PS5 Land Acquisition and Involuntary Resettlement does not apply because no new land will be acquired as part of the project. The land for the hydropower project was acquired in 2002 under the project that was approved by the IFC Board in 2001 and subsequently made available to BEL.   An owner of one piece of land has still not been compensated from this time because of a family dispute that was only recently settled in the Ugandan courts.  UETCL has reached an agreement with him on the amount of compensation, and IFC will confirm that UETCL pays him the agreed amount. CAO complaints Bujagali 05 and 07 have been described in the Scope of Review section above and both relate to UETCL compensation processes for the transmission lines built simultaneously to the project. Any further mitigation action arising from these cases would be the responsibility of UETCL. The transmission line was considered an associated facility under the 2006 ESRS, mostly driven by the World Bank decision to consider it an associated facility under the Bank’s safeguards policies. With many upgrades to the grid, Bujagali HPP now has many options to evacuate power. Furthermore, Nalubaale (180 MW) and Kiira HPP (200 MW) (also known as the Owen Falls dams) have been using the T-line to evacuate their power in addition to the old transmission lines. Thus the status of the T-line as an associated facility is now no longer valid. It should be noted that the Isimba HPP (under construction) is expected to evacuate its power through the Bujagali switch-yard and the transmission line.

PS 7 Indigenous People does not apply because the people living on either bank of the Nile do not fall under the definition of an indigenous people. 

PS 8 Cultural Heritage does not apply because there will be no physical change in the project footprint and because there are no ongoing impacts on cultural heritage.

The existing project, Bujagali Energy (#24408), was categorized as an A. Although this refinancing will result in no new environmental and social impacts and the operational risks of the HPP are lower than the construction phase risks and impacts that led to the original categorization, the original A category will be retained. This categorization reflects the large size and relative importance of this project to Uganda and to IFC, in addition to the potential significance of certain ongoing risks, notably in relation to aquatic ecology.

  BEL, as owner of the Bujagali HPP, has overall responsibility for the environmental and social performance of the facilities. BEL has approximately 10 employees who are primarily engaged in administrative and management activities. The O&M operator, OME, has approximately 41 employees who undertake the day-to-day operations and maintenance activities for the dam and the power station.

Environmental and Social Assessment and Management System

BEL and its O&M operator have put in place robust environmental and social management systems. BEL has adopted an environmental policy as well as a safety policy and a social policy. These policies clearly delineate BEL’s commitments in these three areas. The policies also clearly define the expected capabilities, qualifications and performance expectations for the O&M operator, as well as other minor contractors.  Given that these documents are five years old, BEL should review them to see whether they need to be updated (ESAP item 1).

Consistent with its Environment and Social Policies, BEL has established and maintains an Environmental and Social Management System (ESMS) that is of a form and substance consistent with good international industry practice and IFC’s Performance Standard 1. OME, likewise, has its own management systems that are consistent with BEL’s policy, ESMS, and associated Environmental and Social Management Plan (ESMP).  It consists of a combination of the corporate polices and plans of GNF and the policies and procedures that are specific to OME’s responsibility for the Bujagali HPP. These management systems have been independently reviewed and have been registered as fulfilling the requirements of the following standards:

• ISO 14001:2004 Environmental Management Systems
• ISO 9001:2008 Quality Management System
• OHSAS 18001:2007 Occupational Health and Safety Management System

OME falls under these certifications and, thus, has been the subject of specific audits that feed into the overall review.  BEL’s ESMS does, however, need to be reviewed to ensure that it is updated, but also to identify policies and procedures that are in place but not formally documented within the system (ESAP item 2).

Identification of Risks and Impacts

OME has a procedure for “Identification and Evaluation of Environmental Aspects.” This procedure defines the system to identify, assess, and record the environmental aspects that it can control or influence, caused by the development of its activities, to determine which have or could have significant impact on the environment. The identification of risks is to be updated yearly, or whenever a triggering event occurs, including if any change occurs in the activities undertaken, any emergency situation or accidents, change in law, and complaints.

Organizational Capacity and Competency

As indicated above, OME is part of GNF, which has responsibility for operation and maintenance of approximately 100 power plants. At the corporate level the safety, health, environment and quality (SHEQ) management system has approximately 130 regulations, procedures, and standards. This provides a substantial knowledge base that OME draws upon for its local plans and procedures.

