategy
Objective 9: to ensure that oil and gas activities are undertaken in a manner that conserves the
environment.
- Ensure availability of the necessary institutional and regulatory framework to address
environment and biodiversity issues relevant to petroleum activities.
- Ensure the presence of necessary capacity and facilities to monitor the impact of petroleum
activities on environment.
- Require oil companies and their contractors/subcontractors to use self regulation and best
practices in ensuring environmental protection.
- Require oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
The activities of the current generation shall not put a burden on future generations.
The NOGP shall contribute and promote sustainable development.
NOGP Actions
Upgrade relevant environment legislation to address oil and gas activities.
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
environment and biodiversity.
Sustainability and Compatibility Testing
The NOGP is broad and conservation of the environment is clearly stated.
The management of water resources is not mentioned specifically.
The SEA is focusing on the large quantities of water necessary for the oil production. The rift valley
is relatively arid and large scale water abstraction may lead to decreasing groundwater levels and
changes in groundwater quality and may thus have negative effects for local communities and
users. A decrease in the water level of Lake Albert would impact on coastal ecosystems and
associated fish, amphibian and bird habitats amongst other.
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Proposal for monitoring Key Issues Group 10
Issue Monitoring indicators Responsible Institutions
Regulations Review of National Water Policy
and related regulations
DWRM, DWD
An environmental monitoring
plan for the Albertine Graben
has been developed for the
period 2012 – 2017 (AG EMP).
It includes potable water
sources.
Implementation of this
monitoring plan has to be
followed up in accordance
with the plan.
The indicators, data collection and
analysis described in the AG EMP
shall be used for monitoring.
The data collected shall be
managed through the EIN in line
with its key objectives to create a
publicly available, efficient and
transparent platform.
NEMA, NaFIRRI/DFR, NFA,
DWRM, DWD, Wetlands
Management Dept.,
Physical Planning Dept.,
Surveys and Mapping Dept.
and other relevant
institutions
EIA Requirement to assess necessary
water abstraction volumes over
time and sources of abstraction
Monitoring of EIA forecasts against
abstracted volumes
NEMA
Table 7.11: Key Issues Group 11- Oil Spill Preparedness on Land and Surface Waters
Main Recommendations
1. A functioning NOSCP has to be in place including resources and equipment being available,
personnel fully trained and communication lines tested and fully functioning prior to large scale
development activities.
2. In case relevant input data for the environmental risk assessment, oil spill contingency analysis
and subsequent NOSCP is missing, these gaps shall be filled as soon as possible.
2. This plan should be coordinated with public infrastructure development plans and should be
the basis for provision of specific oil spill response equipment, training needs, etc.
3. There is a need to coordinate efforts between the NOSCP and establishing waste management
procedures/facilities and the development of new public infrastructure.
NOGP Issue
Protection of the environment. Due consideration will be necessary to ensure harmony between
developing the petroleum resources and conservation.
NOGP Strategy
Objective 9: to ensure that oil and gas activities are undertaken in a manner that conserves the
environment.
- Ensure availability of the necessary institutional and regulatory framework to address
environment and biodiversity issues relevant to petroleum activities.
- Ensure the presence of necessary capacity and facilities to monitor the impact of petroleum
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activities on environment.
- Require oil companies and their contractors/subcontractors to use self regulation and best
practices in ensuring environmental protection.
- Require oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
The activities of the current generation shall not put a burden on future generations.
The NOGP shall contribute and promote sustainable development.
The Polluter-Pays-Principle shall apply.
NOGP Actions
Upgrade relevant environment legislation to address oil and gas activities.
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
environment and biodiversity.
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridor.
Sustainability and Compatibility Testing
The NOGP is broad and conservation of the environment as well as oil spill preparedness is clearly
stated. Furthermore, it is stated that relevant institutions are supported to put in place disaster
preparedness and response mechanisms for oil spill preparedness.
The SEA is also focusing on the coordination between the NOSCP, the development of waste
procedures and facilities as well as development of new infrastructure.
Proposal for monitoring Key Issues Group 11
Issue Monitoring indicators Responsible Institutions
Adequate oil spill
contingency
NOSCP
Implementation of NOSCP
Frequency and success of exercises
PEPD, NEMA, fire brigade and
other relevant institutions
EIA Requirement to include an ERA as part of the EIA NEMA
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Table 7.12: Key Issues Group 12 - Infrastructure Development in the Region and Transportation of
Crude, Products and Construction Materials
Main Recommendation
1. Cooperation of the petroleum sector and the Ministry of Works and Transport, UNRA and local
governments should be strengthened to ensure that the needs of the petroleum sector are
integrated in the overall infrastructure planning and budgeting. UWA should be involved in the
planning to ensure concerns regarding protected areas and sensitive habitats are considered.
1. Alternative means of transport need to be developed and include railway, air and water transport
as well as pipeline transportation for crude.
NOGP Issue
Consideration of using finite resources to create lasting benefits to society.
The activities of the current generation shall not put a burden on future generations and resources
shall be used to inter-generation equity.
NOGP Strategy
Objective 5 states the promotion of suitable transport and storage solutions which give good value
to the country’s oil and gas resources by:
- Promoting efficient development and utilization of transport corridors and storage facilities.
- Prioritizing transport methods giving due recognition to cost and efficiency together with
health, safety and environment considerations.
Objective 6 is about ensuring collection of the right revenues and using them to create lasting value
for the entire society by:
- Utilizing petroleum revenues for supporting strategic areas of the national economy like
development of infrastructure and other activities
NOGP Actions
Evaluate existing transport systems with a view of establishing their importance to oil and gas
transportation together with identifying additional requirements.
Put in place the necessary regulatory framework for the utilization of transport corridors
Support development of necessary transport infrastructure for oil and gas
Put in place a law to regulate the payment, sharing, use and management of revenues accruing
from oil and gas activities (Objective 6)
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridors (Objective 9)
Sustainability and compatibility testing
The NOGP is broad and development of infrastructure is mentioned in the context of the
transportation of oil and gas resources and in terms of revenue use to create benefits to the society.
The scenario analysis of the SEA identifies the significant extent of road transportation required.
This exemplifies the need for coordinated efforts on physical planning and infrastructure
development. Recommendations are given.
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Proposal for monitoring Key Issues Group 12
Issue Monitoring indicators Responsible Institutions
Adequate coordination and planning
of infrastructure
Infrastructure master plan
Implementation schedules and
relevant annual budgets
Ministry of Works
Physical Planning Dept.
UNRA, etc.
Table 7.13: Key Issues Group 13 - Institutional Capacity Building. Structure and Functions
Main Recommendations
1. Both, new institutions to be established and existing ones require awareness, training and
infrastructure for handling their mandate in managing the petroleum industry.
1. Ensure capacity and adequately staff and budget ministries that regulate the petroleum sector,
such as Ministry of Tourism, Wildlife and Antiquities; NEMA; MEMD; Ministry of Finance and
Planning; Ministry of Justice; Labour; Education at all levels.
2. Effort shall be made to train NEMA staff and other relevant supervisory agency staff to scrutinize
and review EIAs related to the petroleum sector.
NOGP Issue
Capacity and institutional building is a key principle to enable the country to participate in, and
benefit from oil and gas activities. Institutional capacity building shall entail development of the
necessary regulatory framework, infrastructure and manpower. It necessitates the introduction of
new legislation and institutions, together with enhancement of existing ones.
NOGP Strategy
Objective 8 supports the development and maintenance of national expertise by:
- Providing appropriate training to Government personnel in relevant fields
Objective 9 is about ensuring that oil and gas activities are undertaken in a a manner that conserves
the environment and biodiversity by:
- Ensuring availability of the necessary institutional and regulatory framework to adress
environment and biodiversity issues relevant to oil and gas activities.
- Ensuring the presence of the necessary capacity to monitor impacts on environment and
biodiversity
Upgrading of the existing regulatory framework by putting in a new law on administration of oil and
gas activities and a law for the management of oil and gas revenues. Establishment of new
institutions (NATOIL, PAU, etc.)
NOGP Actions
Train government personnel in monitoring oil and gas exploration, development and production
Require oil companies and subcontractors to provide training to Ugandans
Upgrade relevant environment and biodiversity legislation (Objective 9)
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
the environment and biodiversity (Objective 9)
Sustainability and Compatibility Testing
The NOGP recognizes the need to strengthen capacity of existing institutions and establishment of
new institutions in addition to legislation. Focus is given on establishing new institutions under the
Ministry of Energy and Mineral Development for the upstream sector such as a national oil
Page 126
company (NATOIL), a Petroleum Authority of Uganda (PAU), and a Petroleum Directorate but the
roles of other ministries and agencies as well as civil society is also acknowledged
The SEA also considers development of capacity for other institutions such as NEMA, other
ministries, etc.
Proposal for monitoring Key Issues Group 13
Issue Monitoring indicators Responsible
Institutions
Capacity
building
Training plans
Recruiting strategies
Implementation schedules and relevant annual
budgets
All relevant institutions
Table 7.14: Key Issues Group 14 - Capacity of District Local Governments to Manage Environmental
Concerns
Main Recommendations
1. Environmental management should be given high priority when preparing district budgets. More
skilled personnel should also be recruited at the districts to fill vacant posts in the environment
and natural resources fields. A specific program should be developed and implemented for
capacity building on environmental management related to the oil and gas sector in the AG.
2. Both, new institutions to be established and existing ones, require awareness, training and
infrastructure for handling their mandate in the industry. This can be achieved by strengthening
cooperation between the petroleum industry, PEPD and local governments (districts).
2. There is need for improved coordination between the districts and the relevant central
Government departments and the information flow channels should be clearly outlined and
followed.
3. Environmental and socio-economic data available at central Government departments and
agencies should be available to the districts. Extra data should be collected to fill any gaps.
NOGP Issue
Capacity and institutional building is a key principle to enable the country to participate in, and
benefit from oil and gas activities. Institutional capacity building shall entail development of the
necessary regulatory framework, infrastructure and manpower. It necessitates the introduction of
new legislation and institutions, together with enhancement of existing ones.
NOGP Strategy
Objective 8 supports the development and maintenance of national expertise by:
- Providing appropriate training to Government personnel in relevant fields
Objective 9 is about ensuring that oil and gas activities are undertaken in a a manner that conserves
the environment and biodiversity by:
- Ensuring availability of the necessary institutional and regulatory framework to adress
environment and biodiversity issues relevant to oil and gas activities.
- Ensuring the presence of the necessary capacity to monitor impacts on environment and
biodiversity
Page 127
NOGP Actions
Train government personnel in monitoring oil and gas exploration, development and production
Require oil companies and subcontractors to provide training to Ugandans
Upgrade relevant environment and biodiversity legislation (Objective 9)
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on the
environment and biodiversity (Objective 9)
Sustainability and Compatibility Testing
The NOGP recognizes the need to strengthen capacity of existing institutions and establishment of
new institutions in addition to legislation. No statements have been made regarding central versus
district level.
The SEA recommends that that district level institutions receive the same focus as central
institutions.
Proposal for monitoring Key Issues Group 14
Issue Monitoring indicators Responsible
Institutions
Capacity of district local
government
Training plans
Recruiting strategies
Implementation schedules and relevant
annual budgets
All relevant
institutions
Table 7.15: Key Issues Group 15 - Development of Legislation and Regulations as well as Standards
Main Recommendations
1. There is a need to review the existing EIA regulations and develop sector specific standards and
guidelines for the petroleum sector.
2. Assess whether the existing laws and regulations are punitive enough.
3. Develop regulations on occupational health and safety for the oil and gas sector.
3. Classification of wetlands needs to be reviewed to enable regulations.
NOGP Issue
Capacity and institutional building is a key principle to enable the country to participate in, and
benefit from oil and gas activities. Institutional capacity building shall entail development of the
necessary regulatory framework, infrastructure and manpower. It necessitates the introduction of
new legislation and institutions, together with enhancement of existing ones.
NOGP Strategy
Objective 8 supports the development and maintenance of national expertise by:
- Providing appropriate training to Government personnel in relevant fields
Objective 9 is about ensuring that oil and gas activities are undertaken in a a manner that conserves
the environment and biodiversity by:
- Ensuring availability of the necessary institutional and regulatory framework to adress
environment and biodiversity issues relevant to oil and gas activities.
- Requiring oil companies and their contractors/subcontractors to use self regulation and
best practices in ensuring environmental protection.
Page 128
- Requiring oil companies and any other operators to make the necessary efforts to return all
sites on which oil and gas activities are undertaken to their original condition as an
environmental obligation.
The activities of the current generation shall not put a burden on future generations.
The Polluter-Pays-Principle shall apply.
NOGP Actions
Upgrade relevant environment and biodiversity legislation (Objective 9)
Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on
the environment and biodiversity (Objective 9)
Sustainability and Compatibility Testing
The NOGP recognizes the need to upgrade relevant legislation and providing capacity building to
government personnel to enable them to supervise oil and gas activities.
The SEA focuses on the EIA process as an important tool to manage environmental and social issues
related to petroleum activities.
Proposal for monitoring Key Issues Group 15
Issue Monitoring indicators Responsible
Institutions
Adequate laws and
regulations
Review of laws and regulations with focus on
petroleum aspects and international best practice
EIA guidelines
Review schedules and relevant budgets
NEMA and other
relevant institutions
Table 7.16: Key Issues Group 16 - Land Use and Spatial Planning
Main Recommendations
1. The Ministry of Lands, Housing and Urban Development shall expedite the process for the
development of the AG regional physical development plan with emphasis on ecological land use
planning to cater for the various sensitive areas.
2. The Ministry of Lands, Housing and Urban Development needs to urgently initiate development of
the Urbanization Policy as recommended in the National Land Policy in order to provide sufficient
guidance for the comprehensive orderly planning and sustainable development in the AG.
NOGP Issue
Consideration of using finite resources to create lasting benefits to society.
The activities of the current generation shall not put a burden on future generations and resources
shall be used to inter-generation equity.
NOGP Strategy
Objective 5 states the promotion of suitable transport and storage solutions which give good value
to the country’s oil and gas resources by:
- Promoting efficient development and utilization of transport corridors and storage facilities.
- Prioritizing transport methods giving due recognition to cost and efficiency together with
health, safety and environment considerations.
Objective 6 is about ensuring collection of the right revenues and using them to create lasting value
Page 129
for the entire society by:
- Utilizing petroleum revenues for supporting strategic areas of the national economy like
development of infrastructure and other activities
Objective 7 is about ensuring optimum national participation in oil and gas activities
Objective 9 is about ensuring that oil and gas activities are undertaken in a manner that conserves
the environment and biodiversity.
NOGP Actions
Evaluate existing transport systems with a view of establishing their importance to oil and gas
transportation together with identifying additional requirements.
Put in place the necessary regulatory framework for the utilization of transport corridors
Support development of necessary transport infrastructure for oil and gas
Develop physical master plans, environmental sensitivity maps and oil spill contingency plans for
the oil and gas producing region and any transport corridors (under Objective 9)
Encourage civil society to participate in the building of a productive, vibrant and transparent oil
and gas sector (Objective 7)
Sustainability and Compatibility Testing
The NOGP is broad and development of infrastructure is mentioned in the context of the
transportation of oil and gas resources and in terms of revenue use to create benefits to the society.
Physical master plans are mentioned and impacts on physical planning and preventing uncontrolled
population movements are described. It is acknowledged that organized urbanization in and around
the AG shall be endeavoured. The pacing of such activities is mentioned but appears to be
insufficient in reality. Oil and gas activities appear to move ahead faster than the necessary physical
planning.
The SEA is focusing on efforts to streamline and enhancement of physical planning.
Proposal for monitoring Key Issues Group 16
Issue Monitoring indicators Responsible Institutions
Availability of regional physical
development plans for AG and
other areas
Plans
Stakeholder involvement
Ministry of Lands,
Housing and Urban
Development
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Table 7.17: Key Issues Group 17 – Transboundary and International Issues
Main Recommendations
1. Security planning shall include consideration of the roles and responsibilities of the police, military and private security companies. Security of local communities as well as economic activities shall be the key focus. Planning shall be based on transparency and dialogue with the relevant stakeholders.
2. Any plans and activities which could be in conflict with international conventions/treaties need
to be assessed by the Government with the view of identifying potential breach of the
agreements and possible consequences.
3. Address transboundary challenges to fisheries management and oil spill contingency planning in
AG lakes.
4. The government plans of mapping and demarcating of the boarder as per 1956 between Uganda
and DRC should be fast tracked
NOGP Issue
A guiding principle is the spirit of cooperation. Regarding neighbouring countries this spirit shall be
exercised in accordance with the country’s foreign policy.
NOGP Strategy
The impact on relations with neighbouring countries is acknowledged and focusing on DR Congo
NOGP Actions
Unitization to determine sharing of oil and gas resources extending across borders
Trans-boundary cooperation based on existing foreign policy principles and agreements
Programmes, projects and protocols formulated under the International Conference on the
Great Lakes Region
Consultation with neighbouring countries for potential transport corridors
Sustainability and Compatibility Testing
The NOGP acknowledges the principles of foreign policy for trans-boundary cooperation and
consultation with neighbouring states.
The SEA focuses on transboundary issues such as oil spill contingency, border security matters and
fisheries.
It is important that ratified conventions are respected fully.
Proposal for monitoring Key Issues Group 17
Issue Monitoring indicators Responsible Institutions
Ratification of important
conventions including cultural
heritage
Ratification and
implementation
Ministry of Tourism, Wildlife and
Antiquities and other relevant
institutions
Adhere to ratified conventions Gap analysis Relevant institutions
Adequate consultation Formal consultation
plan process
Relevant institutions
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Table 7.18: Key Issues Group 18 - Establishment of Transparent Baseline Data and Scientific Basis
Main Recommendations
1. The existing Environmental Information Network (EIN) needs better support and more
publicizing to ensure that acquired data is adequately stored and accessible to the public.
1. Independent verification of environmental baseline data for transparency and conformity to
scientific methodology and periodic updates are essential to establishing adequate baseline
information. The establishment of a “Clearing House” for baseline data should be considered.
1. Require appropriate capacity building of relevant technical staff at District local Governments in
the AG to enable them meet the challenges of environmental assessment and monitoring with
particular reference to oil and gas exploration, development and production.
2. Set appropriate qualifications plus regular awareness refresher instruction on EIA practitioners
and reviewers.
NOGP Issue
Man y of the areas with a potential for hydrocarbon production coincide with areas of important
biodiversity like national parks, waster bodies, game and forest reserves among others. Due
consideration will therefore be necessary to ensure harmony between developing the petroleum
resources and conservation.
NOGP Strategy
Objective 9 is about ensuring that oil and gas activities are undertaken in a manner that conserves
the environment by:
- Ensuring the presence of the necessary capacity and facilities to monitor the impact of oil
and gas activities on the environment and biodiversity
Objective 10 is about ensuring mutually beneficial relationships between all stakeholders
NOGP Actions
Strengthen the institutions with a mandate to manage the impact of oil and gas activities on the
environment and biodiversity
Develop environmental sensitivity maps
Provide for availability of information that may be required by stakeholders
Sustainability and Compatibility Testing
The NOGP does not consider the establishment of environmental baseline data.
The SEA highlights the need for high quality baseline data and the importance of the Environmental
Information Network as a structure to manage relevant data.
Proposal for monitoring Key Issues Group 18
Issue Monitoring indicators Responsible
Institutions
Access to appropriate baseline data Progress of EIN with agreed milestones NEMA
Qualification of EIA practitioners
and reviewers
Training program development and
implementation
NEMA
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7.2 Strategic aspects
Table 7.19 presents the most significant recommendations related to each of the selected strategic
aspects discussed in Chapter 6. The recommendations for each aspect are not priotised and
therefore shown in bullets.
Table 7.19: Main recommendations within each strategic aspect
Strategic Aspect:
Petroleum
Activities in
Environmentally
Sensitive and
Protected Areas
Activities in areas which are formally designated for ecosystem protection
and biodiversity conservation should be in accordance with the official
protection status of the area. As an example, the National Parks fall into
category II of the IUCN classification. The activities should also ensure
maintenance of the status quo of the ecosystem and the biodiversity or
even improving it. Any decision-making regarding potential future
petroleum activities in protected or environmentally sensitive areas need
to be based on an Integrated Management Plan according to the principles
outlined in Appendix 12. Therefore the detailed content of the Integrated
Management Plan should be developed and implemented urgently.
Petroleum exploration activities that are already licensed to take place in
protected and environmentally sensitive areas should continue to be
based on approved EIAs and relevant national policies and guidelines such
as the National Policy on conservation and sustainable development of
wildlife resources. In addition such activities should follow
international best practice for operations in protected and
environmentally sensitive areas.
Petroleum companies who are taking part in petroleum developments in
environmentally sensitive and protected areas should build their
involvement on a Framework for ecosystem protection and for integrating
biodiversity into their activities.
Strategic Aspect:
Co-existence with
Other Sectors and
Local Communities
It is recommended to moderate the speed of development to ensure
balanced capacity building amongst relevant institutions, such as NEMA, to
manage the sector. Furthermore, this adjustment would benefit the local
district governments and population to adapt to the new sector.
Create a coordination forum between the fisheries and the petroleum
industry in order to effectively discuss and resolve coexistence issues on a
mutual basis. Representatives from authorities or others could be invited
when necessary.
The oil and gas exploiting firms must ensure minimum disturbance to the
tourism circuits, and alternative circuits should be developed by the oil
firms to replace the ones out of use due to exploration activities.
Resettlement Action Plans should be based on international best practice
in to improve the level of trust in compensation systems within
communities.
Development projects constitute one of the greatest physical threats to
the cultural and archaeological heritage. It is the duty of developers to
ensure that archaeological heritage impact studies are carried out before
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development schemes are implemented. Development schemes should be
designed in such a way as to minimize their impact upon the cultural
heritage.
Strategic Aspect:
Institutional
Framework and
Capacity
Critical for effective performance of the environmental management is the
coordination of various institutions involved. The key area of cooperation
is currently on quarterly monitoring of impacts but oil and gas being a new
sector, the capacity of the institutions to perform this task in a coordinated
manner is limited. The roles and responsibilities by the institutions need
further clarification as capacity of the different institutions in monitoring is
strengthened.
A multi-stakeholder partnership for the AG should be instituted to
integrate government efforts with civil society, business and industry in a
coordinated structure. To affect the partnership model, awareness
building will be required from national to local level and defining of roles
and responsibilities reflecting multi-pronged interdependence.
Review of the concluded capacity needs assessment should be undertaken
once the national and local content plan and legislation are in place. The
review should be done to ensure capacity building and participation of all
line sector personnel that is required at national, district and local levels in
handling oil and gas services.
Sustaining established databases and future updates in the framework of
the EIN requires long term investment in institutional infrastructure and
human capacity for the relevant government agencies. This requires that
Government prioritizes data and information management for oil and gas
sector in the framework of the National Development Plan and National
Budget through concerted effort with the resource mobilization pillar with
an aim for sustainability
Strategic Aspect:
Management of
Pollution and
Waste
No activities shall be allowed prior to comprehensive oil spill preparedness
being in place in sensitive or protected areas, e.g. the Murchison Falls or
other protected areas, including the Nile crossing, drilling in Lake Albert or
wetland areas, trucking of oil and supply activities in the lakes/Nile
systems.
The development of the NOSCP and the underlying ERA and OSCA shall be
undertaken based on specific principles outlined in chapter 6.5.
Oil spill response planning shall be an integral part of Environmental
Impact Assessment.
A solution shall be identified for produced water as a special waste type. It
shall be analyzed for its contents (e.g. hydrocarbons, heavy metals, NORM,
mineral salts, solids and organic and inorganic components). Options shall
consider quantities forecasted, components, receiving environment and
potential dispersion factors. All disposal options (discharge with pre-
treatment, evaporation and salt disposal, injection, etc.) shall be
evaluated.
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7.3 Differences between the development scenarios
This section indicates the most significant differences between the development scenarios with
regard to environmental concerns. As described in Chapter 6, these scenarios are considered:
Scenario 1, a development combining construction and operation of a refinery with
associated power plant and an export pipeline transporting crude oil to markets outside
Uganda. This Scenario was used for identifying Key Issues and has already been described in
Chapter 2.2 (Appendix 3).
Scenario 2, comprising construction and operation of a refinery and a power plant with no
export of crude oil.
Scenario 3a, comprising the export of crude oil via pipeline to markets outside Uganda
(Mombasa) including a small power plant to produce electricity for the public grid.
Scenario 3b, comprising the export of crude oil via railway to markets outside Uganda
(Mombasa) also with a small power plant.
The assessment of differences between the scenarios builds on the conclusions in the Scenario
Matrix (Figure 6.1), and the evaluations made in Chapter 6.2 – 6.5.
Table 7.20: Differences between the development scenarios
Area of Concern Differences between the scenarios
Petroleum Activities
in Environmentally
Sensitive and
Protected areas
- Scenario 1 and 2 are less favourable than Scenario 3 when it comes to
pollution to air/water.
- The dominant disturbance in all scenarios is the field development in
Murchison Falls national park. This is the same for all scenarios if full speed
development is carried on.
- In order to justify an economically viable export pipeline, a certain
minimum volume of crude is necessary. If a slower development in the
Park is decided according to the recommendations in the SEA, Scenario 3a
is less favourable than Scenario 1, 2 and 3b. These scenarios have more
flexibility as to stepvice production of crude.
Co-existence with
other Sectors and
Local Communities
- The direct physical impacts on fisheries from the petroleum development
will take place on and close to Lake Albert/connected waterways and they
will be on the same level for all scenarios. Development of a refinery and
petrochemical industry will lead to extensive impacts on the local society,
require large amounts of construction/operations workers and will
potentially lead to pollution of the waters. It is however difficult to indicate
differences between the scenarios on such issues since impacts are both
negative (e.g. overfishing to cover increased demand for fish) and positive
(e.g. larger population to buy the fish and better prices for the fishermen).
- The most serious impacts on tourism will take place in environmentally
sensitive and protected areas such as the Murchison Falls National Park.
Impacts are considered on the same level for all scenarios. Whether the
impacts related to the refinery/petrochemical industry and
pipelines/railway have a resulting negative or positive influence on tourism
is difficult to indicate. The scenarios are thus considered similar.
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- Even if Scenario 1 and 2 result in extensive long term activities and
potential social tensions/disruption, these scenarios are altogether
expected to create higher socio-economic benefits for the local
communities than scenario 3 if managed well.
- Development projects constitute a big threat to cultural and archaeological
heritage. There is however no reason to distinguish between the scenarios
if this matter is managed well.
Institutional
Framework and
Capacity
- Due to the extensive long term operations related to the
refinery/petroechemical activities in scenario 1 and 2, it is assumed that
these scenarios require more focus on developing regulatory framework
and more institutional capacity building than scenario 3.
Management of
Pollution and Waste
- Scenario 1, 2 and 3b have a higher risk for oil spills than scenario 3a which
has low failure rates and low probability of sabotage if managed well.
- Scenario 1 and 2 will produce large quantities of waste including hazardous
components that need sophisticated and well controlled treatment.
Scenario 3 will lead to much smaller and less demanding quantities of
waste.
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7.4 Achievements as compared with SEA Objectives
This section discusses whether the objectives of the SEA are met by the assessments and conclusions
of the SEA.
Propose options of how to deal with conservation of biodiversity and the most valuable and
sensitive areas.
“Petroleum related activities in environmentally sensitive and protected areas” is identified as Key
Issue Group 1 (Chapter 5). Several Key Issues related to this topic are evaluated and discussed with
relevant stakeholders and recommendations are given on how to integrate these issues into
laws/regulations and PPPs. In Chapter 7.1 the most significant Key Issues are highlighted and the
recommendations are tested as to sustainability and compatibility. Proposals on how to monitor the
implementation of the recommendations are presented as well in Chapter 7.1. “Petroleum activities in
protected and sensitive areas” is also defined as a strategic aspect (Chapter 6) and recommendations
are given on how to deal with this aspect in the context of general petroleum activities and specific
development scenarios. In Chapter 7.1, the most significant recommendations of strategic importance
are highlighted.
Propose options for best exploration/production technologies from an environmental and social
point of view.
“Discharges and emissions from the petroleum industry”, “Waste management” and “Oil Spill
Preparedness and land and in surface waters” are all relevant for this objective and they are all
identified as Key Issues Groups. Recommendations are given on how to integrate these issues into
laws/regulations and PPPs. In Chapter 7.1 the most significant Key Issues are highlighted and the
recommendations are tested as to sustainability and compatibility. Proposals on how to monitor the
implementation of the recommendations are presented as well in Chapter 7.1. “Management of
pollution and waste (oil spill contingency planning and drilling waste/produced water)” is defined as a
strategic aspect and recommendations are given on how to deal with these aspects in the context of
general petroleum activities and related to specific development scenarios. In Chapter 7.1, the most
significant recommendations of strategic importance are highlighted.
Propose how to deal with vulnerability of ecosystems as a result of the oil and gas developments.
Reference is made to the evaluation of the first objective above.
Give options to ensure a sustainable coexistence with other sectors.
“Co-existence with local communities”, “Co-existence with archaeology and cultural heritage”, “Co-
existence with other industries and service providers”, “Co-existence with tourism” and “Co-existence
with fisheries” are all identified as Key Issue Groups (Chapter 5). Several Key Issues related to these
topic are evaluated and discussed with relevant stakeholders and recommendations are given on how
to integrate these issues into laws/regulations and PPPs. In Chapter 7.1 the most significant Key
Issues are highlighted and the recommendations are tested as to sustainability and compatibility.
Proposals on how to monitor the implementation of the recommendations are presented as well in
Chapter 7.1. “Co-existence with ther sectors and local communities (including fisheries, tourism, local
communities and cultural heritage)” is also defined as a strategic aspect (ref. Chapter 6) and
recommendations are given on how to deal with this aspect in the context of general petroleum
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activities and specific development scenarios. In Chapter 7.1, the most significant recommendations
of strategic importance are highlighted.
Assess potential pollution and waste and suggest mitigations.
Reference is made to the evaluation of the technology objective above.
Proposals for improving institutional capacity of different stakeholders to enforce laws and deal
with negative consequences of the petroleum development
“Institutional capacity building: Structure and functions” and “Capacity of district local governments
to manage environmental concerns” are both identified as Key Issue Groups (Chapter 5). Several Key
Issues related to these topic are evaluated and discussed with relevant stakeholders and
recommendations are given on how to integrate these issues into laws/regulations and PPPs. In
Chapter 7.1 the most significant Key Issues are highlighted and the recommendations are tested as to
sustainability and compatibility. Proposals on how to monitor the implementation of the
recommendations are presented as well in Chapter 7.1. “Institutional framework and capacity
(including environmental management on a national level, coordination between governmental
agencies and districts/local level and capcity building)” is also defined as a strategic aspect (ref.
Chapter 6) and recommendations are given on how to deal with this aspect in the context of general
petroleum activities and specific development scenarios. In Chapter 7.1 the most significant
recommendations of strategic importance are highlighted.
Propose different forms for compensation mechanism.
On issues related to displacements of settlements, resettlement compensation issues, it has been
observed that national laws on land regulation and land expropriation are in place but with gaps.
These gaps can be filled by using IFC Operational Standard 5 on Land Acquisition and Involuntary
Resettlement, Equator Principles, African Development Bank’s social and environmental policies and
guidelines. Appendix 10 presents a proposal for a Resettlement Policy Framework for AG.
Compensation mechanisms are also integrated into and discussed as part of Key Issue Group 2, “Co-
existence with local communities” and strategic aspect “Co-existence with other sectors and local
communities”
Assess impacts of ongoing activities and suggest mitigations. In addition review scenarios of future
developments and inform on farther exploration and give recommendations.
Environmental impacts of existing activities are integrated into the discussions throughout the report
and typical impacts related to the oil industry as such are presented in Appendix 2. A specific Scenario
Analysis is made based on a discussion of risks and opportunities for a scenario developing a refinery
in AG (Appendix 3). Three development scenarios are presented and discussed in Chapter 6.
Identify cumulative impacts of the oil and gas developments to national and regional socio-
economic and political developments.
This issue is specifically addressed in the Scenario Analysis in Appendix 3, and the discussion of the
three development scenarios. It is also addressed in the Key Issues discussions.
Advice on how to pace the further exploration and development stages
Pacing is primarily addressed in the Scenario Analysis in Appendix 3 and in the discussion of the
strategic aspect “Petroleum activities in environmentally sensitive and protected areas” (Chapter 6.2.)
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7.5 Performance compared to international best practice
As already indicated in Chapter 2, a typical characteristic of SEA is that there is no single recipe on
how to do SEA for a specific sector in a specific country. In the case of the petroleum sector in
Uganda, the SEA is developed and performed to support the local conditions in Uganda and the
Albertine Graben. As a general reference to international best practice, the OECD document
“Applying Strategic Environmental Assessment”. Good Practice Guidance for Development Co-
operation (2006) is used as support. A parallel ongoing SEA process for the petroleum sector in
Ghana has also been an important reference.
In retrospective, the SEA has been briefly assessed using the IAIA (International Association for
Impact Assessment) criteria for how to build a good-quality SEA process (assessment in bracket).
According to these criteria an SEA process:
Is integrated
Ensures an appropriate environmental assessment of all strategic decisions relevant for the
achievement of sustainable development (partly achieved).
Addresses the interrelationships of biophysical, social and economic aspects (achieved).
Is tiered to policies in relevant sectors and (transboundary) regions and, where appropriate, to
project EIA and decision making (achieved).
Is sustainability-led
• Facilitates identification of development options and alternative proposals that are more
sustainable (defined in the specific policies or values of Uganda) (achieved).
Is focused
• Provides sufficient, reliable and usable information for development planning and decision
making (achieved).
• Concentrates on key issues of sustainable development (achieved).
• Is customized to the characteristics of the decision making process (partly achieved).
• Is cost- and time-effective (achieved).
Is accountable
• Is the responsibility of the leading agencies for the strategic decision to be taken (partly
achieved).
• Is carried out with professionalism, rigor, fairness, impartiality and balance (partly achieved).
• Is subject to independent checks and verification (partly achieved).
• Documents and justifies how sustainability issues were taken into account in decision making
(partly achieved).
Is participative
• Informs and involves interested and affected public and government bodies throughout the
decision making process (achieved).
• Explicitly addresses their inputs and concerns in documentation and decision making
(achieved).
• Has clear, easily-understood information requirements and ensures sufficient access to all
relevant information (partly achieved).
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Is iterative
• Ensures availability of the assessment results early enough to influence the decision making
process and inspire future planning (partly achieved).
• Provides sufficient information on the actual impacts of implementing a strategic decision, to
judge whether this decision should be amended and to provide a basis for future decisions (not
achieved, focus in next phase).
7.6 Concluding Advice
The emerging petroleum sector has a high potential to contribute significantly to Uganda’s economy,
industrialization and poverty alleviation plans. Significant efforts have already been made to use this
opportunity to develop the country. The recommendations of this SEA should be integrated into
national development planning to ensure that environmental and socio-economic concerns are
managed well.
The below points describe the overriding advice based on the recommendation from the SEA
process.
