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BURNSiDE

Uganda Electricity Transmission Company limited

Bujagali Interconnection Project Executive Summary

Prepared by

R.J. Burnside In ternat ional L imi ted 292 Speedvale Avenue West, Uni t 7 Guelph ON N1H 1 C 4 Canada

In association with

Dil lon Consulting Limited, Canada Ecological Writ ings #1, Inc., Canada Enviro and Industr ial Consult (U) Ltd., Uganda Frederic Giovannetti, Consultant, France Tonkin & Taylor In ternat ional Ltd., N e w Zealand

December, 2006

File No: I - A 1 0 0 4 5

The mater ial in this report ref lects best jud&ement in light o f the information available at the time o f preparation. Any use which a third party makes of this report, or any reliance on or decisions made based on it, are the responsibilities of such third parties. R.J. Burnside International Limited accepts no responsibility for damages. if any, suffered by any third party as a result of decisions made or actions based on this report.

R.J. Burnside In ternat ional L imi ted 1.A 10045

Uganda Electricity Transmission Company l imi ted

Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary December, 2006

Dr. Patr ick Mwes igye Cer t i f ied Environmental Practioner Certif icate No. C C / EIA / 034 / 06 In Country SEA Team Leader Env i ro and Indust r ia l Consult (U) Ltd., Uganda

Mr. Robert Tur land Cer t i f ied Fore ign Environmental Practioner Certif icate N o . C C / F002 / 06 SEA Project Manager D i l l o n Consult ing L imi ted, Canada

Dr. B r e t t Og i lv ie Cer t i f ied Fore ign Environmental Practioner Certif icate No. C C / F003 / 06 SEA Specialist / Natura l Resources Team Leader Tonk in & Tay lo r International Ltd., N e w Zealand

Mr. Frederic D. Giovannett i Cert i f ied Fore ign Environmental Practioner Certif icate N o . CC / FOOl / 06 Socio-Economic Team Leader and Resettlement Specialist Frederic Giovannetti, Consultant, France

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Table of Contents

... Glossary ...................................................................................................................................... III

Foreword ....................................................................................................................................... v

1 . 0

2.0

3.0

4.0

5.0

6.0

7.0

8.0

Introduction ...................................................................................................................... 1 Project Overview and History ..................................................................................... 1 1.1

1.2 SEA Process and Report ............................................................................................. 5

Regulatory Requirements .................................................................................................. 7

Project Setting .................................................................................................................. 9 3.1 Project Setting .......................................................................................................... 9 3.2 Biophysical Conditions ............................................................................................... 9 3.3

Project Alternatives ........................................................................................................ 14 4.1 4.3 Description of Interconnection Options ...................................................................... 14 4.4 Deta i led Route Selection and Optimisation ................................................................ 16 4.5 Substation Site and Optimization .............................................................................. 22

Project Description ......................................................................................................... 26

Public Consultation and Disclosure ................................................................................. 32

6.2 Grievance Management Mechanisms ......................................................................... 38 6.3 Disclosure Program .................................................................................................. 39

7.1 Compliance Screening .............................................................................................. 40 7.2 Developmental and Community Benefits .................................................................... 40 7.3

Social and Environmental Action Plan ............................................................................ 48

8.2 Relationship of the SEAP to other Project Plans ......................................................... 49 8.3 Implementation of the Social and Environmental Action Plan ....................................... 49

8.3.1 EPC Contractor's Commitments and Resourcing .............................................. 49 8.3.2 8.3.3 Social and Environmental Auditing and Reporting ............................................ 5 2 8.3.4 Change Management ..................................................................................... 53

Responsibilities for Environmental Monitoring Measures ............................................. 54

Socio-economic and Cultural Conditions .................................................................... 11

Existing Electricity System and Need for the Bujagali Interconnection Project .............. 14

6.1 Consultation Program .............................................................................................. 32

Impact Identification. Management and Monitoring ....................................................... 40

Key Project Issues and Net Ef fec ts Analysis ............................................................. 41

8.1 Environmental Management ...................................................................................... 48

Reporting Lines and Decision-Making ............................................................. 52

Responsibilities for Social and Environmental Mitigation Measures ............................. 53 8.4 8.5

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ES-ii Uganda Electricity Transmission Company l i m i t e d Bujagali Interconnection Project

Social and Environmental Assessment . Executive Summary December. 2006

Tables

Table ES-1: Table ES-2: Table ES-3: Table ES-4:

Consultation Act iv i ty Summary ........................................................................ 3 6 Summary of Key Issues and Responses ............................................................. 37 Summary o f Impact Mi t igat ion and Ef fects Monitoring Activi t ies ........................ 4 2 Responsibilities. Timing and Budgets for Social and Environmental Actions ......... 5 3

Figures

Figure ES-1

Figure ES-3 Figure ES-4

Location o f the Bujagali Interconnection Project .................................................. 3

Location of AES NP Route and Optimized Route ................................................ 2 0 Layout o f Kawanda Substation ........................................................................ 2 4

Figure ES.2

Figure ES-5 Figure ES-6

Preferred Power System Option (3aR) .............................................................. 18

Transmission Line Routes and Land Use ............................................................ 28 Public Consultation and Disclosure Activi t ies .................................................... 3 4

Figure ES-7 SEAP Component Plans ................................................................................... 5 0

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December, 2006

Glossary

AESNP AfDB A01 APRAP BEL BIU CBO CDAP CFR DEG D R C EA EIB EIA E M M P EPC ES EU FSL GoU HPP IBRD I C S I D IDA I E S A IFC ILO I P IUCN km kV LVBC LVDP m AMSL MDE MFL MIGA M o H M O L MRF M W NBI NEMA

AES N i l e Power A f r i can D eve1 opmen t Bank Area o f Inf luence Assessment o f Past Resettlement Ac t i on P lan Bujagal i Energy Limited Bujagal i Implementation Unit Communi ty Based Organisations Communi ty Development A c t i o n Plan Central Forest Reserve Deutsche Investit ions und Entwicklungsgesellschaft mbH Democratic Republic o f Congo Environmental Assessment European Investment Bank Environmental Impact Assessment Environmental M i t iga t ion and Mon i to r i ng Plan Engineer, Procure, Construct Executive Summary European U n i o n Full Supply Leve l Government o f Uganda Hydropower Project International Bank o f Reconstruction and Development International Centre fo r Settlement o f Investment Disputes International Development Association Integrated Environmental and Social Assessment Guidelines International Finance Corporation International Labour Organisation Interconnection Project International U n i o n fo r the Conservation o f Nature Ki lometres K i l o v o l t s Lake Vic tor ia Basic Commission Lake V ic to r ia Development Programme Metres Above Mean Sea Leve l M a x i m u m Design Earthquake M a x i m u m F lood Leve l Mul t i la tera l Investment Guarantee Agency Ministry o f Heal th Minimum Operating Leve l Environmental M i t iga t ion Plan Minimum Residual F l o w Megawatt N i l e Basin In i t ia t ive Nat ional Environment Management Author i ty

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Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary

December, 2006

NGO N i l e C O M N i l e SEC N i l e TAC O E D OPS PCDP P P A H SEA SEAP SEO S I A SSEA T A S O TBD U E T C L WBG

Non-Governmental Organisation Counci l o f Min is t r ies N i l e Secretariat Technical Advisory Committee Operations Evaluation Department Operational Policies Public Consultat ion and Disclosure P lan Pol lu t ion Prevention and Abatement Handbook Social and Environmental Assessment Social and Environmental Ac t i on Plan Site Environmental Of f i cer Strategic Impact Assessment Guidelines Strategic/Sectoral, Social and Environmental Assessment The Aids Support Organisation T o B e Decided Uganda Elect r ic i ty and Transmission Company L i m i t e d Wor ld Bank Group

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Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary December, 2006

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Foreword

The Bujagal i Interconnection Project i s a proposed high voltage electr ical power transmission system that w i l l interconnect Bujagal i Hydropower Project t o the national electrical grid. The project sponsor i s the Uganda Elect r ic i ty Transmission Company Ltd (UETCL).

The Project i s closely associated with Bujagal i Energy Limited’s (BEL) Bujagal i Hydropower Project (HPP), wh ich i s a proposed 250 M W hydropower fac i l i ty on the Vic tor ia N i l e .

This i s the Executive Summary o f the Social and Environmental Assessment (SEA) for the Bu jaga l i IP that i s be ing disclosed by BEL on beha l f o f UETCL. This document provides a non-technical synopsis o f the environmental and social assessment documentation for the project.

Readers are advised to consult the SEA i t s e l f for detailed technical information, inc lud ing references and sources, supporting the summary conclusions included in this non-technical synopsis.

That technical documentation i s presented in two volumes:

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The Social and Environmental Assessment (SEA) Report; and, The Appendices to the SEA.

UETCL has begun an integrated Social and Environmental Ac t i on Plan (SEAP) that wi l l be updated and maintained throughout the l i f e o f the project. UETCL wi l l be consulting upon and prov id ing regular updates to i t s integrated SEAP going forward. The Social and Environmental Ac t ion Plan wi l l be a ‘living’ document that i s revised regularly as pro ject development proceeds.

The SEAP i s designed to define the specific responsibil i t ies o f UETCL, i t s contractors and sub-contractors, as w e l l as any third parties, where applicable, to the eff icient and responsible management o f social and environmental activit ies associated with the project. I t wi l l f o rm one basis fo r UETCL’s covenants with i t s lenders as w e l l as prov ide a vehicle to demonstrate i t s compliance with regulatory requirements.