At Bujagali, OME has a Safety, Health, Environment and Quality (SHEQ) Manager, who reports to the Plant Manager. The SHEQ manager is supported by a SHEQ Specialist. Both of the individuals in these positions have training and experience suitable for their roles and responsibilities.

Emergency Preparedness and Response

OME and BEL have undertaken risk assessments to identify potential emergency situations including fire, internal flooding, river flooding, hazardous material incident, workplace violence and civil unrest, vehicle accident emergency response, earthquake, and electrical shock. There are clear, escalating procedures to be followed in case of minor emergencies, partial emergencies, and total emergencies, including lines of authority, and channels of communications internally and externally. Finally, the plan specifies equipment needs, type and frequency of drills, and staff training.

Monitoring and Review

OME’s internal monitoring and record keeping are well established and defined within the environment, quality and safety management systems. OME generates a monthly report that is submitted to BEL that includes, among other things, commentary and statistics on: safety, health, quality and environment; security; training; and corporate social responsibility.  OME’s SHEQ management system is monitored through the (GNF) computer system, which allows any senior manager, either local or in headquarters, to review information and statistics about the performance of the operation at Bujagali.  OME also carries out on-site monitoring through various mechanisms, including peer audits, in which managers from other GNF operations review those at Bujagali.

In addition, and in keeping with the conditions of approval issued with the certificate of environmental approval issued by the National Environmental Management Authority (NEMA), BEL commissions a yearly, independent, environmental audit, the terms of reference for which are approved by NEMA and the report from which is submitted to NEMA.  To date, six independent audit reports have been released, with the most recent being in March 2017. This most recent audit confirmed that the HPP is being operated in compliance with the conditions of approval as set out by NEMA in the Certificate of Approval. This audit also identified a few issues (e.g. observing speed limits, slope erosion potential due to some planted areas not being completely regenerated, hygiene of sanitary facilities) and provided the recommendations to BEL and OME. Furthermore, this audit found that some portions of river banks outside BEL jurisdiction are being opened up for agricultural development or construction by third parties, with possible impacts on water quality within BEL managed areas. This audit noted that though BEL bore no responsibility for corrective action on this issue, it was recommended that BEL raise this issue with local and national level authorities to highlight the need for government agencies to take action to reverse and prevent such encroachment. BEL has however taken an effort to stabilize all river banks within its jurisdiction that are prone to erosion or landslips.

  BEL has a total of 10 employees working directly for the company.  It has an extensive human resources policy that provides detail on the procedures for hiring and onboarding, working hours and remuneration, leave entitlement, performance management, and disciplinary actions.  The policy has an explicit link to the laws of the Republic of Uganda.  The policy has a clear statement on equal opportunity and non-discrimination that covers race, tribe, political affiliation, religion, gender, and physical condition and/or status.   BEL has a worker grievance mechanism that is combined with the community grievance mechanism and a clear procedure for disciplinary actions. BEL will review the mechanism to identify any specific actions appropriate to just its workers (ESAP item 4). As will be discussed below, OME does have a worker grievance procedure as part of its HR Manual.  Thus, BEL does not need a procedure to cover third party workers. As indicated in the ESAP item 5, the company will ensure that workers for OME are made aware of OME’s grievance procedure and its workings.

Occupational Health and Safety

BEL follows OME’s occupational health and safety standards and procedures within the project fence.  As noted in the section on PS 1, OME is under the OHSAS 18001 certification of its parent company, GNF.  The relevant documents include procedures for safety anomalies, management of worker authorization (i.e., permit to work), definitions of conditions and protective measures for work, list of isolation actions, health and safety standard management and use of PPE (personal protective equipment), preventative safety observation, and accident and incident communication, investigation and follow-up process.  Collectively these standards meet the requirements of Performance Standard 2.  OME and BEL have not reported a single lost time accident on site since the beginning of full operations in 2012, although OME workers have been involved in two off-site traffic incidents, one in 2012 and one in 2015. No fatalities have been recorded since operations began.

Workers Engaged by Third Parties.