The current planning for development of the petroleum sector has a positive drive. However,
it is recommended to moderate the speed of development to ensure balanced capacity
building amongst relevant institutions, such as NEMA, to manage the sector. Furthermore,
this adjustment would benefit the local district governments and population to adapt to the
new sector.
Activities in areas which are formally designated for ecosystem protection and biodiversity
conservation should be in accordance with the official protection status of the area. As an
example, the National Parks fall into category II of the IUCN classification. The activities
should also ensure maintenance of the status quo of the ecosystem and the biodiversity or
even improving it. Any decision-making regarding potential future petroleum activities in
protected or environmentally sensitive areas need to be based on an Integrated
Management Plan according to the principles outlined in Appendix 12. Therefore the detailed
content of the Integrated Management Plan should be developed and implemented urgently.
Petroleum exploration activities that are already licensed to take place in protected and
environmentally sensitive areas should continue to be based on approved EIAs and
relevant national policies and guidelines such as the National Policy on conservation and
sustainable development of wildlife resources. In addition such activities should follow
international best practice for operations in protected and environmentally sensitive areas.
The legal framework and relevant PPPs have to be further adapted to the new petroleum
sector. An important element is to further develop the EIA legislation and guidelines
according to international best practice.
Co-existence of the petroleum sector with other sectors is of high importance. The petroleum
industry should proactively train potential local service providers to reach a high local
content. In order to ensure sustainable co-existence with the fisheries, this sector needs
stronger regulation and management. The tourism sector is depending on the preservation
of ecosystem and recreational functions. The currently weak agriculture sector requires focus
to increase productivity while also ensuring that no land conflicts between the petroleum
and agricultural sector arise. Mechanisms have to be established to avoid that the petroleum
Page 140
industry is undermining these values. The sectors should establish common communication
platforms where relevant concerns can be resolved.
Local communities will experience opportunities as well as risks. The capacity to adapt to the
changing framework conditions has to be a key focus and long-term socioeconomic benefits
have to be ensured. A social development plan should therefore be developed. The scenario
analysis reveals the presence of large numbers of workforce, especially during construction
periods and points at significant in-migration. The planning of urbanization and required
associated infrastructure has to be advanced in line with petroleum development planning to
avoid social tension and lack of capacity of infrastructure.
The Scenario Analysis also reveals that the pressure on public roads is a major concern.
Adequate infrastructure to meet the industry needs while ensuring public road safety has to
be in place.
Selected areas have been designated for industry development and land take is ongoing.
There is concern that resettlement and compensation mechanisms are not adequate.
The SEA advices to implement mechanisms in accordance with international best practice.
The National Oil Spill Contingency Plan is under development. Timely preparation and
implementation including the relevant training is essential.
Waste management has already received increasing attention. Waste management strategies
and facilities covering the existing legacy waste as well as future waste have to be developed
in the very near future in line with international best practice.
Although produced water is not yet a key concern, it requires dedicated attention already
now.
Water management is a major concern. The petroleum industry requires large amounts of
water during their operations and this adds to the pressure on water resources in AG. The
Government should establish water management planning considering the resource needs,
sources and associated environmental impacts.
The National Oil and Gas Policy outlines the spirit of cooperation and the roles of the
Government and the oil industry. The oil industry should be encouraged to take an active
role in developing technology to meet the challenges of ecologically vulnerable areas and
reduce their footprint.
The Government has taken a proactive role in communication with neighbouring states
regarding transboundary issues such as sharing of petroleum reserves across borders with DR
Congo. Further efforts should be made regarding shared oil spill contingency for Lake Albert
and the Nile, fisheries management, security of oil and gas installations, public and border
security.
The National Oil and Gas Policy outlines goals, strategies and actions for revenue
management and transparency. Proper mechanisms and measures should be put in place to
ensure that long-term benefits are created and shared fairly with due consideration of the oil
and gas bearing regions.
Stakeholder engagement is a key principle of the Ugandan government and the SEA builds on
this principle. The disparities in the Ugandan society require attention to ensure that
consultation is meaningful and that information is transparent and easily accessible for
stakeholders. This will contribute to achieving the social license to operate and minimize the
potential for social conflict.
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To ensure that the conclusions from the SEA are adequately considered an Implementation
Plan should be developed. This should include the collection of and access to adequate
baseline data. In addition, the SEA should be updated regularly.
Page 142
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APPENDIX 1: OVERVIEW OF MAJOR REPORTS PRODUCED IN
THE SEA PROCESS
1. Inception Workshop Report (22.-24.05.2012)
2. Final Inception Report (20.07.2012)
The Inception Report deals with the following subjects:
The Screening and Scoping phase
The oil and gas sector
The SEA Process
Legal and institutional framework
PPPs
Baseline conditions
Identification of Key Issues
Specific areas of concern
Stakeholder engagement
3. Final Scenario Analysis (September 22, 2012)
Attached to this SEA Report, see Appendix 3.
4. Final Interim Report (September 30, 2012)
Summary:
The Interim Report is made half way into the SEA process. The intention is to present a short and
structured overview of what has been done and delivered up to end August 2012 and to look ahead
and present the way forward until the final delivery of the SEA report by end January 2013. In addition
the management structure and the resources/budgets are shortly described.
Potential challenges connected to the SEA process and the professional undertaking of the work is an
important part of the Interim Report as this overview and analysis is leading the way forward.
The Appendices are representing the most important deliverables during the Pre-assessment Phase
which followed the Inception Phase. A significant undertaking during the pre-assessment phase, the
Scenario Analysis, has been delivered as a separate document, ref. report 3 described above.
Attached to the Interim Report is also the Issues Register and Analysis. This matrix is attached to this
SEA report in Appendix 6 .
The Interim Report is also presenting the Key Issues Action Matrix which has been an important tool
for the SEA Team during the planning and implementation of stakeholder consultations related to the
Key Issues follow up. This matrix is focusing on explaining the Key Issues (Why is the Key Issue
Relevant?) and preliminary recommendations are identified as a basis for the stakeholder
consultations. Most of these were adjusted and supplemented during the engagement process.
Potential relevant PPPs and Stakeholders to be engaged is also presented in the Key Issues Action
Matrix. Following the completion of the stakeholder engagement process, this matrix was replaced by
the official Key Issues Integration Matrix (Appendix 7).
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The draft table of content for the final SEA report and the updated SEA schedule is attached to the
Interim Report as well.
The delivery of the Interim Report is representing the move from the pre-assessment phase into the
assessment phase according to the SEA schedule.
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APPENDIX 2: THE PETROLEUM INDUSTRY AND TYPICAL
ASPECTS AND IMPACTS
1. PETROLEUM
Petroleum (L. petroleum, from Greek: petra (rock) + Latin: oleum (oil)) or crude oil is a naturally
occurring, flammable liquid consisting of a complex mixture of hydrocarbons of various molecular
weights and other liquid organic compounds, that are found in geologic formations beneath the
Earth's surface. A fossil fuel, it is formed when large quantities of dead organisms, usually
zooplankton and algae, are buried underneath sedimentary rock and undergo intense heat and
pressure.
Petroleum is recovered mostly through oil drilling. This comes after the studies of structural geology
(at the reservoir scale), sedimentary basin analysis, reservoir characterization (mainly in terms of
porosity and permeable structures). It is refined and separated, most easily by boiling point, into a
large number of consumer products, from petrol (or gasoline) and kerosene to asphalt and chemical
reagents used to make plastics and pharmaceuticals. Petroleum is used in manufacturing a wide
variety of materials, and it is estimated that the world consumes about 88 million barrels each day.
The petroleum industry generally classifies crude oil by the geographic location it is produced in (e.g.
West Texas Intermediate, Brent, or Oman), its API gravity (an oil industry measure of density), and its
sulfur content. Crude oil may be considered light if it has low density or heavy if it has high density;
and it may be referred to as sweet if it contains relatively little sulfur or sour if it contains substantial
amounts of sulfur.
Petroleum industry is involved in the global processes of exploration, extraction, refining,
transporting (often with oil tankers and pipelines), and marketing petroleum products. The largest
volume products of the industry are fuel oil and petrol. Petroleum is also the raw material for many
chemical products, including pharmaceuticals, solvents, fertilizers, pesticides, and plastics. The
industry is usually divided into three major components: upstream, midstream and downstream.
Petroleum activities normally start with an exploration phase which involves seismic data acquisition.
There are two methods of carrying out seismographic surveys. The first is to use small explosions at
or just below the earth’s surface. This method has environmental risk of using explosives. The second
method is to use a system called vibroseis to eliminate the latter risk. In this system soundwaves are
produced by a huge vibrator that repeatedly strikes the earth. The vibrator is mounted on a special
truck called a thumper truck.
Once seismic data has been collated, drilling operations normally commence in prospective geological structures. Drilling is normally undertaken during the exploration, appraisal and production phase.
Drilling on land is undertaken by the use of drilling rigs. Offshore drilling is mainly done by:
Jack-up rigs
Semisurbmersible rigs
Drillships.
Due to the limited water depths in the lakes in the Albertine Graben, drilling is likely to be performed
from artificial island (using land rigs) or jack-up rigs.
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Petroleum is recovered in much the same way as underground water is obtained. Like certain water
wells, some oil wells have sufficient natural energy to bring the fluid to the surface. Other wells have
too little energy to produce oil efficiently, or they lose most of the energy after a period of
production. In these wells additional energy must be supplied by pumps or other artificial means. If
natural pressure provides most of the energy, the recovery of petroleum is called primary recovery. If
artificial means are used the process is called enhanced recovery.
After crude oil reaches the surface, any potentially associated natural gas is separated from oil. The
gas is sent to a processing plant. Water and sediments are removed from oil which is then stored in
tanks or sent to a refinery. From the refinery, petroleum products are delivered to markets.
Petroleum is carried chiefly by pipeline, tanker, barge, tank truck and railroad tank car. Pipelines
transport crude oil from wells to storage tanks, to other carriers or directly to refinery. Pipelines also
transport petroleum products from refinery to markets (for example Mombasa – Kisumu / Eldoret
pipeline in Kenya). Some of the largest pipelines carry more than one million barrels of oil daily.
Pipelines are relatively cheap to operate and maintain and generally the most efficient means of
transporting petroleum.
2. Challenges of the Oil and Gas Sector Today
Human, Socio-economic and Cultural impacts
Exploration and production operations are likely to induce economic, social and cultural changes. The
extent of these changes is, especially, important to local groups, particularly indigenous people who
may have their traditional lifestyle affected. The key impacts may include changes in:
land-use patterns, such as agriculture, fishing, logging, hunting, as a direct consequence (for
example land-take and exclusion) or as a secondary consequence by providing new access
routes, leading to unplanned settlement and exploitation of natural resources;
socio-economic systems due to new employment opportunities, income differentials,
inflation, difference in per capita income, when different members of local groups benefit
unevenly from induced changes;
local population levels, as a result of immigration (labour force) and in- migration of a remote
population due to increased access and opportunities;
socio-cultural systems such as social culture, organizational and cultural heritage, practices
and beliefs and secondary impacts such as effects on natural resources, rights of access and
change in value systems influenced by foreigners;
availability of, and access to, goods and services such as housing, education, healthcare,
water, fuel, electricity, sewage and waste disposal, and consumer goods brought into the
region;
planning strategies, where conflicts arise between development and protection, natural
resource use, recreational use, tourism and historical or cultural resources;
aesthetics, because of unsightly or noisy facilities; and
transportation systems, due to increased road, air and sea/water infrastructure and
associated effects (e.g. noise, accident risk, increased maintenance requirements or change
in existing services).
Atmospheric impacts
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Atmospheric issues are attracting interest from both industry and government authorities worldwide.
This has prompted the oil and gas exploration and production industry to focus on procedures and
technologies to minimize emissions. In order to examine the potential impacts arising from
exploration and production operations. It is important to understand the sources and nature of
emissions and their relative contribution to atmospheric impacts, both local and those related to
global issues such as stratospheric ozone depletion and climate change.
The primary sources of atmospheric emissions from oil and gas operations arise from:
Flaring, venting and purging gases;
Combustion processes such as diesel engine and gas turbines;
Fugitive gases from loading operations and tankage and losses from process equipment;
Airborne particulates from soil disturbance during construction and from vehicle traffic;
Particulates from other burning sources such as well testing.
Principal emission gases include: CO2, CO, CH4, volatile organic carbons (VOC) and NOx. Emission of
SO2 and hydrogen sulphide can occur and depend on sulphur content of the hydrocarbon and diesel
fuel, particularly when used as power source.
Ozone depleting substances are used in fire protection systems, principally, halon and as refrigerants.
Flaring contributes about 1 percent of global Co2 emissions (base on 1991 estimates). Methane
emissions which arise from process vents and to a lesser extent from leaks and flaring and
combustions. Methane emissions from oil and gas operations contributed 10% of global emissions in
1991 other gases have to be considered.
Aquatic impacts
The principal aqueous waste streams resulting from E&P operations are:
Produced water
Drilling fluids, cuttings and well treatment chemicals;
Process, wash and drainage water;
Sewage, sanitary and domestic wastes;
Spills and leakage; and
Cooling water
The make-up and toxicity of chemicals used in exploration and production have been widely
presented in the literature (see for example 2,3) whilst the E&P Forum Waste Management Guidelines
summarize waste streams, sources and possible environmentally significant constituents, as well as
disposal methods. Water-based drilling fluids have been demonstrated to have only limited effect on
the environment. The major components are bentonite and clay which are chemically inert and non-
toxic. Oil-based drilling fluids and oily cuttings, on the other hand, have an increased effect due to
toxicity and redox potential. The oil content of the discharge is the main factor governing these
effects.
Oil-based drilling fluids are hazardous to aquatic life and should be replaced by synthetic muds. The
high PH and salt content of certain drilling fluids and cuttings pose potential impact to fresh water
sources.
Produced water is the largest volume aqueous waste arising from production operations and some
typical constituents may include in varying amount: inorganic salts, heavy metals, solids, production
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chemicals, hydrocarbons, benzene, PAHs and on occasions naturally occurring radioactive material
(NORM).
Terrestrial impacts
Potential impacts to soil arise from these basic sources:
Physical disturbance as a result of construction;
Contamination resulting from spillage and leakage or solid waste disposal
Indirect impact arising from opening access and social change.
Potential impacts that may result from poor design and construction include soil erosion due to soil
conditions may result in widespread secondary impacts such as changes in surface hydrology and
drainage patterns, increased siltation and habitat damage, reducing the capacity of the environment
to support vegetation and wildlife.
Due to its simplicity, burial or land-filling of wastes in pits and drilling and production sites has been a
popular means of waste disposal in the past. Historically, pits have been used for burial of inert, non-
recyclable materials and drilling solids; evaporation and storage of produced water; workover /
completion fluids; emergency containment of produced fluids; and the disposal of stabilized wastes.
However, the risks associated with pollutant migration pathways can damage soils and usable water
resources (both surface and groundwater) if seepage and leaching are not contained.
Land farming and land spreading have also been extensively used in the past for treatment of oily
petroleum wastes and water-based muds and cuttings. However, there are potential impacts where
toxic concentrations of constituents may contaminate soil or water resources, if an exposure
pathway is present. In case of muds and cuttings, the most important consideration is the potential
for the waste to have a high salt content.
Soil contamination may arise from spills and leakage of chemicals and oil causing possible impact to
both flora and fauna. Simple preventive techniques such as segregated and contained drainage
systems for process areas incorporating sumps and oil traps, leak minimization and drip pans, should
be incorporated into facility design and maintenance procedures.
Large incidents or spills offsite should be subject to assessment as potential emergency events and,
as such, are discussed under potential emergencies below and also under ‘oil spill contingency
planning’.
Ecosystem impacts
Plant and animal communities may also be directly affected by changes in their environment through
variations in water, air and soil / sediment quality and through disturbance by noise, extraneous light
and changes in vegetation cover such changes may directly affect the ecology: for example habitat,
food and nutrient supplies, breeding areas, migration routes, vulnerability to predators or change in
herbivore grazing patterns, which may have a secondary effect on predators. This is important for
wildlife conservation area in Albertine Graben.
If controls are not managed effectively, ecological impacts may also arise from other direct
anthropogenic influent such as fires, increased hunting and fishing and possible poaching. In addition
to changing animal habitat, it is important to consider how changes in the biological environment
also affect local people and indigenous populations.
The footprint related to the oil and gas activities is probably one of the most challenging concerns
potentially leading to loss of biodiversity, habitat destruction and degradation and fragmentation of
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environmentally vulnerable areas. The characteristics of Albertine Graben indicate that this issue
needs to be carefully assessed in the further SEA.
Accidental events
Plans seismic, drilling and production operations have to incorporate measures to deal with potential
emergencies that threaten people, the environment and property. However, even with proper
planning, design and implementation of correct procedures and personnel training incidents can
occur such as:
spillage of fuel, oil, gas, chemicals and hazardous materials;
oil or gas well blowout;
explosions;
fires (facility and surrounds);
unplanned plant upset and shutdown events;
natural disasters and their implications on operations, for example floods, earthquake,
lightning; and
war and sabotage.
Planning for emergency events should properly examine risk, size, nature and potential
consequences of a variety of scenarios, including combination incidents.
3. Examples of aspects and impacts from petroleum activities onshore and offshore
The following tables illustrate the various petroleum related activities and their aspects and potential
impacts.
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Table 1: The onshore oil and gas activity chain, associated aspects and potential impacts
Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Aerial survey Aircraft Noise Disturbance to wildlife
Disturbance of people
Short-term, transient
Consider seasonality of wildlife.
Avoid sensitive areas
Seismic operations (onshore)
Seismic equipment, Worker presence, Camps, Line cutting
Noise & vibrations
Light emissions
Air emissions
Access/footprint
Vegetation clearing
Interference with other users
Disturbance to wildlife
Disturbance to people
In-migration of job seekers
Habitat fragmentation
Short-medium term, transient
Consider seasonality of wildlife.
Avoid sensitive areas
Minimise footprint
Avoid in-migration
Expectation management
Minimize vegetation clearing and cutting straight lines
Exploration and appraisal drilling (onshore)
Road construction and use
Access
Air emissions
Noise, vibrations
Vegetation clearance
Noise and vibrations
Disturbance of wildlife
Disturbance of local people
In-migration of job seekers
Mainly short-term, transient
Adequate routing to avoid sensitive areas
Site preparation
Footprint
Use of heavy machinery
Vegetation and topsoil clearance
Pot. changes in hydrology
Land use conflicts
Loss of habitat
Noise, vibrations and air emissions
Disturbance to wildlife
Disturbance to local people
Visual intrusion
Short-term (if adequate reinstatement)
Adequate site selection
Minimisation of footprint
Camp and operations
Discharges
Emissions (air, noise, light emissions)
Waste handling
Use of water resources
Water supply (wells, etc.)
Noise, vibrations and emissions from plant equipment and transport
Light emissions
Liquid discharges (muds and cuttings)
Pot. spillages/leakages - soil contamination
Solid waste disposal
Liquid waste disposal
Land use conflicts
Short-term, transient
Minimize duration
Minimize interference with local population (sex workers, poaching, fishing, etc.)
Stakeholder engagement
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Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Disturbance to local people
Interactions workforce – local people
In-migration of job seekers
Pressure on local infrastructure
Pot. hunting, fishing, poaching pressure by workforce
Well testing (flaring or storing/transporting well test products)
Emissions from burning or storing(air, noise, light and heat emissions)
Discharges
Disturbance to wildlife
Disturbance and interference with local people (noise, air emissions)
Safety risks related to storage
Environmental risk related to storage (spills)
Short-term, transient
Minimise duration of well testing
Define adequate well test product management
Avoid sensitive periods for wildlife
Use of well test product or green burners
Decommissio-ning/ reinstatement
Footprint Risk of spills and contamination of soil and water resources
Short-term
Proper reinstatement
Field development and production (onshore)
Road construction and use
Access Loss of habitat
Habitat fragmentation, migration barriers
Loss of land use
In-migration route and secondary effects
Vegetation clearance
Erosion and changes to surface hydrology
Disturbance due to transportation
Traffic density and safety
Impact on local infrastructure
Disturbance to local people
Disturbance to wildlife
Long-term, permanent
Proper route selection process
Consideration whether to close the road for the public or not
Site preparation and construction
Footprint
Vehicle movements
Workforce presence
Emissions
Discharges
Wastes
Loss of habitat
Habitat fragmentation, migration barriers
Loss of land use
In-migration route and secondary effects
Vegetation clearance
Erosion and changes to surface hydrology
Disturbance due to transportation
Short- medium-term, transient
Proper site selection process
Minimization of footprint
Restriction of working hours (if close to local population)
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Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Traffic density and safety risks
Impact on local infrastructure
Disturbance to local people
Disturbance to wildlife
Noise, vibrations, light, air emissions
Visual intrusion
Operations Infield lines, central production facility, well pads, etc.
Use of local infrastructure (roads, hospitals, utilities)
Discharges
Wastes
Noise, light & air emissions
Interference with local infrastructure, other users and local population
Demand on local infrastructure (electricity, water, sewage, roads, etc.)
Liquid discharges from production (waste water, produced water, sewage, sanitary waste)
From power and process plant (air, noise, light emissions, vibration flaring), global warming
Effects on biota,
Disturbance of wildlife
Habitat loss, impacts on biodiversity,
Water soil and air quality impacts
Interaction of local people with workforce
Land use conflicts
Visual intrusion
Risk of accidental events
Long-term, permanent
Proper maintenance and surveillance.
Choice of technology according to BAT
Expectation management
Benefit sharing agreements with local communities
Environmental and social investment plan
Decommissio-ning
Same as for construction
Same as for construction Short-term, transient
Proper controls and careful decommissioning should avoid risk of long-term impacts. Improper controls can result in soil and water contamination, damage to wildlife, habitats and biodiversity. Proper waste disposal essential.
Pipeline transportation (onshore)
Access roads construction and use
Interactions
Use of heavy machinery
Air, noise and light emissions &vibrations
Habitat fragmentation
Loss of habitat and vegetation
Long-term, permanent
Proper route selection
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Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Disturbance of wildlife
Pipeline construction
Linear footprint
Emissions
Discharges
Wastes
Vehicle movements
Workforce presence
Construction camps
Potential blasting activities (depending on terrain)
Loss of habitat
Habitat fragmentation, migration barriers
Loss of land use
In-migration of job seekers / secondary effects
Vegetation clearance
Erosion and changes to surface hydrology
Increased traffic density and safety risks
Impact/demands on local infrastructure
Disturbance to local people
Disturbance to wildlife
Noise, air, light emissions, vibration
Visual intrusion
In-migration of job seekers
Short-term, transient
Proper route selection
Workforce management
Camp management
Expectation management
Local content strategy
Dust suppression
Precommissio-ning
Water abstraction
Discharge
Emissions
Resource conflicts (water)
Risk of contamination & erosion from discharge
Short-term, transient
Avoid use of chemical additives in hydrotest water.
Operations Compressor stations emissions
Surveillance
Maintenance
Disturbance of local people due to emissions
Interference of security staff with local people
Risk of accidental events
Long-term, permanent
Local benefit sharing agreements
Environmental and social investment planning
Proper emergency response planning
Decommissioning/reinstatement
Emissions
Discharges
Wastes
Vehicle movements
Workforce
Camps
Disturbance due to transportation
Traffic density and safety risks
Disturbance to local people
Disturbance to wildlife
Noise, vibrations, light, air emissions
Short-term, transient
Same as for construction
Refining Roads Access Loss of habitat
Habitat fragmentation, migration barriers
Loss of land use
In-migration route and secondary effects
Long-term, permanent
Proper route selection
Avoid sensitive areas
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Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Vegetation clearance
Erosion and changes to surface hydrology
Disturbance due to transportation
Traffic density and safety
Impact on local infrastructure
Disturbance to local people
Disturbance to wildlife
Site preparation and construction
Footprint
Vehicle movements
Workforce presence
Emissions
Discharges
Wastes
Loss of habitat
Habitat fragmentation, migration barriers
Loss of land use
In-migration route and secondary effects
Vegetation clearance
Erosion and changes to surface hydrology
Disturbance due to transportation
Traffic density and safety risks
Impact on local infrastructure
Disturbance to local people
Disturbance to wildlife
Noise, light, air emissions, vibrations
Visual intrusion
Medium -term, transient
Proper site selection process
Minimization of footprint
Grievance mechanism for local population
Traffic management planning
Workforce management plan
Camp management plan
Environmental and social investment planning
Proper emergency response planning
Expectation management
Operations Discharges
Wastes
Noise, light and air emissions
Interference with local infrastructure, other users and local population
Demand on local infrastructure (electricity, water, sewage, roads, etc.)
Liquid discharges from refinery operations (waste water, sewage, sanitary waste)
From power and process plant (air emissions, noise, flaring, vibrations, light)
Decrease in air quality, global warming
Effects on biota
Disturbance of wildlife, habitats, biodiversity, water soil and air quality
Interaction of local people with workforce
Land use conflicts
Visual intrusion
Long-term, permanent
Proper maintenance and surveillance.
Choice of technology according to BAT
Waste management plan
Expectation management
Benefit sharing agreements with local communities
Environmental and social investment plan
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Petroleum Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Risk of accidental events
Decommissioning
Same as construction Short-term, transient
Proper controls and careful decommissioning should avoid risk of long-term impacts. Improper controls can result in soil and water contamination, damage to wildlife, habitats and biodiversity. Proper waste disposal essential.
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Table 2: The offshore (lake) oil and gas activity chain, associated aspects and potential impacts
Petroleum
Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Seismic
operations
(offshore)
Seismic equipment (vessels, streamer, air guns) Vessel operations
Noise
Emissions and discharges
Interference
Disturbance & physiological effects on aquatic species
Disturbance to birds
Air emissions and discharges (bilge, sewage, waste and garbage disposal).
Interference with fisheries / other lake users
Interference with tourism
Possible spills
Short-term, Transient Pot. long-term
Soft start of air guns
Possible limitation of frequencies of shots
No disposal into aquatic environment
Spill response
Stakeholder dialogue &information exchange
Exploration
and appraisal
drilling
(offshore)
Site selection Interactions Disturbance to aquatic biota
Disturbance to fisheries and other lake users (tourism, etc.)
Short-term, transient
Avoid sensitive areas
Operations Discharges
Emissions
Wastes
Exclusion zone for safety reasons
Vessel movements
Use of local infrastructure
Discharges (muds, cuttings, wash water, drainage, sewage, sanitary and kitchen waste)
Disturbance due to noise and light
Solid waste disposal onshore and impact on local infrastructure
Loss of access and disturbance of other lake users
Disturbance to benthic and pelagic organisms (fish, etc.) and birds
Changes in sediment and water quality.
Risk of contamination due to spills/leakages (water, sediment, coastline)
Short-term, Transient (unless accidental event)
Minimize wastes
Minimise duration
Avoid sensitive periods
Avoid sensitive areas
Well testing Emissions from burning or storing(air, noise, light and heat emissions)
Decreased water quality due to produced water discharges
Air quality impacts due to flaring
Disturbance of lake shore communities
Short-term, transient (unless accidental event)
Minimise duration of well testing
Define adequate well test product management
Avoid sensitive periods for wildlife
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Petroleum
Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Discharges and lake users
Effects of vessel movements on humans and wildlife
Use of well test product or green burners
Minimize waste
Avoid sensitive periods
Avoid sensitive areas
Decommissioning Footprint
Emissions (noise, air, light, vibrations)
Vessel movements
Interference with other lake users Short-term, transient
Proper controls should avoid risk of long-term impacts. Improper controls can result in sediment and water contamination, damage to benthic and pelagic habitats, organisms and biodiversity. Onshore in terms of solid waste disposal, infrastructure and resource conflicts
Field
development
and production
(offshore)
Site selection Interactions
Vessel movements and associated emissions
Discharges
Wastes
Risk of impact on sensitive species and/or commercially important species
Resource conflicts
Impacts on local port infrastructure
Avoid sensitive areas
Operations Production from platforms, barges, artificial islands or other
Subsea gathering lines
Supply operations
Helicopter support
Discharges
Wastes
Emissions
Vessel movements
Helicopter movement
Use of onshore infrastructure
Long-term, chronic effects from discharges on benthic and pelagic biota, sediment and water quality
Impact of cuttings and mud discharges, produced water, drainage, sewage, sanitary and kitchen wastes
Emissions from power and process plant (air emissions, noise, light, heat).
Contribution to global warming
Solid waste disposal and impact on onshore infrastructure.
Disturbance from increased vessel and helicopter movement
Loss of access and interaction with other resource users/lake users
Local port, harbor and community
Long-term, permanent
Proper maintenance and surveillance.
Choice of technology according to BAT
Stakeholder communication and grievance mechanism
Benefit sharing agreements with local communities
Local content development
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Petroleum
Activity
Impact Source Aspect Impact Impact assessment
Mitigation
Harbour and supply base development/use
interaction related to supply and support functions
Risk of accidental events (spills, leakages
Decommissioning Footprint
Emissions (noise, air, light, vibrations)
Vessel movements
Interference with other lake users
Emissions (air, noise, light)
Short-term, transient
Proper controls and careful decommissioning should avoid risk of long-term impacts. Improper controls can result in sediment and water contamination, damage to benthic and pelagic habitats, organisms and biodiversity. Onshore in terms of solid waste disposal, infrastructure and resource conflicts
Pipeline
transportation
(offshore)
Pipeline construction
Dredging, trenching
Emissions
Discharges
Wastes
Vessel movements
Vessel movements and exclusion zone
Risk of collision
Disturbance to local people and fisheries
Impacts on aquatic biota due to sediment dispersion and mobilization of contaminants
Noise, vibrations, light, air emissions
Land use conflicts at landfall
Resource conflicts
Short-term, transient
Proper route selection
Stakeholder communication and grievance mechanism
Precommissio-ning
Water abstraction
Discharge
Emissions
Risk of contamination and erosion due to discharge
Short-term, transient
Avoid use of chemical additives in hydrotest water
Operations Surveillance
Maintenance
Impacts on fisheries
Disturbance of local people only during maintenance
Overtrawlable pipeline design
Decommissioning/reinstatement (normally left in place)
Vessel movements Emissions (air, noise, light)
Interference with other users
Short-term, transient
Pipeline either filled and left in place or taken out
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APPENDIX 3: SCENARIO ANALYSIS
Strategic Environmental Assessment (SEA) for
the Petroleum Sector
Albertine Graben, Uganda
Final Scenario Analysis
Kampala, September 22, 2012
The SEA Team
Page 164
1 Introduction
An important objective of the SEA is to identify Key Issues as a platform for a focused process. The
SEA will concentrate on using four methodologies which will each identify relevant issues to be
prioritized and carried on as the most significant issues for further SEA analysis.
The figure below illustrates the process of identifying the Key Issues. As illustrated, issues will be
identified by the review of documentation, by evaluations from expert teams, by engaging
stakeholders and by performing a scenario analysis. The final inventory of Key Issues will be decided
by the SEA Steering Committee based on advice from the SEA Team.
Figure 1: Key Issues Identification
2 Scenario Approach
The Scenario methodology can be used to describe possible developments of the oil and gas sector in
Albertine Graben. They describe a range of images of the future based on different driving forces and
realistic parameters and they are basis for discussion/decision on concerns and positive effects of the
development. Each scenario therefore offers a unique opportunity to visualize and understand
potential “pictures” of the future situation as basis for capacity building and discussions.
As the Ugandan government already has advanced plans for a stepwise development of the
petroleum resources and related facilities and infrastructure in the Albertine Graben for creation of
revenue, a phased approach for the scenarios has been chosen. This approach focuses on a scenario
developing a refinery over four sequential phases, each characterized by activities/key components
and related concerns and opportunities.
The phases analyzed are:
Phase 1 (2012-2015): Early Commercialization
Phase 2 (2015-2017): Refinery of 20,000 BBLS/D
Phase 3 (2017-2022): Refinery of 60,000 BBLS/D
Phase 4 (2022-2030): Refinery of 120,000 BBLS/D
1. Review of
documentation
4. Scenario
analysis
2. Evaluation
by expert teams
3. Stakeholder
opinions
Conclusion on
Key Issues
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The figure 2 below illustrates what the four phases are and how they are interlinked.
Figure 2: Scenario Approach
Scenario Approach
Phase 1 Scenario2012 – 2015
Phase 2 Scenario2015 – 2017
Phase 3 Scenario2017 – 2022
Phase 4 Scenario2022 – 2030
New activitiesPhase 1
Ongoing fromPhase 1
New activitiesPhase 2
New activitiesPhase 3
New activitiesPhase 4
Ongoing fromPhase 1
Ongoing fromPhase 2
Ongoing fromPhase 1
Ongoing fromPhase 2
Ongoing fromPhase 3
Baselineconditions
The systematic methodology of scenario analysis is thus reflecting an assessment of the resource
base on which the petroleum development is building, an understanding of the baseline conditions
today and the plans of the Ugandan government and the oil industry.
In addition several studies have been undertaken to identify the feasibility of petroleum
infrastructure developments. The technical basis of these studies has also been used to identify and
characterize the four phases.
Based on the key components of the scenario for each phase, positive and negative issues have been
identified for further analysis.
These issues will be added to the previously identified issues from the other three steps (see above
illustration). All issues will be evaluated and advice will be given to the SC on which should be
regarded as Key Issues for the further assessment. This assessment will focus on identifying risks and
opportunities, mitigation measures, links to and integration into relevant PPPs, monitoring programs,
etc.
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3 PHASE 1 SCENARIO – EARLY COMMERCIALISATION
TIMELINE
Today until end of 2015
SUMMARY OF MAIN ACTIVITIES IN PHASE 1
The main focus of the early commercialization is to provide feed for the Integrated Power Plant (IPP)
to be constructed during this phase with oil from Mputa and gas from Nzizi to provide electricity to
the public grid. Furthermore, use of the oil produced during Extended Well Testing (EWT) will be sold
to local consumers such as the Hima and Tororo cement plants and the Namanve power plant. Large
scale construction will also take place, namely the 20,000 bbls/d refinery at Kabaale, the regional
construction base around Hoima, the necessary supply bases as well as road construction. An
extensive 3D seismic data acquisition program will be undertaken within the Murchison Falls
National Park (100m x 100m grid).
COMPONENTS IN PHASE 1
Main components:
EWT (already stored 28,000 bbls on drilling sites, ongoing in addition).
Trucking of oil from EWT sites to consumers.
IPP construction and operation at Kabaale.
Construction and operation of Central Processing Facility (CPF)-S1 in the south.
Trucking of oil from CPF-S1 to the IPP.
Field developments for Nzizi (gas/oil) and Mputa (oil) to feed the IPP.
Construction and operation of in-field pipelines to CPF-S1.
Construction and operation of gas pipeline from CPF-S1 to IPP.
Construction of southern pipeline from CPF-S1 to refinery (42,000 – 60,000 bbls/d capacity).
Refinery construction at Kabaale for 20,000 bbls/d module.
Construction of pipeline for transport of Heavy Fuel Oil (HFO) from the refinery to the IPP.
Exploration/appraisal elsewhere in Albertine Graben, incl. Ngassa (gas) directional drilling
from onshore (deep reservoir).
Kingfisher oil field under development.
Construction of CPF-S2 in the south.
3D seismic acquisition in Murchison Falls.
