Early Production System EIA - Environmental Law Alliance Worldwide

337 Pages·2008·4.78 MB·English

Early Production System EIA

Final Report:

Environmental Impact Assessment for the Proposed
Early Production System, Kaiso-Tonya Area, Block 2,
Lake Albert, Uganda.

March 2008

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Tullow Uganda Operations (Pty) Ltd
Early Production System EIA:

FINAL REPORT

Environmental Impact Assessment for the
Proposed Early Production System, Kaiso-
Tonya Area, Block 2, Lake Albert, Uganda

March 2008
Reference 0068662
Prepared by: Environmental Resources Management
(ERM) Southern Africa (Pty) Ltd; and Environmental
Assessment Consult Limited (EACL)
For and on behalf of
Environmental Resources Management

Approved by: Stuart Heather-Clark
Signed:

Position: Partner-in-Charge

Date: 29 February 2008
This report has been prepared by Environmental Resources
Management the trading name of Environmental Resources
Management Southern Africa (Pty) Limited, with all reasonable skill,
care and diligence within the terms of the Contract with the client,
incorporating our General Terms and Conditions of Business and
taking account of the resources devoted to it by agreement with the
client.
We disclaim any responsibility to the client and others in respect of
any matters outside the scope of the above.
This report is confidential to the client and we accept no responsibility
of whatsoever nature to third parties to whom this report, or any part
thereof, is made known. Any such party relies on the report at their
own risk.
Stuart Heather-Clark
Certified Foreign Environmental Practitioner
Project Manager
Environmental Resources Management Pty Ltd

Moses Kagoda
Certified Environmental Practitioner
In-country Project Co-ordinator
Environmental Assessment Consult Limited (EACL)

Zoe Day
Certified Foreign Environmental Practitioner
Assistant Project Manager
Environmental Resources Management Pty Ltd (ERM)

Gertrude Binta Mgezi
Certified Environmental Practitioner
In-country Socio-economic Specialist
Environmental Assessment Consult Limited (EACL)
Sheila D.C. Namuwaya
In-country Stakeholder Consultation
Environmental Assessment Consult Limited (EACL)

Mr David Nkuutu
Certified Environmental Practitioner
In-country Flora Specialist
Environmental Assessment Consult Limited (EACL)
1 NON-TECHNICAL SUMMARY
This non-technical summary incorporates the main results of the
Environmental Impact Assessment (EIA) for the proposed Early Production
System (EPS), Kaiso-Tonya Area, Block 2, Uganda. The developer, Tullow
Uganda Operations Pty Ltd (Tullow) has commissioned Environmental
Resources Management Pty Ltd (ERM) to undertake the EIA. ERM is working
in partnership with a Ugandan environmental consultancy, Environmental
Assessment Consult Limited (EACL).

1.1 INTRODUCTION
The primary petroleum prospect area in Uganda is the Albertine Graben. This
area is located in the northernmost part of the western rift of the East Africa
Rift System. The Albertine Graben stretches from the border of Sudan in the
north, to Lake Edward in the south. Although varying in width, it is
approximately 45 km wide, extending in some areas into the Democratic
Republic of Congo (DRC). The Government of Ugandan (GoU) has divided
the Ugandan part of the Graben into five petroleum exploration areas. Lake
Albert is located towards the northern extremity of the Graben and is covered
by Exploration Areas 1, 2 and 3A. Tullow holds interests in three exploration
licences on the Ugandan side of the Albertine Graben - Block 1, Block 2 and
Block 3A. The Mputa field is located in Block 2 and to date two wells have
been drilled. It is proposed to proceed with the initial development of the
Mputa field. The location of Block 2 and the Mputa and nearby fields is
shown below in Figure 1.1.

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Due to fuel and electricity shortages in Uganda the development of the energy
sector in Uganda is a national priority, as such Tullow has a Memorandum of
Understanding (MoU) with the GoU to develop an Early Production System
(EPS). The proposed development entails the construction and operation of
an onshore Early Production System (EPS) which is rated at 4,000 barrels per
day (bpd) of crude oil. The distillate products (kerosene and diesel) and
heavy fuel oil (HFO), not used for on-site power generation, are intended
principally for Ugandan domestic market consumption.

1.2 APPROACH AND METHODOLOGY
The purpose of the EIA is to provide relevant, understandable and objective
information to inform decisions regarding the authorisation of the EPS for
Kaiso-Tonya Area, Block 2, Uganda.

The EIA consisted of the following four phases:

(cid:2)
Screening;
(cid:2)
Scoping;
(cid:2)
Specialist Studies; and
(cid:2)
Integration and Assessment.

Screening
The initial screening phase identified that a full EIA was required as
petroleum exploration and production is classified as a Category III activity in
terms of the Environmental Impact Assessment Regulations (1998)
promulgated under the National Environment Act of 1995.

Scoping
The second phase of the EIA process was Scoping. The objectives of Scoping
were the following:

(cid:2)
consultation with stakeholders to identify issues of concern;
(cid:2)
ensure all potential impacts, key issues and reasonable alternatives are
identified; and
(cid:2)
ensure informed, transparent and accountable decision-making by the
National Environment Management Authority (NEMA).

As part of the scoping phase, a stakeholder consultation process was
conducted to provide stakeholders with an opportunity to raise concerns and
comment on the potential impacts and merits of EPS development.
Stakeholders input was captured in order to focus the assessment on key
concerns, and to better understand expectations of those potentially affected.
Figure 1.2 identifies the key stakeholders identified during stakeholder
consultation.