OME’s integrated management system allows them to operate in conformance with the     requirements of PS 2.  The human resources policy is provided to workers when they are hired.  The policy is based on Ugandan law and includes the terms and condition of employment, non-discrimination, and human rights.  Some OME workers have belonged to a labor union, Uganda Workers Electricity Union, since 2014. The concerns of workers are collected through an annual working climate survey and periodic departmental meetings. Workers’ concerns can also be expressed online.  These online expressions are sent directly to GNF’s headquarters in Madrid, which then passes them back to the site without attribution.  A suggestion box is also visible at the project site.  The human resources policy does mention grievances but does not provide information about how to file a grievance and what the procedure is once it is received.  To ensure that workers are clear about grievance procedures, a clear statement of the grievance procedure will be available to them (as per ESAP Item #5). OME carries workers’ compensation insurance as required by Ugandan law.  OME ensures that workers are aware of their eligibility and the procedures for filing by periodically bringing representatives of the insurance company onsite to speak to the employees.

  Construction of the facility was completed in 2012 and the project is now fully operational. Thus, emissions and discharges to the environment from the facility will be due to operations and maintenance activities. As an operating hydroelectric facility, the quantity of emissions and discharges are relatively small, consisting of treated waste-water. The untreated wastewater is primarily greywater and blackwater from kitchens and lavatories, and water from sumps and internal drains. Likewise, the use and qualities of hazardous materials is relatively small, and rate of generation of wastes is relatively low. A comprehensive waste management plan outlining sources of pollutants, pollution control and mitigation measures as well as spill prevention and emergency response plan and monitoring activities are in place. Sources of waste in HPPs include hazardous wastes from maintenance activities, scrap materials from replacement programs, and domestic solid waste. These wastes are managed in accordance with the project specific waste management procedures.

Resource Efficiency:

The facility generates electricity from renewable hydro-power and, in this sense, is resource efficient.  Its operation allows Uganda to minimize use of non-renewable sources of electricity. The dam has created a reservoir extending 8 km upstream to the Nalubaale and Kiira HPP facilities located at outlet of Lake Victoria. The reservoir created by the dam is relatively small because the water is contained within the steep banks of the Victoria Nile. At 388 ha, the surface of the reservoir is only 88 ha greater than the 300 ha surface area of the river as it existed prior to the dam. The facility can be considered as ‘highly resource efficient’ based on the amount of energy generated per unit of land flooded.

Water

The facility’s primary use of water is for generation of electricity. The flow of the Nile is passed though turbine generators to generate electricity. In doing so the water is not treated or processed in any way. Small volumes of potable water are purchased and imported to site as bottled water. Small volumes of water are also required for operation of the power plant, as well as the kitchen, toilets, cleaning, landscaping and fire fighting. For these needs water is taken from the river. BEL’s Surface Water Extraction Permit, which allows for extraction of up to 116,000,000 m3 of water per day, was issued on 01 January 2015 and is valid for a 5 year period (renewable).

GHG Emissions

The quantity of greenhouse gas generated by the decomposition of biomass in the reservoir was analyzed as part of the 2006 SEA. The analysis estimated that the reservoir would generate a total of 76,500 tonnes of CO2 for the life of the project. This is considerably less than the estimated 1,1870,000 tonnes of CO2 per year the same analysis predicted would be generated by an equivalently sized thermal power plant.

Pollution Prevention

The O&M operator has identified potential sources of pollutants, including fuel storage tanks for the back-up generator, oil in the main step-up transformers, and storage areas for chemicals and wastes. Secondary containment is provided for potentially contaminating material, including fuel storage tanks and transformers, and spill response materials and procedures are in place to contain and clean up inadvertent releases.

Air Emissions and Ambient Air Quality

The only point sources of emissions to air at the facility is a 1.5 MW diesel-fueled, back-up generator set near the powerhouse and a 400 kW diesel-fueled, back-up generator set in the switchyard. The generators serve as back-up generators to be run only in the case of an emergency, and for periodic, short-duration testing. For this reason these are not considered to be a significant source of emissions to air, and overall the facility is not considered to have a direct impact on air quality. The facility has a direct benefit in reducing the overall load of emissions to air contributed by the power sector in Uganda by offsetting the need for the country to rely on diesel-fueled power generation.