As updates are prepared, the SEAP wi l l be consulted upon regularly with affected stakeholders. Progress on the contents and implementation o f the SEAP wi l l be publicly reported upon, as well, at regular intervals o n a go- forward basis.

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December, 2006

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1.0 Introduction

1.1 Project Overview and History

The Bujagal i Interconnection Project (“the Project” or IP) i s a proposed h i g h voltage transmission system designed to connect the proposed Bujagal i Hydropower Project (HPP) to the national grid (Figure ES-I ) . The pro ject sponsor i s the Uganda Electricity Transmission Company Ltd (UETCL), a publ ic l im i ted company 100% owned by the Government o f Uganda (GoU).

The IP, shown wi l l invo lve the construction and operation o f

A 132kV switchyard on the west bank o f the Victoria N i l e adjacent t o the hydropower facil i ty (previously approved by NEMA in i t s 220/132 kV configuration as part o f the Hydropower EIS, Atkins 1999); A 132 kV l ine south f rom the Bujagali switchyard to the existing 132 kV l ine from Nalubaale to Tororo (length - 4.5 km), where that l ine wi l l be severed; A second 132 kV l ine extending north f rom the severed Nalubaale-Tororo l ine to interconnect with the Bujagali switchyard (length - 5 .O km); A new 220 kV capacity transmission l ine operating at 132 kV f rom the Bujagali switchyard to a new substation at Kawanda, north o f Kampala (length 70.5 km); A new substation at Kawanda; and, A new 132 kV l i ne f rom the Kawanda substation to the existing 132 kV substation at Mutundwe in southern Kampala (length - 17.5 km). Internal improvements (i.e. new bay and switching gear) at Mutundwe to accommodate this new 132 kV l i n e wil l also be required.

Development o f the HPP was in i t ia ted by AES N i l e Power Ltd., (“AESNP”) in the late 1990’s. At that time the IP was bundled together with the HPP as one project. The Social and Environmental Assessment (SEA) documentation prepared by AESNP for the integrated project was approved by the Government o f Uganda’s (GoU) Nat ional Environmental Management Author i ty (“NEMA”) in 1999/200 1 and by the W o r l d Bank, IFC and A f r i can Development Bank Boards in December 200 1.

In 2003 AESNP withdrew, leading the G o U to assign the IP to UETCL, and init iate an international bidding process for the HPP project. In 2005 Bu jaga l i Energy Limited (BEL) was selected as the preferred bidder and entered i n to a power purchase agreement and an implementation agreement with the GoU. BEL expects to complete financing and start construction in 2007. On that timeline, construction wou ld be completed with f i r s t power f l ow ing in to the Nat ional Grid in 2010.

BEL i s a project-specific partnership o f SG Bu jaga l i Hold ings Ltd. (a who l l y owned aff i l iate o f Sithe Global Power, L L C ) and IPS L im i ted (Kenya). U E T C L has

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Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary December, 2006

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contracted BEL t o assist with pro ject p lanning and to coordinate the preparation o f the SEA Documentation.

1.2 SEA Process and Report

The Social and Environmental Assessment (SEA) was completed in compliance with the requirements o f the G o U and the pol ic ies and guidelines o f the Af r i can Development Bank, the ma in International Financial Inst i tu t ion (IFI) that i s expected to finance the project. The purpose o f the SEA i s t o ensure that the project i s designed and developed in a manner that min imizes negative social and environmental effects while max imiz ing pro ject benefits. The SEA Report describes the resu l t s o f the SEA process. The SEA Report i s being made available to stakeholders for their review.

UETCL conducted the SEA according to Terms o f Reference (TORS) that were approved by G o U (NEMA) and were made available to IF1 representatives, project affected people, NGOs and the general pub l i c fo r their review.

The ma in SEA work for the IP commenced in early 2006 inc lud ing ecological f ieldwork, social surveys and consultations with relevant rev iew agencies and potential ly affected people and NGOs. Consultations o n the draft findings o f the SEA were carried out in September and October o f 2006. Consultations with stakeholders, inc lud ing o n this draft SEA, are an ongoing feature o f UETCL ’s SEA process.

The ma in sections o f the SEA Report, wh ich are summarized in the balance o f this executive summary, describe and document:

The applicable regulatory requirements; The existing social and environmental conditions in the study area; The need for the project and the alternatives that were analysed; The design o f the proposed facility, as we l l as the plans for i t s construction, operation, and maintenance; The consultation program including describing the project responses to issues identif ied during public consultation activities; The potential social and environment effects o f the project, along with the proposed mitigation and monitoring measures; and, The Social and Environmental Act ion Plan.

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2.0 Regulatory Requirements

U E T C L i s p lanning the IP, and this SEA Report has been prepared, t o be in compliance with the regulations and standards o f the GoU, and the safeguard pol icies and guidelines o f the AfDB. I t also recognises that the pro ject i s considered by the IFIs invo lved in the HPP to be an associated fac i l i t y to the HPP.

The GoU agency with pr imary responsibly fo r impact assessment o f projects in Uganda i s the Nat ional Environmental Rev iew Agency (NEMA). NEMA was created under the Nat ional Environmental Management A c t and mandated with the responsibi l i ty to oversee, coordinate and supervise environmental management in Uganda.

The Third schedule o f the Nat ional Environmental Management A c t specifies that any development that involves dams, r ivers and water resources ( including storage dams, barrages and weirs) o r electrical infrastructure ( including electr ici ty generation stations, electrical transmission l ines and electrical substations) require an Environmental Impact Assessment. An assessment o f potential environmental and social effects i s also a key po l icy requirement fo r a l l the IFIs invo lved in the project. Fo r the purposes o f this Project the term Social and Environmental Assessment, or SEA, i s considered to be synonymous with the dif ferent terms used by NEMA and the various lenders. for social and environmental assessment documentation.

A concordance analysis has been completed t o show h o w the standards, guidelines and po l i cy requirements o f the G o U and the IFIs applicable to the project have been identif ied, inc lud ing requirements for:

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Social and environmental safeguard policies, performance standards and guidelines; Ongoing stakeholder consultation and engagement; Ongoing public disclosure o f relevant information; Land acquisition and compensation and resettlement planning; and, Mitigation, monitoring and fo l low up o f social and environmental effects; and, Social and Environmental Action Plan updating, consultation and disclosure throughout the l i f e o f the project.

Where such requirements overlap, as for example i s the case fo r wastewater discharge where the G o U has ef f luent qual i ty regulations and the WB has eff luent qual i ty guidelines, than the more stringent o f the overlapping requirement has been adopted as the pro ject applicable requirement. A complete listing o f the social and environmental requirements applicable to the project i s p rov ided in the SEA.

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December, 2006

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3.0 Project Setting

3.1 Project Sett ing

The Lake Vic tor ia basin, in wh ich the I P i s located, i s predominantly lowland, interspersed with remnants o f upland surface typ ica l o f a landscape s t i l l undergoing erosion. The reg ion i s characterised by a pattern o f l o w but of ten steep hills, wh ich are generally highest towards the south, closer to Lake Victoria.

Jinja town, located on the east side o f the r i ver near Nalubaale i s the closest large community to the eastern end o f the IP. The c i t y developed starting in the 50’s when power for industry became available f rom the Owen Fal ls project. Kampala, Uganda’s largest c i t y i s located about 70 km to the west.

The major i ty o f the study area for the I P i s rural, with estate and small-scale o r subsistence agriculture being the predominant land uses. Agr icu l tu ra l act iv i ty i s p r imar i l y a labour-intensive, intercropping system with bo th cash and subsistence crops fo l low ing the seasonal changes. The ma in cash crops are coffee and sugar cane, coupled with more recent cropping o f vanil la. Subsistence food crops include bananas, cassava, sweet potatoes, maize, beans, mil let, and yams. Where the transmission system approaches Kampala the landscape becomes increasingly populated.

The hilly landform determines the drainage pattern fo r the region. Only short loca l streams and the lakeside marshes discharge in to Lake Victoria, with a l l larger watercourses, inc lud ing the val ley marshland around the nor thern side o f Kampala, f low ing generally northwards towards Lake Kyoga o r the Lugogo River . Mab i ra Central Forest Reserve (CFR) occupies a large por t ion (about 17 o f 70 km) o f the transmission system wayleave area between Kampala and Jinja, p rov id ing a distinctive and enclosed contrast t o the more highly populated farmland o f i t s surroundings. There are many large estates, usually tea or sugar plantations, around the periphery o f Mab i ra CFR and to the south, wh ich prov ide an open, ro l l i ng landscape with distant views.

3.2 B iop h ys ica I Conditions

The landscape along the proposed transmission l ine can be d iv ided in to eight areas o f relat ively dist inct landforms, land use and vegetation patterns mov ing f rom west to east inc lud ing Natete; Lubigi; Kawanda; Nor thern Kampala Farmland; Sezibwa Farmland; Mab i ra Fringes; Mab i ra Forest and Eastern Farmland.

There are two ma in hydro log ica l features o n the proposed transmission l i n e route: the River N i l e to the east, and the Lubigi swamp to the west. T o the nor th o f Kampala, in the area o f Kawanda, the transmission l ine wi l l cross a number o f poor ly drained areas with result ing seasonal swamps. The Lubigi swamp, w h i c h l ies approximately

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Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary

December, 2006

8 km west o f central Kampala, i s a large permanent wetland area. In addit ion to the above features, the transmission l i n e wi l l traverse smaller watercourses that generally dra in f r o m south t o north.