Road construction.
Development of a regional construction base at Hoima.
Pipe transportation from Mombasa to Hoima regional construction base.
Trucking of refinery modules and equipment from Mombasa to the refinery area.
Development and operation of potential supply base at Butiaba and other locations.
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The following figure/map illustrates the main components related to the Phase 1 Scenario.
Figure 3: The Phase 1 Scenario, 2012 – 2015
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MAIN CONCERNS
The following concerns are considered to be significant related to the development of Phase
1 and these will be weighted for potential inclusion as Key Issues later on.
Timing of main components. Too fast development. Unrealistic development schedule and
fast tracking of too many major development activities.
Lack of an overall integrated plan that regulates provisions and activities by the local
authorities and oil companies.
Lack of a broad range of public infrastructure primarily related to transportation.
Housing and services for expat and local work forces. Establishing labor camps and associated
utilities (water, waste and security) and construction warehousing.
Land take for the refinery, IPP, bases at Hoima and Butiaba, pipe ROW, roads, etc. (in terms
of area consumption as well as acquisition/resettlement process).
Use of local resources and their management (building materials such as cement, steel
reinforcement, asphalt, sand, gravel, timber, water). Shortage of local goods and services as
a result of high demand by the petroleum industry.
Extensive 3 D seismic acquisition impacts on Murchison Falls NP over 13 month period.
Unprepared to secure local content during construction and operation (local deliveries of
goods/services, professionals and skilled labors). Also potential drainage of skilled workforce
from other sectors into the oil and gas sector.
Extensive pressure on local road systems through settlements/agricultural areas and/or
environmental sensitive areas
o EWT:
- from 8/2012 - 9/2012: 7 large trucks per day one way (14 trips)
- from 9/2012 onwards: 1 large truck per day (2 trips)
o Field developments:
- approx. 30 large trucks per day from CPF plus 2 trucks from EWT sites (64 trips)
o For import of pipes to pipelines connecting CPFs with refinery
- 400 large trucks from Mombasa to Hoima (800 trips)
o Additional transport of drilling supplies, refinery modules and equipment to
Hoima/Butiaba
Lack of Waste Management facilities.
Understanding of the impacts of possible oil and gas effluents in Lake Albert and the Nile,
knowledge about their behavior as recipients for oil and gas pollution and oil spill behavior
on land.
Preparation of oil spill contingency plans, availability of oil and gas dispersal models and
provisions of equipment to fight pollution.
Construction activities causing habitat fragmentation (temporary and permanent).
Regional Emergency Response systems (fire fighting, medical provisions and disaster
management) and security for all people living/working in the region.
In-migration of job seekers and service providers (from Uganda and elsewhere).
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Capacity of government institutions regarding management of activities (number of
employees, relevant expertise and O&G expertise, enforcement skills, supervision needs,
equipment for tasks demanded, laboratory, monitoring facilities and equipment, regulations,
guidelines):
National level: NEMA, MWE, UWA, UNRA, MEMD, MoH, MoLSG, MTWCH, MLHUD,
MAAIF, NFA, etc.
District level: environmental officers, natural resources management officers, water
officer, forestry, health, planning, (nobody responsible for energy, no energy officer
today), community development officer, labor officer, etc.
Local level: community organisations and associations, hygiene officers (village health
teams), farmer groups,
Response centers and teams (oil spill response, medical emergency response, fire
fighting, etc.)
Capacity of NGOs, CBOs, etc. to undertake public scrutiny.
Loss of cultural heritage.
Capacity of cultural institutions (kingdoms, etc.) to undertake public scrutiny.
Co-existence with the tourism industry.
Cumulative impacts of all activities.
MAIN POSITIVE EFFECTS/OPPORTUNITIES
Main positive effects related to Phase 1 could be:
Petroleum generated revenues and strengthening of national social programs.
Job opportunities.
Local deliveries of goods and services.
Value creation from EWT use.
Petroleum related activities as catalyst for development of other industrial activities.
Improvement of local infrastructure.
Potential increase of property value (+ for owner, - for others).
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4 PHASE 2 SCENARIO – REFINERY OF 20,000 BBLS/D
TIMELINE
End of 2015 until end 2017
Activities described in the Phase 1 Scenario will partly be completed when Phase 2 starts. Some
others will continue. New activities initiated in Phase 2 will be added to the total “picture”.
SUMMARY OF MAIN ACTIVITIES IN PHASE 2
The 20,000 bbls/d refinery module is constructed in Scenario 1 and is now operational. In parallel the
construction activities to expand the refinery capacity to 60,000 bbls/d have started.
The Kingfisher, Mputa and Nzizi fields are on stream and provide feed to the IPP which is delivering
50 MW to the public grid, as well as oil to the refinery. The oil is trucked from the CPF-S1 in the south
to the refinery and the IPP. However, pipelines to the refinery from the northern and southern
developments are being constructed to pipe the oil in next phase.
Significant trucking also takes place to transport oil from EWT to the cement factories and to
transport pipe stacks, refinery modules and equipment from Mombasa to the Hoima construction
base and the refinery site. There is further transportation of drilling supplies to Butiaba and other
potential drilling supply bases, etc. Furthermore, the products from the refinery are trucked to
consumers.
COMPONENTS IN PHASE 2
Below are the remaining activities of Phase 1 which will continue in Phase 2:
EWT (still to continue for some years).
Trucking of oil from EWT sites to consumers.
Operation of IPP at Kabaale with feed from Nzizi (1500 boe/d gas) and Mputa (500 bbls/d oil).
Operation of CPF-S1.
Operation of in-field pipelines to CPF-S1.
Trucking of oil from CPF-S1 to the IPP.
Operation of gas pipeline from CPF-S1 to IPP.
Exploration, appraisal and production drilling elsewhere using 5 rigs continuously, thus approximately 30 wells/year.
Road construction.
Pipe transportation from Mombasa to Hoima regional construction base.
Trucking of refinery modules and equipment from Mombasa to the refinery area.
Operation of regional construction base around Hoima.
Operation of supply bases.
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Additional activities that will be carried out in Phase 2:
Extension of the refinery from 20,000 to 60,000 bbls/d incl. tank farm (2000 – 3000 workers).
Operation of the refinery with 20,000 bbls/d (600 employees).
Refinery products to be transported to consumers. Trucks are assumed to transport
approximately 15,000 bbls/d from the refinery to consumers in the direction of Kampala and
onwards, totally 100 truckloads/day each way.
Oil transportation from Kingfisher (15,500 bbls/d, more than 100 truckloads/d each way) and
Mputa (4500 bbls/d, more than 30 truckloads/d each way) by truck from the CPF-S1 and CPF-
S2 to the refinery.
Delivery of Heavy Fuel Oil (HFO) from the refinery to the IPP via pipeline (100 employees).
The HFO replaces the oil from Mputa as feed to the refinery.
Operation of CPF-S2 in addition to CPF-S1.
Kingfisher is operational and connected to CPF-S2.
Construction of CPF-N1 and CPF-N2 in the north.
Construction of northern pipeline from CPF-N1 and CPF-N2 to the refinery (60 – 120,000
bbls/d). Operation requires 246 employees according to pipeline feasibility study (high).
Pipeline construction will require approx. 2000 workers.
Development of fields in the Murchison Falls NP north and south of Victoria Nile.
Operation of the southern pipeline from CPF-S1 to the refinery.
Construction of in-field gathering lines.
Expanding labor camps and construction supply bases.
The following map/figure illustrates the main components related to the Phase 2 Scenario.
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Figure 4: The Phase 2 Scenario, 2015 – 2017
MAIN CONCERNS
The following concerns are considered to be significant and will be carried over as potential
Key Issues
Timing for main components. Too fast and too many simultaneous activities.
Lack of public infrastructure, especially roads/railway.
Institutional capacity to manage and supervise all simultaneous activities.
Land-take, land use and physical planning.
Construction of in-field gathering lines specifically in the Murchison Falls NP.
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Crossing of the Victoria Nile with pipeline to the CPFs south of the river.
Local content during construction and operation and lack of preparedness to involve local
workforce:
- Construction workers in the range of 5000 – 8000 workers
(2000 for pipeline construction, minimum 3000 for refinery plus some 1000 road
workers, etc.).
- Operations personnel in the range of 1400
(600 for refinery, 100 for HFO line, 400 for oil pipelines, 380 for CPFs, etc.).
- Employees for bases at Butiaba, Hoima and others.
Large scale transportation needs by truck:
- Oil to refinery from Kingfisher and Mputa: approx. 133 large trucks (266 trips).
- Ongoing import of pipes to connect CPFs with refinery: 400 large trucks from Mombasa to
Hoima (800 trips).
- Additional transport of drilling supplies, refinery modules and equipment to
Hoima/Butiaba.
- Trucking of waste to waste facilities: 200 trucks/year (400 trips/year)
Potential challenges related to more activities on Lake Albert (DR Congo activities, drilling
support from barge connected to Butiaba supply base and others).
Presence of extremely large workforce and impacts on local communities.
Use of services and infrastructure (water, power, sewage, gravel, etc.).
Activities in protected and sensitive areas.
Consideration of alternative technical solutions incl. routing and siting.
Waste management, incl. sewage.
Oil spill contingency, incl. transboundary issues (also from activities within DR Congo).
Emergency response (capacity for fire fighting, medical response, disaster management, etc)
and security.
Relationship to DR Congo (coordination, harmonization of standards and operations)
Support to DR Congo exploration activities.
Water consumption and sources – very high needs (injection, camps, etc.)
Climate change issues – effects on Lake Albert water table and risk of flooding of
installations.
Loss of cultural heritage.
Capacity of government institutions regarding management of activities (number of
employees, relevant expertise and O&G expertise, equipment for tasks demanded,
laboratory, monitoring facilities and equipment, regulations, guidelines):
National level: NEMA, MWE, UWA, UNRA, MEMD, MoH, MoLSG, MTWCH, MLHUD,
MAAIF, NFA, etc.
District level: environmental officers, natural resources management officers, water
officer, forestry, health, planning, (nobody responsible for energy, no energy officer
today), community development officer, labor officer, etc.
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Local level: community organizations and associations, hygiene officers (village health
teams), farmer groups etc.
Response centers and teams (oil spill response, medical emergency response, fire
fighting, etc.).
Capacity of cultural institutions (kingdoms, etc.).
Capacity of NGOs, CBOs, etc.
Extensive cumulative impacts of all activities.
MAIN POSITIVE EFFECTS/OPPORTUNITIES
Petroleum related revenues and strengthening of social programs
Increased job opportunities.
Increased local deliveries of food and supplies.
Value creation from EWT use.
Improvement of infrastructure (roads, hospitals, etc.).
Increase of property value (+ for owner, - for others).
More and better energy supply.
Local supplies of fuel and reduced imports.
Foreign exchange savings.
Increased awareness on environmental issues.
5 PHASE 3 SCENARIO – REFINERY OF 60,000 BBLS/D
TIMELINE
End of 2017 until end 2022
Activities described in the Phase 1 and Phase 2 Scenarios will partly be completed when Phase 3
starts. Some others will continue. New activities initiated in Phase 3 will be added.
SUMMARY OF MAIN ACTIVITIES IN PHASE 3
Oil is produced from the Kingfisher, Kaiso-Tonya, Buliisa and Murchison Falls NP areas and all four
CPFs are in operation. From these the oil is transported via the southern and the northern pipelines
to the refinery which now produces 60,000 bbls/d. The HFO from the refinery is piped to the IPP
which continues to produce electricity to the public grid. Refinery products are trucked to consumers
and product pipelines from the refinery to Kampala are constructed to replace the trucking.
Simultaneously, the railway system is refurbished and new lines are constructed to reduce truck
transportation in the direction towards Kampala. Construction activities to expand the refinery
further from 60000 bbls/d capacity to 120000 bbls/d are ongoing.
COMPONENTS IN PHASE 3
Below are the remaining activities of Phase 1 and 2 which will continue in Phase 3:
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Extended Well Testing (EWT).
Trucking of oil from EWT sites to consumers.
Operation of IPP with feed from Nzizi (1500 boe/d gas until 2018) and HFO, after 2018 feed will consist of HFO only.
Operation of CPF-S1 and CPF-S2.
Operation of in-field pipelines to CPF-S1.
Operation of gas pipeline from CPF-S1 to IPP until 2018.
Exploration, appraisal and production drilling using 5 rigs continuously, thus 30 wells/year.
Road maintenance and construction.
Transportation of pipes from Mombasa to the regional base in Hoima.
Trucking of refinery modules and equipment from Mombasa to the refinery area.
Operation of the base outside Hoima.
Operation of supply bases.
Delivery of HFO from the refinery to the IPP via pipeline (operated by 100 employees according to pipeline study).
Kingfisher is operational and connected to CPF-S2.
Operation of the southern pipeline from CPF-S1 to the refinery.
Construction of in-field gathering lines.
Additional activities that will be carried out in Phase 3:
Operation of the refinery with 60,000 bbls/d (600 employees).
Oil transportation of 60,000 bbls/d to the refinery (Kingfisher, Mputa and supplies from
additional fields in the Murchison Falls NP, etc. via oil pipelines.
Construction of a products pipeline from 2017 – 2019 which will subsequently transport
refinery products to Kampala from 2019 with onwards transportation by truck/barges (on
Lake Victoria to Kenya and Tanzania potentially)/railway.
Until end of 2019 approx. 300 large trucks will transport approx. 45,000 bbls/d products from
the refinery to consumers. From 2020 onwards trucking will be reduced.
Construction of the extension of the refinery for 120,000 bbls/d.
Extension of the IPP to receive more HFO from the 120,000 bbls/d refinery from 2022
onwards.
Oil production from fields in the Kingfisher, Buliisa, Murchison Falls NP and Kaiso-Tonya
areas.
Operations of all CPFs. Operations require 378 workers.
Pipeline operation from CPF-N1 and CPF-N2 to the refinery (246 operations personnel
according to the feasibility study for the pipeline).
Pipeline operation from the southern CPF-S1 to the refinery
Construction of two new oil pipelines parallel to the northern and southern oil pipelines to
extend transport capacity to the refinery.
Construction and operation of potential supply base in the south of Lake Albert.
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Drilling offshore in the south of Lake Albert from rig, artificial island or other.
Construction of oil export pipeline from the refinery area towards Kampala and onwards to
markets.
Development of the Ngassa gas field and construction of gas pipeline from the field to the
refinery area and onwards to Kampala.
Rehabilitation and construction of railway from the refinery to Kampala and onwards to
Mombasa.
The following map/figure illustrates the main components related to the Phase 3 Scenario.
Figure 5: The Phase 3 Scenario, 2017 to 2022
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MAIN CONCERNS
Concerns considered to be significant and candidates as potential Key Issues:
Timing for main components. Too fast development of the petroleum resources and too
many simultaneous activities.
Lack of public infrastructure.
Transportation needs
- 300 large trucks for transportation of refinery products until 2019.
- Additional transport of drilling supplies, refinery modules and equipment to
Hoima/Butiaba.
- Trucking (or transportation by barge) of drilling supplies from the supply bases to the well
sites, specifically to the Murchison Falls NP
- Trucking (or transportation on barge) of waste to waste facilities: minimum of 200
trucks/year for drilling waste alone
- Transportation needs of DR Congo
More extensive activities on Lake Albert (and potentially Lake Victoria) and related to
crossing of the Victoria Nile.
Operations in protected areas, specifically Murchison Falls NP.
Co-existence with tourism and fisheries.
Presence of large workforce and impacts on local communities.
Change in social patterns and adaptation capacity of local communities.
Boom-bust effects from ending construction activities (the Dutch disease).
Local content during construction and operation
- Construction workers in the range of 5000 – 8000 workers
- Operations personnel in the range of 1400 workers
- Plus employees for bases at Butiaba, Hoima and others
Use of services and infrastructure (water, power, sewage, gravel, etc.).
Oil spill contingency, incl. transboundary issues (also from activities within DR Congo).
Emergency response and security.
Relationship to DR Congo (coordination, harmonization of standards and operations).
Water consumption and sources – very high needs (injection, camps, etc.).
Climate change issues – effects on Lake Albert water table regardin the risk of flooding of
installations.
Pipeline transportation of oil across the Victoria Nile.
Waste management
- Drilling waste alone is approx. 7000 tons/a,
- Refinery waste,
- Produced water, etc.
Relationship to neighbouring countries – transboundary issues.
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Consideration of alternative technical solutions incl. routing and siting.
Air and noise pollution from refinery, IPP and transportation.
Production activities in protected and sensitive areas.
Institutional capacity to manage and supervise activities.
Land-take, land use and physical planning.
Cultural heritage.
Capacity of government institutions regarding management of activities (number of
employees, relevant expertise and O&G expertise, equipment for tasks demanded,
laboratory, monitoring facilities and equipment, regulations, guidelines):
National level: NEMA, MWE, UWA, UNRA, MEMD, MoH, MoLSG, MTWCH, MLHUD,
MAAIF, NFA, etc.
District level: environmental officers, natural resources management officers, water
officer, forestry, health, planning, (nobody responsible for energy, no energy officer
today), community development officer, labor officer, etc.
Local level: community organisations and associations, hygiene officers (village health
teams), farmer groups.
Response centers and teams (oil spill response, medical emergency response, fire
fighting, etc.).
Capacity of NGOs, CBOs, etc.
Capacity of cultural institutions (kingdoms, etc.).
Cumulative impacts of all activities
MAIN POSITIVE EFFECTS/OPPORTUNITIES
Petroleum generated revenues and expansion of social programs
Increased job opportunities.
Increased local deliveries of food and supplies.
Further improvement of infrastructure (roads, hospitals, etc.).
Increase of property value (+ for owner, - for others).
More and better energy supply.
More supplies of fuel and diesel substituting imports.
Foreign exchange savings.
Increased awareness on environmental issues.
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6 PHASE 4 SCENARIO – REFINERY OF 120,000 BBLS/D
TIMELINE
End of 2022 until end 2030
Activities described in Phase 1, 2 and 3 Scenarios are partly completed when Phase 4 starts. Some
others will continue into Phase 4. New activities initiated in Phase 4 are added.
SUMMARY OF MAIN ACTIVITIES IN PHASE 4
All fields are on stream and Uganda now produces 300,000 bbls/d of oil. Bundling of infrastructure
has taken place and pipelines have been constructed parallel to the existing lines to the refinery to
expand the capacity. All oil is piped to the refinery area which has developed as a central oil hub.
In addition to the 120,000 bbls/d for the refinery, the surplus of 180,000 bbls/d is exported together
with oil from DR Congo and possibly South Sudan via an export pipeline. The products from the
refinery are piped to Kampala and distributed onwards.
The refinery produces 120,000 bbls/d and supplies not only Uganda but also markets of the EAC. As
the electricity demand has risen considerably, the IPP has been extended to take all HFO produced by
the refinery. A gas fired power plant and LPG plant has been constructed to use the gas from Ngassa
and other gas fields and reduce use of fire wood. Furthermore, petrochemical industry has been
established in the refinery area.
COMPONENTS IN PHASE 4
Below are the remaining activities of Phase 1, 2 and 3 which will continue in Phase 4
Operation of IPP with HFO feed.
Operation of all four CPFs.
Operation of in-field pipelines to all CPFs.
Exploration, appraisal and production drilling (less than earlier phases).
Road construction.
Pipe transportation from Mombasa to Hoima base.
Trucking of refinery modules and equipment from Mombasa to the refinery area.
Operation of regional construction base around Hoima.
Operation of supply bases.
Delivery of HFO from the refinery to the IPP via pipeline.
Kingfisher is operational and connected to CPF-S2.
Operation of the southern pipeline from CPF-S1 to the refinery.
Construction of in-field gathering lines.
Operation of the refinery with 60,000 bbls/d (600 employees).
Oil transportation of 60,000 bbls/d to the refinery (Kingfisher, Mputa and supplies from
additional field’s incl. Murchison Falls NP, etc. via oil pipelines
Refinery products transported to consumers.
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Construction of a products pipeline from 2017 – 2019 which will subsequently transport
refinery products to Kampala from 2019 with onwards transportation by truck/barges (on
Lake Victoria to Kenia and Tanzania potentially)/railway.
Construction of the extension of the refinery for 120,000 bbls/d.
Oil production from fields in the Kingfisher, Buliisa, Murchison Falls and Kaiso-Tonya areas.
Pipeline operation from CPF-N1 and CPF-N2 to the refinery.
Pipeline operation from the southern CPF-S1 to the refinery.
Operation of potential supply base in the south of Lake Albert.
Drilling offshore in the south of Lake Albert from rig, artificial island or other.
Rehabilitation and construction of railway from the refinery to Kampala and onwards to
Mombasa.
Additional activities that will be carried out in Phase 4:
Operation of the refinery with 120,000 bbls/d
The parallel pipelines from the north and the south are operational and transport 300,000
bbls/d to the refinery site, of which 120,000 bbls/d will fuel the refinery.
The surplus of 180,000 bbls/d is exported via a dedicated export pipeline which also has
capacity for oil from DR Congo and possibly South Sudan.
Operation of the larger scale IPP using the total HFO from the refinery.
Refinery products (petrol, diesel) are transported to consumers. Transportation by pipelines
to Kampala and onwards by truck/barges (on Lake Victoria to Kenya and Tanzania
potentially)/railway. It is assumed that the product pipelines are designed for a capacity of
120,000 bbls/d from the beginning
Gas production from Ngassa and other fields is transported via pipeline to a receiving facility
in the refinery area, where the production of bottled LPG will reduce the use of fire wood.
The remaining gas is transported via a gas pipeline to a gas fired power plant in the refinery
area. Surplus gas is transported via the gas pipeline towards Kampala.
Operations of gas pipeline from refinery to Kampala, also with capacity for gas from DR
Congo.
Production drilling.
Potential further developments in Lake Albert, incl. drilling.
Existing oil/gas fields in northern and southern areas are fully developed and subsequently
on stream.
Ongoing construction of roads and railway networks.
Albertine Graben area serves as a hub for operations in DR Congo and South Sudan providing
oil export capacity and petroleum industry services.
Establishment of petrochemical industry in the refinery area.
The following map/figure illustrates the main components related to the Phase 4 Scenario.
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Figure 6: The Phase 4 Scenario, 2022 to 2030
MAIN CONCERNS
Timing for main components. Too fast development of the Albertine Graben area and too
many simultaneous activities.
Ongoing presence of large construction workforce and impacts on local communities.
Extensive change in regional social patterns and low adaptation capacity of local
communities.
Change of macro-scale social and socio-economic dynamics and adaption capacity within
Albertine Graben influence areas.
Boom-bust effects from ending construction activities.
Use of services and infrastructure (water, power, sewage, gravel, etc.).
Emergency response and security.
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Waste management:
- Drilling waste alone is approx. 7000 tons/a.
- Refinery waste.
- Produced water, etc.
Relationship to DR Congo (coordination, harmonization of standards and operations)
Relationship to neighbouring countries in general (incl. Egypt regarding water resources) –
transboundary issues.
Operations in protected areas, specifically Murchison Falls NP.
Co-existence with tourism and fisheries.
Local content during construction and operation:
- Construction workers exceeding the range of 5000 – 8000 workers.
- Operations personnel in the range of several 1000 workers.
- Plus employees for bases at Butiaba, partly Hoima and others.
Pipeline transportation of oil across the Victoria Nile and other transport crossing the Victoria
Nile.
Consideration of alternative technical solutions incl. routing and siting.
Transportation:
- Transporation for social amenities.
- Transport of drilling supplies from the supply bases to the well sites, specifically to the
Murchison Falls NP and to the bases.
- Transport of waste to waste facilities.
- Transportation needs of DR Congo.
Transportation on Lake Albert and Lake Victoria. Extended activities on the lakes.
Oil spill contingency, incl. transboundary issues (also from activities within DR Congo)
Water consumption and sources – very high needs (injection, camps, etc.). Water
management.
Climate change issues – effects on Lake Albert water table regarding flooding of installations.
Air and noise pollution from refinery, IPP, transportation, operations in protected and
sensitive areas etc.
Capacity of government institutions regarding management of activities (number of
employees, relevant expertise and O&G expertise, equipment for tasks demanded,
laboratory, monitoring facilities and equipment, regulations, guidelines):
National level: NEMA, MWE, UWA, UNRA, MEMD, MoH, MoLSG, MTWCH, MLHUD,
MAAIF, NFA, etc.
District level: environment Officers, natural resources management officers, water
officer, forestry, health, planning, (nobody responsible for energy, no energy officer
today), community development officer, labor officer, etc.
Local level: community organisations and associations, hygiene officers (village health
teams), farmer groups.
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Response centers and teams (oil spill response, medical emergency response, fire
fighting, etc.).
Capacity of NGOs, CBOs, etc.
Institutional capacity to manage and supervise activities.
Capacity of cultural institutions (kingdoms, etc.).
Land-take, land use and physical planning.
Loss of cultural heritage.
Capacity of government institutions regarding management of activities.
Macro-economic issues, inflation, distortion of price ratio regarding exports.
Increased pressure on natural resources in protected areas, riverine habitats, etc.
Cumulative impacts of all activities.
MAIN POSITIVE EFFECTS/OPPORTUNITIES
Petroleum generated revenues and expansion of social programs
Increased job opportunities.
Increased local deliveries of food and supplies.
Improvement of infrastructure (roads, hospitals, etc.).
Increase of property value (+ for owner, - for others).
More and better energy supply.
More supplies of fuel and diesel substituting imports.
Foreign exchange savings and earnings.
Increased awareness on environmental issues.
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APPENDIX 4: STAKEHOLDER ENGAGEMENT PROCESS & LOG
Stakeholder Engagement Process
Stakeholder engagement in this SEA was a key activity that aimed to mobilize participation of the relevant institutions, individuals and communities for environment management of the oil and gas in the Albertine Graben. The specific objectives of the stakeholder engagement were as follows:
Ensure public participation in the SEA process; and
Inform, collect views and build ownership of the different stakeholders as their specific concerns about oil and gas projects are collected and considered during the SEA process.
The stakeholder engagement process is a cornerstone for a multi-stakeholder partnership recommended in Chapter 6.4. A stakeholder analysis presented in the next section was used to determine the stakeholders to involve in the SEA process.
Stakeholder analysis
The oil and gas activities in the Albertine Graben have wide implications on a number of resources and sectors. This is because of the dynamics of oil and gas exploration and development. The dynamics are accentuated by occurrence of the petroleum resources in an area of ecological and socio-economic significance. These include scenic and culturally recognized landscapes (mountains, the rift, escarpments, lakes, etc,) that host key biodiversity resources, moreover of trans-boundary nature. Therefore various institutions have a stake in the developments pertaining to oil and gas in the AG.
The institutions identified were grouped into three different but interlinked main categories depending on stakes, roles and responsibilities in environment management of oil and gas. Figure 1 below presents an illustration of the main kinds of stakeholders, the key categories and responsibilities.
The stakeholders for each key issue were identified through the key issues integration discussed in Chapters 5 and 6.
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Figure 1 - Appendix 4: Key types of stakeholders, categories and responsibilities
Methodology and approach used in stakeholder engagement and outcome of the
consultations
Stakeholder engagement for the SEA employed a highly participatory and consultative methodology.
Considering representation of the stakeholder categories, consultations were undertaken through focus group discussions, meetings with institutions and workshops at different levels (national, local and regional levels).
A Stakeholder Engagement Strategy and a connected detailed Stakeholder Engagement Plan was
developed with the objective of ensuring that a consistent and coordinated culturally appropriate
approach was taken to involve the relevant stakeholders. The strategy ensured that national
requirements were followed and at the same time complying with international standards.
Building on the stakeholder analysis and key issues ( Appendix 6) the Stakeholder Management Plan
involved identification of stakeholders to involve in the SEA , scheduling of meetings (communication
of agenda regarding issues to be discussed, date, time and venue of the meetings) and was
continuously updated during the full SEA process. It involved documentation of relevant background
information, inventories of specific consultations, handling of suggestions, comments and concerns
raised by the stakeholders.
A checklist was the key tool used to collect the views from focus group discussions and meetings. Integrated also was telephone and internet through email correspondences on specific issues. A stakeholder engagement log presented in this Appendix was used to document and track concerns from each stakeholder consulted.
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All major stakeholder consultations are explained and integrated into the SEA process in chapter 2.4.
The conclusions from the consultations are documented in minutes of meetings and specific notes.
Further details can be found in the Inception Report and the Interim Report. All issues of relevance
and importance, from the early start up of the SEA process in 2010, until the SEA assessment phase,
are integrated into the Issues Register and Analysis, Appendix 6. Outcome of the stakeholder
consultations during the assessment phase is documented in Chapter 5 and in the Key Issues
Integration Matrix, Appendix 7.
Consultation meetings with district local governments and communities in the Albertine
Graben
Good communication and involvement with local people in the Albertine graben has been essential for the SEA and such relations are therefore explained specifically in this chapter. District Local Governments
The SEA targeted 12 districts for consultations including those that are outside the geographical
scope of the SEA due to interest in offsite issues. These were: Arua, Nebbi, Nwoya, Amuru, Buliisa,
Hoima, Masindi, Kibaale, Kabarole, Kyenjojo, Ntoroko and Bundibugyo. The Districts were consulted
at three levels as follows:
1. Initial consultations were with authorities in the selected districts of Buliisa, Hoima and Nwoya (see section 2.4.3 on meetings during reconnaissance trip of 8 -11 May 2012).
Further consultations were held in the districts of Hoima and Buliisa between 26-28th November 2012 (see Appendix 7), Only two districts were covered at this stage due to limited time.
In both meetings at District Local government level, the following personnel were targeted:
LC V and selected Executives (Politicians)
Chief Administrative Officer
Environment Officer (main contact person)
Natural Resources Coordinator
District Forest Officer
Fisheries Officer
Agricultural Officer
Water Officer
District Planner
Health officer
Community Development Officer
Officer handling Culture and archeological resources (Note that some personnel double or triple in one position)
2. The District Local Governments were consulted also during stakeholder consultation
workshops: At least an environment officer from each of the 13 districts participated in the
inception and/or validation workshops.
3. Municipality level: A meeting was held with Hoima Municipal Council during the
consultations with the District Local Government of 26-28th November 2012. The meeting
aimed to capture urban/physical planning issues. Participants included Municipality officials
and the Mayor.
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Community levels
At community level, focus group discussions were held with the Bunyoro-Kitara Kingdom as cultural
institution and with a fishing community as follows:
1. The Kingdom of Bunyoro –Kitara during the District Local Government Cosnultations of 26-
28th November 2012. High level officials of Bunyoro Kitara Kingdom attended the meeting
including the Minister of Education, Minister of Finance and Prime Minister.
2. Meeting with the fishing community: The meeting was held at Butiaba landing site during the
District consultations of 26-28th November 2012. The meeting was attended by officials of
the Beach Management Unit (BMU), LC (relevant) Secretary for Defense and Secretary for
Education.
Consultations at international/regional level
Democratic republic of Congo (DRC): Consultations with DRC were concerned with the shared
Lake Albert resources. Initially only email and telephone contacts have been made.
East African Community (EAC): The EAC has oil and gas programmes that involve all the
member countries including Uganda. The community arranges fora on petroleum
development and is influential on planning and decisions within member countries. However,
the SEA interest is to ensure that regional matters of environment management in oil and gas
that apply to the AG are well articulated. Consultations with EAC will be during the validation
process.
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Stakeholder Engagement Log
Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Bulisa District Local Government
Issues of capacity of district & environment management
11/27/ 2012
District head quarters
Meetings Issues of capacity of the district & environment management
Additional recommendations obtained
Email the list of Key Issues Action matrix
B. Turyahumura, T. Twongo, C. Mwebaze., H. Makuma, C. Kinyera
Bunyoro-Kitara Kingdom
Discuss issue of oil & gas coexistence with the Kingdom
11/26/ 2012
Kingdom Prime minister offices
Meetings Discuss issue of oil & gas coexistance with the Kingdom
Issues of cultural heritage discussed and captured
Email the list of Key Issues Action matrix
B. Turyahumura, T. Twongo, C. Mwebaze., H. Makuma, C. Kinyera
Butiaba Beach Management Unit
Fisheries manage-ment
11/27/ 2012
BMU Ofices/ landsite
Meetings Fisheries management
Additional recommendations obtained
Email the list of Key Issues Action matrix
B. Turyahumura, T. Twongo, C. Mwebaze., H. Makuma, C. Kinyera
CNOOC Discussion on scenario analysis
6/27/ 2012
TOTAL offices
presented info + discussion
1. feasibility of phases, 2. other options, 3. additional info
clarifications on scenarios and feasibility, export pipeline requires > 250,000 b/d
further discussion B. Turyahumura, B. Kristoffersen, H. Pflästerer
Department for Urban Development (MoLHUD)
Discussion on physical planning of the AG
18/10/ 2012
MoLHUD Meeting plans to fast-track physical planning for the AG, starting with selected towns, staffing of urban planners
Physical Planning Act, 2010 declared the whole country a planning area.
J. Bemigisha, H. Makuma
Directorate of Water Resources Management (DWRM)
Discussion on role of DWRM in oil and gas planning in the AG
10/18/ 2012
DWRM offices, Entebbe
Meeting How DWRM is prepared to meet challenges of oil and gas in Albertine Graben
Established that preparations are in progress and notably,the directorate received new equipment for analyses related to oil and gas
Ensure deeper understanding on how DWRM is operating
Strenghen capacity to handle oil and gas related challenges
J. Bemigisha, B. Turyahumura, T. Twongo
Hoima District Local Government
Issues of capacity of the district & environment management
11/26/ 2012
District head quarters
Meetings Issues of capacity of the district & environment management
Additional recommendations obtained
Email the list of Key Issues Action matrix
B. Turyahumura, T. Twongo, C. Mwebaze., H. Makuma, C. Kinyera
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Hoima Municipality
Issues of capacity of the district & environment management
11/26/ 2012
Hoima Municipality officies
Meetings Issues of capacity of the district & environment management
Additional recommendations obtained
Email the list of Key Issues Action matrix
B. Turyahumura, T. Twongo, C. Mwebaze., H. Makuma, C. Kinyera
International Alert,Coalition of NGOs of oil and gas CISCO
Capacity building of NGOs and CBOs
22/10/ 2012
Protea Hotel, Kampala
Capacity building for national and local governments, Strengthening the NGOs & CBOs to participate much more effectively
Promised to share plans and data on research undertaken by the organisation
J. Bemigisha
Makerere University-Department of Environ-mental Management
Issues of capacity building and trainin in oil & gas
15/09/ 2012
Makerere University
Checklist Trainng in the oil sector, oil & gas programs
recommendations on capacity building
J. Bemigisha, H. Makuma
Ministry of Agriculture Animal Industry and Fisheries, Fisheries department
Fisheries' preparedness for oil and gas
31/10/ 2012
Fisheries department offices
Key informant interveiw
PPPs, key issues, capacity needs, compliance and monitoring preparedness
ACT and policy need review, need for regulations, transboundary - need for colaboration between Uganda and DRC on fishing intensity
G. Nangendo, T. Twongo
Ministry of Energy and Mineral Development (MEMD)-Petroleum Exploration and Produc-tion Dept. (PEPD)
Discussion on scenarios, PPPs, key issues, petroleum activities in protected and sensitive areas
24/10/ 2012
Entebbe Discussion The three scenarios, key issues, PEPD’s PPPs -institutions and districts relationship
Understanding of the three scenarios, response to and understanding of key issues, PEPD's readiness for oil and gas.