Wastewater Treatment

The O&M operator has identified the wastewater streams and implemented controls and treatments to protect water quality in the receiving environment. Within the plant all drainage and seepage potentially contaminated by oils, greases or other material, including drainage from fuel storage tank areas and from the 6 main step-up transformer units area is collected and treated using gravity flow, three-chamber, oil-water separator units. Treated water that has passed through the units is released to the river. Oil and grit trapped by the units is periodically removed and containerized for treatment off-site. Sewage effluent is collected and treated in a system consisting of a prefabricated septic tank and a constructed percolation bed. Monitoring of water quality in the river has not identified any significant elevations in contaminants.

Hazardous and Solid Waste Management

The O&M operator has established and implemented waste management procedures that include separation of waste streams, storage and labelling, removal, and verification of capability and licenses of treatment and disposal contractors. Hazardous materials on site include fuel for the back-up generator, cooling oil in the step-up transformers, paints, solvents, lubricants, pesticides, and other chemicals. There are also cylinders of compressed gas (including CO2 for fire-fighting). The O&M operator has established and implemented procedures for managing flammable and combustible fluids, and handling and use of hazardous chemicals.

Pesticide Use and Management

There is no large-scale application of pesticides as part of operations. Pesticides may be used at the site in small qualities for control of insects (insecticides) and vegetation (herbicides). The O&M operator has developed and implemented a “Prevention of Breeding of Vermin and Other Pests at the Site” procedure that includes guidance for non-chemical controls and, where warranted, guideline on selection and use of insecticides and herbicides, including safe work practices. The O&M operator’s general procedures for chemicals also applies to the storage, transport, handling, use and disposal of pesticides.

  Community Health and Safety

The project has reduced the risk from accidental drowning in this stretch of river due to the change from falls (rapids) to calm water.  The greatest risk comes from fishers approaching the dam.  Additional signage and education will be needed to make people aware of the dangers of coming too close.  The dam does have a warning siren when gates are opening.  Community leaders and downstream fishers are aware of the meaning of the sound, but some younger users of the reservoir are not as aware.  To increase awareness, the company will place additional signage and distance indicators near the dam to warn away fishers and youth from entering the safety zone, as indicated in the project ESAP item 6. 

Infrastructure and Equipment Design and Safety

Reviews of the dam design and construction by a three-person panel of independent dam safety experts provided reassurance of the safety of the Bujagali structure.  As minor questions have arisen, BEL has brought in independent expertise to review the risks.  The major risk comes from a potential earthquake or a problem with the upstream Kiira and Nalubaale dams.  The project has installed a seismometer to identify earthquakes.  An early warning system will be placed near the tailrace of Kiira to warn against sudden rises in the water level upstream. The early warning system will automatically dial the phone of the O&M operator, as well as BEL and other officials.  If the operator does not respond within a short period of time the system will automatically control water discharge to reduce the risk of overtopping of the dam. BEL does need to update its training with respect to emergency procedures as a result, but also to ensure that people remain familiar with the warning siren associated with opening the gates on the dam (ESAP item 7).

Security Personnel

A large police and military presence is on site at the direction of the Ugandan government.  Bujagali is considered a strategic national asset, and the police and military presence is there to protect it.  BEL does not have a formal agreement with either entity, although it does provide an allowance to both.  Both entities follow OME’s health and safety requirements when present in the actual power plant.  OME does have unarmed security at the gate to the power plant to control access.  Local leaders have not seen any issues with either the military or police.  Indeed, the army commander has served as a neutral mediator between communities.  The main security issue to date has been with the aforementioned fishers coming too close to the dam.  BEL will carry out a security risk assessment, continue to monitor community relations with the police and army through its stakeholder engagement, and document its interactions with security forces.

As per the ESAP item 8, the company will verify that the security personnel contracted by OME are not implicated in any past abuse and that they are appropriately trained in the appropriate use of force, (i.e. use of force not sanctioned except when used for preventive and defensive purposes in proportion to the nature and extent of the threat), and will require them to act within the applicable law. The client will conduct a risk assessment and documentation process on the use of government security personal at the project site, see ESAP item 9. This process will include documentation of their current relationship with the local forces. As per ESAP item 10, the company will inform the Government of Uganda that the company will, based on IFC Performance Standard 4, not encourage any use of force except for preventive and defensive purposes in proportion to the nature and extent of the threat.  

