strategic environmental assessment (sea) …and biodiversity. this document presents a report on...

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

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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:


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

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;

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.

(Source: PEPD)

Figure 1.1: The status of oil and gas licensing in the Albertine Graben (as of February 2013)

(Source: NEMA, 2012)

Figure 1.2: The wider area with Lake Albert, major roads, district borders and settlements

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

http://en.wikipedia.org/wiki/Fuel_oil

http://en.wikipedia.org/wiki/Petrochemical

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

Four out of ten exploration areas in the Albertine Graben have been licensed to international

oil companies


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.

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



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.



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


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.

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.

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).

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!

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.

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



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

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).

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

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.

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.

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.


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

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.

(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.

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.

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

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.

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.

(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

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

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

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).

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

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.

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).

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

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.

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

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.

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

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.

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.

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.

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.

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.

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.

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.

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:

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:

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

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

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.

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.

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”.

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.

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

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.

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.


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.

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.

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:








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.

Key Issues Group 3: Co-existence with Archaeology and Cultural Heritage

Key Issue.


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

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.


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.

Recommendations:

There should be regulations on the maximum acceptable disturbance levels of oil and gas

activities taking the tourism sector views into consideration.


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.


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.

Key Issues Group 7: Sharing of Revenues and Wellbeing between the National and the Local /

Regional level. Co-operation

Key Issue.


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.

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.).

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.


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.

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 .

Key Issues Group 11: Oil Spill Preparedness on Land and in Surface Waters

Key Issue.


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.

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.


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 .

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.


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.

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


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.

Key Issues Group 16: Land Use and Spatial Planning

Key Issue.


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.

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.


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.

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:



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

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).

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

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.

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

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.

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

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






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 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

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.

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

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

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.

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.

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.


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

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.

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



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.

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

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

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.

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

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.

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.

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

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.

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

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

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.

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

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

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


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.

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

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

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.


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.

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.

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.

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

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


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

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

Table 7.2: Key Issues Group 2 - Co-existence with Local Communities


1. Local communities will experience opportunities as well as risks. The capacity to adapt to the







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


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


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.


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



and analysis described in the

AG EMP shall be used for

monitoring.


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


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.

NOGP Actions

No actions are mentioned


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.



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


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


The indicators, data collection and

analysis described in the AG EMP

shall be used for monitoring.



with its key objectives to create a

publicly available, efficient and


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

Table 7.4: Key Issues Group 4 - Co-existence with Other Industries and Service Providers


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


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.



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


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.


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


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.



NOGP Actions



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.



Institutions

Risk of loss of business for tourism sector Co-existence mechanisms PEPD and other

relevant

institutions and

the tourism sector


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





create a publicly available,


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


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



NOGP actions



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.



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.


and analysis described in the AG

EMP shall be used for monitoring.






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


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




Efficient resource management promotes efficient revenue management by ensuring that

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)


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.



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.

Table 7.8: Key Issues Group 8 - Discharge and Emissions for the Petroleum Industry


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






activities on environment and biodiversity.


practices in ensuring environmental protection and biodiversity conservation.




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.


NOGP Actions

Upgrade relevant environment and biodiversity legislation to address oil and gas activities.





Sustainability and compatibility testing


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.



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


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.


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


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


environment.




activities on environment.


practices in ensuring environmental protection.






NOGP Actions

Upgrade relevant environment legislation to address oil and gas activities.







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.



Regulations Waste management

regulation.

NEMA and other relevant institutions

Waste facilities Central waste treatment and

disposal facilities following

international standards


Waste operators Audit requirements

Compliance monitoring.


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


and analysis described in the

AG EMP shall be used for

monitoring.




NEMA, NaFIRRI/DFR, NFA, DWRM, DWD, Wetlands Management Dept., Physical Planning Dept., Surveys and Mapping Dept. and other relevant institutions

accordance with the plan. create a publicly available,


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


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


environment.












NOGP Actions





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.



Regulations Review of National Water Policy

and related regulations

DWRM, DWD


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.


analysis described in the AG EMP







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


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


environment.












The Polluter-Pays-Principle shall apply.

NOGP Actions





the oil and gas producing region and any transport corridor.


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.



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

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




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)


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.



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


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)


the environment and biodiversity (Objective 9)


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

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.



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


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


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





NOGP Strategy







- Ensuring the presence of the necessary capacity to monitor impacts on environment and

biodiversity

NOGP Actions

Train government personnel in monitoring oil and gas exploration, development and production

Require oil companies and subcontractors to provide training to Ugandans


Strengthen the institutions with a mandate to manage the impacts of oil and gas activities on the

environment and biodiversity (Objective 9)


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.