B. Turyahumura, B. Kristoffersen, H. Pflästerer, G. Nangendo, J. Bemigisha, E. Kahubire
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Ministry of Finance Planning and Economic Development
Revenue sharing
Ministry offices
Use of a checklist and discussion
Need for discussion with the stakeholder districts to explain why 7% percent is the ideal share.
E. Kateregga
Ministry of Gender and Social Development
Discussion on Co-existance with Local Communities and Capacity Building Issues
Kampala Key informant interveiw
Existing Policies, Plans and Programmes for the Graben
Proposals on communities coping with development in AG and handling occupational health and safety issues
Need for an AG social develop-ment programme to ensure that communities cope with development
Take these discussions further in minstry activities
J. Bemigisha., E. Kahubire
Ministry of Lands, Housing and Urban Development (MLHUD)
Discussions on Land and compensation issues in particular sensitisation materials and manuals
Kampala Telephone Interview
Existing tools for sensitisation and capacity buidling
All manuals and materials are exising but need to be translated into local languages of the Graben, this has to be budgeted for
further discussion E. Kahubire
Ministry of Lands, Housing and Urban Development (MLHUD)
Preparedness for oil and gas
Ministry offices
Key informant interveiw
Existing plans in presence of oil and gas,
Knowledge about existing national plans, Oil area designated special planning area, Urbanization policy has been initiated
J. Bemigisha, G. Nangendo
Ministry of Lands, Housing and Urban Development (MLHUD)
Discussions on Land and compensation issues
Kampala Key informant interveiw
Existing Policies, Plans and Programmes for the Graben
Discussions on issues that have come up as a result of land administration gaps, capacity gaps of district land boards and related frameworks
further discussion E. Kahubire
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Ministry of Local Government
SEA action key isues
24/10/ 2012
Workers House, Level 4
Use of a checklist and discussion
Co-existence with Local Communities incl. Indigenous Peoples; other industries & service providers; sharing of revenues and wellbeing between National and Local/ Regional level. Co-operation and land use and spatial planning
Various recommendations made on the stated issues
H. Makuma, G. Nangendo, T. Twongo
Ministry of tourism, wildlife and heritage
Preparedness for oil and gas, co-exitance with Tourism
28/11/ 2012
Ministry offices
Discussion PPPs. Key issues, capacity
Shortage of both staff and equipment to meet oil and gas requirements, Lack of capacity to monitor complience, wildlife policy review complete, wildlife ACT review at infancy
G. Nangendo, H. Makuma
Ministry of Water and Environment (Wetlands Department; Directorate of environment)
Preparedness for oil and gas
25/10/ 2012
Kampala (munyonyo resort)
Discussion PPPs, capacity needs, plans for sensitive areas outside protected areas, compliance and monitoring preparedness
ACT, policies and regulations need review, need for baseline data highlighted, need to clarify role of principle agency and that of lead institutions, observation that oil process is very fast and expectations are high and uncompromisable
B. Turyahumura, G. Nangendo, J. Bemigisha
Ministry of Works and Transport
Consultations on Infrastructu-ral Issues and Findings from Scenarion Analysis
17/10/ 2012
Entebbe Key informant interview
Infrastructural Plans
Information on Plans that the Ministry Has in the Graben and clarification of mandates of both UNRA and Ministry of Works and Transport
Discuss with UNRA on capacity of Kaiso -Tonya Road to meet the transport demands
Attendance required in validation workshop so that plans are intiated
E. Kahubire
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
National Environment Management Authority (NEMA)
Institutional set up and mandate, PPPs and capacity
1/11/ 2012
NEMA BOARDROOM
Discussion with Key informants
Institutional setup and mandate, PPPs, Institutional capacity, monitoring of oil activities especially in sensitive areas
Clarification of institutional set up and mandate, ACT is under review, regulations need update, those completed need approval
B. Turyahumura, J. Bemigisha. G. Nangendo, D. Ongwen
National Fisheries Resources Research Institute (NaFIRRI)
clarifyon ares of research
NaFIRRI Discussion with Key informants
sensitive areas that could by impacted by oil and gas, hydro-dynamics of Lake Albert
T. Twongo
National Forest Authority
Institution's preparedness for oil and gas activities
23/10/ 2012
Kampala Discussion key informants
Adequacy of existing PPPs, capacity of government for oil and gas
Information on Plans that need review or completion, highlighting of capacity needs,
G. Nangendo, J. Bemigisha
Office of the Prime Minister
Role of OPM in oil spill contingency planning
OPM offices Meeting Role of Department of disaster preparedness in oil spill contingeny planning
It was as noted that Department of Disaster preparedness was not consulted on ongoing oil spill contengency plan formulation and yet it has a role to play
Reminded the department to take part in oil spill contingency planing
Review the existing policy and take part in the oil spill contingency planning
B. Turyahumura
Oil & Gas security team
Clarification on security plans for the AG wrt. oil and gas discoveries
15/03/ 2013
PEPD Entebbe
Discusion/meeting
Security, transboundary issues, conflicts
Plans on Uganda DRC boarder demercation
Provide recommendation later on the issue of security in the AG
Recommenda-tion on security isssue in the AG
J. Bemigisha, H. Makuma
Oil security coordination team
Clarification on security planning for AG
12/06/ 2013
ESIPPS offices
Discussion/ meeting
Transboundary issues, coordination of security agencies, env. impacts of oil activities
Draft multi-disciplinary security plan (2012) awaiting president approval
Env. impacts and land speculation to be controlled, Uganda-DRC boundary to be marked.
B. Turyahumura J. Bemigisha
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Physical Planning Department, MoLHUD
Dsicussion on physical planning of the AG
02/11/ 2012
MoLHUD Meeting environment as one of the biggest considerations due to the sensitivity of the National parks, foretst, lakes etc and need for ecological considerations
J. Bemigisha, G. Nangendo
The Parliament –Natural Resources committee
Consider SEA notes in petroleum (exploration, development and production) Bill, 2012 are included
Munyonyo Delivery of advisory notes to remind the chairperson
Reminded chairperson of advisory notes, earlier delivered to the committee
Chairperson promised to folow up
Contacted Hon. Lukyamuzi to remind Chairperson
B. Turyahumura, J. Bemigisha
Total Discussion on scenario analysis
27/06/ 2012
Total offices presented info + discussion
1. feasibility of phases, 2. other options, 3. additional info
clarifications on scenarios and feasibility, export pipeline requires > 250,000 b/d
further discussion B. Turyahumura, B. Kristoffersen, H. Pflästerer
Tullow Oil Discussion on scenario analysis
27/06/ 2012
Tullow offices
presented info + discussion
1. feasibility of phases, 2. other options, 3. additional info
clarifications on scenarios and feasibility
further discussion B. Turyahumura, B. Kristoffersen, H. Pflästerer
Uganda Association for Impact Assessors (UAIA)
EIA quality control, capacity for oil and gas EIAs
11/07/ 2012
Hotel Protea
Use of a checklist and discussion
Committee's role in EIA quality control, Practitioners' capacity to prepare oil and gas related EIAs
Set up standards for EIA preparation pricing, training of practioners in oil and gas EIA preparation, others selected for training, complaint about clogging of EIAs at NEMA and delay of approval
The UAIA strategy to be made available
J. Bemigisha, H. Makuma, G. Nangendo
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
Uganda National Roads Authority (UNRA)
Discussion on Issues of spatial/transport planning of the area, EIA process and safety
11/2/ 2012
UNRA Offices, lourdel Road
Use of a checklist and discussion
Spatial and road planning for the Albertine Graben
Environment issues intergrated in the road design, various plans in place for the Albertine Graben, Revisions have been made on the design of the road to ensure that the road meets the expected demand
further discussion will avail to us the AG roads master plan. Also the Kaiso Tonya road feasibility study
E. Kahubire, H. Makuma
Uganda Police - Fire Brigade
Role of fire brigade in oil spill contingency planning
Kampala Fire Brigade head office
Meeting Policy, Police Act, operations of fire brigade in Uganda
It was noted that fire brigade head office was not consulted on ongoing oil spill contengency plan formulation and yet it has a role to play
Ensure police fire brigade is involved in oil spill contincy formulation study
Kampala fire brigade agrred to take part in oil spill contingency formulation if consulted
B. Turyahumura, T. Twongo
Uganda Wildlife Authority (UWA)
Institution's preparedness for oil and gas activities
4/11/ 2012
Kampala Discussion Petroleum activities in protected areas, available and updated ppps, wate management, institutional capacity to handle oil issues
Policy already reviewed, ACT at infancy stages of review, Management plans are under review, Guidelines for oil companies' operations in pretected areas ready
E. Kateregga
Wildlife Conservation Society
Discussion on ways oil and gas activities could improve conservation
23/10/ 2012
Kampala Discussion Adequacy of existing PPPs, oil and gas infrastructure in protected areas, capacity of government conservation institutions for oil and gas, transboundary issues
Advice on where conservation approaches need improvement to survive the oil and gas impacts
G. Nangendo, J. Bemigisha, T. Twongo
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Stakeholder organization
Purpose Date Location Consulta-tion means
Discussion topics Outcome Actions agreed for SEA Team
Actions agreed for stakeholder
SEA Team participant
WWF Discussion on the key issues of consultation
12/11/ 2012
WWF country Offices
Use of a checklist and discussion
Issues of bioviversity hotsopts and capacity of the institutions specifically the CSOs
GEF project report of strengthening of forest management in northern AG, support of recommendations of world heritage sites like the Viruga areas, Habitat degradation and rehabilitation, waste management and land ownership and compensation modes, management of indirect impacts and long term impacts
share following reports: International best management practices report by WWF of oil & gas environmetal issues, BD corridor map, SEA for the lake Edward, Congo Side
J. Bemigisha, H. Makuma
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APPENDIX 5: ENVIRONMENTAL LAWS AND REGULATIONS;
INTERNATIONAL AND REGIONAL CONVENTIONS AND
AGREEMENTS AND ADDITIONAL POLICIES
This appendix presents the following:
a) National environmental laws regulations , including compliance and enforcement tools b) International and Regional Conventions and Agreements c) Highlight of the policies that are listed in Chapter 4 but not described in detail d) Other key ministries and agencies referred to in Chapter 4
a) ENVIRONMENTAL LAWS AND REGULATIONS
THE NATIONAL ENVIRONMENT ACT 1995, CAP 153 of 2000:
The following principles of the Act directly apply to Oil and Gas Sector activities:
I. Reclaim lost ecosystems where possible and reverse the degradation of natural resources
(Restoration).
II. Establish adequate environmental protection standards and monitor changes in
environmental quality.
III. Publish relevant data on environment quality and resource use.
IV. Require prior environmental assessments of proposed projects that may significantly affect
the environment or use of the natural resources.
V. Ensure that the true and total costs of environmental pollution are borne by the polluter.
VI. Promote international cooperation between Uganda and other states in the field of
environment.
The main gap regarding enforcement and compliance to environmental standards by the Oil and Gas
sector is inadequate support by the current licenses and Permits to the application of “Polluter Pays
Principle”.
THE NATIONAL ENVIRONMENT (AUDIT) REGULATIONS (2006): These Regulations prohibit the
carrying out of environment audits without due certification and registration, except if the person is
an environmental inspector. The Regulations also provide for the preparation of environmental audit
reports; require owners or operators of facilities whose activities are likely to have a significant
impact on the environment to establish environmental management systems; provide for
enforcement environmental audits; and encourage voluntary environmental audits and compliance
agreements to aid facility compliance to environmental requirements.
The Regulations apply to the oil and gas activities as follows:
Section 3 (Application of Regulations), Section 7 (Submission of environmental audit report), Section
8(Requirements for environmental management systems), Section 15 (Powers of environmental
inspector upon entry of facility) and, Section 16 (Public involvement in enforcement of
environmental audits)
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Section 19 (Initiating Voluntary Environmental Audits) provides for conducting voluntary audits by
the operators while Section 24 (Environmental compliance agreement) provides for an
environmental compliance agreement between NEMA and the Operator.
Although the regulations provide for self-monitoring, the SEA concern will be the inadequacy of an
independent system to verify the reports submitted by the Operator.
THE NATIONAL ENVIRONMENT (MINIMUM STANDARDS FOR MANAGEMENT OF SOIL QUALITY)
REGULATIONS (2001): The purpose of these Regulations is: to establish and prescribe minimum soil
quality standards to maintain, restore and enhance the inherent productivity of the soil in the long
term; to establish minimum standards for the management of the quality of soil for specified
agricultural practices; to establish criteria and procedures for the measurement and determination of
soil quality; and to issue measures and guidelines for soil management. The Regulations have six
schedules which deal with all these aspects. The first schedule provides for soil quality parameters;
the second schedule is on guidelines for management of fragile or peculiar soils; the third schedule
provides for parameters and methods of determination of soil quality; the forth schedule is on soil
conservation measures and guidelines; the fifth schedule provides for recommended frequency for
monitoring of soil quality parameters for enforcement purpose; and the sixth schedule is on
improvement notice.
The regulations provide sufficiently for soil quality, conservation and monitoring but the SEA concern
will be the capacity for enforcement of the regulations regarding impacts of gas and oil exploration
waste on soils in the Albertine Graben.
THE NATIONAL ENVIRONMENT (MINIMUM STANDARDS FOR DISCHARGE OF EFFLUENTS INTO
WATER OR LAND) REGULATIONS (1998): These Regulations prohibit discharge of effluent or waste
on land or into the aquatic environment contrary to established standards and without a waste
discharge permit. They provide for the general obligation to mitigate pollution by installation of
antipollution equipment for the treatment of effluent and waste discharge emanating from an
industry or establishment. They also provide for sampling of effluent and waste water analysis.
The provisions directly applicable to oil and gas activities are included in Section 4 (General
Obligations to mitigate pollution), Section 3 (Standards for effluent) and Section 5 (Duty to keep
records).
The regulations are explicit on monitoring processes but concern is the heavy dependence on the
“Self-monitoring” records without sufficient safeguards for verification of the records by the
regulator.
THE NATIONAL ENVIRONMENT (WETLANDS, RIVERSBANKS AND LAKE SHORES MANAGEMENT)
REGULATIONS (2000): These Regulations provide for the protection of wetlands; their conservation
and wise use; inventorying of wetlands; and wetland use permits for regulated activities. The
Regulations also provide for protection zones for riverbanks and lakeshores. In particular, the rivers
and lakes outlined in the sixth and seventh schedules to the Regulations have a protection zone of
two hundred meters from the low water mark for lakes and one hundred meters from the highest
water mark for rivers. Other lakes and rivers have a protection zone of one hundred meters from the
low water mark for lakes and thirty meters from the highest water mark for rivers. No activity is
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permitted in the protection zone without the written authority of the executive director of the
National Environment Management Authority.
The following provisions are applicable to the oil and gas activities in the Albertine graben.
Part I (Wetlands)...subsection (f) of Section 4 (Objectives) provide for minimizing and controlling
pollution of wetlands. In addition, Section 5 (Principles in the management of Wetlands) adequately
provides for wetlands management. However, Schedule 3 of the Regulations should specify all
Ramsar Sites in the Albertine graben (Lake George Ramsar Site and Murchison Fall Albert Delta
Ramsar Site).
Part III (Riverbanks and lakeshores) provides for prevention of siltation of rivers and lakes and
controlling pollution-degrading activities (Subsection (f) of Section 19 (Objectives). Additional
provisions are included in subsection (c) of Section 20 (special measures for the protection of
riverbanks and lakeshores as preventing soil erosion, siltation and water pollution), Section 23
(Permit to use riverbank and lakeshore) on activities of drilling, excavating and disturbance of lake
shores, Section 29 (Protection zones for riverbanks) in reference to the Nile and Lake Albert and,
Section 35 (Environmental Restoration Orders).
Part III of the Regulations is deficient in the following aspects. Sixth Schedule defines River Nile as
being from Lake Victoria to Lake Albert thus leaves out Albert Nile north of Lake Albert.
THE NATIONAL ENVIRONMENT (NOISE STANDARDS AND CONTROL) REGULATIONS (2003): These
Regulations aim at ensuring the maintenance of a healthy environment for all people in Uganda, the
tranquility of their surroundings and their psychological well being by regulating noise levels; and
generally to elevate the standards of living of the people by prescribing acceptable noise levels for
different facilities and activities. The Regulations prescribe the maximum permissible noise levels
from a facility or activity to which a person may be exposed; provide for the control of noise; and
provide for mitigating measures for the reduction of noise.
These Regulations apply to oil and gas activities through Section 3 (Purpose) considering that oil and
gas exploration and future petroleum production activities operate within the wildlife protected
areas whereby noise is regulated. However, the issue of noise control is also applicable in the
communities outside the protected areas.
Section 4 provides for the functions and powers of Local Councils and Environment Committee to
make laws to regulate noise and vibration pollution, Section 8 provides duties for the operator in
regulating or controlling noise, Section 12 provides for licensing works or activities likely to emit
noise in excess of permissible levels, Section 16 gives NEMA powers to issue Noise Control Orders,
Section 17 give Inspectors powers to confiscate machinery emitting noise, Section 18 grants
reinstitution of the machinery when measures for further emissions have been installed, Section 19
provides for guidelines for controlling noise and Section 21 specifies the offenses under these
Regulations.
The main challenge of enforcing these regulations is capacity to measure/monitor noise levels by the
regulators. These Regulations also may face the challenge of unpublished noise level permissible in a
protected area.
THE NATIONAL ENVIRONMENT IMPACT ASSESSEMENT REGULATIONS, 1998: These Regulation deals
with the environmental impact assessment (EIA) process, including project briefs and environmental
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impact studies. The Regulation provide for EIA review processes, including invitation of general public
comments and public hearings, and the decision of the Executive Director of the National
Environment Management Authority in respect of the grant, rejection or cancellation of an EIA
certificate.
The provisions of the Regulations comprehensively address oil and gas activities. However, there is
no provision for addressing trans-boundary issues relating to oil activities. For example, under
section 14 (Contents of Environment Impact Statement), oil activities are not explicit.
THE WATER ACT -CAP 152 (2003): The Water Act is one piece of Uganda's sectoral legislation with
key provisions to enhance sustainable development. It provides for the use, protection and
management of water use and supply. Important aspects in the Act include water rights; planning for
water use; control on the use of water resources; water easements; and control over water works
and water use.
The following provisions apply to oil and gas sector activities:
Part II provides for regulating motorized water pumps through permits. Section 3 provides for
application of permit, Section 7 provide conditions attached to and transfer of water permits, Section
15 provides for water drilling permits, Sections 21 and 22 provide conditions attached to drilling and
construction permits respectively, Section 23 provides for access to water use records, Section 25
establish water permit fees and section 27 specifies the offenses under these Regulations.
The current water abstraction by oil and gas activities are regulated by water permits and general
permits conditions. However, there is a challenge of determining the special conditions associated
with the oil and gas activities due to logistical constraints on the part of the Regulator (DWRM).
Secondly, there is an issue of capacity to analyze samples or to afford costs for analyzing these
samples in privately operated laboratories. Thirdly, there is need for “gazetting” laboratories whose
results would be accepted by both parties, i.e., the Regulator and Operator.
THE MINING ACT (2003): The Act was enacted to repeal and replace the Mining Act, Cap. 148, with a
new legislation on mining and mineral development which conforms, and otherwise gives effect, to
the relevant provisions of the Constitution; to vest the ownership and control of all minerals in
Uganda in the Government; to provide for the acquisition of mineral rights; and to provide for other
related matters. The Act provides for administration, mineral agreement, prospecting licence,
exploration licence, retention licence and mining lease, location licence, inspection of operations
under mineral rights, buying, selling and dealing in minerals, mineral rights and surface rights,
Surrender, Cancellation and suspension of mineral rights, registration and records, financial
provisions and protection of the environment.
This Act vests the ownership and control of all minerals in Uganda in the Government and provides
for the acquisition of mineral rights and other related rights. The Act requires every holder of an
exploration license or a mining lease to carry out an EIA of their proposed operations in accordance
with the provisions of the Environment Act. A holder of such permit is also required to carry out an
annual environmental audit and to keep records describing how far the operations conform to the
approved environmental impact assessment. The Act also provides for environmental protection
standards, environmental restoration plans and environmental performance bonds in accordance
with the Environment Act.
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The Act generally provides for the protection of the environment and provides for regulation of oil
well permitting and rights but this is not explicit regarding particular ecosystems such as rights in
waters and wetlands.
THE MINING REGULATIONS (2004): The regulations apply to section 121 of the Mining Act, 2003, Act
No. 9 of 2003. They address prospecting licenses, priority for applicants, retention licenses, location
licenses, mining leases, representatives, records and returns, beacons, boundaries and surveys,
registration, protection of the environment and financial provisions.
THE NATIONAL ENVIRONMENT FORESTRY AND TREE PLANTING ACT (2003): This is an Act for the
conservation, sustainable management and development of forests for the benefit of the people of
Uganda. The Act establishes central forest reserves and other forest reserves. It provides for
collaborative forest management, establishes a tree fund and provides for licenses. It also provides
for the EIA process for developments intended in forest reserves.
This is the principal law regulating the development, conservation and management of forestry
resources in Uganda. Section 14 (Prohibited activities in forest reserves)....states that no person shall
in a forest reserve, cut, disturb, damage, burn or destroy any forest produce or remove or remove
any forest produce except in accordance with regulations or guidelines made for the proper
management of the forest reserve as stipulated in a licence or permit.
Section 92 (Regulations) ... the Minister may; i) regulate the manner and circumstances in which a
licence may be grated, varied, suspended or cancelled, ii) prohibit or control acts, materials,
machines likely to cause damage to a forest reserve or community forest, iii) prohibit entry of
persons or vehicles into forest reserve or part of a forest reserve or community forest.
The current exploration areas are located outside protected forest reserves. However, it is likely that
future oil and gas production activities may traverse forest reserves.
THE WILDLIFE ACT, (CAP 200) of 2000: The Act provides for sustainable management of wildlife,
consolidating law relating to wildlife management and establishing a coordinating, monitoring and
supervisory body (Uganda Wildlife Authority). The following specific provisions relate to oil and gas
activities.
a. Part (a) of section 1 of Article 2: conservation of wildlife...so that the abundance and diversity
of their species are maintained in order to support sustainable utilization of wildlife.
b. Part (b) of section 1 of Article 2: sustainable management of wildlife conservation areas.
c. Part (d) of section 1 of Article 2: protection of rare, endangered and endemic species of wild
plants and animals.
d. Part (f) of section 1 of Article 2: enhancement of economic and social benefits from wildlife
management by establishing wildlife use rights and promoting tourism.
e. Part (i) of section 1 of Article 2: public participation in wildlife management.
f. Article 13 provides for management of wildlife conservation areas under approved
management plans.
g. Article 15 provides for undertaking Environmental Impact Assessments of any project or
activity, which may have a significant effect on any wildlife species or community.
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h. Article 16 provides for carrying out Environmental Audits and monitoring of all eligible
projects or activities.
i. Article 19 defines the purpose for creating Wildlife Conservation Areas.
The following purposes directly relate to oil and gas activities:
I. Preserve selected examples of the biotic communities of Uganda and their physical
environment.
II. Protect areas of aesthetic beauty and of special interest.
III. Preserve populations of rare, endemic and endangered species of wild plants and
animals.
IV. Generate economic benefits from wildlife conservation.
V. Provide facilities for public use and enjoyment of resources in the wildlife
conservation area.
j. Article 21 defines the general offenses in wildlife conservation area which include:
I. Injuring, killing or disturbing any wild plant or animal or any domestic animals.
II. Taking, destroying, damaging or defacing any object of geomorphologic,
archaeological, historical, cultural or scientific interest or any structure lawfully
placed or constructed.
III. Driving, conveying or introducing any wildlife animal into wildlife conservation areas.
IV. Starting or maintaining fire without lawful authority.
k. Article 22 regulates entry into a wildlife conservation area, including requirement for
payment of entry permit fees.
l. Article 26 provides for making regulations for regulating actions or omissions within a wildlife
conservation area. The following actions or omissions may be regulated:
I. Use of weapons and firearms.
II. Condition under which any person, vehicle, boat, aircraft may enter or travel
through, reside or be in wildlife conservation area.
III. Lighting picnic fires, use of lamps or fires.
IV. Disposal of waste or litter.
V. Introduction of alien species of animals or plants.
VI. Commercial enterprises within wildlife conservation area.
m. Part IX (Management of Problem Animals) gives procedures for declaring a problem animal
and regulations for killing and owning the carcass of problem animal, reporting damage,
handling wounded protected animals or wounded dangerous animals.
n. Part X (The Wildlife Fund) establishes a Wildlife Fund and defines sources of funding.
o. Part XIV (Miscellaneous) provides for general indemnity against UWA for recovery of any
damage caused to any person or property by an animal in a national park or wildlife reserve.
The Wildlife Act is adequate in regulating the functions of UWA with respect to the management and
use of wildlife resources within and outside wildlife-protected areas. However, the Act is deficient in
the following aspects:
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1. The Act does not explicitly define institutional roles of UWA in the regulation of Oil and Gas
activities in wildlife conservation areas or collecting revenues other than entry permits.
2. Part IV (Wildlife Conservation Areas)... section 5 does not permit “extractive activities” within
a national park. The provisions for the Executive Director/Minister to grant permission to
specific activities do not include oil and Gas activities.
Part XI (The Wildlife Fund) ...section is not explicit whether the Fund can receive funds from oil
licences fees or loyalties for those activities in the national parks
THE UGANDA TOURISM ACT (2008): The Act was enacted to reform, consolidate and streamline the
law relating to tourism ; to provide for licensing , regulation and controlling of the tourism sector ; to
give effect to the implementation of the tourism policy of Government ; to reconstitute the Uganda
Tourism Board to make it private sector driven; to establish a tourism development levy; to provide
for establishment and management of tourism development fund; to repeal the Hotels Act , the
Tourist Agents (Licensing) Act, and the Uganda Tourist Board Act; and to provide for related matters.
Part IV, Clause 18 of the Act on Supervision, monitoring and coordination of tourism has provisions for environmental management whereby the Ministry may undertake the following:
(a) by means of legal institutional, financial and other initiatives to plan and develop a sustainable tourism sector with due regard to the economic, social, environmental and cultural consequences of such developments;
(d) to ensure compliance with best environmental practices by tourists, tour operators and owners of tourism facilities;
(i) as appropriate and necessary, in conjunction with the Uganda Bureau of Statistics, collect, process and distribute tourism statistics.
Regulating tourism activities in oil and gas exploration and production areas in order to forge
sustainable co-existence is a key concern. Following the recommendation that the Tourism Policy be
reviewed to provided for oil and gas activities, the Act will require review in the same light once the
new policy is in place.
To cater for the effects of both activities on wildlife, the SEA recommendation is that regulations that
will follow the Act should include provision for establishing thresholds for every sensitive sections
(habitats) of the protected areas to avoid irreversible damage should include thresholds.
At the same time, the oil and gas activities in an area with high wildlife significance may compromise
tourism values. This calls for guidelines on damage assessment, compensation for foregone tourism
business.
THE NATIONAL ENVIRONMENT WASTE MANAGEMENT REGULATION, (1998): These Regulations
apply to all categories of hazardous and none hazardous waste. They cover movement of hazardous
waste into and out of Uganda, its storage and disposal. . The Regulations also provide for conditional
licensing of transportation of waste from one district to another. The Regulations prohibit the
disposal of untreated waste into the environment. Any person intending of run a waste treatment
facility may, after carrying out an EIA, apply for a license. In carrying out waste treatment, the
operator of a waste treatment facility shall take all necessary measures to minimize or prevent
pollution from site or plant.
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The relevance of the Regulations to oil and gas activities is provided in Part 2 (all categories of
hazardous and non-hazardous waste, storage and disposal of waste and, disposal facilities) and
Section 12 (Duty to treat waste from industries), Section 16 (Disposal of waste), Section 24 (Duty to
keep records).
The concern for the SEA is that the regulations do not provide for approving the waste storage
facilities before use, a matter that should be considered in the current review process for the
regulations.
THE NATIONAL ENVIRONMENT OZONE DEPLETION AND SUBSTANCES PRODUCTS REGULATIONS
(2001): These Regulations aim to regulate the production, trade and use of controlled substances
and products; provide for a system of data collection to facilitate compliance with relevant reporting
requirements under the Montreal Protocol on Substances that Deplete the Ozone Layer; promote
the use of ozone friendly substances, products, equipments and technology; and ensure the
elimination of substances and products that deplete the ozone layer. The various schedules provide
for controlled products, controlled substances and prohibition dates; application for licenses to
import controlled substances and export them; declaration by the end user of controlled substances
or products; and the need for records to be maintained for controlled substances.
These Regulations apply to the oil and gas activities through Section 3 (Object of Regulations),
Section 5 which provides for licensing importation of controlled substances or products, Section 10
which provides for maintaining of and submitting to NEMA records containing applicable
information specified in Six Schedule, Section 12 which provides for raising public and workers
awareness on activities relating to elimination of ozone depleting substances or products, Section 13
which provides for taxation on imports and Section 14 which specifies the offenses under these
Regulations.
The analysis concludes that these Regulations are weak on aspects of production of ozone depleting
substances or products, which include aspects such as air conditioning.
THE NATIONAL ENVIRONMENT HILLY AND MOUNTAINOUS AREAS REGULATIONS (2000): These
Regulations facilitate sustainable utilization and conservation of resources in mountainous and hilly
area. They promote soil conservation and restrict the use of these areas. They restrict cattle grazing,
provide for the declaration of closed and open seasons, afforestation and reforestation, and prevent
the introduction of alien or exotic species. The district councils are permitted to make bye laws for
the protection of mountainous and hilly areas which are at risk of environmental degradation.
These Regulations apply to the proposed site for the construction of the Oil refinery that lies above
the escarpment. By definition, the escapement qualifies as a hilly or mountainous area. In this
regards, the principles of the Regulation (section 4) apply. The Regulations also provide for the
functions of the Environment Committees at Local and District levels in approving activities in the
hilly or mountainous areas.
However, the Regulations focus on forms of land use other than land based developments such as
the oil refinery.
THE LOCAL GOVERNMENT ACT (2006): The Act
Empowers local Government to make bye-laws for proper use of land
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Hold in trust natural resources in the locality for the benefit of people
Enforces legislations on conservation and
Supervises the use of natural resources to ensure equitable use for development
THE WATER RESOURCES REGULATIONS (1998): Water quality and quantity are taken into account
when considering applications for water permits to ensure drainage regimes and the environment,
among other things are not compromised. The regulations also address issues of safety regarding
works on waterways and protection and enhancement of in-stream uses of water; government policy
on conservation; and plans and information to be provided to the Director as a condition for
registration of the permits. However, the regulations are not explicit on EIA requirements as a tool
that elaborates potential impacts and mitigation, a matter of significance in managing new water
utilization types of oil and gas in ecologically sensitive areas such as the Albertine Graben.
THE LAND ACT (CAP 227)
Section 78 of The Land Act presents varios provisions that are essential for land take and
cmpansation in the Albertine Graben as follows:
i) The value for customary land is the open market value of unimproved land;
ii) The value of buildings on the land is taken at open market value for urban areas, and
depreciated replacement cost for rural areas;
iii) The value of standing crops on the land is determined in accordance with the district
compensation rates established by the respective District Land Board. Annual crops which
could be harvested during the period of notice to vacate given to the landowner/ occupier
of the land are excluded in determining compensation values;
iv) In addition to the total compensation assessed, there is a disturbance allowance paid of
15% or, if less than six months’ notice to vacate is given, 30% of the total sum assessed.
The Land Act principally addresses four issues namely; holding, control, management and land
disputes. As regards tenure, the Act repeats, in Section 3, provisions of Article 237 of the Constitution
which vests land ownership in the citizens of Uganda, to be held under customary, freehold, mailo or
leasehold tenure systems. However, the Land Act provides for acquisition of land or rights to use land
for public works.
Regarding control of land use, the Act reaffirms statutory power of compulsory acquisition conferred
on the government and local authorities under articles 26 (2) and 237(2) (a) of the Constitution
(Section 43). Since the Act does not repeal the Land Acquisition Act No. 14 of 1965, it is assumed that
this legislation, meets requirements of Article 26(2) of the Constitution that requires a law to be in
place for the payment of compensation and access to the courts. The Act also requires that
landowners manage and utilize land in accordance with regulatory land use planning (Sections 44
and 46). Section 77(2) of the revised edition (2000) of the Land Act 1998 provides for a disturbance
allowance on top of the computed compensation amount as shown below:
i) 30% of compensation amount if quit notice is given within 6 months.
ii) 15% of compensation amount if quit notice is given after 6 months.
The Land Act, together with the Constitution are two key legal instruments under which
compensation and resettlement can be implemented in the Albertine Graben.
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COMPLIANCE TOOLS
Tools used by Regulators to monitor compliance
The oil and gas activities have been and continue to be monitored using the following tools:
a. Scheduled field inspections and monitoring visits by NEMA, Multi-stakeholder Monitoring Team (Coordinated by NEMA), PEPD, UWA, Ministry of Water and Environment (MWE), MTWH and Ministry of Gender, Labour and Social development (MGLSD). Other than the field based inspector under PEPD who inspect active sites on daily basis, the other schedules are quarterly.
b. Un-scheduled visits by Regulators in response to emerging issues.
c. Compliance assistance through field based Inspectors from NEMA, PEPD and UWA.
d. Daily operations reporting submitted by oil companies to Commissioner PEPD.
e. Quarterly reports, work plans and programs for specific undertaking e.g., drilling plans, oil well flow testing plan, restoration plans, etc.
f. Environmental audits conducted by NEMA in collaboration with Oil companies.
g. Guidelines for Oil activities in National Parks issued by UWA in 2011.
h. Cost-benefit analysis and other financial monitoring systems of field operations by PEPD.
In addition, the following tools applied by PEPD targeting operations in general, they also contribute towards monitoring environmental aspects in some respects.
a. Monitoring oil and gas sector performance and National Oil and Gas Policy by PEPD/MEMD
through:
I. Bi-weekly meetings on operations between PEPD and Oil companies. These meetings
are convened to discuss the progress over the reporting period and activity plans for
the next reporting period.
II. Semi-annual meetings of the Technical Committee consisting of PEPD and Oil
companies. Reporting to the Advisory Committee, the Technical Committee handles
technical information on the oil resources (Status and projections) as well as progress
over the reporting period.
III. Annual meetings of the Advisory Committee (Chaired by the Permanent Secretary,
MEMD) consisting of MEMD/PEPD, Oil companies. The following institutions
participate in the meeting as observers: Ministry of Finance, Planning and Economic
Development, Ministry of Justice and Constitutional Affairs and, Uganda Revenue
Authority. The Annual meeting approves annual work plans and budgets.
b. Monitoring environmental aspects of the oil industry: This is handled at policy level by the
MWE. In addition, NEMA convenes a Multi-stakeholder Environmental Monitoring Team that
conducts quarterly inspection visits. In addition, NEMA delegates monitoring tasks to
Districts (DEOs) on case by case.
c. Lead agencies monitoring processes by NEMA, UWA, PEPD and DWRM.