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Figure 1.2 Key Stakeholder Groups
(cid:2) Project participants (Tullow management and employees)
(cid:2) Community leaders
(cid:2) Local community members
(cid:2) Vulnerable groups (e.g. women, refugees)
(cid:2) Local businesses
(cid:2) National and District level authorities
(cid:2) Local authorities
(cid:2) International, national and local environment and social NGOs
(cid:2) Media groups

A range of issues were raised by stakeholders during consultation. The main
issues include the following:

(cid:2) Site Selection - Some stakeholders mentioned that site alternatives needed
to clearly outline both the positive and negatives impacts for each site
alternative and that the criteria used for the selection of each alternative
site documented. Numerous stakeholders indicated their preference for
the EPS to be located outside of the Kabwoya Wildlife Reserve.

(cid:2) Awareness Raising and Community Liaison - Many stakeholders felt that
Tullow should play a more active role in raising awareness about the
project specifically and oil exploration in general. Stakeholders felt there
had been a number of misperceptions amongst stakeholders that could
easily have been clarified if Tullow had a proactive community liaison
strategy. The stakeholders requested that Tullow improve their
community liaison capabilities.

(cid:2) Biodiversity - The impact on wildlife and the need for biodiversity and
habitat conservation was a general concern for many of those consulted;
specifically that increased infrastructure and development in the Kaiso-
Tonya Valley would lead to further reduction of biodiversity.

(cid:2) Fish and Fishing - The majority of villagers raised concerns about the
impact on the numbers of fish in Lake Albert during the operation phase
of the EPS. The impact of the current ban on night fishing was also raised
as a concern since it was felt that it may have severe consequences on the
local fishing economy and affect peoples’ income and livelihoods.

(cid:2) Waste Management - A number of stakeholders were concerned about the
kind of waste that the EPS was going to generate and how that waste was
going to be handled or disposed.

(cid:2) Oil Spills - Stakeholders wanted to know if Tullow had any management
measures in place that would address clean-ups of oil spills. The impact of
oil spills on fish stocks and water resources was also a significant concern
to local stakeholders.

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(cid:2) Air Quality - Stakeholders were extremely concerned about the impact of
the EPS on air quality, especially during flaring (1). Stakeholders also
wanted to know what measures Tullow would put in place to mitigate air
pollution and greenhouse gases.

(cid:2) Flaring - Given the sensitivity of the environment in the project area and
the dry conditions during much of the year, stakeholders were concerned
about the risks of fire and potentially other risks associated with flaring
that could threaten the environment.

(cid:2) Water - Some stakeholders expressed concern about the potential
extraction of water from Lake Albert and the impact it would have on the
level of the lake and the fish. They also feared further contamination of
Lake Albert.

(cid:2) Kabwoya Wildlife Reserve - Many stakeholders observed that the
proposed site was located in the Kabwoya Wildlife Reserve and were
concerned that the extraction of oil would adversely impact on the
environment within the reserve. Some stakeholders also raised the issue
that degazetting the reserve could be a protracted process which could
potentially delay the Project.

(cid:2) Employment - Expectations around employment opportunities were
extremely high among all stakeholders consulted. There were concerns
that the influx of job-seekers would impact on the local residents’ access to
employment opportunities. The community members wanted to know
how Tullow planned to manage this. Some stakeholders emphasised that
Tullow should ensure that a Ugandan labour force works along side
expatriates so that skills transfer is ensured and that where appropriate
skill sets exist, employ Ugandans for the more technical roles.

(cid:2) Increased Pressure on Infrastructure - A number of stakeholders stated
that with Tullow’s increased operations there would be further pressure
on the existing roads and that Tullow would need to improve road
infrastructure.

(cid:2) Community benefits – An overwhelming number of stakeholders
expressed the view that the project should ensure that the local people
experience social transformation and that they must directly benefit from
the project. For example many of the local stakeholders were anticipating
electricity provision to the villages in the Kaiso-Tonya Valley.

(cid:2) Tourism - There was a general concern about tourism being affected in the
area. A twenty-year concession was signed between the Lake Albert Safari
Lodge, Uganda Wildlife Authority and the District Officials which is a
government commitment. As such, it was emphasised that it is Tullow’s
responsibility to ensure that all environmental issues are addressed and

(1) Flaring is the burning off of waste gas or flammable gas and liquids.
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that the project coexists with the local tourism in the area. It was felt that a
site should be selected that strikes a balance between oil exploration and
maintaining the wildlife reserve.

Other issues raised included issues surrounding: project life span, the need for
a Strategic Environmental Assessment, concerns around resettlement,
community benefits, security and conflict, and perceptions of corruption.

Specialist Studies
Specialist studies included baseline information gathering relating to the
affected environment and an assessment of the impacts associated with the
proposed development. In support of the EIA, the following specialist studies
were undertaken:

(cid:2)
Noise;
(cid:2)
Visual;
(cid:2)
Air quality;
(cid:2)
Waste management;
(cid:2)
Ground and surface water;
(cid:2)
Flora and fauna;
(cid:2)
Socio-economic; and
(cid:2)
Archaeological.

Integration and Assessment
A synthesis of the baseline information and impact assessment undertaken by
the specialists, which addresses the key issues identified during the scoping
process, is integrated into the Environmental Impact Statement. Potential
impacts are assessed according to predefined assessment criteria and
mitigation measures developed for the impacts.

1.3 LEGAL AND POLICY FRAMEWORK
Uganda has a wide array of legislation that promotes the protection of the
environment. A number of Policies, Acts and Regulations were taken into
account during the EIA process.

An Environmental Impact Study (EIS) has been compiled as part of the EIA
process in accordance with the regulatory requirements stipulated in the EIA
Regulations, 1998 promulgated under the National Environment Act of 1995.

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