Type of Habitat

The project is near Jinja, Uganda on the White Nile between Lake Kyoga (downstream) and Lake Victoria (upstream). The project overlaps the Victoria Basin forest-savanna mosaic terrestrial ecoregion and Lake Victoria Basin freshwater ecoregion. These ecoregions do not form part of any biodiversity hotspot or endemic bird area. The total project footprint is 617 ha, including a 388 ha impoundment, which was first flooded in 2011, and the land lease of 229 ha. Prior to start of construction (2007), the terrestrial area to be inundated (approximately 80ha) was classified as modified habitat. The nearest upstream dams are Nalubaale and Kiira (approximately 8 km) commissioned in 1954 and 2000, respectively. The nearest downstream dam will be Isimba Dam (approximately 32km), currently under construction by a third party contracted by the Government of Uganda (GoU), with completion expected in the near future.

An independent biodiversity baseline, focused on several species of fish - identified as haplochromines - between Lake Victoria and Lake Kyoga, was completed in 2001, as a supplement to a broader social and environmental assessment for the project. Haplochromines are a family of fish species known for high diversity and endemism within the region and identified as a set of high biodiversity values during the original IFC project appraisal. Biannual monitoring with support from the project has been undertaken by National Fisheries Resources Research Institute (NaFIRRI) from 2006 to present, with the most recent monitoring report in March 2017. An additional aquatic survey of the entire river between Lake Victoria and Lake Kyoga was conducted by NaFIRRI and international species experts in 2016. Independent annual audits of the project, including review of NaFIRRI monitoring reports described above, have been conducted annually to meet NEMA and lenders’ requirements. The status of biodiversity is thus well understood, consisting of a decade of surveys and monitoring by various parties.

At the time of IFC’s original investment in 2007, BEL was required to offset impacts to the Nile River and environs via enhanced protection of the Kalagala Falls, along with the Kalagala Central Forest Reserve and the Nile Bank Central Forest Reserve (CFR). (Separately, impacts from the transmission line to Kawanda - ‘the transmission line’ described above - were addressed through the offset of the Mabira CFR.)  These two CFRs (along with the Mabira CFR) are included within the area covered by the offset as agreed by World Bank and the GoU. BEL’s role was defined as supporting development of this offset, in collaboration with the National Forestry Authority (NFA). In addition, it was agreed that responsibility for implementing the mitigation measures with regards to the transmission line rested largely with the NFA, with UETCL contributing to on-going management of the Mabira CFR (also included in the offset governend by the IA) by paying ground rent to NFA and covering its incremental costs. As was required under the 2006 SEA, BEL has monitored progress on these measures and collaborated, as necessary, to ensure their implementation.

The offset was established and protected by an indemnity agreement (IA) between World Bank and the Government of Uganda, which was signed on July 18, 2007. The IA is the legal instrument governing the Government of Uganda’s obligations regarding the Kalagala Offset Area (KOA), referred in the IA as the Kalagala Falls Site (KFS). The IA defines the KFS by reference to a map attached to it. The map indicates that the KFS includes a 10-km long stretch of the river. The southern and northern boundaries of the KFS are about 12.5 km and 22.5 kilometers, respectively, downstream of the Bujagali dam. The KFS extends some distance away from the river, to include two forest reserves on the river banks – the Kalagala CFR and the Nile Bank CFR, as noted earlier. The IA also extends specific protections to the Mabira CFR.

The IA specifically requires the Government of Uganda to set aside the KFS “to protect its natural habitat and environmental and spiritual values in conformity with sound social and environmental standards acceptable to the Association [International Development Association or ‘IDA’].” It also limits any tourism development at the KFS and requires that such tourism development only be carried out “in a manner acceptable to IDA and in accordance with the aforementioned standards.” Further, it requires that any power generation development that could adversely affect Uganda’s ability to maintain the above stated protection at the KFS obtain the prior agreement of IDA. The IA remains in effect until the commercial loans guaranteed by IDA are fully repaid (expected to occur in November 2023). While the IA is in effect, the Government of Uganda will continue to be bound to its contractual obligations in connection with the KFS and the Bank will continue assessing compliance of this contractual obligation by the Government of Uganda.