With respect to self-monitoring, the Oil companies apply the following tools:
a. Approved EIAs conditions including recommended or approved environmental management
plans, mitigation measures, restoration plans, etc.
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b. Terms and conditions of the Production Sharing Agreements.
c. Reports from seismic studies.
d. Inspection visits to exploration sites.
e. Internal company compliance tools (e.g., Staff induction, Staff drills, Daily Compliance
Tracker, Daily Staff reports, etc)
ENFORCEMENT TOOLS
The following tools are used by the regulators namely National Environmental Management
Authority (NEMA), Uganda Wildlife Authority (UWA), Petroleum Exploration and Production
Directorate (PEPD), Directorate of Water Resources Management (DWRM).
National laws and policy instruments
The national legislation and policies highlighted under section 5.1. as well as international and
regional conventions and agreements signed by Uganda form the principal tools used to enforce
compliance.
Permits
The following types of permits or licenses have been issued to regulate respective environmental
aspects of the oil and gas activities.
Water Abstraction and Use Permits.
Solid Waste Disposal Permits.
Waste Water Disposal Permits.
Effluent Discharge Permits.
Noise Control and Production Permits.
Certificate of Approval for Environmental Impact Assessment Study
Each of these permits provides general and special conditions that form basis for enforcement and
compliance monitoring by respective regulators or lead agencies and monitors.
Production Sharing Agreements (PSA)
These Agreements form the official commitment between government and Oil Companies. Within
these PSA, environmental aspects of oil and gas activities are treated under the over-all theme on
Health, Safety and Environment (HSE) which tends to focus on drilling and production operations.
Therefore, PSA are deficient in addressing the wider environmental issues.
Field operations plans
The following field operations plans are approved and used by PEPD for enforcement purposes.
Work program and budget
Drilling program
Well testing program
Program for conducting geological and geophysical studies
Site Restoration Plans
Well abandonment plans
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Daily operational reports
Communications Strategy
National Park Management Plans and Regulations
These tools have been applied by UWA over activities within wildlife conservation areas namely,
national parks and wildlife reserves. UWA uses these management plans to enforce compliance to
the over-all park management objectives and guidelines. In addition, UWA has issued specific
guidelines for regulating Oil exploration activities and general operations within the National Parks
and Wildlife Reserves.
Inspection
Inspections have been conducted mainly in form of visits to the exploration or operational sites and
deployment of field Inspectors by NEMA, PEPD and UWA. In case of the latter, inspectors are on
active sites full time. Their main function is to ensure that oil and gas activities comply with
conditions issued alongside the permits and licenses. They also serve to provide onsite compliance
assistance in form of advice and technical guidance.
Reporting
The oil and gas activities are required to submit daily activity reports to the Commissioner PEPD.
These reports have been used to enforce compliance to the approved activity plans and schedules.
Delegated Authority
On several occasions, NEMA has delegated authority to Districts (by NEMA) to enforce environmental
standards in exploration areas outside the protected areas.
Self-Regulation
Oil companies have been required to regulate themselves and report to Commissioner PEPD.
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b) INTERNATIONAL AND REGIONAL INTERNATIONAL CONVENTIONS/
TREATIES
THE UNITED NATIONS CONVENTION ON BIOLOGICAL DIVERSITY, 1992
This convention was signed at the Earth summit in Rio de Janeiro, Brazil, on the 5th of June 1992 and
on the 29th of December 1993, it entered into force. So far, 193 states have signed this convention.
The main objective of the convention is to conserve biological species, genetic resources, habitats,
and ecosystems; to ensure the sustainable use of biological materials; and to guarantee the fair and
equitable sharing of benefits derived from genetic resources. It was conceived as a practical tool for
translating the principles of Agenda 21 into reality.
A number of protocols have been signed to further strengthen the objectives of the convention on
biodiversity, such as the Cartagena Protocol on Biosafety of the convention, also known as the
Biosafety protocol of 2000, which seeks to protect the biological diversity from the potential risks
posed by living modified organisms resulting from modern biotechnology.
The main concern for the SEA is the compliance to the convention as oil and gas activities intensify in
the Albertine rift, which is already classified internationally as a biodiversity hotspot.
THE UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE, 1992
This convention was signed on 9th may 1992, in New York. It was signed by 165 states and as of to
date, 195 UN member states have signed it except south Sudan. It was also as a result of the Earth
summit of 1992.
The principal objective of this treaty is to stabilize greenhouse gas concentration in the atmosphere
at a level that would prevent dangerous anthropogenic interference with the climate system.
The Convention divides countries into two groups: those who are listed in Annex 1 of the Convention
and those who are not (known as 'non-Annex 1 Parties'). Annex 1 Parties are the industrialized
countries, who have historically contributed the most to climate change. For example, North America
and the European Union are jointly responsible for 85 percent of the human-made carbon dioxide in
the atmosphere today. The UNFCCC established leading roles for industrialized countries in curbing
global warming and required them assist developing countries to avoid the negative effects of
climate change and to allow adaptation. UNFCCC called on Annex-1 Parties to stabilize their
greenhouse gas emissions at 1990 levels by the year 2000.
As contracting party, Uganda must ensure that the oil and gas activities do not contravene the
framework objectives. Therefore, the issue for the SEA is the likely impact of oil and gas activities on
air quality.
THE MONTREAL PROTOCOL ON SUBSTANCES THAT DEPLETE THE OZONE LAYER, 1987
This convention came into force on 1st January 1989 and it was ratified by all member states to the
United Nations. It is a protocol to the Vienna Convention for the protection of the ozone layer. It was
designed to protect the ozone layer by phasing out the production of numerous substances believed
to be responsible for ozone depletion.
Concern that chlorofluorocarbons (CFCs) might deplete the ozone layer, causing skin cancer and
other health and ecological effects, dates to 1974. Understanding of the problem changed
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significantly with detection of the Antarctic ozone “hole” in 1985 and subsequent studies to explain
it. In the 1970s the United States, Canada, Norway, and Sweden acted unilaterally to control some
uses of CFCs. International efforts included monitoring, research, and assessment programs
beginning in the middle 1970s. The Vienna Convention (1985) established a framework for
subsequent protocols; the Montreal Protocol (1987), negotiated and signed shortly after the ozone
hole was detected, committed signatories to cut the planned use of offending chemicals by half.
Amendments and adjustments to that protocol, signed in 1990, call for a ban of ozone-depleting
substances (with a few exceptions) by 2000 with an additional decade for developing countries.
The issue for the SEA will be mitigating emissions, e.g., methane leakages from the oil and gas
exploration and production activities.
THE CONVENTION ON WETLANDS OF INTERNATIONAL IMPORTANCE ESPECIALLY AS WATERFOWL
HABITAT (RAMSAR CONVENTION), 1971
This convention provides for a framework for national action and international cooperation for the
conservation and wise use of wetland and their resources. It covers all aspects of wetland
conservation and “wise use” of wetland. It is an international treaty for the conservation and
sustainable utilization of wetlands. Its main object is to stem the progressive encroachment on and
loss of wetlands now and in the future, recorgnizing the fundamental ecological functions of
wetlands and their economic, cultural, scientific and recreational value.
The issue for the SEA will be compliance to the Ramsar convention specifically considering oil and gas
activities around the Murchison Falls Albert Delta wetlands system which is a Ramsar site. The key
resources of concern include avian diversity, fisheries/spawning sites and refuge/watering points for
wild animals.
THE CONVENTION CONCERNING THE PROTECTION OF WORLD CULTURAL AND NATURAL
HERITAGE, 1972
This convention was adopted by the General conference of UNESCO on the 16th November 1972. It
mainly deals with the identification and conservation of the world cultural and natural heritage of
international importance. This SEA has empahsized the impacts of oil and gas activities on the
cultural and archeological heritage as well as participation of cultural institutions in the Albertine.
CONVENTION ON MIGRATORY SPECIES (BONN CONVENTION) 1979)
Conserves territorial, marines and avian migrating species. It adopted the most strict protection
measures for endangered migratory species and cooperative research activities. Conservation of
Albatroses and Petrels. The concern for the SEA on this convention is the rich avian diversity in the
Albertine Rift.
WORLD COMMISSION OF THE WORLD ENVIRONMENT AND DEVELOPMENT (WCED)
Established the principle of sustainable development an equitable and sustainable sharing of natural
resources, an overarching principle for the SEA process.
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AFRICAN CONVENTION ON THE CONSERVATION OF NATURE AND NATURAL RESOURCES
Encourages individual and joint actions for the conservation utilization and development of flora and
fauna for the present and future welfare of mankind from an economic nutritional which the SEA will
consider.
UNITED NATION CONFERENCE ON HUMAN ENVIRONMENT (1972 STOCKHOLM DECLARATION)
Promotes and enhances ecosystem for production without detriment.
PROTOCOL CONCERNING PROTECTED AREAS AND WILD FAUNA IN THE EAST AFRICAN REGIONS (1985)
Contracting parties are obliged to take appropriate measures to maintain essential ecological
processes and life support system to preserve genetic diversity and ensure sustainable utilization of
harvested natural resources.
CONVENTION ON THE PROTECTION AND USE OF TRANS BOUNDARY WATER COURSES AND INTERNATIONAL LAKES
This convection will be considered as it provides means of protecting and conserving water surface
and ground waters across national boundaries. The SEA process has recognized the relevance of
cooperation with DRC, Sudan, etc., for trans-boundary management of the Nile and Lake Edward.
BAMAKO CONVENTION ON THE BAN ON THE IMPORT INTO AFRICA AND THE CONTROL OF TRANSBOUNDARY MOVEMENT AND MANAGEMENT OF HAZARDOUS WASTES WITHIN AFRICA (1991)
This convention was signed on the 30th of January 1991 in Bamako, Mali and it became effective on
the 22nd of April 1998.
It was intended to prohibit importation of hazardous waste to less developed countries, Minimize
and control trans-boundary movement of hazardous waste within African countries, Prohibit Ocean
and inland dumping or incineration of hazardous waste. The convention ensures that disposal of
wastes is conducted in an environmentally sound manner, promote cleaner production over the
pursuit of a permissible emissions approach based on assimilations capacity assumptions, and also
establishes a precautionary principle.
KYOTO PROTOCOL
Established rules for implementation called the Marrakesh Accords
Intended to reduce green house gas emissions that is responsible for depletion of ozone layer which is responsible for climate change.
The concerns are mainly on gas emissions, similar to those pointed out under the Montreal Protocol.
WORLD BANK’S OPERATIONAL POLICY 4.12 ON INVOLUNTARY RESETTLEMENT
World Bank’s Operational Policy 4.12 on involuntary resettlement requires that affected persons should be compensated at full replacement cost and assisted during relocation. There are some stark gaps between Uganda and WB resettlement requirements. For example, as earlier mentioned, a project proponents are not legally bound to neither procure alternative land nor provide relocation assistance to affected people if they provided fair financial compensation based on a legally accepted valuation process.
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In a number of situations, as shown in table above, WBG requirements are more favorable to
affected persons than Ugandan law including aspects like:
a. Compensating for loss of income after affected persons are displaced.
b. Compensation for tenants who might not have legal land rights, but have undertaken
development or farming activities on affected land.
c. Wherever feasible and acceptable to affected persons, provide land-for-land compensation.
d. Provide property owners with cash compensation at full replacement cost.
e. Wherever appropriate, provide skills assistance to affected farmers in areas such as improved
crop and animal husbandry and records keeping.
C) ADDITIONAL POLICIES
THE NATIONAL ENERGY POLICY, (2002)
The policy emphasizes that government improves the level of energy supplies at the least cost to the
national economy, by promoting efficient use and conservation of energy resources. However,
several problems have persisted and continue to threaten woodland and forest resources. Demand
for biomass is very high and growing, with wood representing 98% of the fuel used for cooking and
this has promoted deforestation.
THE NATIONAL WATER POLICY, (1997)
The objective of the National Water Policy is to manage and develop water resources in an
integrated and sustainable manner to secure and provide water of adequate quantity and quality for
all social and economic needs of the present and future generations with the full participation of
stakeholders. This goal is set to be achieved under two broad components of water resources
management.
1. Water resources management; that encompasses monitoring, assessments, allocation and protection of water resources.
2. Water development and use: that encompasses allocating and regulating water use for recreation and ecosystem needs as well as measures for controlling water pollution.
Under water allocation principles, the policy provides for ensuring that sufficient water is reserved for meeting environmental requirements and services, i.e., maintain minimum flow to maintain water quality and aquatic ecosystems.
THE NATIONAL LAND USE POLICY (2007)
The policy promotes the land use and physical planning at national and local levels. Whereas the
policy grants ownership of land to land owners and bonafide occupants of land in Uganda, it requires
management and use of land and all land resources in accordance with other laws. The planning for
the exploration and production of oil and gas resources found underneath the land surface are not
regulated by this policy. This could be because oil and gas resources are by virtue of the constitution,
vested in the government of Uganda.
THE WILD LIFE POLICY, (1999)
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The Policy promotes the long-term conservation of the country’s wildlife and biodiversity in a cost
effective manner, which maximizes the benefits for the people of Uganda. The following provisions
are applicable to oil and gas activities:
a. Promote and maintain viable and representative wildlife populations in Uganda, both within and outside protected areas.
b. Ensure that the biological diversity of Uganda is conserved within the country’s protected area system, and is managed on sound conservation principles.
c. Protect the country’s national parks and wildlife reserves from human settlement and adverse activities.
d. Encourage the protection and conservation of wildlife outside protected areas, and create an enabling environment for communities and the private sector to participate in different forms of sustainable wildlife utilization and conservation.
e. Promote sustainable extractive utilization of wildlife by facilitating the involvement of landowners and users in managing wildlife on private land.
f. Control wild animals that pose threat or cause injury to human life, or which cause damage to property.
g. Generate revenue from tourism, to support wildlife conservation efforts and the national economy.
h. Promote positive attitudes towards wildlife conservation through education and public awareness campaigns.
i. Promote good neighborliness’ and extension services between the local communities and protected areas.
The main challenge faced under this policy is that of allowing extractive use of resources from the
national parks. The second challenge is the management of oil and gas activities to ensure that they
do not significantly undermine or harm tourism potential. These challenges should be addressed in
the new policy (Draft, 2012).
NATIONAL POLICY ON CONSERVATION AND SUSTAINABLE DEVELOPMENT OF WILDLIFE RESOURCES (DRAFT, 2012)
The new policy is premised on the principle of sustainable development among other things stating
that “Conservation of the wildlife resources of Uganda shall be in such a way as to meet the
development and environmental needs of present and future generations”. The policy goal is to
conserve wildlife resources of Uganda in a manner that contributes to the sustainable development
of the nation and the well-being of its people. The policy recognizes that minimizing negative
impacts of oil and gas, mining and tourism development activities on wildlife is one of the key
challenges . Objective 7 of the draft policy adresses this challenge. The objective aims to ensure net
positive impacts of exploration and development of extractive industries and other forms of
development in wildlife conservation areas and presents the following strategies:
a. Cooperate with the ministry responsible for oil and gas, mineral and energy development, oil companies and other relevant stakeholders to ensure co- existence of wildlife with other development activities
b. Establish standards, guidelines and mitigation measures to be followed for any development activities that may have a significant impact on wildlife
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c. Monitor impacts of exploration and development of oil, gas and other minerals, tourism and energy infrastructure development in wildlife conservation areas
d. Ensure that exploration and development of oil, gas and other minerals; tourism and energy infrastructure development in wildlife conservation areas follow approved environment impact assessments
e. Create capacity of wildlife sector institutions to monitor impacts of oil and gas exploration and development and any other industrial or infrastructural developments
f. Pursue biodiversity offsets and payment for ecosystem services initiatives where mitigation is inappropriate.
THE FORESTRY POLICY (2001)
The objective of the policy is to promote sound management and development of forestry resources in Uganda. The following provisions apply to the oil and gas activities.
a. Protect and manage sustainably the Permanent Forest Estate.
b. Promote the development and sustainable management of natural forests on private and customary land.
c. Promote collaborative partnerships with rural communities for the sustainable management of forests.
d. Promote tree growing on farms in all farming systems and innovative methods for delivering forestry extension and advisory services through decentralized and farmer – driven mechanisms.
e. Conservation and management of biodiversity in support of local, national social and economic development and international obligations.
Although the current exploration areas fall outside forest reserves, there is no sufficient evidence on the impacts of current exploration and future production activities on forest reserves.
THE FISHERIES POLICY, (2003)
The objective of this policy is to conserve and manage sustainably fisheries and other aquatic resources for sustainable production. The following provisions apply to the oil and gas activities:
a. Compilation of inventories of aquatic biodiversity resources, species distribution and role in aquatic systems for all waters.
b. Strengthen the role of enforcement and extension and involve NGOs, among others, in implementation and extension.
c. Give local communities better control over the management of fisheries resources and strengthen local management capacity.
d. Increase knowledge on the role of non-fish aquatic life in aquatic ecosystem dynamics and develop safeguards to ensure their protection and sustainable use.
e. Contain over-exploitation, the destruction of habitat and control species introduction through strengthened research efforts and better planning and monitoring.
f. Identify and map critical and sensitive habitats and take appropriate steps (gazetting) to minimize damage and disturbance to breeding, nesting, aestivation and feeding areas of all aquatic species.
g. Collaborate and participate with the neighbouring countries to harmonize the management and development of shared aquatic resources.
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The main SEA concern, however, is the management of oil and gas activities along the Lake Albert in a manner that does not negatively impact fisheries and other aquatic biological resources or does not undermine the fishing activities by communities. The specific concerns regarding petroleum activities include:
a) Inadequate monitoring, extension and enforcement mechanisms;
b) Inadequate mobilization and involvement of communities in management and development
of fisheries resources;
c) Ill-equipped extension services and inadequate research information to promote sustainable
management and development of capture fisheries and aquaculture;
d) Absence of regional mechanisms for cooperation in the management of the shared lakes in
the Albertine Graben.
The key SEA recommendation is to develop regulatory framework to operationalize the Fisheries
Policy (2004).
THE NATIONAL TOURISM POLICY (2003)
The objective of the policy is to ensure that tourism becomes a vehicle for poverty reduction. Within the Albertine rift, tourism thrive on the rich biological attractions, water based tourism attractions and scenic view. The oil and gas activities interfere with the natural attraction. The following policy provisions apply to the oil and gas activities:
a. Develop tourism in sustainable manner, focusing on Agenda 21 issues in respect of the development of tourism facilities and encouraging nature friendly product development.
b. Ensure that conservation programs between Government agencies (Uganda Wildlife Authority, National Forestry Authority and Wetlands Department) are well coordinated.
c. Develop facilities and products in the national parks in accordance with the park management plans.
d. Provide for channeling of tourism revenues towards the protection of the natural resource base.
The policy was developed before the oil exploration era. The concern for this group of stakeholders is
the disturbance to wildlife habitats. The observation is that there are specific circuits where the
chances of seeing animals are high. A number of these circuits have been taken over by the oil
exploration activities. Thus there has been a reduction in access to wildlife viewing. The consulted
person suggests that the oil and gas exploiting firm must ensure minimum disturbance to the circuits,
and alternative circuits should be developed by the oil firms. This will internalize the external
disturbances of oil activities. The other concern was that of waste disposal versus the health of the
protected areas. The consulted officer emphasized the need for the oil exploiting firms to employ
technology that ensures minimal ecosystem disturbances.
THE NATIONAL POLICY FOR CONSERVATION AND MANAGEMENT OF WETLAND RESOURCES (2005)
The objective of the policy is to promote the conservation of Uganda’s wetlands in order to sustain
their ecological and socio-economic functions for the present and future well being of the people.
The following provisions apply to the oil and gas exploration and production activities.
a. Establish the principles by which wetland resources can be optimally used, and their productivity can be maintained into the future.
b. Maintain a biological diversity in wetlands either in the natural community of plants and animals or in the multiplicity of agricultural activity.
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c. Promote the recognition and integration of wetland functions in resource management and economic development decisions making about sector policies and programs such as forestry, agriculture, fisheries, and wildlife and sound environmental management.
The National Environment (Wetlands, Riverbanks and Lakeshores) Regulations give legal basis for
enforcing compliance by oil and gas exploration and production activities.
THE NATIONAL POLICY FOR DISASTER PREPAREDNESS AND MANAGEMENT (2010)
The overall policy goal is to promote national vulnerability assessment, risk mitigation, disaster
prevention, preparedness, effective response and recovery in a manner that integrates disaster risk
management with development planning and programming. This approach will ensure people of
Uganda build capacities that would enable them minimise serious social and economic disruptions as
a result of disaster events. The policy will also create an integrated and multi-sectoral systems
approach to planning, preparedness and management of disasters which is fundamental to sustained
productivity and socio-economic growth.
The main thrust of this policy is to make disaster management an integral part of the development
process. It recognizes the profound impact of human activity on the interrelations within the natural
environment as well as the influence of population growth, the high density of urbanization,
industrial expansion, resource exploitation and technological advances. The policy also emphasizes
the critical importance of restoring and maintaining the quality and overall welfare and development
of human beings in their environment.
The SEA interest is that the policy recognizes that on-going developments in the energy and mining
sector in Uganda, especially oil exploration, requires the country to put in place strict and effective
mechanisms to avert disasters related to oil exploration, transportation and use, including
environmental degradation. Particular attention is on oil spill contingency. One of the objectives is:
“To ensure that the oil and other mineral exploration activities are well coordinated, regulated and
monitored to ensure adherence to risk reduction strategies”.
The implementation of this policy shall also take into account the international and regional
instruments ratified by Uganda Government. These include: UNFCCC and Kyoto Protocol, the
Montreal Protocol on Substances that Deplete the Ozone Layer of 16 September 1987 ; the IGAD
Initiatives on Drought and Desertification; the SPHERE Project, Minimum Standards on Disaster
Response; the African Charter on Rights and Welfare of the Child; United Nations Guiding Principles
on Internal Displacement; African Charter on Human and Peoples’ Rights 1991; International
Covenant on Civil and Political Rights, 1966; and the 2004 African Union Regional Strategy for
Disaster Risk Reduction.
Disaster risk reduction is an integral component of sustainable development. Specifically, oil and
other mineral exploration activities should be done in a manner that does not comprise the
livelihoods of the surrounding communities as well as the environment. The following recommended
actions are relevant to the SEA:
• Ensure oil and other mineral exploration companies carry out environmental Impact assessment before commencing exploration.
• Ensure livelihoods of local communities are protected.
• Monitor and supervise operations of the exploration companies to ensure adherence.
• Develop a policy on oil and gas exploration.
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• Due to the flammable nature of oil and gas, ensure all companies put in place and maintain fire prevention and fighting equipment.
NEMA is mandated to encourage the development of early warning systems for drought, floods, and
other environmental disasters and ensure development of hazard mapping mechanisms for the
sector.
The challenge considered in the SEA is the institutionalization of early warning systems for oil and gas
related disasters such as oil spills as well as environmental disasters such as floods and earth quakes
as the Albertine is a seismically active area and at the same time a biodiversity hotspot. Another
issue is to ensure the development of hazard mapping mechanisms for the sector.
THE NATIONAL CULTURE POLICY (2006)
The National Culture Policy (2006) was formulated with a vision as “a culturally vibrant, cohesive and
progressive nation” The policy mission is to promote culture and enhance its contribution to
community empowerment. The policy recognizes lack of a stakeholder coordination structures for
cultural promotion. This may explain the challenges of understanding between the cultural
institutions in the Albertine and the Government A lot of effort is still required on advocacy and
capacity building for personnel, but also material and equipment. The requirements are likely to
increase with further oil and gas exploration activities. Although the policy emphasizes
environmental protection as basis for averting negative impacts from environment degradation,
there is still concern over the protection of cultural heritage resources amidst oil and gas activities.
Other relevant policies include:
The National Industrial Policy, 2008; National Soils Policy, 2002; Uganda national Land Policy (Draft 2011); Uganda Mineral Policy, 2000; and Health Policy National Child Labour Policy (2006) The National Employment Policy for Uganda (2011)
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D) OTHER KEY MINISTRIES AND AGENCIES REFERRED TO IN CHAPTER 4
Ministries
1) Ministry Responsible for Justice and Constitutional Affairs 2) Ministry Responsible for Finance, Planning and Economic Development 3) Ministry Responsible for Local Governments 4) Ministry Responsible for Works and Transport 5) Ministry Responsible for Water and Environment 6) Ministry Responsible for Forests and Wetlands 7) Ministry Responsible for Tourism and Wildlife 8) Ministry Responsible for Labour, Gender and Social Development 9) Ministry Responsible for Education 10) Ministry Responsible for Industry 11) Ministry Responsible for Physical Planning 12) Ministry Responsible for Foreign Affairs 13) Ministries Responsible for Security 14) Ministry Responsible for Information and Communication Technology
Government Agencies
1. The Central Bank 2. Uganda Revenue Authority 3. National Planning Authority (NFA) 4. Uganda Wildlife Authority (UWA) 5. The Auditor General 6. Uganda Tourist Board (UTB) 7. Uganda Bureau of Statistics (UBOS) 8. District Land Boards
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APPENDIX 6: ISSUES REGISTER AND ANALYSIS
SEA Issue Register and Analysis
Abbreviations used
X (SS): Issues identified during the screening/scoping process (April 2010)
X (DT): Issues identified in draft Terms of Reference (not registered since X (SS) should cover
these)
X (ST): Issues identified by SEA Team (March 2012)
X (FT): Issues identified at Field Trip for Steering Committee and others (March 16-18, 2012)
X (RT): Issues identified at Reconnaissance Field Trip by local SEA Team (May 8-11, 2012)
X (IW) : Issues identified at Inception Workshop (May 22-24, 2012)
X (SA): Issues identified in Scenario Analysis (June 2012)
X (NO): Issues identified by Norwegian partners (Comments to IR from DN, Klif May 2012)
X (OI): Issues identified by Ugandan Oil industry
(Comments to IR from CNOOC, Tullow and Total June 2012)
Criteria for evaluation of significance
The evaluation of significance is based on: number of scores from the above mentioned sources (X),
urgency for the SEA, duration of impact, extent of impact and reversibility of impact. Further details
of the evaluations are shown in the Interim report, Appendix 1.
The following table is only showing the conclusions of the evaluations.
Significance for the current SEA process:
High (H)
Medium (M)
Low (L)
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Table 1: Issues related to Natural Environment
No. Issue Screening/ scoping for the SEA. Existing docu-ments
Expert teams
Stake- holders incl. Inception workshop
Scena-rio analy-sis
Signifi-cance
1 Consideration of biodiversity loss, also aquatic. Footprint
X (SS) X (IW), X(NO)
H
2 Air emission, soil and groundwater pollution X (SS) X (IW, X (RT), X (NO)
X (SA) H
3 Climate change and associated issues X (SS) X (ST) X (IW) X (SA) M
4 Geohazards X (IW) *comment
5 Attention on sites with international conservation status
X (ST)
X (NO) X (SA) H
6 Impacts on wildlife population and movement X (SS) X (ST) X (SA) H
7 Emphasis on lower mammals (indicators) X (ST) *comment
8 Impacts on physical phenomena such as drainage, erosion
X (ST) L
9 Geology such as water table, infiltration capacity
X (SS) X (ST) L
10 Sensitive aquatic resources such as deltas, shorelines
X (ST) H
11 Fish species diversity X (ST) M
12 Coexistence with wildlife X (FT) X (RT) H
13 Site restoration X (FT) L
14 Operations within the protected areas X (FT) X (RT) X (SA) H
15 Need program for monitoring of groundwater quantity and quality
X (RT) M
16 Environmental protection on long term not prioritized against building public infrastructure on short term
X (RT) *comment
17 Pollution of surface waters and aquifers. Water management
X (SS) X (NO), X (OI)
X (SA) H
18 Pollution and disappearance of endemic species X (SS) H
19 Destruction of landscape and lack of restoration X (SS) M
20 Discussion/use of trade-offs X (NO) *comment
21 Habitat fragmentation due to construction works
X (SA) H
22 Increased awareness on environmental issues X (SA) L
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Table 2: Issues related to Socio-Economic Environment
No. Issue Screening/ scoping for the SEA. Existing docu-ments
Expert teams
Stake-holder opinions incl. Inception Workshop
Scena-rio analy-sis
Signifi-cance
1 Compensation, livelihood restoration, resettlement
X (ST), X (FT)
X (IW), X (RT), X (OI)
X (SA) H
2 Participation in planning and capacity building X (IW) *comment
3 Security Issues and regional emergency response
X (IW) X (SA) H
4 Benefit sharing (local and international) X (IW) X (SA)
Medium
5
Archaeology and cultural heritage X (IW) X (SA) High
6 In-migration at a larger scale. Large workforce X (SS) X (ST) X (IW), X(RT)
X (SA) High
7 Socio-economic issues incl. education, health, social patterns, adaptation capacity etc
X (SS) X (IW), X (RT)
X (SA) High
8 Offset opportunities, payment for ecosystem services
X (ST) X (IW), X (RT)
*comment
9 Land rights and tenure, land conflicts and speculation
X (SS) X (IW) X (SA) High
10 Occupational health and safety X (IW) Low
11 Gender aspects are to be considered X (ST) X (IW) Low
12 Consultation with Bunyoro Kingdom and traditional institutions. Traditional knowledge
X (SS) X (IW) X (SA) High
13 Fishery potential due to escalating demand X (ST) Medium
14 Coexistence with tourism X (SS) X (ST) X (SA) High
15 Impacts on population dynamics in the region. Urbanisation
X (ST) High
16 Socio-cultural profile in the region is changing X (ST) Medium
17 Protection of the vulnerable and weak X (ST) Medium
18 HIV/AIDS X (ST) High
19 Involvement of locals in new job market X (ST) X (SA) High
20 Relations between local communities and petroleum industry
X (SS) X (ST) High
21 Coexistence with fisheries X (SS) X (ST), X (FT)
X (RT) X (SA) High
22 Compensation schemes for victims of pollution
X (ST) Medium
23 Possibilities of expanding relations and markets to neighboring countries
X (ST) Low
24 Recreation and amenity facilities offered by the environment
X (ST) High
25 Revenues to the benefit of local communities and future generations
X (SS) X (ST) High
26 Governance structure X (ST) *comment
27 Awareness about and coexistence with cultural heritage
X (SS) X (FT) High
28 Distance between petro facilities and existing settlements
X (FT) *comment
29 Coexistence with private forestry X (RT) Medium
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30 Increase of costs of living X (RT) High
31 Large challenges for the districts to prepare for new settlements. Infrastructure
X (RT) X (SA) High
32 RAP reports not followed up X (RT) High
33 Methodology for sensitization valuation to be improved
X (RT) High
34 Fish prices high due to competition on salaries X (RT) High
35 Disruption of existing livelihoods X (SS) High
36 Pressure on all resources X (SS) High
37 Increase in crime rate X (SS) Medium
38 Expectation management X (SS) High
39 Potential shortage of local resources due to high petro demand
X (SA) Low
40 Local deliveries of goods and services X (SA) High
41 Petro activities as catalyst for other service/industry development
X (SA) High
42 Increase of property value X (SA) Medium
43 Boom-bust effects from ending construction X (SA) Medium
Table 3: Issues related to Institutional Matters
No. Issue Screening/ scoping for the SEA. Existing documents
Expert teams
Stake-holders incl. Inception workshop
Scena-rio analy-sis
Signifi-cance
1 Strategic environmental management plan X (IW) *comment
2 Land use and Physical/spatial planning X (SS) X (ST), X (FT)
X (IW, X (OI))
X (SA) High
3 Regional cooperation X (IW) Low
4 Oil spill contingency planning, onland/offshore
X (SS) X (ST) X (IW), X (NO)
X (SA) High
5 Management of pollution and waste X (SS) X (ST), X (FT)
X (IW), X (NO)
X (SA) High
6 Institutional capacity regarding petro sector X (FT) X (IW) X (SA) High
7 Conflict management incl. transboundary issues
X (SS) X (IW) X (SA) Medium
8 Freshwater management X (IW), X (RT)
High
9 Integrated management plan for AG X (IW) *comment
10 Need for urbanization policy X (IW) High
11 Knowledge about movement of spilled oil X (ST) X (SA) High
12 Inclusion of cultural institutions in the petro strategies. Capacity building
X (ST)
X (SA) High
13 Waste management. Regulations and guidelines missing
X (ST) X (RT), X (OI)
High
14 Lack of capacity among practioners to do EIAs X (ST) X (RT) Medium
15 Lack of laboratories adequate to follow up the petro industry
X (ST) Medium
16 Identifying and regulating transporters and waste facility operators
X (ST) High
17 Inadequate local capacity to review oil and gas EIAs and do audits
X (ST) X (RT), X (OI)
High
18 Capacity building for national and local X (ST) X (RT), X (SA) High
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governments X (OI)
19 Informal and traditional administrations worked before. What now.
X (ST) High
20 Overlapping responsibilities, e.g between MWE and NEMA on local matters
X (ST) Medium
21 Lack of collaboration between local and central government. Also influencing budgets
X (ST) X (RT) High
22 Include environment and natural resources at district level. Awareness
X (ST) High
23 Transfer of EIA when operatorship change X (FT) High
24 Environmental monitoring of operations in sensitive areas
X (FT) X (RT) High
25 Ownership to land required by the petro industry
X (FT) High
26 Lack of adequate baseline data is restricting effective monitoring. Only compliance monitoring
X (FT) High
27 EIAs are too generic. Standard controls more than specific mitigation
X (FT) High
28 Need monitoring plan on district level for water resources
X (RT) High
29 Need inter district cooperation on water management
X (RT) High
30 District budgets on environment management X (RT), X (OI)
High
31 No natural resources database at district level X (RT) Low
32 Understaffing at district level X (RT) High
33 District officers are overlooked by the petro industry
X (SS) X (RT) High
34 Conflicts with international environmental agreements
X (SS) High
35 Relations to the existing Monitoring Plan to be clarified. Coordination
X (NO) *comment
36 Data storage important for the SEA monitoring and follow up
X (NO)
*comment
37 Capacity of NGOs, etc. to undertake public scrutiny
X (SA) Medium
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Table 4: Issues related to Other Matters
No. Issue SEA screening/ scoping. Existing documents
Expert teams
Stake-holders incl. Inception workshop
Scena-rio analy-sis
Signifi-cance
1 Strong scientific basis for decisions X (IW) High
2 Stakeholder involvement on all levels X (IW) High
3 Transportation systems. Infrastructure X (ST) X (IW), X (RT)
X (SA) High
4 Baseline survey to be undertaken by Sept.12 X (IW) *comment
5 Transportation of crude and materials X (IW), X(RT)
X (SA) High
6 Also consider all positive effects related to the petro development
X (IW) *comment
7 Situation when the petro age is over. Future opportunities.
X (ST) X (RT) Medium
8 Infrastructure needs X (ST) High
9 Consequences of introducing midstream activities in Uganda
X (ST) *comment
10 Management of navigation in the lakes/rivers X (ST) Low
11 Policy guidance and legal safeguard for the petro industry missing
X (ST) High
12 Issues related to the use of deep wells for injection of waste
X (ST) Low
13 Produced water management X (ST) X (FT)
X (NO) *comment
14 Use of technology and possibilities to use standard reporting, data collection etc.
X (ST) Medium
15 Differentiation between natural and anthropogenic oil contamination. Baseline studies
X (FT) Low
16 Lack of information sharing between all involved parties
X (FT) High
17 Technology for drainage of shallow reservoirs. Oil based drilling fluids?
X (FT) *comment
18 Transportation of waste. No control X (RT) High
19 Food insecurity X (SS) Low
20 Energy efficiency related to the oil and gas value chain
X (NO) Medium
21 AG as a regional hub to serve petro activities also in DRC and South-Sudan
X (NO) X (SA) Medium
22 Assessment of alternatives for petro activities in space, time and amount
X (NO) X (SA) *comment
23 General consideration of cumulative impacts and indirect impacts
X (NO), X (OI)
X (SA)
High
24 Evaluation of best available technology should be integrated
X (NO) *comment
25 Focus on trend analysis as to baseline conditions
X (OI), X (IW)
High
26 Pacing of the oil and gas development in AG X (SA) *comment
27 Existence of necessary public infrastructure to meet the petro development
X (SA) High
28 Existence of necessary public infrastructure to meet the petro development
X (SA) High
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29 Large scale activities on lake Albert X (SA) Medium
30 More and better energy supply locally and national
X (SA) Low
31 More and better supply of fuel and diesel X (SA) Low
32 Macro-economic issues, inflation, distortion of price ratio regarding exports etc.
X (SA) Medium
Comments to the matrix
NE4 Geohazards Low urgency. Needs to be taken into consideration in design.