Lake Victoria, the Mab i ra CFR and Lake Kyoga inf luence ra in fa l l . The rainfal l pattern i s dist inct ly bimodal, with peaks occurring in March-May and again in September-November. Mean annual temperatures recorded throughout Mukono District range f r o m 23.5’C to 24.1’C. Mean max imum temperatures recorded range f rom 25.1°C in July to 27.5’C in January, wh i le the minimum mean recorded temperatures range f rom 14.2”C in August to 16.0°C in April. The loca l meteorology i s characterised by a very high frequency o f southerly winds. Prevai l ing southerly winds occur for over 30 percent o f the year. Winds f r o m the west-northwest t o the east are very infrequent.

The proposed transmission l i ne wi l l traverse four ecological ly signif icant areas: Mab i ra CFR, two smaller CFRs, Kifu CFR and Namyoya CFR (the latter also known as Mwola) and Lubigi Swamp. Plant, bird and mammal surveys were carried out in the Mabira, Kifu and Namyoya CFRs during January 1999 and November 2000 and again in mid-2006.

Mab i ra CFR i s the largest natural high forest reserve in the biogeographical zone o f Lake Vic tor ia Crescent and i s an important source o f forest products. The vegetation o f Mab i ra Forest i s classified as “medium altitude mois t semi-deciduous”. The forest has been greatly inf luenced by human activities, inc lud ing t imber harvesting, cu l t ivat ion and grazing, and i s regarded as secondary forest result ing from, and constantly being inf luenced by, human activit ies. In the Forestry Nature Conservation Master Plan, Mab i ra C F R i s designated a CORE conservation forest in recognit ion o f i t s biodiversity importance and a forest management p lan (FMP) for Mab i ra C F R has been developed, and covers the per iod 1997 to 2007. An important n e w development i s the imminent opening o f a luxury ‘eco-friendly’ lodge pro ject located deep within the Mab i ra CFR some 25 km f rom Jinja.

Namyoya C F R was established in the 1960s as a Natura l Forest Reserve. Pr ior t o 1996, the reserve was managed for production and environmental benefits. However, the reserve i s located in a densely settled area and was severely degraded due to encroachment. O f the three CFRs situated along the exist ing transmission route, Namyoya CFR has the lowest propor t ion o f forest bird species, an ind icat ion that the forest cover i s either very scattered or i s composed o f a l im i ted variety o f species.

Kifu CFR to the south o f the existing transmission l ine i s in a secondary growth state with th ick undergrowth. The sections o f the forest t o the N o r t h o f the transmission l ine are currently plantat ion forests; the same i s the case in Namyoya CFR.

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The Lubigi Swamp i s the on ly permanent wetland area within the proposed transmission system. I t i s situated to the west o f Kampala and nor th o f the Mutundwe substation. I t i s considered to represent a typ ica l papyrus swamp vegetation type found throughout Uganda. Although Lubigi Swamp i s situated within 15 km o f Lake Victoria, i t forms the headwaters o f a continuous f looded va l ley system that eventually drains in to Lake Kyoga. Despite i t s closeness t o Kampala, and levels o f human disturbance, the Lubigi swamp s t i l l supports notable numbers o f birds and mammals.

3.3 Socio-economic and Cultural Conditions

There i s widespread pover ty in Uganda, and the country i s consistently ranked one o f the poorest nations in the wor ld . Approx imate ly 85 percent o f the populat ion in Uganda reside in rura l areas and depend ma in l y o n agriculture for their l ive l ihood. L i teracy rates are low.

Agr icu l tura l act ivi ty i s p r imar i l y a labour-intensive, intercropping system with bo th cash and subsistence crops fo l l ow ing the seasonal changes. The ma in cash crops are coffee and sugar cane, coupled with more recent cropping o f vanil la. Subsistence food crops include bananas, cassava, sweet potatoes, maize, beans, mi l le t , and yams.

The C i t y o f Kampala i s Uganda’s po l i t i ca l and commercial centre. The T o w n o f Jinja, Uganda’s second largest urban centre, serves as the administrative centre fo r Jinja D is t r i c t and i s the Dis t r ic t ’s prime economic hub, housing industries such as textiles, beer, plastics, food processing, and f lour milling.

Within the project area, there are several ethnic groups, most ly o f Bantu origins. Historical ly, the Basoga people inhabited the areas o f southern Uganda east o f the N i l e and the Baganda inhabited the areas west o f the N i le . This i s s t i l l la rge ly the case, although people o f bo th t r iba l backgrounds live o n bo th banks o f the r iver today. A l though the Busoga and Buganda languages vary, they are s imi lar t o one another and mutual ly understandable. M a n y people s t i l l practice tradit ional religions, although they are of ten practised in concert with Christ ianity and Islam. Several people have amasabo (roughly translated as shrines) o n their properties where they can pay respect to their ancestors and commune with spirits.

F r o m the social surveys that were undertaken as part o f the IP RAP, 46 percent o f the people affected by the proposed transmission l ine depend on agriculture as their pr imary source o f income, with the major i ty o f the remaining people der iv ing some income f rom farming. The major i t y o f the affected household heads are tenants, while the remainder are licensees and landowners. The major occupations reported by the affected persons include: merchants, students, professionals, low-income entrepreneurs, drivers, c i v i l servants, teacherhesearchen, re t i red persons, house help, and, others. Thi r ty- f ive percent o f a l l affected household heads are women. The average affected household size i s 4.9 individuals. Thirty seven percent o f

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Social and Environmental Assessment - Executive Summary December, 2006

households within the study area are Protestant, 36 percent are Catholic, 23 percent are M u s l i m and 4 percent practice other beliefs.

The proposed transmission system corridor passes through Mukono, Wakiso and Kampala Districts. Distr icts are further divided in to counties, sub-counties, parishes and villages.

Comparing the two rura l districts within the study area, the populat ion density i s generally lower in Mukono than in Wakiso, part icularly in the central par t o f the District. This i s p r imar i l y due to the presence o f the Mab i ra Forest and a number o f large agricultural plantations. Within the par t o f Kampala D is t r i c t relevant t o the proposed Bujagal i interconnection system, densities are fa i r l y consistent and are about twelve t imes those o f Wakiso D is t r i c t and thirty times those o f Mukono Dis t r ic t .

Within Kampala D is t r i c t the predominant land use proposed i s residential, although the swampy areas on the western fringes o f the c i ty are designated ‘environmental areas’ where the po l i cy i s the protection and preservation o f open space.

A number o f all-weather roads run in a roughly north-south d i rect ion and wi l l be crossed by the proposed transmission l ine. As with a l l the ma in roads in this area, a large number o f loca l tracks branch o f f o f them, prov id ing access to numerous small settlements and agricultural areas.

The general landscape o f the reg ion through wh ich the proposed transmission system passes i s comprised o f f la t o r round topped hills, valleys incised in to the plateau with farmlands and occasional swamps. The area l i e s to the nor th and west o f Lake Victoria, commonly referred to as the banana -coffee belt. In the eastern por t ion o f the proposed Bujagal i transmission system, the agricultural activit ies are characterised by small-scale coffee banana based inter-cropping or in termixed systems in the V ic to r ia N i l e area and large-scale sugarcane product ion bo th to the east and west o f the Mab i ra CFR. M o r e small-scale coffee-banana systems occur in Wakiso district. The suburbs o f Kampala have small-scale backyard farms consisting main ly o f subsistence food crops.

N o significant cultural properties are k n o w n to occur within the proposed transmission corr idor and a 2006 archaeological assessment o f the Kawanda sub- station site confirmed the absence o f archaeological artefacts.

Ma lar ia and respiratory infect ions account for about h a l f o f a l l outpatient diagnoses in Uganda. The prevalence o f HIV/AIDS i s high, with HIV/AIDS-re la ted i l lness accounting for over 30 percent o f a l l hospital admissions, and increasing. In an ef for t to address the spread o f H I V / A I D S , widespread publ ic education campaigns have been established and condoms are readi ly available.

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4.0 Project Al ternat ives

4.1 Existing Electricity System and Need for the Bujagali Interconnection Project

Histor ica l ly v i r tua l ly a l l (99 percent) o f Uganda’s electr ici ty has been generated at the Nalubaale and K i i r a hydropower facil i t ies that are located at Jinja (Energy Informat ion Administration, 2004). Energy generated by the Nalubaale (formerly Owen Falls) and the K i i r a (formerly Owen Falls Extension Project) hydropower stations, i s transmitted f rom the substation at Nalubaale to three substations around Kampala, wh ich i s the ma in load centre o f Uganda (Kampala North, Lugogo, and Mutundwe), and to an exist ing substation in Tororo.

The development o f the Bujagal i HPP by BEL wi l l require n e w transmission infrastructure to interconnect the project t o the existing power transmission system. Feasibi l i ty studies undertaken for the project (Knight Piesold and M e r z and McLel lan, 1998 and Siemens, 2006) have concluded that the exist ing national ne twork in Uganda i s insuff icient to evacuate the full 250 M W generating capacity o f the Bu jaga l i HPP using the exist ing l ines . Thus, there i s a clear need for upgrades to the exist ing or development o f new transmission infrastructure to accommodate the proposed Bujagal i HPP.

4.3 Description of Interconnection Options

The AESNP alternatives analysis fo r the transmission faci l i t ies was completed to ident i f y the potential key impacts o f the alternative corridors considered and, f rom these, select a preferred alternative. This process also invo lved consultations with the UEB (the electr ici ty regulator at that time). F r o m these consultations, i t was concluded that the Bujagal i transmission system should use exist ing transmission corridors as much as possible to reduce impacts; enable future system expansion to northern Uganda; and, min imise the number o f crossings o f exist ing transmission faci l i t ies and other ut i l i t ies.