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


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





NOGP Strategy







- Requiring oil companies and their contractors/subcontractors to use self regulation and

best practices in ensuring environmental protection.

Requiring oil companies and any other operators to make the necessary efforts to return all




The Polluter-Pays-Principle shall apply.

NOGP Actions



the environment and biodiversity (Objective 9)


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.



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


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




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

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


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)


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.



Availability of regional physical

development plans for AG and

other areas

Plans

Stakeholder involvement

Ministry of Lands,

Housing and Urban

Development

Table 7.17: Key Issues Group 17 – Transboundary and International Issues


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


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.



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

Table 7.18: Key Issues Group 18 - Establishment of Transparent Baseline Data and Scientific Basis


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


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.



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

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

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.

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:



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.

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.

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

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.)

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).

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


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



new sector.






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.






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

industry is undermining these values. The sectors should establish common communication

platforms where relevant concerns can be resolved.








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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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).

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.

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.

http://en.wikipedia.org/wiki/Latin

http://en.wikipedia.org/wiki/Greek_language

http://en.wikipedia.org/wiki/Latin_language

http://en.wikipedia.org/wiki/Flammable_liquid

http://en.wikipedia.org/wiki/Hydrocarbon

http://en.wikipedia.org/wiki/Organic_compound

http://en.wikipedia.org/wiki/Formation_(stratigraphy)

http://en.wikipedia.org/wiki/Earth

http://en.wikipedia.org/wiki/Fossil_fuel

http://en.wikipedia.org/wiki/Zooplankton

http://en.wikipedia.org/wiki/Algae

http://en.wikipedia.org/wiki/Sedimentary_rock

http://en.wikipedia.org/wiki/Oil_drilling

http://en.wikipedia.org/wiki/Boiling_point

http://en.wikipedia.org/wiki/Petrol

http://en.wikipedia.org/wiki/Gasoline

http://en.wikipedia.org/wiki/Kerosene

http://en.wikipedia.org/wiki/Asphalt

http://en.wikipedia.org/wiki/Reagents

http://en.wikipedia.org/wiki/Plastics

http://en.wikipedia.org/wiki/Pharmaceuticals

http://en.wikipedia.org/wiki/Petroleum_industry

http://en.wikipedia.org/wiki/West_Texas_Intermediate

http://en.wikipedia.org/wiki/Brent_oilfield

http://en.wikipedia.org/wiki/Oman

http://en.wikipedia.org/wiki/API_gravity

http://en.wikipedia.org/wiki/Light_crude_oil

http://en.wikipedia.org/wiki/Heavy_crude_oil

http://en.wikipedia.org/wiki/Sweet_crude_oil

http://en.wikipedia.org/wiki/Sour_crude_oil

http://en.wikipedia.org/wiki/Hydrocarbon_exploration

http://en.wikipedia.org/wiki/Extraction_of_petroleum

http://en.wikipedia.org/wiki/Oil_refinery

http://en.wikipedia.org/wiki/Petroleum_transport

http://en.wikipedia.org/wiki/Oil_tanker

http://en.wikipedia.org/wiki/Pipeline_transport

http://en.wikipedia.org/wiki/Fuel_oil

http://en.wikipedia.org/wiki/Petrochemical

http://en.wikipedia.org/wiki/Upstream_(oil_industry)

http://en.wikipedia.org/wiki/Midstream

http://en.wikipedia.org/wiki/Downstream_(oil_industry)

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

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

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

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.

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.


Minimise footprint

Avoid in-migration


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


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 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


Minimize duration

Minimize interference with local population (sex workers, poaching, fishing, etc.)

Stakeholder engagement

Petroleum Activity


Mitigation


Interactions workforce – local people


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 and interference with local people (noise, air emissions)

Safety risks related to storage

Environmental risk related to storage (spills)


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


Erosion and changes to surface hydrology

Disturbance due to transportation

Traffic density and safety

Impact on local infrastructure



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


Loss of land use





Short- medium-term, transient

Proper site selection process

Minimization of footprint

Restriction of working hours (if close to local population)

Petroleum Activity


Mitigation

Traffic density and safety risks




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,


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


Proper maintenance and surveillance.