NE7 Emphasis on lower mammals (indicators)
Low urgency. However important indicator to follow up by time.
NE16 Environmental protection on long term…
High urgency. To be discussed related to scenarios
NE20 Discussion/use of trade-offs High urgency which needs to be discussed. Not defined as Issue.
SE2 Participation in planning and capacity building
High urgency. Important to prepare for participation. Not defined as Issue.
SE8 Offset opportunities, payment for ecosystem services
High urgency. Recommendation.
SE26 Governance structure High importance. Needs to be established and in place. Too general as Issue. Covered by other Issues.
SE28 Distance between petro facilities and existing settlements
Hugh urgency. Important to integrate in technical planning.
IM1 Strategic environmental management plan
High urgency. Actually a part of the SEA itself.
IM9 Integrated management plan for AG
See above.
IM35 Relations to the existing Monitoring Plan to be clarified. Coordination
High urgency. The monitoring plan for the SEA is directly connected to monitoring the recommendations in the SEA. Needs to be coordinated with the general Monitoring Plan.
IM36 Data storage important for the SEA monitoring and follow up
High urgency. Recommendation.
OM4 Baseline survey to be undertaken by Sept.12
Not needed and relevant for the SEA.
OM6 Also consider all positive effects related to the petro development
High urgency and an important reminder.
OM9 Consequences of introducing midstream activities in Uganda
High urgency. To evaluate as part of refinery discussion and decision.
OM13 Produced water management High urgency. To be discussed as a high level strategic issue
OM17 Technology for drainage of shallow reservoirs
High urgency. To be discussed as part of technology
OM22 Assessment of alternatives in space, time and amount
High urgency. To be discussed related to development scenarios
OM24 Evaluation of BAT High urgency. To be discussed as part of technology
OM26 Pacing of oil and gas development
High urgency. To be discussed as part of scenarios
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APPENDIX 7: KEY ISSUES INTEGRATION MATRIX
Key Issues Group 1: Petroleum related Activities in Protected and Environmentally Sensitive Areas
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Consideration of biodiversity loss, also aquatic. Footprint (NE1)
2. Attention on sites with international conservation status (NE5)
3. Impacts on wildlife population and movement (NE6) 4. Sensitive aquatic resources such as deltas, shorelines (NE10)
5. Coexistence with wildlife (NE12)
International conventions and protocols - The United Nations Convention on Biological
Diversity, 1992
- Convention on Migratory Species (Bonn Convention) 1979)World Commission of The World Environment and Development (WCED)
- The Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar Convention), 1971
- African Convention on the Conservation of Nature And Natural Resources
- Protocol Concerning Protected Areas and Wild Fauna in the East African Regions, 1985
National level
The Uganda Wildlife Act, Cap 2000
The Uganda Wildlife Policy, 1999 (in review)
Tourism Master Plan (in review)
UWA strategic plan 2008-2012 will in 2013 be replaced by a new plan (2013-2018)
Toro-Semliki Wildlife Reserve management plan 2008-2018
Murchison Falls Conservation Area management Plan 2012-2022 (Draft)
Ministry of Tourism, Wildlife and Antiquities - UWA
There is need to harmonize the wildlife policy and the wildlife ACT on issues of carrying out mining activities in protected areas. Whereas the revised policy has a provision for it, the ACT does not yet have that.
The NEMA ACT is adequate on EIA in protected areas. There is need to broaden it to include the SEA.
The tourism Master Plan is under review
The Wildlife policy has been reviewed to accommodate the petroleum related issues. It has already been taken to stakeholders and is now before the cabinet.
It is the duty of the Ministry of Tourism, Wildlife and Antiquities to enact regulations but those presented to them by UWA but they are taking a slow pace e.g. one on fire arms and another on wildlife use rights already drafted by UWA
UWA has developed operational guidelines for oil companies and has presented them to the board of trustees and are waiting for approval. UWA also hopes that these guidelines will eventually be translated into laws.
The strategies for the new UWA strategic plan have already been developed and they address the oil issues. The plan will be ready in March 2013
Plans are reviewed every 5 years. Although the Toro-Semliki WR management plan takes into consideration oil activities, it is due for revision and the oil issues will be better addressed.
The other plans that are in draft form already include petroleum issues.
NFA
The forest policy was formulated before petroleum was discovered. It therefore needs revision.
The National Forest Plan takes into consideration the oil and gas issues.
Effort needs to me made to complete the Forest Regulations document and the EIA guidelines and ensure that they include guidelines related to oil and gas activities.
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6. Operations within the protected areas (NE14)
7. Pollution and disappearance of endemic species (NE18)
8. Habitat fragmentation due to construction works (NE21)
9. Environmental monitoring of operations in sensitive areas (IM24)
Kabwoya Wildlife Reserve management plan 2012-2022 (Draft)
Plan for preparing a detailed sensitivity atlas for MFNP are in advanced stages
UWA and Ministry of Tourism, Wildlife and Antiquities officials programs
- Movement of wildlife in relation to wildlife activities
- Monitoring and research programs
- Compliance monitoring of oil and gas impacts
- McArthur Foundation partnership for training UWA staff in oil and gas activities
- WCS and WWF providing capacity building of UWA staff in oil and gas related activities
- Quarterly field inspections by Ministry of Tourism, Wildlife and Antiquities officials
National Forest Authority (NFA)
The Uganda Forestry Policy, 2001
National Forest Plan, 2011/12-2021/22.
The Forestry and Tree Planting Regulations, 2012
National guidelines for implementing collaborative management in Uganda (Draft 7)
Guidelines for Environment Impact Assessment in Forestry Developments, October 2005
First Schedule. Statutory instruments 1998, No, 63. The Forest Reserves (declaration) order, 1998. (Under section 4 and 5 of the Forest ACT, CAP 246
Forest Regulations (in draft since 2006)
There are no guidelines yet for guiding oil and gas activities in Forest Reserves but they can be developed.
There is need for regulations for management of forests on private land.
Although the ACT and the regulations exist, only a small portion of each is implemented.
When oil and gas activities have to be carried out in a forest reserve, the current mitigation focuses on only restoration. There is need to also negotiate with companies to consider offsetting for destroyed forest areas.
Ministry of Local Government
The environment officers were put in place based on the ACT but standards of their operations were never developed.
During the preparation of the development plan, environment should also be considered, and the environment and forestry officers should participate in the planning process so that they know what to monitor. The plans developed would then be justification for inclusion of environment in the Local Government budget.
PEPD
PEPD develops policies and guidelines directly related to oil and gas. Institutions that are responsible for the natural resource are expected, under their mandate, to include oil and gas issues in their policy, regulations and guidelines.
The PEPD personnel that go to the field have environmental knowledge and can carry out environment assessment, report and also ring a bell for the mandated institutions to act when need arises.
Ministry of Water and Environment
The oil and gas industry is very new yet some of the institutions under this ministry e.g. NFA and FSSD are still relatively new and they are still working towards coming to grips with all country issues that are under their mandate. So oil only compounds their challenges.
Most of the policies are very general and they basically handle the broad framework of the oil and gas issues.
The policies are internal or national yet decisions are made at international level.
Most data is general yet oil and gas activities are carried out at micro level.
The Wetlands strategic plan considers oil and gas issues
Whereas the Murchison Falls Conservation Area plan included part of the Ramsar site that is
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NFA programs and projects
- Community tree planting
- REDD+
- Payment for Ecosystem Services (PACE) being carried out by NEMA and Chimpanzee Sanctuary
Ministry of Water and Environment
The National Environment Act, Cap 153
National Policy for the Conservation and Management of Wetland Resources, 1995
Uganda Wetland Sector Strategic Plan 2001-2010
The National Environment (Wetlands, Riverbanks and Lake Shores Management) Regulations (2000)
Wetland strategic plan 2011-2020
Plans and programs
- Environment support service - Development strategic plan
The National Fisheries Policy, 2004
Fish ACT, 1964
Plans and programs - Development Strategy Investment Plan (DSIP),
2011-2016
- Increasing Mukene production and consumption of small fish project
- Fish quality and marketing project
NEMA - Environment compliance and monitoring
strategy - Environment monitoring plan, 2012-2017
under their jurisdiction, conservation plans need to be made for the area outside the protected area to ensure holistic conservation of the site.
A unit should be established in each department, under MWE, to strengthen the monitoring of oil and gas activities.
There is need to assess the effectiveness of the environment pillar and also to clearly define the roles of the Lead Agency and of each institution.
Fisheries Department (MAAIF)
The National Fisheries Policy needs review for it does not consider oil and gas activities.
The Fish ACT 1964 was partially amended in 2000 but oil activities were not considered. So there is need for review of the ACT.
There is no fish regulation
There is no legal framework for instruction about oil and gas activities e.g. pipelines and other activities that may cause fragmentation of fish breeding or sensitive areas. Fisheries department depends on NEMA for such instruments.
Oil companies
A basin wide plan is being developed to guide operations of the three oil companies working in Northern Albertine Rift.
In order to reduce the impact of the 3D seismic activity, an internationally competent biodiversity team will be hired to advise on best practice, hand portable equipment will be used in the Ramsar site. The area of interest will also be mapped and coded with levels of sensitivity, which will guide the operators on where to take extra caution or not to go at all. Specific avoidance features will also be identified.
To monitor the impact of the 3D seismic on large mammals, aerial surveys will be carried out monthly.
There is need for the oil companies to have a joint meeting with the responsible institutions i.e. PEPD, NEMA and MWE to obtain a streamlined understanding of the role of each institution.
The economic interest most times overrides the ecological interest. Oil companies have to work under very tight schedules to beat set deadlines and in so doing avoid economic loss; This causes work to be carried out without good/adequate baseline data since EIAs must also be completed within a very short time. This makes it difficult to monitor impacts of such activities. There is therefore need for good baseline data and a regional EIA to guide planned activities. A small site specific document would be prepared for the site under development. This would also ease the
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Ministry of Lands, Housing and Urban Development
The Physical Planning ACT 8, 2010
National Land Use policy, 2007
The Uganda National Land Policy, 2011 (final draft)
Stakeholders consulted:
Ministry of Lands, Housing and Urban Development:
- Dept. of Land Use Regulation & Compliance;
- Physical Planning Department;
District Local Government ( District Planner, Environmental officer, Land officer)
NEMA;
MWE (Wetlands Department,
Department of Water resources Management);
Department of Fisheries Resources
PEPD
UNRA
Ministry of Tourism, Wildlife and Antiquities
EIA clogging at NEMA
Civil Society
Mitigation measures alone will not be adequate. EIA guidelines should include possibility of offsets. Responsible institutions also need to understand under what circumstances an offset is required.
All pipelines, transmission cables and other linear infrastructure should be underground and, where possible, they should be near the road to reduce footprint.
There is need for community conservation and sensitization. Community conservation should incorporate oil and gas issues to reduce blaming of human-wildlife conflicts on oil and gas activities.
National Environment Management Authority (NEMA)
NEMA has established an oil and gas unit, which has already been approved by the board. It awaits approval by parliament. The unit should liaise with UWA, PEPD, MWE responsible institutions and District Environment Officers.
The Ministry of Lands, Housing and Urban Development, under ACT 8, 2010, CAP 24 recommends areas with unique development potential to be designated as special planning areas. The Ministry has designated the Albertine Graben as a special planning area because of the petroleum deposits that have been discovered and its high biodiversity content. Development of the plan is now in infancy stage
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Key Issues Group 2: Co-existence with Local Communities Including Indigenous Peoples
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Compensation, livelihood restoration, resettlement
2. In-migration at a larger scale. Large workforce
3. Socio-economic issues incl. education, health, social patterns, adaptation capacity etc
4. Land rights and tenure, land conflicts and speculation
5. Consultation with Bunyoro Kingdom and traditional institutions. Indigenous knowledge
6. Impacts on population dynamics in the region. Urbanization
Land Acquisition Act 1995
Physical Planning Act, 2010
Registration of Titles Act
Land (Amendment) Act, 2010
Land Acquisition Act, Cap 223
The Local Government Act (2006)
- to be analyzed
Land Regulations, 2004
Health Sector Strategic Plan
Stakeholders consulted:
Ministry of Internal Affairs
The Ministry of Lands Housing and Urban Development
The Land Administration Department in the Ministry of Lands, Housing and Urban Development is aware of the challenges that have been experienced in the Graben and while all the laws are in place, the current challenges have been integrated in the oil and gas bill. However, what comes out clearly is that there is a land administration system in Uganda with district land boards that should be in charge regarding matters of land. Additionally, there are tools for sensitizing communities to prepare them for different land transactions
According to the Minsitry of Local Government, In compensation, one of the greatest changes is valuation. At the district, although there is a position of “valuer”. n many districts this is not filled, however, Hoima District has a valuer. Resultantly, the delegated persons with t the responsibility of the valuing are not skilled and often under estimate the value of natural resources. Furthermore, the communities are not empowered to bargain/ negotiate. Therefore the recommendation is to recruit valuers to fill this gap and further strengthen the structure of compensation and resettlement.
Another challenge here also noted is the issue of ownership of property. Most of the property especially land is owned in the names of the man. Often by the time the women realize that there has been compensation, the money has already been given to the man who may have not put it to the right use.
According to the Ministry of Gender, Labor and social development, on social tension the Albertine Graben is likey to experience issues of tension and therefore the need to have conflict resolution mechanisms and therefore a need to have a programme to build the capacity of community in conflict resolution to cope with this change
According to the Ministry of Works and Transport, there are standards for buildings and these should be followed when constructing infrastructure within the Graben so that the needs of the increased workforce are taken into account
Local Governments receive money depending on the population numbers they are to deliver the services too. The challenge is however, there is no update population census of the Albertine Graben now as the population census was last done in 2000. It was therefore recommended that UBOS carries up at least 5 years census especially for the Albertine Graben population and this way, appropriate planning can be done.
Ministry of Gender, Labor and Social development has an equal opportunities policy that aims to address vulnerable persons to socio-economic development, within the Graben there is need to raise awarenes of all actors on inclusive development
According to the Minstry of Local Government, it is envisaged that the displacement or resettlement of people is likely to come with erosion of culture. The key recommendation is that the plan of resettle to should as much as people resettle people in groups rather than individually. This way, the culture of these groups will still be maintained despite
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7. HIV/AIDS
8. Involvement of locals in new job market
9. Relations between indigenous communities and petroleum industry
10. Recreation and amenity facilities offered by the environment
11. Increase of costs of living
12. Large challenges for the districts to prepare for new settlements. Infrastructure
13. RAP reports not followed up
14. Methodology for sensitization valuation to be improved
15. Disruption of existing livelihoods
16. Expectation management
17. Informal and traditional
Ministry of Health
Ministry of Trade Industry and Cooperatives
District Local Government (District (planning officer, env. officer, commercial officer, land officer, community development officer)
District Local Government (district planner, env. officer, land officer)
NEMA
Ministry of Tourism, Wildlife & Antiquities
Ministry of Local Governments
TOTAL E&P
Tullow Uganda Oprations Pty Limited
CNOOC
the displacement.
On urbanisation, a land use plan is already being developed for the graben and therefore aspects of planned development should be taken into account
On interaction with natural resources including encroachement in protected areas, the social development programme proposed by Ministry of Gender, Labor and Social development should include coping strategies including energy saving technologies, adoption of alternative income generating activitues so that increased demand for resources is managed. Access to safe water will ensure that communities have access and secondly they do not have to depend entirely on unsafe water sources
There are alot of interventions on HIV/AIDS awareness, and as a Ministry of Gender, Labor and Social Development noted, sensitisation materials are already developed but there is need to have budgetary allocation for more sensitisation and monitoring of related interventions.
The local people are definitely lacking in expertise and may thus not be able to participate. Although the Ministry of Energy has a local content policy that aims at promoting Ugandans in benefiting in the oil and gas sector, an intensive progrramme to ensure that local communities are including in this development is needed.
The Ministry of Energy has developed a comprehensive communication policy and has recruited communication staff to manage communities grievances in land acquisition processes, additionally to other inclusive development strategies increased sensitization of stakeholders to ensure that local communities trusts the sector is needed.
A new environmental monitoring plan for the Graben has been developed and is available on line where there are indicators based on valued ecosystem services. Therefore, during the specific EIAs, the ecosystem approach is recommended to ensure that ecosystem services are identified and mitigations measures adequately planned for.
Inclusive development programme is recommended for the Graben to enable communities cope with the development especially for those not directly involved in the sector
There has been no land use plan for the Graben, but the process has already began for its development and this should be able to address the infrastructural needs based on the new settlements. Additionally, population figures will highlight the need for increased local government budgets
It is indeed a challenge when a number of developments are taking place under the Ministry of Energy that are involved in land acquisition including under Rural Electrification Agency, Uganda Electricity Transmission Company Limited and now land acquisition for the refinery. There is need for more sensitization to communities on the fact that the different entities have different planning cycles and that may be perceived as delays. That notwithstanding, disclosure of information should be done adequately bearing in mind that the different sectors affect the perception of community members that currently does not trust the they will be adequately compensated
District land boards need more training so that they can sensitize communities when there are such gaps, currently most land acquisition exercises work with Local council leaders, but district land boards and mandated by law to handle
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administrations worked before. What now
18. Ownership to land required by the petro industry
issues of land administration
The fear that current sectors like agriculture being affected can be addressed by promoting technologies that would address challenges of working in this environment. The current policy direction of Uganda is increasing farmer incomes through the DSIP and to ensure that households do not become food insecure. Therefore interventions such as improved technologies, support in accessing inputs and agricultural finance can be considered
Inclusive development programme is recommended for the Graben to enable communities understand their expectations, an expectation management or community strategy be supported with guidelines to ensure that communities do no remain aggrieved.
This concern that traditional institutions be involved in the oil and gas sector, while traditional institutions would are very influential in the sector, they can actively be used in promoting sustainable environmental management strategies including conservation of sensitive ecosystem, however, guidelines have to be developed given that environmental challenges keep changing, they can also be used for monitoring but these have to work hand in hand with formal institutions at the district level.
In some cases oil companies have been getting leases on customary land which is not in compliance with the land laws of Uganda, in the event that oil companies are acquiring land, they need to consult with the Land Administration Department but they can rent land under the customary land tenure arrangement
Key Issues Group 3: Co-existence with Archaeology and Cultural Heritage
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Archaeology and cultural heritage (SE5)
2. Awareness about and coexistence with cultural heritage (SE27)
3. 3. Inclusion of cultural institutions in the petro strategies. Capacity building (IM12)
Uganda National Cultural Policy
The Historical Monuments Act,
The National Environment Act,
The National Culture Centre Act,
The Copyright and Neighboring Rights Act
The Traditional Rulers Restitution of assets and Properties Act
Stakeholder consulted:
Ministry of Tourism, Wildlife & Antiquities, Dept.of Museums &
The inconsistent Government policy: The government of Uganda has over time and again restructured the relevant key instructions under different ministries thereby making it difficult for the institutions to carry out there duties according to a given plan and policy.
Limited funding from government: Despite the fact that most institutions responsible for the management of cultural heritage in Uganda are public institutions, they are poorly funded to undertake their respective responsibilities.
The lack of public- private partnership: The International trend of privatizing public services also concerns the conservation of cultural heritage as a public value.
The Demographic Challenges: Cultural heritage also continues to become weaker and more vulnerable on its own, because of the fast pace of transformation processes resulting from the increasing population density, urbanization, development
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Monuments
National Environment Management Authority
Ministry of Water and Environment (MoWE)
Ministry of Gender, Labor and Social Development
Bunyoro-Kitara Kingdom
Hoima & Bulisa Districts local government
Ministry of Lands, Housing & Urban Development
UNESCO Uganda.
pressures, poverty and also changing perceptions.
Weak Institutions: The institution charged with the protection of cultural heritage is often one of the weakest governmental agencies.
Most national legislation still tends to focus on protecting places rather than knowledge or cultural practices.With the changes in society the local communities are no longer as socially cohesive before and the hold of traditional institutions has weakened particularly in the face of economic and developmental forces emanating from ‘without’.
Inadequate Gazettement of Sites.
Social and economic incentives to curb illicit traffic in antiquities are often lacking.
Lack of record and data base on cultural heritage.
Unqualified staff: The relevant key offices are often understaffed and employ unqualified staff with limited technical knowhow on the issues of conservation and cultural heritage management.
Key Issues Group 4: Co-existence with Other Industries and Service Providers
Key Issues Relevant PPPs and stakeholders.
Laws and Regulations
Outcome of the consultations
Petroleum activities as catalyst for other service/industry development (SE41)
The National Land Use Policy (2008)
- Policy concerns relevant to petroleum activities
- The National land Policy to be reviewed,
- Programmes/projects include: Municipal /urban infrastructure development, The slum upgrading programme, physical planning development of AG and Formulation of urban forum
The Local Government Act (2006)
The National Environment Policy 1994
- National Environment Policy to be reviewed to include oil and gas concerns
The Ministry of Lands, Housing and Urban Planning,- Department for Land Use:
- Albertine Graben (AG) given status of special planning area, - In Hoima, refinery land and area around it undergoing planning, - Bulisa, Sebagola and Butyaba to be fast tracked, - Wider AG (from Kanungu to Nebi) planning to be undertaken by World bank
District Local Governments: District Planning officer, Environmental officer,
Commercial officer, Land officer, etc:
- Decisions made at central Government level without consulting respective
district local governments for example when preparing RAPs,
- Need to include District oil office to coordinate different departments,
- Capacity building (skills)among the district staff to handle oil and gas issues,
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The National Environment Act, Cap153
- -The National environment Act to be reviewed
- -Environmental Impact Assessment Regulations (1998) to be reviewed,
- -Waste Management regulations (1999) to be reviewed,
- -The National Environment (Audit) Regulations (2006) to be reviewed
- Other relevant laws and regulations such as Effluent Discharge Act, Waste water Act to be reviewed
- New regulations such as Air quality and Oil spill Liability regulations are underway
Plans/projects:
- Oil Spill Contingency Plan underway,
- Environmental monitoring plan has been developed,
- Environmental Sensitivity Atlas,
- Capacity needs assessment (ready)
- Interim waste management guidelines (ready) to become guidelines after reviewed waste management regulations are ready
The Petroleum Act (refining, gas processing, conversion, transportation and storage), Bill, 2012
- The bill is still being debated by parliament (as of June 2013)
Revenue Management Bill, 2012
To be debated by parliament
Plans:
- to upgrade railways and air transport including large air port for big planes necessary for oil spill contingency;
- -Development of Hoima –Wanseko road
- Increase in facilitation to monitor oil and gas related activities in addition to
usual tasks,
Ministry of Water and Environment, Department of environmental affairs:
- Department in conflict with NEMA regarding their respective roles,
- Harmonize Environment Act with the Constitution to avoid conflict between
NEMA and lead Agencies
National Environment Management Authority (NEMA)- Department of
Compliance and Monitoring:
- To handle oil and gas issues a multi-sector monitoring committee (8 sectors) coordinated by NEMA established,
- NEMA staff lacks skills on EIA/Audit related to oil and gas and training required,
- At district level skills to review EIAs is even worse than at NEMA,
- Oil companies have given some money for training in oil and gas,
- There is lack of updated data at NEMA, which is a problem for the whole country and affects how EIA and audits are done including process duration,
- NEMA lacks equipment for verification and on-spot checking which lead to inefficiency in motoring activities in AG’
- NEMA plans to provide monitoring equipment to lead agencies to improve their efficiency.
The Ministry of Energy and Mineral Development, PEPD:
- -Three directorates to be created (may be one or more can deal with issue related to co-existence with other industries/service),
- -Communication strategy (for communicating with local communities)
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Key Issues Group 5: Co-existence with Tourism
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
Co-existence with tourism (SE14)
Oil and Gas policy 2008
Uganda Tourism policy, 2003
Uganda Wildlife Policy, 2000 Stakeholders consulted:
Ministry of Tourism Wildlife and Antiquities
Uganda Wildlife Authority
Association of Uganda Tour Operators
Uganda Wildlife Policy (2000)
The policy was developed before the oil exploration era. A revision of the policy is ongoing to incorporate the activities of the oil and gas sector. UWA has developed guidelines to ensure that the oil and gas sector activities do not interfere with their mandate of protecting and conserving biodiversity. For example, UWA has ensured that the oil pipelines pass through the less sensitive areas of parks and reserves. The main impacts from pipelines is connected to the construction phase. The major concern is how to deal with the pollution damages to the wildlife and the health of their habitats.
Uganda tourism policy (2003)
The policy was developed before the oil exploration era. The concern is the disturbance to wildlife habitats. The observation is that there are specific circuits where the chances of seeing animals are high. A number of these circuits have been taken over by the oil exploration activities. Thus there has been a reduction in access to wildlife viewing. Stakeholders suggest that the oil and gas exploiting firm must ensure minimum disturbance to the circuits, and alternative circuits should be developed by the oil firms. The other concern was that of waste disposal versus the health of the protected areas. Stakeholders emphasized the need for the oil exploiting firms to employ technology that ensures minimal ecosystem disturbances.
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Key Issues Group: 6: Co-existence with Fisheries
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Co-existence with fisheries (SE21
2. Fish prices high due to competition on salaries (SE34)
Fisheries Policy (2004):
Policy concerns relevant to petroleum activities:
- Inadequate monitoring, extension and enforcement mechanisms;
- Inadequate mobilization and involvement of communities in management and development of fisheries resources;
- Ill-equipped extension services and inadequate research information to promote sustainable management and development of capture fisheries and aquaculture;
- Absence of regional mechanisms for cooperation in the management of the shared lakes in the Albertine Graben.
The National Water Policy (1997):
Policy concerns relevant to fisheries in relation to petroleum activities
- Insufficient capacity to collect and analyze data essential for allocating water resources to multiple users without compromising ecosystem maintenance requirements;
- Inadequate capacity to detect and monitor environmental pollution in surface and ground waters associated with petroleum activities.
The Water Act Cap. 152 (2003)
Concerns related to petroleum activities :
The National Environment (minimum standards for discharge of effluents into water or land) regulations (1998):
Concerns related to petroleum activities
- Stockpiling petroleum drilling waste close to surface water bodies
The Wetlands Policy (1995):
Policy concerns relevant to fisheries in relation to petroleum:
- Apparent inability to promote sustainable conservation of wetlands to safeguard their ecological and socio-economic functions and values
The Fisheries Policy (2004) outlines policy concerns, objectives and strategies; as well as institutional mandates suitable for management of emerging constraints to fisheries. Many of the policy interventions outlined include those due to petroleum activities in the AG. The Fisheries Policy (2004) has no operational regulatory framework as yet.
While increase in fishing pressure is common to almost all fisheries in the country, petroleum activities in the AG are enhancing the constraint. Road construction to facilitate petroleum activities increased demand by opening up the fishery to distant. The growing work force, able to pay more is leading to higher demand for fish at higher prices. The result has been marked increase in fishing pressure accompanied by the use of illegal destructive fishing gears and methods. In Lake Albert popular table fishes are becoming increasingly unaffordable to traditional fish eaters due to high prices. Unusually low fish catches have been reported for the Nile perch. The fish processing factory at Butiaba built in 2004 for this species closed in 2009.
Resources are lacking to facilitate acquisition of spatial and temporal research information:
- to map critical breeding, nursery and feeding grounds for major commercial fish species;
- to track impacts of pollution on the aquatic environment and fisheries;
- on hydrodynamics of major lakes in the AG;
- to model population dynamics of major commercial fisheries for management purposes,
This information will contribute to management of
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The National Environment (wetlands, riverbanks, lake shore management) regulations (2000):
Concerns related to petroleum activities:
- Apparent inability to promote sustainable conservation of fringing wetlands to safeguard their ecological and socio-economic functions and values
MWE: Department of Wetlands:
Beach Management Unit Guidelines (2003); Fish (Beach Management Unit) Rules
Policy concerns relevant to fisheries in relation to petroleum activities:
- Insufficient facilitation (e.g. water transport, sensitization on appropriate aspects of fisheries management);
- Political interference in BMUs’ mandated activities;
- Marginalization by senior actors;
Stakeholders consulted:
Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) - Dept. of Fisheries Resources (DFR);
National Fisheries Resources Research Institute (NaFIRRI);
NEMA
District Local Government: District Fisheries Officer; District Environment Officer;
Beach Management Unit (BMU)
Ministry of Water and Environment (MWE): Directory of Water Resources Management (DWRM)
Ministry of Local Government
fisheries towards co-existence with petroleum activities in the AG.
(i) The high demand for water by some petroleum activities could lead to insufficiency of water for vital fish habitats as well as for aquatic ecosystem maintenance.
(ii) Interaction and coordination between the Centre (Department of Fisheries Resources – DFR) and the District Local Governments towards effective fisheries Management and development in the AG is inadequate. Similarly, formal inter district dialogue, coordination and collaboration that could support fisheries management and development in the AG is lacking.
Consultations with Beach Management Unit (BMU) officials revealed eagerness to play their official roles if empowered with needed resources such as water transport and sensitization on fisheries management approaches. The officials reported marginalization by senior actors, and political interference in their mandated activities.
Transboundary illegal fishing activities on Lake Albert accompanied by use of illegal fishing gears and methods reportedly contribute significantly to the heavy fishing pressure enhanced by petroleum activities in Uganda and in Democratic Republic of Congo (DRC).
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Key Issues Group 7: Sharing of Revenues and Wellbeing between the National and the Local/Regional level Cooperation
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Revenues to the benefit of local communities and future generations (SE25)
2. Lack of collaboration between local and central government. Also influencing budgets (IM21)
Oil and Gas policy 2008 Stakeholders consulted :
Ministry of Finance Planning and Economic Development
Ministry of Local Government
Oil and gas Policy (2008) (Revenue Sharing National versus local areas with deposits)
Proposed sharing arrangement:
Each district is to receive 7% of the revenues generated from its extracted deposits. These funds will be a constant amount which is exchange rate immune. The resources are strictly for use in the development of the respective district social and economic infrastructure. The basis for determining the percentage that goes to districts is not clear. However, the idea is to keep a bigger percentage of the revenues at the center (MPFED, and is held in trust) such that at the end of the extraction period, the center can use the funds to support continued social and economic development in the districts.
Concern about the arrangement:
1. The revenue recipients may express discontent with the 7% share. For example Bunyoro kingdom’s demand is 15%.
2. Over time population in these districts will increasing putting more pressure of the projected infrastructure developments.
3. With inflation taking pace, the real value of the revenue shares will be eroded. The districts will soon find themselves with inflation generated budget deficits that the center may have to assist clear.
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Key Issues Group 8: Discharges and Emissions from the Petroleum Industry
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Air emission, soil and groundwater pollution (NE2)
Stakeholders consulted: The Petroleum Industry:
Tullow Uganda Operations Pty
Total E&P Uganda
CNOOC Uganda
A key concern is the lack of appropriate waste facilities beyond the intermediate storage sites currently approved. At least Total’s intermediate waste facilities are furthermore at full capacity. It is therefore unclear how to continue with exploration/appraisal drilling.
Operations and safeguarding/controlling intermediate storage sites as well as take-over of waste in such sites from previous operators create a large liability for the oil industry. Despite safeguards, wildlife and other interference has the potential for pollution.
Storage of well testing products is also a concern as it adds costs and liability until a solution is found.
There is concern that future waste management regulation will focus on legacy wastes and not adequately regulate future wastes, incl. the liquid part of drilling waste
Tier 1 oil spill response provisions are in place, the waxyness of the oil facilitiates a potential clean-up.
A solution for produced water has to be found. Re-injection has been proposed but rejected by the authorities.
Waste burial in protected areas (Murchison Falls NP) is not an acceptable solution.
Key Issues Group 9: Waste Management
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Management of
pollution and
waste (IM5)
2. Waste
management.
Regulations and
guidelines missing
(IM13)
The National Land Use Policy (2008)
- Policy concerns relevant to petroleum activities
- The National land Policy to be reviewed
The Local Government Act (2006)
The National Environment Policy 1994
- National Environment Policy to be reviewed to include oil and gas concerns
The National EIA regulations (1998)
The Ministry of Lands, Housing and Urban Planning- Department for Land
Use:
- Designate areas for waste management, especially drilling waste and produced water,
- Gazette area where hazardous can be permanently disposed of,
- Demarcate areas where waste management activities are not allowed, e.g. in protected areas
District Local Government (District water officer, Environmental officer,
Land officer):
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3. Identifying and
regulating
transporters and
waste facility
operators (IM16)
4. Transportation
of waste. No
control (OM18)
Waste management Act (1999)
(undergoing review)
The National Environment (Audit ) Regulations,2006
- to undergo review
National Oil and Gas Policy
The Petroleum( Exploration, development and production) Act, 2013
- Containments of waste management concerns.
The Petroleum Act (refining, gas processing, conversion, transportation and storage), Bill,2012
-Yet to be debated by parliament
Plans:
Capacity building under the environmental pillar, including formal (higher) education
Stakeholdes consulted:
E&P Oil Companies:
The Ministry of Energy and Mineral Development, PEPD
NEMA, Department for compliance and monitoring:
District Local Government (District water officer, Environmental officer, Land officer):
The Ministry of Lands, Housing and Urban Planning- Department for Land Use
- Lack of capacity in terms of skills to monitor drilling and refinery waste;
- Lack of capacity in terms of facilitation (transport, laboratories, testing kits etc)
NEMA, Department for compliance and monitoring:
- Multi-sectoral Monitoring Committee for Oil and Activities (coordinated by NEMA) inadequate after world bank funding stopped,
- Current Oil and gas monitoring officers to be replaced by multi-sectoral monitoring unit’
- Regulations undergoing review include EIA, Audit, Effluent discharge, waste management,
- Skills for reviewing EIA for oil and gas related activities are wanting within NEMA staff and among environmental practitioners,
- Oil companies have given Government money for training in oil and gas
- Are tests for waste characteristics being carried out without conflict of interest? NEMA bought equipment for PEPD and other agencies to make local institution independent
The Ministry of Energy and Mineral Development, PEPD:
- Field officers from head office but none from local districts in AG,
- HSE guidelines: who is in charge? May be have an office in labour department dedicated to petroleum sector?