The pr imary transmission l ine corr idor rou t ing alternatives connecting Bujagal i t o Kawanda that were considered were: a route rough ly paral lel to the exist ing 132 kV “northern” route between Nalubaale and Kampala, and one rough ly paral lel to the exist ing 132 kV “DANIDA line” corr idor between Nalubaale and Lugogo substation in south-eastern Kampala.

I t was concluded that the northern route was preferred as impacts on settlement and property are lower, i t i s shorter, and i t does no t require any crossing o f exist ing transmission l ines. Moreover, the capacity o f the southern corr idor system was considered difficult to expand as bo th the substation and transmission l ine facil i t ies were considered to be at capacity in the current locations. F r o m an overal l system design perspective, the northern route wou ld prov ide the Government Utility with

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greater flexibility fo r future system expansion, when compared to the southern route. In i t s independent assessment o f the transmission l i ne routes, the Panel o f Experts, in i t s four th report, concluded that AESNP had selected the most appropriate transmission l ine route.

The AESNP preferred op t ion was to connect the Bujagal i HPP at 220 and 132 kV as fol lows:

0

0

0

A 220/132 kV switchyard on the west bank o f the N i l e adjacent to the hydropower facility; A double circuit 220 kV l i ne between the Bujagali Switchyard and a new substation to be located in Kawanda; A double circuit 132 kV l i ne between the Kawanda substation and the existing Mutundwe substation; and, Double c i rcu i t 132 kV lines between Bujagali and Tororo and Bujagali and Nalubaale. These double circuit lines wi l l be established by intersecting the existing Nalubaale- Tororo l ine.

As part o f the ongoing p lanning for the IP and the HPP new interconnection analyses were completed to ensure that the project was proceeding with the opt imal interconnection opt ion (Siemens PTI, 2006). Siemens PTI conducted extensive load f low, stabi l i ty and economic evaluation studies for each o f the interconnection options in the short, med ium and long term, as well as testing each option’s sensitivities to the uncertainties associated with the predicted load growth, the instal lat ion o f new generation in Uganda, Lake V ic to r ia hydro logy and costs o f fuel, among others.

Field reconnaissance and analysis o f recent satellite imagery completed as part o f this SEA process confirmed that there have been n o major changes to environmental o r social conditions in the area that wou ld affect the overal l conclusions set out above.

Building on the work completed for the AESNP project f ive alternatives were formulated for the interconnection o f the Bujagal i HPP. The preferred opt ion (3a) includes the fo l low ing components:

Construction o f Kawanda Substation;

0

Construction o f a 2 x 220 kV l ine f rom Bujagal i to Kawanda but operated in i t ia l l y at 132 kV; Construction o f a 2 x 132 kV l ine f rom Kawanda to Mutundwe; Construction o f a 2 x 132 kV l ine f rom Bu jaga l i t o Nalubaale; Construction o f a 1 x 132 kV l ine f rom Bujagal i to Nalubaale; and, Construction o f a 2 x 132 kV l ine f rom Bujagal i to Tororo.

Med ium to long term faci l i t ies include construction o f a 1x132 kV l ine f rom Nalubaale to Kampala N o r t h and a 1x132 kV l ine f rom Bu jaga l i t o Nalubaale. In the

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l ong term there w o u l d be an upgrade o f operation o f the Bu jaga l i to Kawanda t o 220 kV and the construction o f an addit ional 1 x 132 kV l i ne f r o m Bu jaga l i to Nalubaale.

Improved f lex ib i l i t y wou ld be achieved by insta l l ing a second c i rcu i t f r o m the outset, as proposed in Opt ion 3a, outweigh the capital cost difference between the other options. Opt ion 3a has comparatively the least land use affected, the pr imary exception being the last k i lometre o f the 132 kV Kawanda-Mutundwe l ine, where land use near the Mutundwe substation has become highly constrained. However, un l ike other options, series reactors could be used with Opt ion 3a to preclude the future need fo r the 132 kV Bujagali-Nalubaale, F o r this reason, Opt ion 3a with series reactors (Option 3aR) i s the overal l preferred Opt ion from the social standpoint. The preferred system i s shown on Figure ES-2.

4.4 Detailed Route Selection and Optimisation

Opt ion 3aR, i l lustrated o n Figure ES-2, was selected as the preferred system plan. The land required fo r the p lan i s the same as the land that w o u l d have been required for the AESNP plan. B o t h plans have the same lines and substations - the on ly difference being that, wh i le the Bujagali-Kawanda L i n e wi l l be constructed at 220 kV, i t wi l l be operated in i t ia l l y at 132 kV. As the constructions standards are the same, the land area remains the same, also.

Pr ior to wi thdrawing f rom the project AESNP ident i f ied a specific route for the wayleaves and specific s i te fo r the Kawanda substation. Consultations with the potential ly affected vil lages along the routes indicated that in many places vil lagers and PAPS k n o w where the AESNP L i n e was routed, and in many cases concrete markers can s t i l l be located by affected individuals. Comments were received by some PAPS previously surveyed by AESNP that they have been wa i t ing a l l these years for their compensation, and that they have no t maintained their buildings that were within the wayleaves. T o locate the l ine elsewhere wou ld leave such affected parties with n o compensation fo r the disruption caused as a resu l t o f the earlier rout ing work, and thus, legacy issues that wou ld need to be addressed.

Where n o signif icant changes have occurred to land use the route fo r the transmission l i n e s fo l lows the rou t ing previously ident i f ied by AESNP. Opt imizat ion was necessary at the Kawanda Substation, to avoid effects o n the neighbouring school, and between Kawanda and Mutundwe, where urban land use has intensified. An optimized route was ident i f ied that reduces resettlement, with minor additional impacts to Lubigi Swamp. Figure ES-3 shows the or ig ina l AESNP route and the optimized route fo r the l ine between Kawanda and Mutundwe.

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4.5 Substation Si te and Optimization

Under the planned transmission system configuration fo r the IP, a substation wi l l be required in the Kawanda area, 10 km nor th o f Kampala (Figure ES-4). During the AESNP assessment three potential s i tes in the Kawanda area were evaluated fo r the location o f the substation, based on social, environmental and technical criteria. The preferred site was the Maganjo site, and landowners were subsequently re-settled f r o m the site and g iven compensation, in the per iod 2001-2003..

Review of the approach and rationale used fo r the AESNP assessment within the context o f the current situation concluded that the or ig ina l siting decision i s s t i l l val id. However, potential ly negative aspects o f the Maganjo site, invo lv ing impacts to graves on the s i te as w e l l as t o the nearby Kawanda Secondary School, were resolved through optimisation o f the site design and rou t ing o f l i n e s in and out o f the si te. The optimised layout o f the Kawanda substation i s shown o n Figure ES-4.

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5.0 Project Description

The IP wil l consist o f the development o f new high voltage transmission lines, and a substation at Kawanda. The general location o f the l i n e and the s i te are shown on Figure ES-5., as i l lustrated o n Figure ES-2. There wi l l be a new substation developed at the HPP site area as par t o f that project. The proposed l ines and substation to be developed as par t o f the IP project are:

“Bujagali to Tororo” and “Bujagali to Nalubaale” Lines: T w o new 132 kV double circuit lines wil l run about 5 km south f rom the Bujagali Substation to a junction point along the existing Nalubaale to Tororo line. The existing l ine wi l l be severed with one end reconnected to the new lines so as to create a new l i n e between Nalubaale and Bujagali and a new l i ne between Bujagali and Tororo. Power for Tororo wou ld now be delivered f rom Bujagali substation rather than the Nalubaale substation. Power could f low in either direction between the Bujagali and Nalubaale substations depending on the operational status o f the generation stations.

“Bujagali to Kawanda” Line: This new 70 km long l ine wil l be designed and constructed to 220 kV standard. Although i t may be operated in i t ia l ly at 132 kV.

Kawanda Substation: This station wil l be designed and constructed to al low operation at 220 kV, although it may init ial ly be operated at 132 kV. The station wi l l be sized and la id out to al low interconnection o f future lines with UETCL’s longer range system plans in mind.

“Kawanda to Mutundwe” Line: a new 17 km, 132 kV double circuit l ine wi l l interconnect the Kawanda substation and the existing Mutundwe Substation and thus comprise the third interconnection point for the HPP. Internal improvements (e.g., new bay and switching gear) at Mutundwe will be needed to accommodate this new line.

The transmission l ines shall be designed with steel lattice towers o f the type commonly used in Uganda and wor ldwide. The 220 kV towers wi l l be slightly larger and spaced further apart than the 132 kV l ines. The larger 220 kV l ine wi l l require a 40 m wide wayleave; the 132 kV l i nes wi l l require a 30 m wayleave. N o permanent structures, such as houses or outbuildings, wi l l be a l lowed to remain or be constructed within the wayleaves. Farming o f crops wi l l be permitted, but limited to a height o f 1.8 m or less - thus most annual crops and l o w growing perennial crops such as tea wou ld be permitted.

Construction wi l l take approximately two to three years, although except fo r Kawanda Substation the activit ies at any one spot wou ld be o f shorter duration. The main construction steps for the transmission l i n e s wou ld invo lve:

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Clean up and restoration.