Choice of technology according to BAT


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


Proper route selection

Petroleum Activity


Mitigation


Pipeline construction

Linear footprint

Emissions

Discharges

Wastes

Vehicle movements

Workforce presence

Construction camps

Potential blasting activities (depending on terrain)

Loss of habitat


Loss of land use

In-migration of job seekers / secondary effects



Increased traffic density and safety risks

Impact/demands on local infrastructure



Noise, air, light emissions, vibration

Visual intrusion




Workforce management

Camp management


Local content strategy

Dust suppression

Precommissio-ning

Water abstraction

Discharge

Emissions

Resource conflicts (water)

Risk of contamination & erosion from discharge


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



Local benefit sharing agreements

Environmental and social investment planning

Proper emergency response planning

Decommissioning/reinstatement

Emissions

Discharges

Wastes

Vehicle movements

Workforce

Camps







Same as for construction

Refining Roads Access Loss of habitat


Loss of land use





Petroleum Activity


Mitigation




Traffic density and safety




Site preparation and construction

Footprint

Vehicle movements

Workforce presence

Emissions

Discharges

Wastes

Loss of habitat


Loss of land use









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


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




Waste management plan



Environmental and social investment plan

Petroleum Activity


Mitigation


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.

Table 2: The offshore (lake) oil and gas activity chain, associated aspects and potential impacts

Petroleum

Activity


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.)



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


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

Petroleum

Activity


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


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


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




Stakeholder communication and grievance mechanism


Local content development

Petroleum

Activity


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)


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


Land use conflicts at landfall

Resource conflicts



Stakeholder communication and grievance mechanism

Precommissio-ning

Water abstraction

Discharge

Emissions

Risk of contamination and erosion due to discharge


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


Pipeline either filled and left in place or taken out

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

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



1. Review of

documentation

4. Scenario

analysis

2. Evaluation

by expert teams

3. Stakeholder

opinions

Conclusion on

Key Issues

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




New activitiesPhase 1

Ongoing fromPhase 1




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.

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.

The following figure/map illustrates the main components related to the Phase 1 Scenario.

Figure 3: The Phase 1 Scenario, 2012 – 2015

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).

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).

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”.


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.


Below are the remaining activities of Phase 1 which will continue in Phase 2:

EWT (still to continue for some years).


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.


Operation of regional construction base around Hoima.

Operation of supply bases.

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.

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.

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.



employees, relevant expertise and O&G expertise, equipment for tasks demanded,

laboratory, monitoring facilities and equipment, regulations, guidelines):


MAAIF, NFA, etc.




Local level: community organizations and associations, hygiene officers (village health

teams), farmer groups etc.


fighting, etc.).

Capacity of cultural institutions (kingdoms, etc.).

Capacity of NGOs, CBOs, etc.

Extensive cumulative impacts of all activities.


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.


TIMELINE


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.


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.


Below are the remaining activities of Phase 1 and 2 which will continue in Phase 3:

Extended Well Testing (EWT).


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.


Operation of the base outside Hoima.


Delivery of HFO from the refinery to the IPP via pipeline (operated by 100 employees according to pipeline study).






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.

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.


Figure 5: The Phase 3 Scenario, 2017 to 2022

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


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.


Air and noise pollution from refinery, IPP and transportation.

Production activities in protected and sensitive areas.

Institutional capacity to manage and supervise activities.


Cultural heritage.





MAAIF, NFA, etc.





teams), farmer groups.


fighting, etc.).



Cumulative impacts of all activities


Petroleum generated revenues and expansion of social programs



Further improvement of infrastructure (roads, hospitals, etc.).



More supplies of fuel and diesel substituting imports.

Foreign exchange savings.



TIMELINE


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.


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.


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.


Operation of regional construction base around Hoima.


Delivery of HFO from the refinery to the IPP via pipeline.





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.

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.


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.


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.


Emergency response and security.

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.


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.





MAAIF, NFA, etc.

District level: environment Officers, natural resources management officers, water




teams), farmer groups.


fighting, etc.).


Institutional capacity to manage and supervise activities.




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.


Petroleum generated revenues and expansion of social programs



Improvement of infrastructure (roads, hospitals, etc.).



More supplies of fuel and diesel substituting imports.

Foreign exchange savings and earnings.


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.

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.

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.

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.