The Kalagala Offset Sustainability Management Plan (KOSMP) was developed by the Ministry of Water and Environment in response to IA requirement (iv) for the GoU to “conserve through a sustainable management program and budget mutually agreed by the Government and the Association, the present ecosystem of the Mabira Central Forest Reserve, as well as the Kalagala Central Forest Reserve and the Nile Bank Central Forest Reserve on the banks of Kalagala Falls (as such Reserves are included in the Kalagala Falls Site).” The KOSMP was finalized and adopted in 2010, covering the period 2010 through 2019, and was launched by the GoU in 2011. The KOSMP sets forth appropriate mitigation measures to conserve and safeguard the ecosystem of the CFRs and address some of the impacts of the Bujagali project. The plan recognizes the contributions by BEL through actions implemented under the BEL SEA in order to mitigate the negative effects of the Bujagali HPP.

The KOSMP is a Government program with a geographic scope that extends beyond the area defined as the KFS, as defined in the Bujagali IA, and which covers activities that go well beyond the specific contractual undertakings in the IA between the Government of Uganda and the World Bank. In that regard, the title of Kalagala Offset Sustainable Management Plan is misleading, since the KOSMP covers a broad range of reforestation, capacity building and livelihood restoration activities outside the KFS and the specific obligations set out in the IA.

The Kalagala Falls Site (KFS has been shown to be an area of high haplochromine diversity due to presence of rapids and includes important sites for restricted range species. The Isimba HPP, which as noted above is currently under construction, will affect the river downstream from Bujagali and is expected to flood a portion of the KFS, including aquatic areas, and is subject to assessment as an addendum to the Isimba ESIA, which is now disclosed on NEMA’s website (http://nema.go.ug/sites/all/themes/nema/docs/UG-ISIMBA-ESIA%20Addendum-TRACKED%20WB.%20June%2022%202017.pdf) for public consultation before being finalized. The Government of Uganda is being supported by the  World Bank to prepare the addendum. The addendum includes recommendations to mitigate impacts to the offset from the construction of the Isimba HPP. 

IFC and the client will continue to monitor the discussions between the Government of Uganda and the World Bank (ESAP item 15). As per ESAP item 16, in the unlikely event that the KFS ceases to exist (in the current or modified form), and is not replaced by alternative measures with similar objectives, BEL would be required to review 2006 requirements and develop an alternative offset approach to address compliance requirements agreed to between IFC and BEL at the time of the original investment, i.e., enhanced protection of the Kalagala Falls and Nile Bank Central Forest Reserve (CFR). (Any such measures would not include the Mabira Forest CFR, which is the responsibility of UETCL.) These alternative mitigation measures, if required, will not be asked to replace the broader set of actions and programs currently described within the KOSMP.  Instead, the actions would be limited to reasonable actions within BEL’s control, namely enhancing the current fish surveys to focus on the species affected by the project and programs that could reduce threats to these species (e.g., provision of fish nets and education on fishing techniques to local fisherman), with a focus on the impacts of introduced predators, which have been the main cause of decline in the native species.  In the unlikely event that there are further mitigation actions that may be required, but remain outside of BEL’s control, these will need to be discussed with the Government of Uganda in order to identify an appropriate course of action.

One issue that BEL is currently addressing is agricultural activities within a 100 meter buffer from the edge of the Nile River that is within the project site’s temporary lands and is required under Regulation 29 of Ugandan law (see ESAP item 12) to be free of those activities. BEL’s response includes replanting of river bank areas and notifying authorities of such encroachment This encroachment affects water quality and ultimately fish habitat.

Despite past conversion and existence of modified habitat pre- and post-construction, the project area is likely to qualify as critical habitat as defined by the (updated) 2012 edition of PS6. This is based on the continued occurrence in 2017 of aquatic restricted range species (e.g., Haplochromis simotes) and unique/threatened ecosystems (e.g., Lake Victoria/Kyoga transition zone rapids) within the broader river area. Ongoing monitoring and recent surveys indicate that at least two new-to-science species may also occur within the project area. No new impacts to these values are, however, expected as a result of the proposed financing because they have co-existed with the Bujagali dam and reservoir since inception, and no new construction or development is planned at the Bujagali dam site and reservoir. As per the ESAP item 13, BEL will commission a critical habitat assessment that will focus - though not exclusively - on the haplochromine species of fish in order to confirm the project area’s status as critical habitat and describe the full extent of possible values triggering critical habitat. Existing data is likely to be adequate for this assessment. As per ESAP item 14, should the critical habitat assessment find that the Bujagali HPP is in critical habitat, the company will prepare a biodiversity action plan (BAP) to deliver net gains for Critical Habitat values via reasonable actions that are within BEL’s control. Net gain will be assessed against a baseline at the time of the existing investment. Given existing monitoring by the project (e.g. NaFIRRI fish surveys) and management of the KFS by Government of Uganda  no significant changes to existing practices by BEL and agreed SEA comitments from the original investment are expected.