Completion o f land acquisition and resettlement; Developing access to the wayleaves; Clearing the wayleaves o f buildings and non-compatible vegetation; Delivering material to tower sites; Install ing foundations and erecting towers; Stringing and tensioning conductors (wires); and,

W o r k at the Kawanda substation wi l l take place over a per iod o f approximately 30 months. The level o f act iv i ty in the f i rs t year wi l l be most significant, and wi l l consist o f s i te surfacing and other c i v i l works. The electrical instal lat ion activit ies wi l l take place in the second year and wi l l consist o f the erection o f steel structures and the instal lat ion o f high voltage equipment, control boards, wiring and contro l cables. At the peak o f construction activi ty, about 100 workers wi l l be invo lved in the construction o f substation facil i t ies at Kawanda

Fo l l ow ing the completion o f construction tests wi l l be undertaken t o ensure that the IP performs as per specifications. During testing, l i ne ground clearances wi l l b e thoroughly checked. Once the transmission l ines are constructed, tested and commissioned relat ively l i t t le maintenance i s required. The k e y activit ies invo lve surveillance o f the condit ion o f the transmission l ine and wayleave; emergency maintenance and repairs; and yearly vegetation contro l in accordance with UETCL’s exist ing wayleave clearance programme.

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6.0 Public Consultation and Disclosure

6.1 Consultation Program

UETCL, together with BEL, has undertaken extensive consultations as part o f the SEA work for the IP and the HPP. Because the projects are closely associated, some o f the consultation activit ies were closely integrated. F o r example, publ ic meetings he ld on the west bank o f the N i l e discussed bo th the HPP and the IP. Closer t o Kampala meetings and consultations tended to focus p r imar i l y o n the IP. In addition, BEL retained the services o f a witness NGO ( InterAid Af r ica) in August 2006 to provide independent moni tor ing o f the consultation activi t ies o f the HPP and IP, and to provide a mechanism for stakeholders to f i le a grievance with the SEA processes.

Overall, the consultation activit ies and disclosure program has been designed so as to maximise community awareness o f the proposed pro ject and SEA study and report and to maximise opportunities fo r community input and involvement. The approach was designed recognizing that extensive consultations and communi ty engagements were completed by A E S N i l e Power, and fo l low ing their withdrawal, ongoing consultations have been carried out by UETCL 's Bu jaga l i Implementation Unit. By a l l indications, the starting po in t was a relat ively high awareness leve l o f the project; this was confirmed through the in i t ia l community consultations undertaken as part o f this SEA in August 2006.

The PCDP has built on publ ic consultation procedures carr ied out in 1999/2001 by the previous project sponsor, AES N i l e Power (AESNP), as w e l l as extensive publ ic consultation carried out by the U E T C L Bujagal i Implementation Unit (BIU) Team since then, part icularly in 2004-2005, Similar t o the previous publ ic consultations, U E T C L has sought to obtain alternative views on the design and construction o f the transmission system, inc lud ing concerns o f potential impacts and ways to mit igate such impacts. Based o n this input, UETCL has assessed alternatives and considered raised concerns in i t s decision-making process.

The consultation activit ies have been organized in to six dist inct phases, as i l lustrated on Figure ES-64. The stakeholders that are invo lved in the consultation activities, and the consultation modalities, are summarized in Table E S 1. The consultation program has been designed, and wi l l continue to be implemented, in a manner to ensure part icipation f r o m women.

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Public Consultation & Disclosure Activities

Project Name: BUJAGALI INTERCONNECTION

PROJECT EXECUTIVE SUMMARY

UGANDA ELECTRICITY TRANSMISSION COMPANY LIMITED

Prepared for:

Phase I - Initial Stakeholder Consultation

10045.T.ES.5 , ! FigureES-6 Date: December, 2006

PUBLIC CONSULTATION AND DISCLOSURE ACTIVITIES

L (obtain initial input & issues from agencies)

Phase II . SEA TOR & PCDP Consultation

(Project Notice, release of SEA TOR 8 request for comments)

Phase 111 . SEA Summary Report Consultation

(Release of SEA Summary Report & request for comments)

Phase IV . SEA Report & Action Plan Consultation

(Release o f SEA Report & request for comments)

Phase V . CDAP Consultation Planning

(Confirm communtiy needsldesires & confirm CDAP & implementation plan)

Phase VI. Ongoing Project Consutation

1 I

Timeline

January 2006

1 May 2006

June 2006

1 August 2006

September 2006

October 2006

December 2006

February 2007

March 2007

I June 2007

JulylAugust 2007

201 1

Project Activities

Preparation of SEA TOR

Release of SEA TOR & Draft PCDP

Release o f SEA Summary Report

Release of SEA Report & Action Plans

SEA Report Updates (if required)

NEMA & International Lenders anticipated SEA approvallacceptance

Anticipated financial close! construction start date

Updated by: fkJKNSiDE

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Table ES.1: Consultation AI Stakeholders

National Public

Government Agencies

NGOs (national and local)

Local Communities

Project Affected Persons

Vulnerable groups

Business Operators

Tourist/visitors

Cultural Groups

Indigenous Peoples

ivity Summary Consultation Activities

Project notices in national newspapers, web site and making documentation available to all interested parties. Meetings were held with various government agencies and SEA documentation wadis being circulated through NEMA. Numerous NGOs were identified and contacted to arrange meetings w i th to discuss their concerns and interests. Project documentation was circulated to the NGOs and offers made for additional meetings. Contact was made w i th District and Sub-county leve l governments to inform them o f the project. Sub-county Consultation committees were established and met wi th to assist in consultation activities wi th local villages. Public meetings, organised by the Sub-county Community Development Officers were held in the affected communities to advise people o f the project and to receive their comments and concerns. PAPs include that own property, live andlor are involved in economic activities (typically farming) within the transmission l i ne corridor and associated activities. As part o f the RCDAP process, socio-economic surveys were undertaken to establish a prof i le o f the PAPs. It i s noted that PAPs within the boundaries o f the Kawanda Substation were resettled by the previous project sponsor. An assessment of this past resettlement was undertaken and the results document in the APRAP Report. Vulnerable group representatives, including women, were included on the Sub-county Consultation Committees. Business operations located within the transmission corridor were identified and profi led as part o f the Rap process. A section o f the transmission project parallels a section o f the N i l e River and has the potential for visual impacts and could potentially affect tourism activity. Tourist interests were represented through contact w i th tourist based organisations. The Kingdom o f Buganda was directly consulted w i th through meetings and the submission o f project documentation. These consultations are ongoing. In consultation w i th W B G specialists, i t was determined that no indigenous peoples, as defined for the purposes o f Wor ld Bank and I F C policies and Performance Standards, were ident i f ied to be resident w i th in the project area o f influence.

As a resul t o f Phase 1-3 engagement and consultation activities, a number o f issues were ident i f ied and which were taken in to account in the preparation o f the SEA. A comprehensive listing o f the issues ident i f ied and project responses are prov ided in Table ES- 2.

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able ES-2: Summary o Issue

Issue 1: Past resettlement activities

Issue 2: Land Compensation for the T-line

Issue 3: Will the previous valuation results be considered?

Issue 4: Will I be compensated for loss o f land use over the past 5 years?

Issue 5: Community development opportunities/the need to consult

(ey Issues and Responses

To accommodate the Kawanda substation, residentdtenants were resettled by the previous project sponsor (Nansana village). There has remained some unfilled promises regarding the resettlement. An audit of the past resettlement act ivi t ies was undertaken and an Assessment of Past Resettlement Action P l a n (APRAP) report prepared that outlines the concerns/issues and proposed activities to be undertaken. U E T C L has committed to resolve certain o f these past resettlement i s s u e s in the immediate future and pr ior to construction init iat ion. Some actions have already been taken. Consultation on resolving these past problems has been occurring b y the BIU and i s expected to continue in to 2007. The key concern relat ing the I P process i s the land/asset valuation process and what people can expect (and when) t o receive as compensation. The issue has been complicated by the previous (2001) valuation exercise (see below). As well , along some section o f the line, land speculation has occurred wh ich has raised concern regarding the legit imacy o f some o f the claimed assets on the affected properties. The RCDAP report provides a detailed description o f these issues. The Witness B G O (InterAid) became very famil iar w i th this issue. As noted above, people were in i t ia l l y concerned that the previous valuations wou ld no t be honoured and that the new valuation wou ld be lower because some lands have been idle since the original valuation was done (people were to ld no t to improve/use their land by the previous project sponsor after this first valuation was completed). I t was explained to them that based on a G o U directive that the original valuation wou ld be honoured (where records are available) so that people wou ld no t be worst o f f w i t h the more recent valuation. As people reported being to ld by the previous project sponsor to no t improve/use their land after the or ig inal valuation, some have requested that they be compensated for this loss o f land use for the past 5 years. This issue i s s t i l l being considered as part o f the R A P process. There would appear to be some expectation that the affected communities should receive some benefit f rom the project in some way (beyond land compensation). U E T C L agrees that the local communities should benefit social ly and economically f rom the project. As such, an I P specific R C D A P i s to be implemented whereby the communities are to propose projects and make application to U E T C L for funding. consultations/awareness bui ld ing exercises w i t h the potentially affected communities pr ior to construction init iat ion.

Response

U E T C L wil l undertake

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Issue Issue 6 : Construction workforce impacts

Issue 7: Local community access to electricity

Response The project i s expected to attract large numbers o f migrants looking for employment opportunities through the project. This i n f l ux o f people into the area can create challenges in regards to the demand for social services and accommodations. As well, local residents have expressed concerns in regards to the social and health consequences o f migrant workers coming in to their community.

N o specific workers camps are to be created for the I P construction. Instead, workers w i l l be bussed in f rom the Kampala area o f dai ly basis.