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



Butiaba Beach Management Unit

Fisheries manage-ment

11/27/ 2012

BMU Ofices/ landsite

Meetings Fisheries management




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










Hoima Municipality

Issues of capacity of the district & environment management

11/26/ 2012

Hoima Municipality officies





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


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






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


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


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






Ministry of Local Government

SEA action key isues

24/10/ 2012

Workers House, Level 4


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






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


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






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


clarifications on scenarios and feasibility, export pipeline requires > 250,000 b/d


Tullow Oil Discussion on scenario analysis

27/06/ 2012

Tullow offices

presented info + discussion


clarifications on scenarios and feasibility


Uganda Association for Impact Assessors (UAIA)

EIA quality control, capacity for oil and gas EIAs

11/07/ 2012

Hotel Protea


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






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


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






WWF Discussion on the key issues of consultation

12/11/ 2012

WWF country Offices


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


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)

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

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

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.

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.

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:

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.

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

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.

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.

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

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.

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

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.

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.

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)

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

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.

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.

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.

• 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)

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

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)

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

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

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

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

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

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

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.

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.


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

NFA programs and projects

- Community tree planting

- REDD+

- Payment for Ecosystem Services (PACE) being carried out by NEMA and Chimpanzee Sanctuary


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

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.


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

Key Issues Group 2: Co-existence with Local Communities Including Indigenous Peoples



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


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

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

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



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

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


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 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,

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)

Key Issues Group 5: Co-existence with Tourism



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.

Key Issues Group: 6: Co-existence with Fisheries



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

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;


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)


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).

Key Issues Group 7: Sharing of Revenues and Wellbeing between the National and the Local/Regional level Cooperation



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 :



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.

Key Issues Group 8: Discharges and Emissions from the Petroleum Industry



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



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 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):

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

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.

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)


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

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



1. Infrastructure Needs 2. Existence of necessary public

infrastructure to meet the petro development

Transport Sector plans and strategies (Refer also to Scenario analysis)


Ministry of Works and Transport

Uganda National Roads Authority

National Planning Authority


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

Key Issues Group 13: Institutional Capacity Building, Structure and Functions



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 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.

Key Issues Group 14: Capacity of District Local Governments to manage Environmental Concerns



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 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



UNRA

NEMA

DWRM


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.

Key Issue Group 15: Development of Legislation and Regulations; standards



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)

Consulted Stakeholders:


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



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:

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



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)

Key Issues Group 18: Establishment of Transparent Baseline Data. Scientific Basis



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:


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.

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.

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.

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


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)



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.

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


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)



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.

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

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 3b Export only -via railway


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


- 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 2 60,000 bbls/d refinery only




High High

High High

Medium Low

Medium Medium


High High Low

High High Low

Medium - Low

Medium - Low


Waste volumes High High Low Low



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


High High X

High High X

Medium Low X

Medium Medium X

Phase 4 - Scenario overview matrix (end 2022 – 2030)


Scenario 2 120,000 – 300,000 bbls/d refinery only




Low High

High High

Low Low

Low Medium


Low Low -

High Low -

Low - -

Low - -


Waste volumes Medium High Low Low

Disturbance of protected and sensitive areas and biodiversity


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


High Medium X

High High X

Medium Low X

Medium Low X

APPENDIX 9: PETROLEUM INDUSTRY IMPACTS IN

ENVIRONMENTALLY SENSITIVE AND PROTECTED AREAS

Typical primary and secondary impacts related to petroleum activities in environmentally


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

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


Killing or maiming of wildlife by vehicles

Impedes revegetation

Land-take and presence Disturbance/destruction of local habitats and animals


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

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)


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


- Ecological alterations through removal of keystone species

Local commerce with communities


Elimination or decreased populations of local species, possibly leading to extinction of the species

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.

• 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,

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.

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

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.


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


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


Jane Bemigisha Environmental information, planning and policy expert

International experience in institutional capacity assessment and development

Assistant local team leader

Support to report production


Dismas Ongwen Archaeology and cultural heritage

NEMA certified EIA practitioner


Eseza Kateregga Natural resource and Environmental Economics


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


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


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

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

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.

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.

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.

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 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.





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.


Sharing of revenues with traditional rulers has

not been adequately outlined.






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.

















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.





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.





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.





The recommendations for Infrastructure

development and transportation of crude,

products and construction material do not

include UWA.

This is now integrated into the SEA.





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.

Petroleum Authority.

Local governments do not have a clear

structure and no link with the Ministry of

Energy.


The capacity gap at the local government

includes expertise, resources, etc. and these

should be improved.


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.





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.





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 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.





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

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.


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.


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.


Cultural awareness training for people coming

from the outside is required to avoid tension.


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.

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.

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.

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.

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

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.