Protected or Recognized Areas

The project does not overlap any known protected areas or internationally recognized areas. The nearest such site upstream is the Jinja Wildlife Sanctuary (IUCN Category IV, approximately 5km away). The nearest such sites downstream are Namavundu Forest Reserve (IUCN undesignated, 5km away), Kalagala Falls Central Forest Reserve (IUCN Category undesignated, 15 km away) and Nile Bank Central Forest Reserve (IUCN Category undesignated, 15 km away). The KOA was built around these last two protected areas, and they were targeted for enhanced management as part of the SMP. 

Alien Invasive Species

Alien species are present within the project area. The most critical of these is the Nile Perch (Lates niloticus). The species is found in Lake Kyoga, Lake Victoria and the entire stretch of the Nile that connects them. It has been linked to widespread loss of endemic haplochromines within Lake Victoria, Lake Kyoga and associated catchments.  The species was present prior to inundation, but inundation has improved habitat suitability and allowed individuals to reach larger sizes. Local fishers prize this species, which has had additional impacts from the fishing of haplochromines and other species for live bait. The quantities and size of Nile Perch are lower below the dam and this is associated with a stretch of river with the highest haplochromine abundance and diversity.

Kariba Weed (Salvinia molesta) is also found in both lakes and intervening river channel. BEL has an undocumented procedure for addressing alien invasive species.  ESAP item 11 will ensure that the procedure is documented.

Control of such invasive species, particularly the Nile Perch, is likely to yield gains in haplochromine fish, including species of concern, but will be limited due to community preferences for Nile Perch as a preferred fishing species.

Management of Ecosystem Services

Community members and National Fisheries Resources Research Institute (NaFIRRI ) agree that fishery value has increased in the inundation area post dam construction due to increased size of Nile Perch. This has attracted local communities to the area and catch per unit effort has declined. This increased use has caused impacts to haplochromines and other indigenous fish species within the inundation area, as described above. 

 The nine host communities are Namilyango, Buloba, Naminya,  Malindi and Kikubamutwe  (on west bank); and  Ivunamba, Bujagali, Kyabirwas, and Namizi (on the east bank).  Population statistics for these villages are not available, but the local population is likely to be in the tens of thousands.  In addition to the district governments of Jinja and Buikwe, the main government stakeholders are UETCL, which purchases electricity from the project, the Electricity Regulatory Authority, which regulates the entire sector including electricity tariff, the National Environmental Management Authority, which regulates the environmental and social aspects of the project, and the Ministry of Energy and Mineral Development, which is the key government liaison ministry.

BEL is responsible for the project’s community relations.  At present the arrangement is based on the local leaders being able to call the general manager and the project community liaison officer.  As the existing project was prepared under the 2006 Performance Standards, there was a requirement for consultation to a level of free, prior, informed consultation and informed participation, particularly during the construction phase when the risks and impacts were at their highest. IFC established broad community support for the original investment, as documented in the original ESRS. A public consultation and disclosure plan (roughly equivalent to a Stakeholder Engagement Plan) was part of the social and environmental assessment documents and key elements are implemented on an ongoing basis, commensurate with the reduced scope and risks of the operational phase. As outlined in the ESAP item 3, BEL will develop an updated stakeholder engagement plan appropriate to its operations. The plan will identify host communities and will ensure periodic meetings between BEL personnel and both leaders and individually affected people, e.g. fishers, in those communities. The plan will also contain periodic information sessions on the safety zone around the dam. The plan will also identify a procedure for recording community interactions, their subjects, and any outcomes. BEL has a combined community and worker grievance mechanism, which BEL will review to ensure that it is appropriate to the operating phase of the hydropower plant.  BEL will also provide training to its staff on its provisions, and will, as part of its community engagement, inform communities about its existence (ESAP item 4).

      John Berry

General Manager

8km Kayunga Rd. Kikubamutwe

PO Box 186

Jinia, Uganda

+256434132532/3

jberry@bel.co.ug

www.bujagali-energy.com