A comprehensive Aids/HIV programme i s to be implemented (wi th the assistance o f the Ugandan Aids/HIV NGO TASO or similar organisation) which i s to involve education programmes fo r both the local community and the workers. The h i r ing practices o f the EPC Contractor w i l l be designed so as to minimise people showing up for work on a regular basis. Local communities have expressed interest in getting improved access to electricity as a community development init iat ive. I t has been explained to the communities that electrical distr ibution i s the responsibility o f UMEME, which i s a private company. BEL i s committed to work w i t h the communities and UMEME to facilitate improved access to electricity.

6.2 Grievance Management Mechanisms

Grievance mechanisms have been included in the Resettlement Ac t i on Plan (RAP) studies for this project for both the hydroelectric component and i t s associated interconnection (transmission) system. They were available during the AESNP sponsorship o f the pro ject and were re-instated by U E T C L / B E L fo r the R A P work under the n e w sponsorship. Go ing forward, the avai lab i l i ty o f a Grievance Mechanism wi l l be advertised with the other pro ject noti f icat ions regarding the release o f the SEA Reports. The advertisements wi l l include the contact in format ion for the Witness NGO (InterAid). A grievance f o r m has been prepared and wi l l be available through the chairpersons o f the loca l vil lages. The Sub County Committees wi l l also be used to channel the forms and vet the grievance issues. They wi l l ident i fy wh ich ones can be solved local ly o r one that has to go to higher leve l beyond the v i l lage and Sub-county. Generally, community leaders k n o w the ind iv idual PAPS and have the po l i t i ca l and social responsibil i ty for the communi ty members. Once a grievance i s received, I n te rA id wi l l investigate the concern and f i r s t make a determination o f i t s legit imacy. Assuming the issue to be a va l i d concern, InterAid wi l l communicate the issue to UETCL and faci l i tate the process to resolve the issue. Responses and actions (if necessary) t o resolve the grievance wi l l be communicated

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to the ind iv idual who submitted the grievance. A written record o f a l l grievances received, and h o w they were dealt with, wi l l be kept by InterAid and U E T C L .

6.3 Disclosure Program

In promot ing transparency and accountabil ity, U E T C L has and wi l l continue to provide relevant material in a timely manner p r io r to consultation and in a f o r m and language that are understandable and accessible to the groups being consulted. T o date, U E T C L has disclosed the fo l low ing documents:

SEA TOR and the draft PCDP; Consultation Summary o f the draft findings o f the SEA; and, HPP SEA Report, which includes APRAP, CDAP, and PCDP

The SEA TORS and draf t PCDP were distributed in July 2006 to the Nat iona l government (NEMA) and loca l government stakeholders (sub-county level). The Consultation Summary Report was released in late September 2006. The f ina l SEA Report was released in December 2006.

The SEA Report and Act ions Plans are being made available to the other identi f ied stakeholders and the pub l ic at large at pub l i c ly accessible locations and o n the fo l low ing web s i te : www.Bujagali-energy.com.

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7.0 Impact Identification, Management and Monitoring

This SEA adopts a pro ject l i f e cycle assessment format. I t focuses o n the development o f specific management init iat ives fo r a l l phases o f the project to ensure that: i) the people closest to the project receive the projected benefits; ii) potential ly negative environmental and socio-economic impacts are minimised; and iii) potential ly negative heal th and safety impacts are kept t o a minimum. T o optimise the l i f e cyc le assessment, l inkages between potential impacts (i.e., k e y environmental issues), mi t igat ion measures (i.e. management actions), net effects (i.e. residual effects), and mon i to r ing programmes (i.e. management decision tools) are expl ic i t ly made.

This section summarizes:

0

0

0

7.1

Compliance screening o f the project against Government o f Uganda Legislation, International Treaties and Conventions Ratif ied by Uganda, and project applicable safeguard policies, performance standards and guidelines; Identif ication and analysis o f developmental and community benefits; and, Identif ication and analysis o f key project issues, and net effects analysis.

Compliance Screening

A screening exercise, the details o f wh ich are presented in the SEA Report, confirms that the project complies with:

G o U statues and regulations; 0

0

Relevant international environmental treaties and conventions; and, Project applicable standards as determined f rom the concordance analysis o f the social and environmental policies, performance standards and guidelines applicable to the project.

7.2 Developmental and Community Benefits

The project wi l l result in several developmental and communi ty benefits at the national, regional and communi ty levels. These benefits include:

0

0

The project wi l l facilitate interconnection o f the Bujagali HPP into the national grid, thereby providing business and people access to much needed power; Communities and villages that host the proposed facilities wi l l benefit f rom access to a Community Development Fund for worthy projects such as upgrades to schools, health centres, and water supply; The infrastructure being provided wil l support transmission needs beyond the IP. Ugandans wil l benefit through improved system redundancy and potential capacity for future expansion; and,

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The regional and local economies wi l l benefit f rom opportunities for employment and by opportunities to provide goods and services required during construction.

Women wi l l be consulted and benefi t (as with men) in the compensation programmes and be pr ime beneficiaries in the Communi ty Development Ac t ion Plan

7.3 Key Pro jec t Issues and N e t E f fec ts Analysis

Table ES-3 highlights the key project issues, as w e l l as the corresponding avoidance, protective and mi t igat ive measures relevant t o the construction and operational phases o f this project.

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Table ES-3: Summary of Impact Mitigation and Effects Monitoring Activities Project Issue I Summary of Mitigation and Net Effects

Resettlement and Land Compensation

At the time of writing the estimated number o f affected plots i s about 2,485. As different household members within the same household may hold several distinct plots under different land tenure arrangements, this number i s higher than the actual number of affected households (about 1,900). This number includes the 120 potentially physically displaced people and the 40 potentially economically displaced people. A Resettlement and Community Development Action Plan has been prepared, the key principles of which are:

Resettlement and compensation of Project-Affected People wil l be carried out in compliance with Ugandan legislation, IFC's Performance Standard 5 and WB OP 4.12; Al l physically or economically displaced people wil l be offered an option between either a full resettlement package, including the provision o f replacement residential land and a house, or cash compensation; Past experience in Uganda has shown that cash compensation, although very sought for by many household heads, could be detrimental in the medium term, to other household members, particularly the females and children; the Project wi l l make every effort to promote resettlement rather than cash compensation, and this plan i s designed accordingly; Women wil l be consulted and benefit (with men) and the compensation program - the project i s not expected to have any undue impacts on gender A majority of Project-Affected People derive their livelihood from agriculture. Where farmers are physically or economically displaced, they wil l be offered a resettlement option including the provision of agricultural land of potential equivalent to that of the land they have lost; UETCL wil l assist PAPs' in restoring their affected livelihoods, and wil l provide transitional assistance as necessary as long as livelihoods are not restored to their previous level; The RCDAP implementation and outcomes wil l be monitored and evaluated as part of a transparent process; and, PAPs and host communities wil l be informed and consulted during the whole course of RCDAP development, implementation and evaluation.

In addition an Assessment of Past Resettlement and Action Plan has been prepared to ensure those PAPS resettled by the previous project sponsor are no worse off as a result o f the project. At Kawanda Substation landowners were either resettled or provided cash compensation for loss of land by the previous project sponsor.

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Wildl i fe

Summary of Mitigation and Net Effects To minimise land-based effects, the EPC Contractor shall s i te and construct laydown and storage areas, in agreement w i t h the Environmental Manager, who may consult NEMA or other Relevant Authorit ies fo r the purpose o f agreeing on such a site. Mabira FR wil l n o t be used fo r staging area.

Various measures w i l l be put in place to minimise topsoi l compaction, rut t ing and soi l m ix ing f rom construction activi t ies (e.g. use o f existing access roads where possible).

The power l i n e s introduce a potential physical hazard to birds and cl imbing animals. Risk o f electrocution by large cl imbing animals, such as vervet monkeys, or bats are no t expected as the spacing o f the conductors and the length o f the insulators exceeds the reach o f the cl imbing species and wingspan o f bats present in the area.

The proposed l ine through the Mab i ra FR i s no t located near any significant breeding or staging areas, and therefore bird strikes are no t expected to have any significant effects on bird populations in Uganda. Where the transmission l i n e w i l l cross areas that are potential ly important as bird f l ight paths, in particular large wetland bird species, U E T C L shall take reasonable measures to make the conductor more conspicuous. These may include the use o f reflectors placed at intervals along the conductor. Such measures wou ld be employed, in consultation w i th the Wetlands Inspection D iv is ion and/or National Forest Author i ty where the l ine crosses the Lubigi Swamp and where the l ine crosses the seasonal swamps to the nor th o f Kampala. T o reduce the potential for microbial contamination o f surface water and soil, a Waste Management Programme w i l l be developed, t o include measures such as the provision for on-site treatment o f eff luent at l ong term work sites.

To minimise the deposition o f eroded soils in to watercourses and disturbance o f f lows and habitat, towers are to be located outside the top-of-bank o f a l l watercourses; and a vegetated buffer w i l l be maintained along both sides o f a l l watercourse crossings.

Some towers w i l l be located in and adjacent to the Lubigi Swamp. Special construction techniques w i l l be used to minimize impacts including using large mats for movement o f heavy equipment, special procedure for re-fuelling to avoid contamination, and scheduling construction for dry periods. During detailed design taller towers w i l l be considered to enable longer spans and thereby minimize the number o f towers in wet areas.