E&P Oil Companies:
- No onsite burial of waste desired,
- No toxic components are included in the drilling muds,
- Each company has its own waste management guidelines to supplement NEMAs guidelines
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Key Issues Group 10: Water Management
Key Issues Relevant PPPs and Laws and Regulations
Outcome of the Consultations
1. Pollution of surface waters and aquifers. Water management (NE17)
2. Freshwater management (IM8)
3. Need monitoring plan on
district level for water
resources (IM28)
The National Water Policy, (1999)
Water is considered as a social and economic good
The National Environment Water Act The Water Act is one piece of Uganda's sectoral legislation with key provisions to enhance sustainable development.
The National Environment (Audit) Regulations 2009 Prohibit the carrying out of environment audits without due certification and registration, except if the person is an environmental inspector.
The National Environment (Minimum Standards For Discharge Of Effluents Into Water Or Land) Regulations Prohibit discharge of effluent or waste on land or into the aquatic environment contrary to established standards and without a waste discharge permit.
National Water Action Plan
Oil Spill Contingency Plans
Environmental monitoring plan for the Albertine Graben
Stakeholders consulted: DWRM, MWE, NEMA, UWA, NAFFIRI, PEPD, MWE
No water quality standards related to oil and gas activities
Trans-boundary issues related to oil and gas need to come out very clearly
Little knowledge of staff on what to look out for during enforcement and compliance monitoring
Technology to be employed is very crucial and should be environmentally friendly
No oil and gas related regulations since it’s a new sector in the country
In Hoima district, Under staffing. In 2007 there was a water officer with four assistants, one in charge of sanitation, community mobilization, water supply and statiscian, Currently, the water officer has only two assistants in charge of sanitation, and water supply.
Visual monitoring of the water resources, no laboratory testing of water quality, and no water quality sampling this financial year.
In the Hoima district local government rural water and sanitation workplan for the FY 2012/13, there is no component of oil and gas related issues.
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Key Issues Group 11: Oil Spill Preparedness on Land and in Surface Waters
Key Issues Relevant PPPs and Laws and Regulations
Outcome of the Consultations
1. Oil spill contingency planning, on land and surface waters (IM4) 2. Knowledge about movement of spilled oil (IM11) 3. Existence of necessary public infrastructure to meet the petroleum development (OM28)
The National Land Use Policy (2008) - Policy to be reviewed
The Local Government Act (2006) - Act to be reviewed
The National Oil policy - Undergoing review
The Petroleum Act (refining, gas processing, conversion, transportation and storage), Bill,2012 - To include oil spill contingency in the bill
The National water policy (1998) -The policy undergoing review to include oil related pollution
The Water Act, Cap 153 -To be reviewed
Plans: - Oil spill contingency plan (being developed) - The National water development plan, - Upgrading capacity of National reference laboratory to address oil concerns, - Procure equipment for analysis of organic pollutants, - Upgrade basic water quality test labs (central and regional)
Stakeholders consulted:
E&P oil Companies
Makerere University
Ministry of Water and Environment, Department of Meteorology
Ministry of Water and Environment, DWRM
The Ministry of Energy and Mineral Development, PEPD
NEMA, Department for compliance and monitoring
E&P oil Companies - Each oil company to have internal oil spill contingency plan - All oil company to provide assistance to one with major spill
The Ministry of Works and Transport, Department of Transport - Plan for large air port to accommodate wide body airplanes carrying
oil spill contingency equipment - Plan for oil spill at water transport facilities on Lake Albert and along
the roads in AG
District Local Government (District Planning officer, Environmental officer) - Establish mechanism for quick reporting on occurrence of oil spill in
the respective district
NEMA, Department for compliance and monitoring - Coordinating development of oil spill contingency
(being undertaken by NORCONSULT and COWI)
The Ministry of Energy and Mineral Development, PEPD - Characteristics of oil from AG to be studied
Ministry of Water and Environment, DWRM - In charge of oil spill contingency plans - Communication strategy - National water quality management strategy
Ministry of Water and Environment, Department of Meteorology - -Climate change issues, - Meteorological data for oil spill studies
Makerere University - -Study characteristics of oil from AG
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District Local Government (District Planning officer, Environmental officer)
The Ministry of Works and Transport, Department of Transport
Key Issues Group 12: Infrastructure Development in the Region and Transportation of Crude, Products and Construction Materials
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Infrastructure Needs 2. Existence of necessary public
infrastructure to meet the petro development
Transport Sector plans and strategies (Refer also to Scenario analysis)
Stakeholders consulted:
Ministry of Works and Transport
Uganda National Roads Authority
National Planning Authority
Ministry of Finance Planning and Economic Development
In terms of allocating responsibilities UNRA is responsible for developing national networks linking districts and other countries. The major development of the Hoima – Kaiso Tonya Road that will addresss the transport needs of oil and gas sector. UNRA undertook consultations with PEPD, and has since integrated the needs of the sector in the updated the specifications in the road being constructed
The Ministry of Works is in charge of district urban community roads (DUCAR) and therefore it is likely to be in charge of the roads connecting facilities within the middle stream activities.
According to the transport master plan, there is also a plan to revive the railway line to ensure that the sector is adequately support
Also given that a number of airports will be constructed, guidelines and standards are already in place for construction and maintenance
Also when it comes to public buildings and related infrastructure, there are standards that should be followed and all these are available at the Ministry of Works and Transport
As oil companies develop their road networks, they should follow the standards
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Key Issues Group 13: Institutional Capacity Building, Structure and Functions
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Institutional capacity regarding petro sector (IM6)
2. Inadequate local capacity to review oil and gas EIAs and do audits (IM17)
3. Capacity building for national and local governments (IM18)
The environment Act 1994 Provides for appointment of Environmental Inspectors
Petroleum (Refining, Gas Processing and Conversion, Transportation and Storage) Bill 2012
National Oil and Gas Policy, 2008 Provides for monitoring of the Environment. It provides a conducive policy environment.
Mineral Policy 2000
The Energy Policy for Uganda, 2002
Strengthening the Management of the Oil and Gas Sector in Uganda - A Development Programme in Co-operation with Norway, (2010)
Consulted Stakeholders:
MEMD
PEPD
NEMA
Ministry of Local Government
Ministry of Tourism, Wildlife and Antiquities
District Local Government
Ministry of Public Service
Uganda Association of Impact Assessors(UAIA)
SCOs, CBOs and Cultural Institutions within the Albertine
Makerere University
Total, CNOOC and Tullow
EIA practitioners are not equipped with oil and gas skills making the EIA produced not clearly addressing the likely impacts
The capacity of line ministries and lead agencies in review of EIAs is not adequate enough
There exists a capacity development fund managed by PEPD where oil companies contribute
Staffing of most ministries is not adequate enough to monitor oil & gas activities
Proposal of EIA practitioners to undertake EIAs are procured by the government and not the Oil companies to avoid conflict of interest and enhance the quality of EIAs
The National Oil & gas policy provides for joint monitoring of environment by line ministries. However there is no monitoring framework developed, no monitoring protocols, TORs
The Environment act provides for appointment of Environment Inspectors, this has not been effectively implemented.
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Key Issues Group 14: Capacity of District Local Governments to manage Environmental Concerns
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Strengthen environmental concerns at district level. Awareness (IM22)
2. Lack of adequate baseline data is restricting effective monitoring. Only compliance monitoring (IM26)
3. Need inter district cooperation on water management (IM29)
4. District budgets on environment management (IM30)
5. Understaffing at district level (IM32)
6. District officers are overlooked by the petroleum industry (IM33)
The Local Government Act (2006)
The National Environment Act, Cap 153
The Water Act cap 152 (2003)
The Albertine Road Master plan
Proposed Physical Plan for the Albertine Graben
Communication strategy on oil/gas by PEPD
Stakeholders consulted:
Ministry of Water and Environment
UNRA
NEMA
DWRM
Ministry of Local Government
District Local Government (District Planning officer, Environmental officer, Water officer, Land officer)
In the ongoing training of government officials in oil and gas related activities, a number of district natural resources (i.e. environment, forestry, water) officers have also been considered. This will enable them communicate knowledgably to the communities.
A clearinghouse for natural resources data will soon be instituted at NEMA. District officers will then either access data housed at NEMA or be guided as to where certain datasets can be found.
The Department of Water has already set up regional offices to ensure collaboration. The district water officers can on the other side work together to ensure that sharing watersheds or sub watersheds ensure proper management of the water resource in their jurisdiction.
The environment officers need to be proactive and come up with a budget, which can be included in the national budget.
Understaffing remains an outstanding issue that needs to be addressed. Current staffing is at 56%.
District officers are not intentionally overlooked. PEPD makes sure information is disseminated to the districts but there are sometimes bottlenecks in the communication that the information either never gets or gets late to the relevant officers at the district.
Critical baseline data is not well documented. This data may be existing but fragmented or in bits and pieces.
The Local government Act (2010) provides for provision of cooperation for district in the management of cross boarder resources such as water.
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Key Issue Group 15: Development of Legislation and Regulations; standards
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Transfer of EIA when operatorship change (IM23)
2. EIAs are too generic. Standard controls are used more than specific mitigation measures. (IM27)
3. Policy guidance and legal safeguard for the petro industry missing (OM11)
National Oil & Gas Policy 2008
The National Environment Act 1995, Cap 153 of 2000
Meteorology Policy 2011
National Meteorology Act 2012- Established the national Meteorology Authority
Forestry Policy 2001
The Forestry and Tree Planting Act 2003
The National EIA regulations (1998)
National wetlands Policy 1994
National Climate Change Policy – in advanced stages The CC policy has under the mitigation strategy weather and CC monitoring where oil and gas have come out as one of the key areas focusing on the carbon footprint. OPEC countries are contesting – recommending that oil and gas industry should abandon the industry or engage in high level technology.
The Petroleum Act (refining, gas processing, conversion, transportation and storage), Bill,2012
- The national/local content - To be analyzed
The National Employment Policy, 2011
HIV Aids at the Workplace Policy 2009
National Child Labour Policy, 2006
Occupational Safety and Health Act, 2006.
o Wetlands sector strategic plan 2011-2020
o Draft strategic plan for the National Environment Support Services
No Air quality standards – There has been a draft for about 8 years
Gaps in waste management regulations – NEMA has tentative guidelines to consolidate the waste but needs well developed ones.
NEMA is receiving Norwegian support on review Environmental Acts and regulations and draft new ones to ensure that oil and gas are addressed
Wetlands specific law is being formulated
The occupational Act The Act addresses Oil and Gas but in general terms.
Regulation to help in enforcement and compliance are lacking.
Social Development Sector Investment Plan II 2002 ( draft submitted to Cabinet , awaiting approval
The plan is broad does not cater for oil and gas.
Following the review of the policy environment policy, the Act also needs to be reviewed
Existing regulations and guidelines need to be reviewed and where necessary new ones developed
The process for review of the Environemnt Act as started – now procuring consultants
The following regulations are also under review:
1. Regulations and audit 2. Effluent discharge 3. Noise regulation 4. Waste management 5. Air quality (new) 6. Oil spill liability (new)
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Consulted Stakeholders:
Ministry of Water and Environment
The Ministry of Energy and Mineral Development
PEPD
NEMA
Ministry of Gender, Labour and Social Development - Department for compliance and monitoring
Waste management guidelines to be prepared once the regulations are in place
Key Issues Group 16: Land Use and Spatial Planning
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Land use and Physical/spatial planning (IM2)
2. Need for urbanization policy (IM10)
The National Land Use Policy, 2000/2007? (The policy provides guidance on land use and physical planning at national and local levels. The Uganda National Land Policy 2011(draft): The National Environment (wetlands, riverbanks, lake shore management) regulations (2000): - Concerns related to petroleum activities Physical development Plan for the Albertine Graben Prepared and Physical Development Plans for five (5) selected towns/areas within the graben commenced; Albertine Graben Situation Analysis report produced Physical planning Act, 2010: Consulted Stakeholders:
There is under staffing of urban planners at the district.
Land ownership is a hindrance to planning as it is difficult to plan for land that you do not own. Most of the land is privately owned.
Urban areas have been planned for but there has not been adequate implementation of the plans. Furthermore, the whole of the AG as region is yet to be planned for.
Also noted that inter-district collaboration is captured in the Local government Act 2010 (Amended) which should be used to foster inter-district landuse/spatial planning.
There is need for urbanization policy to guide the planning.
There is need to define urban areas according to functionalities and different status:
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- Ministry of Lands, Housing and Urban Development;
Department of Land Use Regulation and Compliance;
Physical Planning Department; - District Local Government ( District Planner, Environmental officer, Land officer) - NEMA; - MWE (Wetlands Department, - Department of Water resources Management); - Department of Fisheries Resources - PEPD - UNRA - International Alert/Coalition of NGOs of oil and gas CISCO
- City
- Municipality/town council
- Growth centers
- Major Settlements
- Minor settlements
Key Issues Group 17: Transboundary and International Issues
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
1. Conflicts with international environmental agreements
2. Security Issues and regional emergency response.
Stakeholder consulted:
The Ministry of Foreign Affairs (not yet approached)
UPDF (not yet approached)
PEPD
Uganda Police
The President’s Office
Potential discussion with:
The Ministry of Foreign Affairs, Uganda Peoples Defense Force (UPDF)
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Key Issues Group 18: Establishment of Transparent Baseline Data. Scientific Basis
Key Issues Relevant PPPs and stakeholders. Laws and Regulations
Outcome of the consultations
3. Strong scientific basis for decisions.
4. Focus on trend analysis as to baseline conditions.
The National EIA regulations (1998) Relevant stakeholder concerns: The National EIA regulations does not adequately provide for establishment transparent baseline data Stakeholders consulted:
Ministry of Water and Environment
NEMA- Department for compliance and monitoring
District Local Government -District Environment Office
Ministry of Tourism, Wildlife and Antiquities: Uganda Wildlife Authority (UWA)
Some EIAs are overly generic and do not conform to appropriate scientific methodology
The duration allotted for EIS reviews by key stakeholders is insufficient to permit exhaustive scrutiny in view of other more substantive work schedules;
Technical staff for example environment officers at District local Government level are often only casually consulted by EIA practitioners even though they are expected to review, validate and monitor EIAs/ EISs.
Some of the technical officials e.g. District Environment Officers in the AG expected to review, validate and monitor EISs do not have the relevant capacity for environmental tasks related to oil and gas exploration, development and production.
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APPENDIX 8: DESCRIPTION OF SCENARIO 2 AND 3
Information about the three scenarios:
Overall description of oil field development
Overall description of Scenario 2 and 3
Scenario overview matrixes for each development phase
1 Oil Field Development Activities
Phase 1 focuses on the early commercialization of crude produced during extended well testing and
early production from the Mputa and Waraga fields (oil) and the Nzizi field (oil and gas) to feed an
Integrated Power Plant (IPP) supposed to produce electricity for the public grid when operational.
Exploration and appraisal drilling is ongoing in various parts of the Albertine Graben. The Ngassa gas
field is drilled from onshore via directional drilling. The Kingfisher oil field is under development and
extensive 3D seismic acquisition is taking place in the area of Murchison Falls.
During Phase 2 the Kingfisher, Mputa and Waraga oil fields as well as the Nzizi oil and gas field are
coming on stream. Kingfisher produces 15,500 bbls/d and Mputa 5000bbls/d. The fields in the
Murchison Falls National Park north and south of the Victoria Nile are under development (Mpyo,
Ngege, Ngiri, Jobi, Jobi East, etc.).
In Phase 3 oil production takes place from the Kingfisher, Kaiso-Tonya, Buliisa and Murchison Falls
areas south and north of the Victoria Nile (Kingfisher, Kanywataba, Mputa, Nzizi, Waraga, Mpyo,
Ngege, Ngiri, Jobi, Jobi East, etc. fields) producing 60,000 bbls/d of crude. The Ngassa gas field in Lake
Albert is under development and exploration activities take place on the DR Congo side.
In Phase 4 all fields in the Kingfisher, Kaiso-Tonya, and Buliisa and Murchison Falls areas are on
stream and Uganda produces 300,000 bbls/d of oil. Pipelines have been constructed crossing the
Victoria Nile to bring crude from the fields to a CPF south of the Victoria Nile. Activities in Lake Albert
have increased with the Ngassa gas field being on stream. Petroleum activities also take place in DR
Congo.
2 Scenario 2 - Refinery Only
This scenario is building on the oil and gas production described above. The produced oil will be used
for refining and selling refinery products as well as running a small power plant (IPP) producing 50
MW for the public grid. The refinery capacity will be gradually increased from start of operations by
end of 2015 with a capacity of 20,000 bbls/d to 300,000 bbls/d capacity by 2026. The development
activities are broken down into the four phases as follows:
Today - end 2015 (Phase 1):
Large scale construction activities are taking place in the region, namely the 20,000 bbls/d refinery at
Kabaale, the regional construction base around Hoima, the necessary supply bases and central
processing facilities and in-field pipelines and pipelines from the fields to the CPFs. Also the
construction and subsequent operation of the IPP takes place and the urbanization plans for Hoima
and other local centers are proceeding. Road construction is ongoing at various locations to facilitate
the trucking of oil and import of necessary equipment, pipe sections and other goods.
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The oil produced during extended well testing will (EWT) be sold to local consumers such as the Hima
and Tororo cement plants and the Namanve power plant. Large scale trucking will take place to bring
oil from the EWT sites to these consumers and goods into the regions.
End 2015 – end 2017 (Phase2):
Phase 2 will see the operation of the 20,000 bbls/d refinery with simultaneous construction activities
to extend the capacity to 60,000 bbls/d. The IPP continues to produce 50 MW electricity but is also
extended to receive more HFO in the next phase. Oil is still trucked from the CPF in the south to the
refinery and IPP, but pipelines are constructed to transport oil from the northern and southern
developments in the next phase. Significant trucking still takes place to transport oil from EWT to
consumers and to transport pipe stacks, refinery modules and equipment from Mombasa to the
Hoima construction base and the refinery site. Furthermore, refinery products are trucked to
consumers.
End 2017 – end 2022 (Phase 3)
Oil is produced from the Kingfisher, Kaiso-Tonya, Buliisa and Murchison Falls areas and all four CPFs
are in operation. From there the oil is transported via the northern and southern pipelines to the
refinery which now produces 60,000 bbls/d. The HFO from the refinery is now piped to the IPP
(formerly trucked) and the IPP produces more electricity for the public grid using only HFO from 2018
onwards replacing the Nzizi gas. Refinery products are trucked to consumers while product pipelines
to transport products from the refinery to Kampala are constructed. Construction activities to
expand the refinery to 120,000 bbls/d from 2023 onwards are also taking place. Furthermore, two
parallel pipelines are under construction to expand the capacity of crude transportation from the
CPFs to the refinery. Pipelines are constructed from the gas fields for onward transportation of gas to
Kampala.
End 2022 – 2030 (Phase 4)
The refinery operates with a capacity of 120,000 bbls/d while an extension up to 300,000 bbls/d is
under construction from 2026 onwards to enable receiving the full production in Uganda of 300,000
bbls/d. All produced oil is used by the refinery to produce refinery products for the EAC and beyond.
All oil is piped to the refinery and refinery products are piped to Kampala and beyond. Petrochemical
industry has developed in the vicinity of the refinery and Uganda has developed into a petroleum
hub servicing also DR Congo. The IPP has been extended to provide more electricity to the public grid
and to take all HFO produced by the refinery. A gas fired power plant and LPG plant has been
constructed to make use of the gas from Ngassa and other gas fields, any surplus of gas is
transported by pipeline to Kampala.
3 Scenario 3 – Export of Crude Only
This scenario is building on the oil and gas production described above. The produced oil will be used
for export of crude to markets outside Uganda. One option is to pipe the oil in a heated export
pipeline to Mombasa. Compressor stations will be located at suitable locations to ensure stable
pumping pressure. Block valves stations will be sectioning the pipeline as necessary with special
focus on protecting sensitive areas, such as rivers, sensitive habitats, etc.
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The other option is to transport the crude in a newly established rail road to Mombasa. Both options
require a tank farm in the Albertine Graben area (assumingly at Kabaale) as well as in Mombasa to
buffer production and transport irregularities.
To make use of the oil from extended well testing a small power plant (IPP) will be constructed to
produce 50 MW for the public grid. The IPP will be fed with produced crude once EWT oil is no longer
available.
a) Option 1 Export pipeline
Today - end 2015 (Phase 1):
Construction activities are taking place in the region, namely the field developments to produce the
oil, the regional construction base around Hoima, the necessary supply bases and central processing
facilities and in-field pipelines and pipelines from the fields to the CPFs. Also the construction and
subsequent operation of the IPP takes place. Road construction is ongoing at various locations to
facilitate the trucking of oil and import of necessary equipment, pipe sections and other goods.
The oil produced during extended well testing will be sold to local consumers such as the Hima and
Tororo cement plants and the Namanve power plant. Large scale trucking will take place to bring oil
from the EWT sites to these consumers and goods and construction material into the region.
The planning for the tank farm at Kabaale and Mombasa, the 300,000 bbls/d export pipeline and
associated compressor stations is proceeding.
End 2015 – end 2017 (Phase2):
About 20,000 bbls/d of oil is produced and trucked to markets outside Uganda. At the same time the
tank farms, compressor stations and 300,000 bbls/d export pipeline are under construction and full
field development is ongoing.
The IPP is fed with oil from Mputa and gas from Nzizi and produces 50 MW for the public grid. The
northern CPFs are under construction to receive oil from Jobi, Jobi East, Mpyo, Ngege, Ngiri and
other fields in the area. Oil transportation from the Kingfisher and Mputa fields is by truck to the tank
farm until the construction of the pipeline from the southern CPFs is operational.
Altogether significant trucking takes place to transport the 20,000 bbls/d of crude to consumers
outside Uganda, the oil from EWT to consumers and to transport pipe stacks and equipment from
Mombasa to the Hoima construction base and the pipe yard.
End 2017 – end 2022 (Phase 3)
Oil is produced from the Kingfisher, Kaiso-Tonya, Buliisa and Murchison Falls areas and all four CPFs
are in operation. From there the oil is transported via the northern and southern pipelines to the
tank farm and from there onwards in the newly constructed 300,000 bbls/d oil export pipeline, which
will transport the oil to Mombasa.
The IPP still produces 50 MW electricity for the public grid, but construction of a gas fired power
plant and an LPG plant has started to make use of the gas from Ngassa and other gas fields. The
amount of truck transportation is still high as equipment and goods for the gas fired power plant and
LPG plant has to be brought into the region. Road construction and maintenance is ongoing.
Pipelines are constructed from the gas fields for onward transportation of gas to Kampala.
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End 2022 – 2030 (Phase 4)
All oil fields and the export pipeline are in operation and 300,000 bbls/d crude oil from the Albertine
Graben is transported to markets outside Uganda. The gas fired power plant is operational and
produces electricity. The LPG plant is also operational and and bottled LPG is sold on Ugandan
markets to reduce the reliance on fire wood.
b) Option 2 Export by railway
Today - end 2015 (Phase 1):
Construction activities are taking place in the region, namely the field developments to produce the
oil, the regional construction base around Hoima, the necessary supply bases and central processing
facilities and in-field pipelines and pipelines from the fields to the CPFs. Also the construction and
subsequent operation of the IPP takes place. Road construction is ongoing at various locations to
facilitate the trucking of oil and import of necessary equipment, pipe sections and other goods.
The oil produced during extended well testing will be sold to local consumers such as the Hima and
Tororo cement plants and the Namanve power plant. Large scale trucking will take place to bring oil
from the EWT sites to these consumers and goods and construction material into the region.
The planning for the constructing the railway line from the Albertine Graben to Mombasa is in
progress.
End 2015 – end 2017 (Phase2):
About 20,000 bbls/d of oil is produced and trucked to markets outside Uganda. At the same time the
construction of the railway line from Kabaale to Mombasa is undertaken and full field development is
ongoing.
The IPP is fed with oil from Mputa and gas from Nzizi and produces 50 MW for the public grid. The
northern CPFs are under construction to receive oil from Jobi, Jobi East, Mpyo, Ngege, Ngiri and
other fields in the area. Oil transportation from the Kingfisher and Mputa fields is by truck to the tank
farm until the construction of the pipeline from the southern CPFs is operational.
Altogether significant trucking takes place to transport the 20,000 bbls/d of crude to consumers
outside Uganda, the oil from EWT to consumers and to construction material for the rail road to the
construction yard and the various construction sites.
End 2017 – end 2022 (Phase 3)
Oil is produced from the Kingfisher, Kaiso-Tonya, Buliisa and Murchison Falls areas and all four CPFs
are in operation. From there the oil is transported via the northern and southern pipelines to the
tank farm and from there onwards via the newly constructed railway to transport 300,000 bbls/d oil
to Mombasa.
The IPP still produces 50 MW electricity for the public grid but construction of a gas fired power plant
and an LPG plant has started to make use of the gas from Ngassa and other gas fields. The amount of
truck transportation is still high as equipment and goods for the gas fired power plant and LPG plant
has to be brought into the region. Road construction and maintenance is ongoing. Pipelines are
constructed from the gas fields for onward transportation of gas to Kampala.
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End 2022 – 2030 (Phase 4)
All oil fields and the export pipeline are in operation and 300,000 bbls/d crude oil from the Albertine
Graben is transported by railway to markets outside Uganda. The gas fired power plant is operational
and produces electricity. The LPG plant is also operational and and bottled LPG is sold on Ugandan
markets to reduce the reliance on fire wood.
4 Scenario Overview Matrices
This section provides a high level qualitative assessment of selected indicators for the various
Scenarios during the specific phases. The categories high, medium, low in the tables below are used
as an indication of differences within each indicator across the phases of the scenarios. They cannot
be used to rank the different indicators.
Phase 1 - Scenario overview matrix (today – end 2015)
Scenario 1 Refinery + export pipeline
Scenario 2 Refinery only
Scenario 3a Export only -via pipeline
Scenario 3b Export only - via railway
Workforce presence - Construction - Operation
High Low
High Low
Medium Low
Medium Low
Road usage and trucking of - goods / equipment - refinery products - EWT oil
High - High
High - High
Medium - High
Medium - High
Conversion of land High High Medium Medium
Waste volumes High High Medium Medium
Disturbance of protected and environmentally sensitive areas and biodiversity
- Refinery/pipeline/rail - Oil field activities
Medium High
Medium High
Low High
Low High
Risk of construction related accidents High High Medium Medium
Risks of accidental events during operations
Low Low Low Low
Pressure on local communities High High Medium Medium
Institutional capacity needs High High High High
Creation of jobs and benefits - Skilled workforce - Unskilled workforce - Benefits
Low High X
Low High X
Low Medium X
X Low Medium X
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Phase 2 - Scenario overview matrix (end 2015 – end 2017)
Scenario 1 20,000 bbls/d refinery + export pipeline
Scenario 2 20,000 bbls/d refinery only
Scenario 3a Export only -via pipeline
Scenario 3b Export only -via railway
Workforce presence - Construction - Operation
High Medium
High Medium
High Low
High Low
Road usage and trucking of - Goods / equipment - Refinery products - EWT oil
High Low Medium
High Low Medium
High - Medium
High - Medium
Conversion of land High High High High
Waste volumes High High High High
Disturbance of protected and environmentally sensitive areas and biodiversity
- Refinery/pipeline/railway - Oil field activities
High High
High High
High High
High High
Risk of construction related accidents High High High High
Risks of accidental events during operations Medium Medium Low Low
Pressure on local communities High High Medium Medium
Institutional capacity needs High High High High
Creation of benefits and jobs - Skilled workforce - Unskilled workforce - Benefits
Medium High X
Medium High X
Low High X
Low High X
Phase 3 - Scenario overview matrix (end 2017 – end 2022)
Scenario 1 60,000 bbls/d refinery + export pipeline
Scenario 2 60,000 bbls/d refinery only
Scenario 3a Export only -via pipeline
Scenario 3b Export only -via railway
Workforce presence - Construction - Operation
High High
High High
Medium Low
Medium Medium
Road usage and trucking of - Goods / equipment - Refinery products - EWT oil
High High Low
High High Low
Medium - Low
Medium - Low
Conversion of land High High Medium Medium
Waste volumes High High Low Low
Disturbance of protected and environmentally sensitive areas and biodiversity
- Refinery/pipeline/railway - Oil field activities
High High
Medium High
Medium High
Medium High
Risk of construction related accidents High High Medium Medium
Risks of accidental events during operations Medium Medium Low Medium
Pressure on local communities High High Low Low
Institutional capacity needs High High Medium High
Creation of benefits and jobs - Skilled workforce - Unskilled workforce - Benefits
High High X
High High X
Medium Low X
Medium Medium X
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Phase 4 - Scenario overview matrix (end 2022 – 2030)
Scenario 1 120,000 bbls/d refinery + export pipeline
Scenario 2 120,000 – 300,000 bbls/d refinery only
Scenario 3a Export only -via pipeline
Scenario 3b Export only -via railway
Workforce presence - Construction - Operation
Low High
High High
Low Low
Low Medium
Road usage and trucking of - Goods / equipment - Refinery products - EWT oil
Low Low -
High Low -
Low - -
Low - -
Conversion of land High High Medium Medium
Waste volumes Medium High Low Low
Disturbance of protected and sensitive areas and biodiversity
- Refinery/pipeline/railway - Oil field activities
Medium Medium
Medium Medium
Low Medium
Medium Medium
Risk of construction related accidents Low High Low Low
Risks of accidental events during operations
Medium Medium Low Medium
Pressure on local communities Medium High Low Low
Institutional capacity needs Medium High Low Medium
Creation of benefits and jobs - Skilled workforce - Unskilled workforce - Benefits
High Medium X
High High X
Medium Low X
Medium Low X
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APPENDIX 9: PETROLEUM INDUSTRY IMPACTS IN
ENVIRONMENTALLY SENSITIVE AND PROTECTED AREAS
Typical primary and secondary impacts related to petroleum activities in environmentally
sensitive and protected areas.
Primary Impacts
PROJECT ACTIVITIES ASPECTS AND POSSIBLE PRIMARY IMPACTS
1. Onshore seismic activity
Site clearance, access roads, basecamp construction, traffic, waste deposition
Erosion, compaction and changes in surface hydrology
Siltation of waterways causing negative impacts on aquatic and marine environments
Disturbance/destruction of local habitats and animals
Fragmentation of habitats
Killing or maiming of wildlife by vehicles
Pollution Short-term disturbance to wildlife from NOx, SO2, VOC emissions, noise and light, vibration
Local damage to flora and fauna
Onshore seismic lines and grids Damage to vegetation and surface hydrology from seismic lines, improperly plugged shot holes, vibroseis machinery etc
Disturbance to wildlife from vegetation clearing, traffic, vibrations/explosions etc
Destruction and fragmentation of habitats
Killing or maiming of wildlife/animals
2. Onshore exploration, appraisal and production drilling
Site clearance, access roads, basecamp construction, traffic, waste
Ref. activity 1
Pollution Ref. activity 1
Produced water, effluent, sewage water, drill cuttings and mud
Contamination of local waterways, water table and ground surface with subsequent impacts on flora and fauna
Oil spills Contamination of local habitats, especially waterways, water table and ground surface with subsequent impacts on flora and fauna
3. Onshore field development
Site clearance, access roads, basecamp construction, traffic, waste
Ref. activity 1 and 2
Pipeline construction Destruction and fragmentation of habitats from the clearing of vegetation
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Interference with wildlife movements and fragmentation
Soil deposition and revegetation Burial of sensitive habitats
Increased erosion, leading to water turbidity, and impacts on organisms and habitats
Revegetation with non-native or invasive species can disrupt ecosystems and displace native species
Pollution Ref. 1, 2 and 3
Produced water, effluent, sewage
water, drill cuttings and mud
Ref. activity 2
Oil spills Ref. activity 2
4. Onshore Production
Operations and maintenance traffic,
waste deposition
Erosion, compaction and changes in surface hydrology
Siltation of waterways causing negative impacts on aquatic and marine environments
Disturbance/destruction of local habitats and animals
Fragmentation of habitats
Killing or maiming of wildlife by vehicles
Impedes revegetation
Land-take and presence Disturbance/destruction of local habitats and animals
Fragmentation of habitats
Pollution Ref. 1-4
Impacts arising from the generation of acid rain
Produced water, effluent, sewage
water, drill cuttings and mud
Ref. 2 and 3
Oil spills Ref. 2 and 3
5. Onshore decommissioning
Project sites, land filing Loss of land-use options
Long-term dispersion of contaminants from unrestored areas
Long-term impacts on drainage patterns
Invasion by non-native species in unrestored areas
Health and safety issues for subsequent users of the area
Removal of temporary infrastructure
(base camps, access roads etc)
Permanent damage to local habitats from wastes, fires and discharges
Erosion and changes in surface hydrology
Traffic Disturbance, maiming and killing of animals
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Secondary Impacts
PROJECT ACTIVITIES ASPECTS AND POSSIBLE PRIMARY IMPACTS
Opening new areas Immediate destruction of local habitats, with wider destruction possible unless access is prohibited (possibly long term)
Increased pressure on flora and fauna populations
Immigration, new settlements and cultivation
Immediate destruction and fragmentation of local habitats, with wider destruction possible unless the number of immigrants decreases over time (possibly long-term and widespread)
Increased pressure on flora and fauna populations
Erosion and changes in surface hydrology/water quality from increased human activities
Hunting/poaching Elimination or decreased populations of local species, possibly leading to extinction of the species
Ecological alterations through removal of keystone species such as predators
Gathering of non-timber forest products
Increased pressure on flora and fauna populations
- Ecological alterations through removal of keystone species
Local commerce with communities
Increased pressure on flora and fauna populations
Elimination or decreased populations of local species, possibly leading to extinction of the species
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APPENDIX 10: RESETTLEMENT POLICY FRAMEWORK
SUMMARY FOR OIL AND GAS ACTIVITIES IN AG
Appendix 10 presents a summary of the resettlement policy framework (RPF) for Oil and Gas
Activities in the Albertine Graben of Uganda that has been prepared as a SEA output contained in a
separate document.
The resettlement policy framework (RPF) addresses land aquisition and loss and/or restrictions of
access to economic assets and resources as they relate to displacement of people in the course of
Oil and Gas Activities in the Albertine Graben. The RPF was prepared as part of the SEA in line with
World Bank Operational Policy, OP 4.12 on Involuntary Resettlement. The main aim of the RPF is to
provide guidance on how to address all impacts associated with the access to land and resources to
be obtained by the project developers and their associated facilities and actors. It is based on
international best practice to ensure that the people living in Albertine Graben and/or depending on
its resources don’t face adverse socio-economic impacts as consequence of the development of the
oil and gas industry in this region such as: Landlessness, Joblessness, Homelessness, Marginalization,
Food Insecurity, Increased Morbidity and Mortality, Loss of Access to Common Property and Services,
and Social Disarticulation.