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Project Issue Effects on A i r Quali ty

Effects on Noise

Access Roads and Traf f ic

~~ ~~~~ ~ ~~

Summary of Mit igat ion and Net Effects There exists the potential fo r dust in the immediate v ic in i ty of construction activities, and along loose surface roadways. A variety o f measures to control fugit ive dust wi l l be implemented such as the protection o f soi l stockpiles through wett ing and grassing; and the watering o f roadways to reduce dust when necessarv. To reduce noise leve ls during construction, a variety o f measures w i l l be implemented including restr ict ion o f noise-generating activities that take place near residential o r sensitive inst i tut ional receptors t o the per iod between 0600 and 2200 h, which i s defined as ‘daytime’ in the draft Ugandan noise standards. There exists the potential fo r increased traf f ic congestion as a result o f incremental traff ic associated with the project. The Kampala to Jinja highway has a high capacity factor. The estimated day-to-day vehicle requirements w i l l not result in significant change in traff ic f lows or volume on this road. The occasional movement o f abnormal loads to the wayleave, substation sites or storage areas may impede traf f ic f l ow on occasion. Procedures w i l l be included in the Traf f ic Management Plan to ensure transport o f abnormal loads i s timed and executed to minimise traf f ic disruption. The selection o f local access roads w i l l be made in consultation w i th local off icials to optimise use o f roads w i th adequate capacity.

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Project Issue Effects on Managed and Protected Areas

Tourism and Aesthetics

Summary of Mi t iga t ion and Net Effects The permanent loss o f about 60 h a o f forested l and w i l l reduce the available habitat for vegetation and wildl i fe, To reduce effects o f the wayleave w i th in Forest Reserves this has been l im i ted to 35 m, versus 40 m in non-forest reserve areas. U E T C L has estimated the Total Economic Value o f lost forest resource, and w i l l allocate at least equivalent monies t o support ini t iat ives by NFA, e.g. enhancement planting, wh ich w i l l compensate fo r loss o f forest resource and associated benefit stream.

After construction, ecological surveys wi l l be undertaken by U E T C L to monitor post construction effects.

The result ing cleared corridor may pose a barr ier to movement o f “forest interior” w i ld l i fe species between the forested areas nor th and south o f the route. The 220 kV l i ne through the Mabira Forest Reserve has been routed immediately adjacent to the existing 132 kV line t o minimise fragmentation effects. Cross l i n e vegetative corridors between the nor th and south forested areas w i l l be established by minimising clearing and selective plant ing o f suitable vegetation at select val ley locations.

Improvements to access required for construction may have potential to increase grazing, bushmeat hunting and i l legal fe l l ing o f timber. However, access has been improved in recent years, by U E T C L upgrading the exist ing r ight-of-way through Mabira Forest, including associated bridges and culverts. This has no t resulted in significant encroachment. As n o significant further upgrades are foreseen, n o specific mit igations are necessary. Presence o f the l ine reduces aesthetic values fo r ecotourism and recreation in managed and protected areas. N o existing or planned tourism faci l i t ies are wi l l be direct ly affected.

Concern was raised during consultations about the visual impact o f the lines f rom vistas along the east bank o f the N i l e . U E T C L i s prepared a detailed visual analysis for that port ion o f the route, and i s investigating opportunities to adjust the route to minimise visibility f rom key vistas.

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Project Issue Effects on Cultural Property

Community, Health, Safety and Security

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Summary of Mitigation and Net Effects No major archaeological sites have been identified in the areas affected by the IP. As part o f the SEA, an archaeological survey has been completed for the Kawanda substation. Prior to construction, the sites fo r the towers w i l l be surveyed by an archaeologist. Should any s i t e s be identified, including graves, mit igation measures are to be agreed upon by the Department o f Antiquities, the local community and U E T C L .

Discussions are ongoing w i th the Buganda Kingdom. Should any sites o f spir i tual significance be identified, the K ingdom wil l be consulted to determine the most appropriate means to addredmi t iga te impacts on these sites.

The transmission corridor may pass over small structures used by the residents for offerings t o spirits (known as Amasabo). The location o f these sites i s to be determined through the ongoing socio-economic surveys. I t i s possible to relocate amasabo subject to certain ceremonies. Appropriate measures wi l l be put in place to reduce risk to publ ic safety including: accidental contact w i th lines, col l is ion w i t h construction equipment, excavations on ROW, material storage, tower construction.

T o reduce risk o f accidents due to project related traffic, U E T C L and the EPC Contractor w i l l prepare and implement a Traf f ic Management Plan (TMP) that contains appropriate strategies for: mov ing materials, equipment and workers to and f rom the site, including abnormal loads; and, management o f connection points between access roads and main publ ic highways.

T o reduce risk to students and staff o f Kawanda Secondary School, as part o f upgrading the access road, U E T C L w i l l erect a barrier to separate vehicles and pedestrian traffic. U E T C L to post and abide by speed l im i ts on this access road. The EPC Contractor w i l l provide a manned crossing at the beginning and end o f the school day, i f required U E T C L w i l l make a presentation to school staff and students about traff ic safety and project scheduling.

To reduce the risk o f environmental contamination f rom spillage or disposal o f fuels, lubricants, oils and solvents on the construction site, U E T C L and the EPC Contractor shall dispose o f materials defined as hazardous waste (e.g. hydraulic oi l) in a responsible way, and where reasonable, shall return such materials to the manufacturer for recycling. There w i l l be no permanent construction camp(s) associated w i th the I P that might attract camp followers. Workers w i l l be bussed f rom urban areas to the work site. The EPC Contractor wi l l , as part o f each worker’s in i t ia l

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Project Issue

Labour and Work ing Conditions

Cumulative Effects

Summary of Mit igat ion and Net Effects orientation and ongoing education, provide publ ic education informat ion about H I V / A I D S transmission and preventative measures. Condoms w i l l be made available to project workers at n o cost. Thus the spread o f A IDS/H IV and other STDs are no t expected to increase disproportionately as a result o f the IP.

There i s often concern regarding the health effects o f Electro-Magnetic Fields (EMF) f rom h igh voltage transmission l ines. Avai lable laboratory or human data have not demonstrated what, if any, magnitudes o f power-l ine electric and magnetic f ie lds cause human health effects. The electrical transmission l i n e w i l l be designed and constructed to ensure that EMF levels are below the International Commission on Non-Inionis ing Radiation Protection’s Guidelines. N o adverse effects on human health and welfare can be expected f rom operation o f the proposed facilities, either on the basis o f EMF guidelines, or on the basis o f conclusions reached by scientific review groups that have examined EMF studies reported in the scientific literature. EPC contractor w i l l implement a Labour Force Management Plan that includes pol icies and procedures on:

- -

Human resources pol icy and information provision to workers Respect for collective agreements and provision o f reasonable working conditions and terms o f employment

- Freedom o f association and collective bargaining - Non-discrimination and equal opportunity - Retrenchment - Grievance mechanisms - - Health and safety - Non-employee workers - Supply chains

Child labour and forced labour

U E T C L has avoided potential ly significant cumulative social effects by routing the 220 kV l i n e t o the Kawanda substation, rather than to the existing Kampala Nor th substation. In Forest Reserve Lands, the normal 40 wayleave w id th w i l l be restricted to 35 m to reduce cumulative effect o f the clearing needed for the wayleaves - at select locations w i ld l i fe corridors w i l l be maintained across the wayleaves.

U E T C L i s working w i t h the Nat ional Forestry Agency on the details o f mit igation and monetary compensation for loss o f trees and associated forestry, ecological and tourism uses.

The enhanced capacity o f bui ld ing a 220 kV capacity line now avoids the need for construction o f an additional line in future as loads and transmission demands grow.

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8.0 Social and Environmental Action Plan

The SEA provides a framework for the Social and Environmental A c t i o n P lan (SEAP) that w i l l be developed fo r the project. At the time the S E A was writ ten, certain detailed planning and design activi t ies relevant to the SEAP were s t i l l t o be completed. Thus, the SEAP i s described at the level o f detai l available at the time o f writ ing. When the detailed activit ies are completed, they wi l l be integrated within the framework o f the SEAP and an update wi l l be prepared and released by BEL. Currently, the SEAP framework addresses the fo l low ing k e y components:

0

0

Moni to r ing activities; 0

0

Social and environmental management policies and systems; Mi t iga t ion plans, procedures, and programmes;

Implementation schedules and cost estimates; and, Plans for integrating the SEAP within the overal l development p l a n fo r the project ,

8.1 Environmental Management

U E T C L i s the project sponsor and wi l l have overal l responsibi l i ty f o r the design and building o f the interconnection system and wi l l be responsible fo r the operation o f the system, and for implementing environmental the social and management measures associated with operation o f the transmission system.

As project sponsor, the ul t imate responsibi l i ty for the project’s compliance with Ugandan and international lender legislat ion and guidelines for environmental and social performance wi l l l i e with UETCL. However, UETCL has retained BEL as i t s Authorised Agent, and as such BEL wi l l be responsible fo r managing the environmental permi t t ing and construction phases o f the interconnection project.

B o t h U E T C L and BEL are committed to executing their respective responsibil i t ies in an environmentally responsible manner and in compliance with a l l applicable environmental laws, regulations, and guidelines.

A contractor, wi l l construct the transmission system o n a turnkey Engineer, Procure and Construct (EPC) basis. This contractor i s referred to as “the EPC Contractor” in the remainder o f this document. F o r the most part day-to-day responsibi l i ty for implementing environmental and social mitigation, compensation and moni tor ing actions related to construction wi l l in many cases be devolved to the EPC Contractor o r to third parties.

The SEAP addresses bo th the construction and operational phases o f the hydropower fac i l i ty for a 30 year period, until UEGCL, or i t s successor, assumes ownership and responsibi l i ty o f the hydropower faci l i ty.

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UETCL and BEL i s committed t o the creation and implementation o f programmes to reduce the probabi l i ty o f occurrence o f deleterious environmental incidents. Contingency plans wi l l be developed for dealing with such adverse incidents, if they occur.

U E T C L and BEL wi l l expect the same level o f environmental performance f rom i t s agents, suppliers, and sub-contractors and wi l l stipulate this in any legal ly binding agreements i t enters with these parties.

8.2 Relationship o f the SEAP t o other Project Plans

The SEAP i s an umbrel la p lan that i s comprised o f several components that are to be integrated and implemented by UETCL and i t s contractors with regard to the IP. These components are shown in Figure ES-57.

Wh i le this SEA includes work ing versions o f three o f the Sponsor’s Ac t ion Plans (namely the PCDP, the APRAP and the RCDAP), those wh ich are the responsibil i ty o f the EPC Contractor, and those o f the sponsor no t inc luded herein wi l l be developed after the EPC Contractor has been appointed at the appropriate leve l o f detai l f o r that stage o f project development. The overal l objective i s t o have f ina l versions ready as needed for their implementation. Consultations and disclosure o f the various plans wi l l occur throughout the process o f their development and implementation.

8.3 Implementation o f the Social and Environmental Action Plan

8.3.1 EPC Contractor‘s Commitments and Resourcing

The EPC Contractor wi l l designate an appropriately experienced and quali f ied Site Environmental Of f i cer (SEO), who wi l l be responsible for implementation o f the measures set out in the Contractor’s EMMP.

The Environmental F ie ld Inspectors wi l l be appointed during the mobil isat ion phase, and wi l l be local s ta f f with relevant environmentaUengineering experience, who are f luent in loca l languages. The number o f f i e ld inspectors may be adjusted according to the environmental issues on-site.

The SEO wi l l have overal l responsibi l i ty for the activit ies o f the Contractor’s Environmental department. On a day-to-day basis the emphasis o f his work wi l l be upon l ia ison with BEL’S Environmental Manager, and with relevant authorities, loca l residents and NGOs o n environmental issues (i.e. external liaison). The responsibi l i ty for day-to-day management o f the f ie ld team wi l l be devolved to the Environmental F i e l d Co-ordinator. The field team wi l l comprise F ie ld Inspectors, supported by drivers and labourers. The Field Inspectors wi l l mainta in a permanent presence on-

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Social & Environmental Action Plan (SEAP)

I

Sponsor’s Action Plan

Regulatory & Management Framework: LegislationPolicies, Environmental Review,

Contractor’s Action Plan

I Change Management I

Monitoring Plan (EMMF’)

-

Plan (F‘CDP)

Hazardous Materials Management Programme (HMMP)

Assessment o f Past Resettlement Activities and Action Plan (APW)

Project Name: Date: December. 2006 BUJAGALI iNTERCONNECTlON

I I I

Figure ES-7 10045.T.ES.6

Resettlement and Community Development Action Plan (RCDAP)

Labour Force Management Plan

Traffic/Access Management Plan (TMP)

4 Waste Management Plan (W)

Labour Force Management Plan ( L F W

Environmental Mitigation & 4 Monitoring Plan (EMMP)

Health & Safety Management Plan (HSMP)

Pollutant Spill Contingency Plan i (PSCP) I

Prepared by: BuRNSiDE

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ES.5 1

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site, carrying out routine checks o f operating procedures and environmental moni tor ing,

8.3.2 Reporting l ines and Decision-Making

O n a quarterly basis, the SEO wi l l prov ide the Environmental Manager with a report containing moni tor ing results (and a summary o f these), a synopsis o f environmental issues encountered, and the eff icacy o f solutions to these issues. The Environmental Manager wil l u s e these as the basis fo r UETCL;s quarterly environmental reports. UETCL’ s quarterly reports wi l l also include commentary o n the implementation and eff icacy o f environmental mi t igat ion actions implemented by UETCL.

The Environmental Manager wi l l develop annual environmental reports suitable for submission to NEMA (as a requirement o f the Ugandan Environmental Impact Assessment Regulations) and to other stakeholders as appropriate. This wil l provide an opportunity for NEMA and stakeholders to comment bo th o n the impacts o f the project i t se l f and the eff icacy o f the SEAP. Where necessary, the SEAP wil l be updated.

8.3.3 Social and Environmental Auditing and Reporting

Auditing o f the environmental compliance o f the pro ject wi l l be carried out at two levels: internal and external.

UETCL wil l specify procedures fo r annual internal audits as par t o f the SEAP, and any other environmental requirements, such as those imposed by NEMA and/or the international lenders. The responsibi l i ty for implementing these audits wi l l l i e with the Environmental Manager, who may elect to employ external Consultants.

External audits o f EPC Contractor’s environmental compliance wi l l be carried out by UETCL, and potential ly by representatives o f NEMA and the W o r l d Bank/ IDA.

I t i s a requirement o f NEMA and the lenders that annual environmental reports (‘self- auditing’) be submitted for review. The Environmental Manager wi l l be responsible for compi l ing and submitting these reports, and wi l l consult with NEMA to determine any addit ional mi t igat ion measures or moni tor ing that i s considered to be required. Self-audit reports wi l l be compiled f rom internal and external audits carried out by both UETCL and EPC Contractor. I t should be noted that the EIA Regulations require the names and qualif ications o f persons carrying out ‘self-auditing’ t o be approved by the Executive Di rector o f NEMA. Therefore the Environmental Manager and the SEO wi l l have to be approved by NEMA before o f f i c ia l appointment.

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Issue

Staff ing fo r SEAP Implementat ion

ES.53

Responsibilit Estimated Actionls Timing

Y Cost (USD) U E T C L -

250,000 Recrui t SEAP Months 1-3 after Implementat ion Team Financial Close Implementat ion Manager

8.3.4 Change Management

Labour Force Management

During the implementation o f the project, change may be required to address unforeseen or unexpected condit ions or situations. A change management process wi l l be applied to ensure environmental and social issues are addressed as par t o f any significant changes to pro ject procedures, processes, design or activit ies. B o t h UETCL and the EPC Contractor wi l l be responsible fo r managing changes within their respective areas o f responsibi l i ty.

Develop EPC Months 1-3 after Within EPC Contractor’s L F M P appointment

8.4 Responsibilities for Social and Environmental Mi t igat ion Measures

Table ES-4 be low outlines the overa l l package o f environmental m i t iga t ion measures that wi l l be implemented in re la t ion to the Bu jaga l i interconnection system. The table also assigns general responsibil i t ies fo r implementing each group o f mi t iga t ion measures, and prov ide budget estimates and locations fo r each. A detailed implementation schedule wi l l be developed once the EPC Contractor i s selected and further detailed p lanning i s completed.

Consistent with the Bujagal i Project’s contracting strategy o f integrating environmental protection and mi t iga t ion activit ies in to the EPC Contractor’s Scope o f Work, the specifications fo r many o f the activit ies wi l l be inc luded in the bid package upon wh ich the EPC Contractor wi l l develop i t s base rates.

I Implement A P R A P Resettlement Corrective Actions

Communi ty Development I Implement R C D A P

I Implement R C D A P Land Acquis i t ion and Resettlement

Publ ic Consultation/ Community L ia ison Implement PCDP

Labour Force Management

Develop Sponsor’s L F M P

Year 1 after Financial Close

Preconstruction and Construction

Preconstruction

Throughout Construction Phase

Months 1-3 after Financial Close

I 40,000 I U E T C L - Social Unit

I 300,000 I U E T C L - Social Unit

I 16,643,663 I U E T C L - Social Unit

Inc luded in salary fo r SEAP

implementat ion

U E T C L - Communi ty L ia ison Manager

U E T C L - H&S/HR Managers

20,000

M i t i ga t i on o f b iophysical impacts - not construction-

I I

Implement S E M M P I Manager) I I

R.J. Burnside International Limited 1.A 10045

ES-54

~~ ~

Issue

related

M i t i ga t i on o f b iophysical impacts -construe t ion-

Uganda E lec t r i c i t y Transmission Company l i m i t e d

Bujagali Interconnection Project Social and Environmental Assessment - Executive Summary

December, 2006

Responsibilit Estimated Y Cost (USD)

Actionls Timing

U E T C L

Manager) U E T C L

Manager)

Construction Phase (Environmental 25,000

W i t h i n above salaries

‘perations Phase (Environmental (first 2 years)

Implement Throughout EPC Contractor Within EPC Contractor’s EMMP Construction Phase (SEO) contract pr ice

8.5 Responsibilities for Environmental Monitoring Measures

The SEAP outlines the overa l l package o f environmental mon i to r ing that wi l l be carried out in re lat ion to the Bu jaga l i IP. The SEAP also assigns responsibil i t ies for each moni tor ing activi ty, and proposes parties who are capable o f carry ing out the monitoring, o n beha l f o f the responsible body.

I t should be noted that, consistent with the strategy o f integrating social and environmental protection and mi t igat ion activit ies in to the EPC Contractor’s Scope o f Work, the specifications fo r many o f the construction-related mon i to r ing activit ies were included in the bid package upon wh ich the EPC Contractor i s developing i t s base rates. Therefore i t i s no t possible to present a detailed accounting o f a l l the monies devoted t o the project’s environmental moni tor ing activi t ies during the construction phase.

R.J. Burnside International l imi ted 1.A 10045