In order to address these impoverishment risks adequately, this RPF establishes resettlement and
compensation principles and organizational arrangements for the elaboration of further safeguard
documents to meet the needs of people that may be affected by the development of the oil and gas
sector in the Albertine Graben. By the provisions of the RPF, all investment projects will be required
to submit as part of their Environmental Impact Assessments RAPs to the relevant institutions for
approval that specify the footprint of the investments, the magnitude and type of economic and
physical displacement as well as detailed mitigation and compensation measures including a time
bound action plan of their implementation.
In line with the World Bank’s OP 4.12 Involuntary Resettlement and/or the IFC’s Performance
Standards 5, the RPF provides guidance for the screening of oil and gas activities in the Albertine
Graben and establishes parameters for conducting land acquisition and compensation including
resettlement of persons who may be affected during implementation of oil and gas investment
activities in the Albertine Graben, particularly for infrastructure, socioeconomic activities and
conflict-prone activities such as the taking of land for oil and gas exploration, processing and related
production facilities such as cement factories, power stations as well as associated facilitates such as
roads, pipelines etc.
The screening process developed in the framework is to be guided by the following principles:
• Avoiding or minimizing involuntary land acquisition and resettlement, where feasible and
exploring all viable alternatives before resorting to involuntary resettlement.
• Where involuntary resettlement and land acquisition is unavoidable, assistance and sufficient
resources should be provided to the displaced persons with the view to maintaining and/or
improving their standards of living, earning capacities and production levels.
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• Encouraging community participation in planning and implementing land acquisition,
compensation and/or resettlement, and provision of assistance to affected people regardless
of the legality of their land rights or their title to land.
The RPF requires that the implementation of individual RAPs are a prerequisite for the
implementation of project activities causing resettlement, such as land acquisition to ensure that
displacement or restriction to access does not occur before necessary measures for resettlement and
compensation are in place. It is further required that these measures include provision of
compensation and other assistance required for relocation, prior to displacement, and preparation
and provision of resettlement sites with adequate facilities, where required. In particular, the taking
of land and related assets or the denial of access to assets may take place only after compensation
has been paid and where applicable, resettlement sites, new homes, related infrastructure, public
services and moving allowances have been provided to displaced persons. Furthermore, where
relocation or loss of shelter occurs, the policy further requires that measures to assist the displaced
persons are implemented in accordance with the resettlement and compensation plan of action.
The RPF is to be implemented within the legal framework of land access in Uganda that includes:
i. Administrative framework: The Local Government Act 1997
ii. Land Tenure and Ownership /Property Rights: The Uganda Constitution of 1995; The Land Act
1998; The Acquisition Act (1965)
iii. International best practice: World Bank’s Safeguard Policy in Involuntary Resettlement (OP
4.12)
Description of the process for preparing and approving RAPs
To address the impacts under this policy, resettlement and compensation plans must include
rneasures to ensure that displaced persons are (a) informed about their options and rights pertaining
to resettlement and compensation, (b) consulted on, offered choices among, and provided with
technically and economically feasible resettlement and compensation alternatives and (c) provided
prompt and effective compensation at full replacement cost for losses of assets and access,
attributable to the project.
Preparation and submission of the Resettlement Action Plan to the relevant local government
authorities comprises the following steps:
Step 1: The program investment activities to be undertaken and the locations of the investments will
undergo preliminary evaluation on the basis of the objectives of the program.
Step 2: The developer, MEMD, and implementing institutions will approach the communities
impacted through the local government authorities with the view to arriving at a consensus on
possible sites for the type of facility to be adopted.
Step 3: The Local Communities authorities (village councils, parish/sub-county county and district
development committees) will undertake their inter-communal consultations in order to review the
siting of the facility.
Step 4: The environmental and social screening process in conformity with the provisions of the SEA
and the RPF screening process. The process will determine whether any resettlement will be required
at the chosen site and if so whether alternative sites are available and whether any loss of land,
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assets or access to economic resources will occur and therefore the provisions under this RPF been
triggered.
Step 5: On the basis of analysis of the matrix emanating from the two screening processes a final
selection of the optimum site presenting the least negative environmental and social impacts
including resettlement /loss of assets can be made.
Step 6: Where resettlement or loss of assets cannot be avoided, the provisions of the RPF will be
applied and a RAP prepared for each sub project /investment. From this point, the provisions of this
RPF will be utilized up to payment of the compensation package including resettlement support
where appropriate.
The costs associated with this resettlement or relocation will be included in the RAPs for all the
investments. For all Government projects including those implemented by MEMD, the government
through the implementing agency shall provide funds for compensation after identification of the
land and a comprehensive evaluation report done and approved by the Government Valuer. For
private sector led projects, the developer shall provide funds for compensation after full
identification of the land and a comprehensive evaluation by an approved valuer based on rates
equal to or better than those published by the district where the sub project is located.
Basic Contents of a RAP include: description of activity and potential impact; census of displaced
persons if any; eligibility, valuation and compensation for losses; community participation;
environmental protection and management; grievance procedures/ redress; organizational
responsibilities; implementation schedule; arrangements for implementation, monitoring and
evaluation; and budget
The RAP prepared by the sponsor shall be approved by the MEMD if compliance with international
standards and provisions. MEMD might want to seek assistance from a specialised service provided
to assist in the review and approval process.
At this stage it is not possible to estimate the likely number of people who may be affected since
neither the location of oil and gas activities in the area nor comprehensive information on
land/resource ownership/use exists. However, the likely displaced persons can be categorized into
these 4 groups: 1) Affected Individual; 2) Affected Household; 3) Vulnerable Households and 4) the
Host population.
Eligibility Criteria for Defining Various Categories of PAPs
Best practice suggests the following three criteria for eligibility:
a. Those who have formal rights to land (including customary land, traditional and religious
rights, recognized under the Laws of Uganda)
b. Those who do not have formal legal rights to land at the time the census begins but have a
claim to such land or assets provided that such claims are recognized under the Laws of
Uganda or become recognized through a process identified in the resettlement and
compensation plan.
c. Those who have no recognizable legal right or claim to the land they are occupying.
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An important element is the eligibility for community compensation. Elements of the RPF guidelines
on Notification, Valuation Procedures and Entitlements as follows:
Valuations for State Owned land
Valuation for customary land including: Computation of Compensation for land, Crop
Compensation Rates, Compensation Rates for Labour, Compensation for Buildings and
Structures, Compensation for Vegetable Gardens and Compensation for Horticultural,
Floricultural and Fruit trees
Entitlements for compensation based on the eligibility criteria and the various categories of
losses identified in the desk studies and field consultations
Procedure for Delivery of Compensation
Consultation and Public participation
Notification of land resource holders
Documentation of holdings and assets
Complaints / Grievance Resolution Mechanism
Resettlement funding
Resettlement Action Plans
Monitoring Arrangements to assess whether the goals of the resettlement and compensation
plan are met
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APPENDIX 11: THE SEA ORGANISATION Members of the Steering Committee and their Institutions
Name Position Institution
Mr. Dozith Abeinomugisha (Chair)
Ag. Principal Geologist /Exploration
Petroleum Exploration and Production Department, Ministry of Energy and Mineral Development
Eng. Caroline Korutaro (Secretary)
Petroleum Engineer Petroleum Exploration and Production Department, Ministry of Energy and Mineral Development
Mr. Edgar Buhanga Planning & EIA Coordinator
Uganda Wildlife Authority (UWA)
Mr. Waiswa Ayazika Director Environment Monitoring & Compliance Dept.
National Environment Management Authority (NEMA)
Eng. Simon P. Otoi Member/Representative Uganda Association of Impact Assessors ( UAIA)
Mrs. Teddy Tindamanyire Principal Environment Officer
Directorate of Environmental Affairs, Ministry of Water and Environment
Mr. Vincent Byendamira Ag. Commissioner /LURC Directorate of Physical Planning & Urban Development, Ministry of Lands, Housing & Urban Development
Mr. Aventino Bakunda Senior Fisheries Officer Department of Fisheries Resources, Ministry of Agriculture Animal Industry and Fisheries,
Mr. Emmanuel Olet Senior Water Officer Directorate of Water Resource Management
Members of the SEA Team and their areas of expertise
SEA Team Member Field of Expertise
SEA Team Task
Bjørn Kristoffersen International SEA expertise
Environmental management
Extensive knowledge about the petroleum industry
SEA Team leader
Ensure Team engagement and joint SEA participation
Deliver the SEA products with quality on time
Balla Turyahumura NEMA registered environmental practitioner for chemical and process industries; enterprises using or producing or handling chemicals/synthetic materials/ petroleum products; institutional establishments; and waste disposal facilities.
NEMA Certified TEAM
Deputy Team leader
Manage Team participation when Team leader is out of the country
Team participation and deliveries within area of expertise
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SEA Team Member Field of Expertise
SEA Team Task
LEADER/MEMBER of environmental impact assessment and audit teams.
Grace Nangendo Broad knowledge on terrestrial ecology
High environmental and natural resources management expertise
General and oil related environment impact assessment knowledge
Team participation and deliveries within area of expertise
Jane Bemigisha Environmental information, planning and policy expert
International experience in institutional capacity assessment and development
Assistant local team leader
Support to report production
Team participation and deliveries within area of expertise
Dismas Ongwen Archaeology and cultural heritage
NEMA certified EIA practitioner
Team participation and deliveries within area of expertise
Eseza Kateregga Natural resource and Environmental Economics
Team participation and deliveries within area of expertise
Conduct economic analyses of the resulting main impacts
Suggest social corporate responsibility options
Gaddi Katashaya Aquatic resources specialist Team participation and deliveries within area of expertise
Edith Kahubire Sociology and socio-economic specialist
Team participation and deliveries within area of expertise
Timothy Twongo Aquatic ecology and aquatic resources management
Team participation and delivery within area of expertise
Firipo Mpabulungi Land Surveying
GIS and Remote Sensing
Mapping and database compilation
GIS specialist
Map production
Heike Pflästerer International SEA expertise
Environmental and social management
Extensive knowledge about the petroleum industry
SEA Team coordinator
International best practice
Henry Makuma Massa Environmental scientist
Natural resources management
Research Assistant and coordinator local team
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SEA Team Member Field of Expertise
SEA Team Task
Geo-information
Kai Schmidt-Soltau Social and socio-economic expertise
Stakeholder management expertise
Resettlement and compensation issues
Kjell Aalandslid Technical expertise Scenario Analysis
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APPENDIX 12: OUTLINE OF AN INTEGRATED MANAGEMENT
PLAN
The below provides an outline proposal for an Integrated Management Plan (IMP).
Outline of an Integrated Management Plan (IMP)
1 Basic principle for the IMP
The content and significance of the IMP shall be defined in the context of the 12 principles of the
Convention on Biological Diversity (CBD).
Basic understanding that plants, animals and microorganisms are considered at the genetic,
species/community and ecosystem/habitat level and in terms of ecosystem structure and function
(ecosystem approach).
Thorough understanding of the scientific basis through data gap analysis and potential
compilation of new environmental baseline data.
Assessment of impacts and mitigation measures as basis for detailed spatial plans within the area
of interest and as a foundation for specific project assessments and plans at a later stage.
All waste produced to be transported out of the area for permanent treatment/storage according
to best practice.
No activities allowed prior to comprehensive oil spill preparedness in place. This is mainly
connected to crossing the Nile, drilling in Lake Albert, trucking of oil and supply activities in the
lakes/Nile systems.
Involvement and consultation with local communities and other stakeholders such as fishery
interests and petroleum companies.
Development of sound ecosystem protection and biodiversity conservation practices from which
can be chosen the most appropriate measures fitting the specific setting in each case.
2 The holistic ecosystem-based management approach
This section provides an introduction into holistic and eco-system based management of the
protected and environmentally sensitive areas in Uganda.
Environment should be understood as encompassing the physical and biological environment as well
as the social and socio-economic dimensions to ensure that all aspects of relevance are covered in
the IMP.
The IMP shall take a phased approach where the results of one step decide on the further steps.
In general the IMP is supposed to follow the following approach: first establish the factual basis for
the assessment, and then undertake sector-specific impact assessments followed by a cumulative
impact assessment considering all sectors and the vulnerability of particularly valuable areas. During
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all phases stakeholder involvement shall take place. All phases shall lead to the development of the
IMP. The figure below indicates this approach.
The figure below illustrates the overall approach:
The interfaces with national work programs such as the environmental sensitivity atlas, the park
management plans, guiding principles for operations in sensitive areas, etc. shall be defined.
Furthermore, transboundary and international dimensions shall be considered. This includes
consideration of international conventions, agreements and other tools.
3 Objectives and Methodology
The geographical scope of the IMP shall be clearly defined. Furthermore, the foreseen outcomes and
deliverables as part of the IMP development, such as the various factual reports and sector-specific
impact assessments as well as any constraints mapping, GIS and database developments, etc. shall
be established.
The phased approach outlined below should be followed. The process for developing and
implementing the IMP should be defined by NEMA with the support from relevant agencies. A
professional team should be established consisting of representatives of relevant ministries. Local
and international consultants should be engaged as required.
A broad stakeholder engagement has to be ensured.
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4 Baseline conditions
The existing conditions to date shall be described for all relevant aspects. This shall include a
description of physical, biological and social/socio-economic parameters as well as a description of
factors influencing the state of the environment such as anthropogenic factors (e.g. poaching, tree
felling, in-migration and cattle influx) or climate change. Ecosystem values and sensitivities to date
have to be established.
5 Outlook of future ecosystem conditions
Impact assessment of the potential future conditions of the physical and biological environment
without further industrial interference. This should also include consideration of ecosystem services.
6 User interests and associated consequences
Imp act assessments of economic activities shall be undertaken per sector including economic value,
geographical locations, scale, and socio-economic aspects. , future expansion planning, etc.
In addition potential future economic interests shall be identified and forecasted.
Sector shall include e.g. tourism, fisheries, agriculture, forestry, petroleum, mining, etc. as applicable.
7 Conflicts of interest and co-existence
This section shall assess cumulative impacts deriving from sector-specific impact assessments and the
ecosystem assessment described above. Conflicts of interest shall be identified as well as synergies
and co-existence issues. The vulnerability of especially valuable areas should be identified and
assessed.
8 Knowledge-based management
This section shall define the objectives for the management of the area under consideration.
Institutional oversight and monitoring of specific indicators shall be established and prioritized. Focus
shall be given to the overall ecosystem functioning as well as individual species. The monitoring shall
be linked with the Environmental Monitoring Plan already established to ensure efficient use of
resources and data sharing.
Climate change as well as pollution aspects shall be discussed. Furthermore, the risk of accidental
events including oil spills shall be assessed and mitigation measures should be defined.
An assessment of the existing legal framework and institutional capacity shall be provided and gaps
or weaknesses be identified. Recommendations shall be made for improvement if applicable.
9 Sustainable management recommendations
The recommendations should focus on the area-based management approach to protect sensitive
species and ecosystems. The framework for economic activities, particularly petroleum activities,
should be established. This is likely to include the following; management principles, no-go areas and
areas of restricted access, timing issues, sequencing of industrial activities, sustainable resource use,
etc.
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APPENDIX 13: COMMENTS RECEIVED FROM STAKEHOLDERS
DURING THE VALIDATION PHASE
Comments have been received verbally during the Validation Workshop on 23. May 2013 and in
writing until the end of the commenting period, 30. May 2013.
The comments are considered as follows:
Relevant minor comments are incorporated into the final SEA report without further
reference.
Other comments are listed in the below table. Some are incorporated into the report with a
reference to the relevant chapter given in the table. Others are not incorporated and a
response from the SEA Team is given in the table.
Comment SEA Team Response
Time frameworks should be given in the SEA to
guide the review and implementation.
This issue is not part of the mandate for the SEA and should
be covered in the Implementation Plan.
Changing policy/legal provisions is a long-term
process and therefore interim means should
be considered incl. gap analysis of the existing
regulatory framework.
This issue is not part of the mandate for the SEA and should
be covered in the Implementation Plan.
Linkages to existing planning frameworks such
as the sectoral strategic plans, NDP, Vision
2040, etc. is not sufficiently provided.
The NDP is referred to in Chapter 4.6.2.
The strategic plans for the sectors are added in the same
chapter. The detailed linkage between recommendations
/actions in these plans and the SEA needs to be established
in the Implementation Plan.
The SEA should have a stronger focus on the
holistic approach in the socioeconomic
analysis.
The concluding advice in Chapter 7 has been strengthened
regarding long-term socioeconomic benefits.
The SEA should emphasize on investing in
people.
The concluding advice in Chapter 7 has been strengthened
regarding long-term socioeconomic benefits.
Positive impacts should be highlighted. The Scenario Analysis clearly reveals positive as well as
negative effects.
There is a need for an implementation
monitoring plan
Monitoring is covered in Chapter 7 and will be taken further
in the Implementation Plan.
Oil and gas issues and EIAs are not
understandable for local people.
This is not part of the mandate of the SEA.
The SEA should address the cumulative
impacts of petroleum developments.
This is covered in the Scenario Analysis.
The CSOs should have a role in monitoring the
implementation of the SEA.
The role of the CSOs has to be emphasized in the
Implementation Plan.
Costs and a financing strategy for the SEA
recommendations should be outlined in the
This is not the mandate of the SEA and should be part of
the Implementation Plan.
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SEA.
The legal foundation for SEA is not clear. The SEA is initiated by the Government. Today there is no
legal requirement to undertake a SEA.
The follow-up of the SEA should be
coordinated among relevant ministries
managed by the Prime Minister’s office.
This should be further addressed in the Implementation
Plan.
Air quality issues are not sufficiently covered
by the SEA.
The Key Issues Integration Matrix in Appendix 7 with Key
Issues Group No. 8 deals with air emissions and
recommendations.
The existential value of biodiversity and
environmental sensitive areas are not explicitly
addressed by the SEA.
Biodiversity conservation and ecosystem values are
considered in the SEA in various (e.g. Chapter 5, 6, 7 and
Appendices).
Ecosystem services are not adequately
addressed.
Ecosystem services are explicitly mentioned in the
Integrated Management Plan outline in Appendix 12. In
addition, the issues has been added to the
recommendation of Key Issues Group No. 1 in Chapter 5.
Habitat degradation is not explicitly
addressed.
Covered by the SEA.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.2.
These recommendations should be further considered in
the Implementation Plan.
The Land Policy has not been outlined as a
relevant PPP.
The land policy is mentioned in Key Issues Group 16 of
Chapter 5 and in Appendix 7 under other relevant PPPs.
There is a contradiction between the Land Act,
the Land Acquisition Act and the Constitution
of 1995. This is not considered in the SEA.
This issue should be considered in the Implementation Plan.
The SEA states that there is no position of
valuer at local government level.
This statement is changed in the table in Appendix 7.
International boundary migration is not well
captured in the SEA.
This is covered by the SEA.
Compensation guidelines and procedures are
not known by the affected persons.
Information is added to Key Issues Group No. 2 in
Chapter 5.
The resettlement action plan is not publicy
available which triggers speculation.
This is not the mandate of the SEA.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.3.
These recommendations should be further considered in
the Implementation Plan.
Co-existence with archaeology and cultural
heritage has not been sufficiently addressed.
The SEA covers archaeology and cultural heritage in depth.
The issue is also considered to be a strategic aspect, see
Chapter 6.3.4.
The Culture Policy of 2006 and the Traditional
Rulers Bill (2010) have not been reviewed.
This issue should be considered in the Implementation Plan.
Sharing of revenues with traditional rulers has
not been adequately outlined.
This issue should be considered in the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.4.
These recommendations should be further considered in
the Implementation Plan.
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UNBS has not been consulted UNBS will be consulted in the Implementation Phase
The Dutch disease concept has not been
analysed.
This has been covered by the Scenario Analysis in
Appendix 3.
Leadership on capacity building is with the oil
companies instead of Government.
This is not the mandate of the SEA but should be
considered in the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.5.
These recommendations should be further considered in
the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.6.
These recommendations should be further considered in
the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.7.
These recommendations should be further considered in
the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.8.
These recommendations should be further considered in
the Implementation Plan.
Comment and recommendations made by the
Joint Position by the CSOs and DLGs in Chapter
2.9.
This comment and the recommendations should be further
considered in the Implementation Plan.
Waste management guidelines and
mechanisms to manage waste are missing.
Developing guidelines for waste management has not been
the mandate of the SEA. The SEA considers waste
management as a key issue (key issues group no. 9) and
contains recommendations for waste management on a
strategic level.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.10.
These recommendations should be further considered in
the Implementation Plan.
Laboratories for water analysis should be
established also outside Entebbe.
Establishing laboratories has been recommended in the
SEA, their locations are however not part of the mandate.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.11.
These recommendations should be further considered in
the Implementation Plan.
There are no existing response units for oil spill
contingency and there is no provision for
community involvement.
The SEA recommends the finalization and implementation
of the NOSCP, which includes involvement of all relevant
stakeholders.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.12.
These recommendations should be further considered in
the Implementation Plan.
The recommendations for Infrastructure
development and transportation of crude,
products and construction material do not
include UWA.
This is now integrated into the SEA.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.13.
These recommendations should be further considered in
the Implementation Plan.
Institutional capacity building
recommendations do not include other
institutions such as the Ministries of Justice,
Labour, Education, etc.
This issue is now integrated into Key Issues Group No. 13 in
Chapter 5 and 7.
The SEA does not consider proposed new
institutions such as the National Oil Company,
This issue is covered in the SEA report in Chapter 4.5.
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Petroleum Authority.
Local governments do not have a clear
structure and no link with the Ministry of
Energy.
This issue should be considered in the Implementation Plan.
The capacity gap at the local government
includes expertise, resources, etc. and these
should be improved.
This issue should be considered in the Implementation Plan.
The NOGP outlines an array of stakeholders
including civil society and others but the SEA
does take cognizance of them.
The SEA adequately covers all stakeholders mentioned.
EIAs are still too complex and the input of local
communities is thus not feasible.
A recommendation has been added in Chapter 5.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.14.
These recommendations should be further considered in
the Implementation Plan.
The resource envelope of the districts does not
allow to allocate meaningful resources to the
District Environment Offices.
This issue is covered in Key Issues Group No. 14 in
Chapter 5.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.15.
These recommendations should be further considered in
the Implementation Plan.
The SEA has not undertaken a rigourous
assessment of international instruments and
standards.
This is not the mandate of the SEA and should be part of
the Implementation Plan.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.16.
These recommendations should be further considered in
the Implementation Plan.
The SEA does not sufficiently consider the right
of people to live in well planned areas.
The SEA discusses urban and spatial planning and concludes
that the planning of urbanization has to be advanced in line
with petroleum development.
The SEA does not discuss the Environmental
Sensitivity Atlas.
The SEA considers and makes linkages to the Environmental
Sensitivity Atlas.
Recommendations made by the Joint Position
by the CSOs and DLGs in Chapter 2.17.
These recommendations should be further considered in
the Implementation Plan.
Other neighbours than DRC should also be
considered in the Sea.
The Scenario Analysis considers also South Sudan.
The SEA should also consider district boundary
concerns.
The SEA process has not identified district boundary
concerns as an issue and therefore this has not been taken
into account.
Concerns with neighbouring countries does
not include resource-based issues.
This is mentioned in Key Issues Group No. 17 in Chapter 5.
The SEA should have a lifeline and provision
for regular updating.
The SEA proposes that the document is regularly updated.
This should be further considered in the Implementation
Plan.
There is a need for scientific standards for
parameters such as water, air, noise, etc.
The SEA makes recommendations for establishing the
relevant regulations.
The entire AG should be included in the SEA The scope for this SEA was only covering Exploration Areas
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assessment. 1, 2 and 3A.
A Steering Committee should be established
for implementation of the SEA.
This should be part of the Implementation Plan.
The SEA should make recommendation how to
avoid the oil curse.
The recommendations of the SEA are tailored to avoid the
oil curse.
The SEA should have more focus on water
management including the sources of water.
Water management in general is addressed and a separate
point has been made in the concluding advice in Chapter 7.
Details on water consumption, etc. are to be covered by
specific EIAs.
The SEA should describe the history of the
local people and how they have suffered in the
past.
This is not the mandate of the SEA.
Consider gender mainstreaming in the SEA. Gender aspects are identified as an issue in Table 2 of
Appendix 6 but have not been carried forward as a key
issue.
The role of PEPD is not clear, is it a promoter or
a regulator.
This is not within the mandate of the SEA.
CSOs should have been a member of the
Steering Committee for the SEA.
This is not within the mandate of the SEA team to decide
upon.
The SEA has been initiated too late and its
relevance was therefore questioned.
It is an advantage that the SEA has been undertaken at this
stage because the stakeholders now have a basic
understanding of the petroleum industry.
The SEA has provided many recommendations
but they should be prioritized.
The SEA process has narrowed down the many issues
through a prioritization process. Further prioritization will
be part of the Implementation Plan.
The gap between rich and poor will increase
with the petroleum. Affirmative action is
necessary to protect the vulnerable.
Vulnerable groups have been mentioned in the SEA. Further
recommendations should be covered in the
Implementation Plan.
The risks of the frontline communities have to
be considered in the equity distribution.
This is not the mandate of the SEA.
Land laws are not adequate and land
management has to be considered.
This issue is covered in Key Issues Group No. 16 in
Chapter 5.
There should be capacity building also for the
CBOs to enable their participation in the
management of the petroleum sector.
This issue has been added to Key Issues Group 13 in
Chapter 5.
Cultural leaders require a line of financing to
undertake their role.
This is not the mandate of the SEA.
Cultural awareness training for people coming
from the outside is required to avoid tension.
This is not the mandate of the SEA.
Some of the scenarios are inaccurate and not
consistent with the conceptual development
plan to be finalized between the GoU and the
Operators
The scenario approach is used to establish a basis to
identify typical issues and to assess strategic aspects.
Scenarios are reflecting possible future situations and are
not meant to be consistent with the latest plans. New
scenarios will be developed according to needs in the
future.
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The SEA attempts to identify impacts and the
significance of impacts where only the
integrated ESIA could possibly do so.
The SEA is limited to overall identification and reflection on
impacts. Further details are expected to be part of project
specific ESIAs.
The SEA is not addressing climate change. Climate change is included in the Issues Register and
Analysis, Appendix 6, table 1, but is not identified as Key
Issue now. The reason is that the issue is not considered
urgent in the context of this SEASEA.
The SEA does not acknowledge the ongoing
basin wide planning involving the GoU and the
operators.
A basin wide development plan was assumed to be an
important basis for the SEA. This plan was however never
presented to the SEA Team.
The report falls short on addressing details of
international best practice.
It is not within the mandate of the SEA to present details on
international best practice. The importance of following
such practices is however focused throughout the report.
The report is not addressing the finite nature
of the oil and gas resources and the long term
impa
This issue is covered in the table 4 in Appendix 6, but is not
considered significant in the context of this SEA. The issue is
however very important in a long term perspective.
A specific frequency should be listed for
revision of the plan.
This should be addressed in the Implementation Plan
Lack of baseline data will be covered during
ongoing studies and connected to specific
ESIAs.
The SEA is focusing on the fact that significant data gaps
should have been filled at an earlier planning stage to be
used in basin wide planning, the SEA and other large scale
planning.
The information about the refinery is incorrect
and does not take into account other possible
locations.
The SEA is based on available information. It is not the
mandate of the SEA to speculate on potential alternative
plans.
There is no mention of oil spill response
capacity building.
This issue is covered in Key Issues Group 11,
recommendations.
There is no mention of integrated ESIA for
infrastructure development.
This issue is added to Key Issues Group 12,
recommendations.
The scope of ongoing baseline studies done by
the oil industry does not seem to be
acknowledged in the SEA
Such studies will be part of the gap analysis which need to
be integrated in the Implementation Plan.
It is not clear how recommendations to slow
down activities can be understood within the
context of existing agreements.
The SEA is the procuct of an independent SEA Consultant
Team. Any recommendations which are in conflict with
existing agreements have to be evaluated and followed up
by the GoU and should be addressed in the Implementation
Plan.
Lake transportation activities are not
adequately addressed in the SEA.
This important activity is added to the assessment of
fisheries in chapter 6.3.1.
Too limited attention on tourism
beinginfluenced by oil infrastructure
Issue strengthened in chapter 6.
The SEA should establish a framework for the
management of cumulative impacts.
To be addressed in the Implementation Plan.
The SEA should identify and present the
measure of success related to each
To be addressed in the Implementation Plan based on a
priority list of actions.
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recommendation.
Many recommendations will have influence on
other sectors. How to incorporate their needs
into sector specific PPPs etc.
To be addressed in the Implementation Plan.
There is a need to carry out an inventory of
greenhouse gases and monitoring as basis for
impact assessment and mitigation measures
Reference is made to the aspect of climate gases already
covered above.
There is not much consideration of fish species
for conservation or cultural importance (e.g
Engara).
These aspects are adequately highlighted (to the level of
the SEA) in various sections of the Report e.g. in Chapters
3.2, 6.2 and 6.3.
The linkage between the SEA and other
planning frameworks is very hazy if highlighted
at all.
The SEA is addressing the key strategic plans according to
consultations with relevant stakeholders.Plans which are
not highlighted in the SEA are also important and should be
further followed up in the Implementation Plan. This
limitation is now highlighted in chapter 4.6.2. Information
related to two mentioned Strategic Plans in chapter 4.6.2 is
added.
The Inception Report should be published as it
is referred to in the SEA.
This is the responsibility of PEPD.
There is little mention of the two Ramsar sites,
namely Lake George Ramsar Site and
Murchison Falls Albert Delta Ramsar Site.
The Ramsar sites are adequately mentioned in various parts
of the SEA, e.g. in Chapters 3.3.3 and Key Issues Group 1.
The SEA requests capacity building for district
local governments but should also include the
Central Government.
The key issues have been identified as part of the SEA
process.
The correct title of the Ramsar Convention
should be mentioned.
The full name of the Convention on Wetlands of
International Importance especially as Waterfown Habitat
(Ramsar Convention) has been included in the SEA.
The executive summary should include the
recommendations and what is needed to fulfill
the requirements of the SEA.
This cannot be part of an Executive Summary and should be
addressed in the Implementation Plan.
It is one of the key obligations for Uganda to
maintain the ecological character of the
Ramsar sites.
This is not part of the mandate of the SEA.
Uganda’s obligations under international
Conventions and agreements (e.g. Ramsar or
CBD) should be added in the executive
summary.
Relevant international Conventions and multi-lateral
agreements are listed in Appendix 5 of the SEA.
The main goals of the SEA in the executive
summary should be refined.
The main goals are stated in Chapter 1 while an assessment
whether the objectives are met is given in Chapter 7.4.
Religious organizations should be considered
in the SEA
Faith-based organizations have been added in Chapter
6.4.2.
Agriculture has not been covered adequately Agriculture is mentioned throughout the SEA, e.g. in
chapters 3.4.2 or 6.3.3 but has now also been added as a
co-existence issue in Chapter 7.6.
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There are more cultural institutions than only
the Bunyoro Kingdom.
Cultural institutions include Bunyoro, Acholi and Alur
Kingdoms in the study area. This has been added
throughout the SEA, e.g. in Chapters 3.1, 3.3 and 6.3.4.
The text on the Petroleum (Exploration,
Development and Production) Bill, 2012 is
outdated.
The text has been amended to reflect the enacting of the
recent Petroleum (Exploration, Development and
Production) Act 2013, e.g. in Chapter 4.1.
An Implementation Plan should be part of the
SEA.
Appendix 14 has been added providing an outline of
implementation planning.
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APPENDIX 14: IMPLEMENTATION PLANNING
TOWARDS IMPLEMENTATION PLANNING FOR SEA RECOMMENDATIONS
The Strategic Environmental Assessment of the Albertine Graben presents a set of recommendations
connected to the regulatory framework and various policies, plans and programmes cutting across
sectors and to selected high-level strategic aspects. In order to ensure that the recommendations
are implemented efficiently, there is need for structured implementation planning involving all the
relevant sectors. The responsibility of implementation planning rests with the relevant sectors who
have the knowledge and understanding of the available resources, capacities and timeframes of the
wider national planning frameworks. Inter-sectoral analysis and implementation and prioritization of
SEA recommendations is envisaged. The following provides key considerations for implementation
planning of the SEA recommendations.
The following are key considerations for successful implementation of the SEA recommendations:
1- Understanding of SEA process, outcomes and synergies: This SEA process was the first for oil
and gas operations in Uganda. Although ample participation was realized from the relevant
stakeholders, there was limited time to build sufficient awareness and understanding of the
process identified for Uganda (out of many other global processes) for the unique and
complex environmental issues in the AG. The implementation planning should, therefore
include preliminary awareness seminars and explanation of the approach, outcomes and
disciplinary as well as regional and local context to cultivate common understanding of the
SEA and therefore successful implementation
2- Clear definition of roles and responsibilities: This SEA report highlights over 35 institutions
representing various sectors (Appendix 4) that were involved in the development of the SEA
but many others will come on board during implementation. Through a stakeholder
engagement process, the SEA achieved initial mobilization of stakeholders for ownership and
future implementation. However the main challenge will be ensuring that each stakeholder
institution understands clearly their roles and responsibilities as well as reporting and
accountability structures to minimize conflicts and negative implications to implementation.
This requires that stakeholder partnership emphasizes communication pathways for relevant
stakeholders and a need for a communication platform to precede implementation.
3- Capacity for coordination, implementation and monitoring: Government has taken various
steps in strengthening the capacity of the institutions responsible for the implementation of
the SEA but responsibilities keep evolving at a fast rate as the industry also develops. The
pace of oil industry development has not been commensurate to the capacity of the
coordinating institutions and the issue will be more important for implementation and
monitoring of the SEA recommendations. Capacity for management controls through
effective coordination implementation and monitoring needs to be built for all sectors that
are envisaged to implement the Sea. Therefore capacity for management control in the
areas of leadership and management expertise including best practice program planning
and management (financial and non-financial) and risk management is critical for leading
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institutions especially PEPD and NEMA in order to steer the coordination, implementation
and monitoring.
4- Investment framework: A key element of the implementation plan will be an investment
framework that will define resources including personnel, equipment, operational costs, etc.,
required for recommended actions, prioritization, scheduling, budgetary costs and
mobilization strategy. Connected to the investment framework will be key actors or
responsibility for implementation elaborating both primary and secondary responsibilities (in
reference to item 3 and 4 above). The process of implementation planning will, therefore,
determine resources available and needed as well as the mechanisms for resources
management availability over the period of implementation.
5- Monitoring , evaluation and improvement framework: To ensure efficient and effective implementation, a monitoring, evaluation and improvement framework will be pertinent. Monitoring is to involve systematic collection of data and information on tracking implementation progress based on clearly defined indicators and milestones. Evaluation activities will be considered for checking to see if implementation is on course or if corrective measures have to be taken.
According to the concluding advice of the SEA, a specific Implementation Plan should be developed to ensure structured and successful implementation of the SEA recommendation within a given timeline.