Now - Access Power MEA

Transcription

Proposed Development of Two 5 MW
Solar Photovoltaic (PV) Power Facilities
Soroti, Uganda
Scoping Report
Prepared for: ACCESS Advisory
July 2014
2x5 MW Photovoltaic Power Plant in Soroti, Uganda
Scoping Report
Page 1 of 173
Document Information
Project
Two 5MW Solar Photovoltaic Power Facilities, Soroti, Uganda
Project Number
1405/007
Report Title
Environmental & Social Compliance Study for Bid Submission
Client
ACCESS Advisory
Project Manager
Carlos Ponte
Project Director
Ken Wade
Document Control
Rev
Issue Date
1
28/07/2014
2
01/08/2014
Description
Authors
Reviewed
Approved
Draft
CPM
KRW
KRW
Final
CPM
KRW
KRW
Scoping Report
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Table Of Contents
Table Of Contents ................................................................................................................. 3 List of Figures .......................................................................................................................... 9 List of Tables ......................................................................................................................... 11 Acronyms ............................................................................................................................. 13 1 Introduction .................................................................................................................... 15 2 Environmental And Social Assessment Team ............................................................. 17 2.1 BIMCO ...................................................................................................................... 17 2.2 5 Capitals ................................................................................................................. 19 2.3 ESIA Team Members ............................................................................................... 22 3 Project Description ........................................................................................................ 26 3.1 Project Justification ................................................................................................. 26 3.2 Project Location ...................................................................................................... 27 3.2.1 Existing Land Uses on the Proposed Site......................................................... 28 3.2.2 Sensitive Receptors ........................................................................................... 29 3.3 Project Description .................................................................................................. 30 3.4 Construction Phases and Workforce Requirements ........................................... 37 3.5 Construction techniques, schedule and equipment ......................................... 39 3.5.1 Construction equipment .................................................................................. 39 3.5.2 Project Schedule ............................................................................................... 41 3.6 Sourcing of the PV panels ...................................................................................... 42 3.7 Project Alternatives ................................................................................................. 42 4 Legal Framework, Standards and Guidelines ............................................................ 45 4.1 National Requirements ........................................................................................... 45 4.1.1 The Ugandan Constitution ............................................................................... 45 4.1.2 Uganda’s Vision 2040 ....................................................................................... 45 4.1.3 Environmental Management .......................................................................... 46 4.1.4 Energy Policy ..................................................................................................... 47 4.1.5 Water Resources Management ...................................................................... 47 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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4.1.6 Wildlife Management....................................................................................... 49 4.1.7 Waste Management ........................................................................................ 49 4.1.8 Forestry ............................................................................................................... 50 4.1.9 Development Plans .......................................................................................... 50 4.1.10 Land and land acquisition ............................................................................. 50 4.1.11 Local Land Use Planning ................................................................................ 51 4.1.12 Roads ............................................................................................................... 52 4.1.13 Public Health ................................................................................................... 52 4.1.14 Occupational health and safety .................................................................. 53 4.1.15 Employment .................................................................................................... 54 4.1.16 Archaeology ................................................................................................... 54 4.2 International Treaties and agreements signed by Uganda ............................... 55 4.3 International Requirements .................................................................................... 57 4.3.1 The World Bank / IFC Environmental Safeguard Policies and Performance
Standards ....................................................................................................................... 57 4.3.2 KFW Development Bank Sustainability Guidelines ........................................ 61 5 ESIA Methodology ......................................................................................................... 62 5.1 Need for an ESIA ..................................................................................................... 62 5.1.1 Ugandan Legal Requirements ........................................................................ 62 5.1.2 IFC/WB Project Categorisation ....................................................................... 62 5.1.3 KfW Project Categorisation ............................................................................. 63 5.2 ESIA Requirements .................................................................................................. 63 5.3 Scoping Report........................................................................................................ 65 5.4 ESIA Approach ........................................................................................................ 66 5.4.1 Impact Assessment Significance Criteria ....................................................... 66 5.4.2 Mitigation Measures and Management Plants ............................................. 72 6 Stakeholder Engagement Plan.................................................................................... 73 6.1 Objectives ................................................................................................................ 73 6.2 Stakeholder Engagement Requirements ............................................................. 74 6.2.1 Ugandan Requirements ................................................................................... 74 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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6.2.2 WB / IFC Requirements ..................................................................................... 74 6.3 Project Stakeholders ............................................................................................... 76 6.4 Stakeholder Engagement Programme ................................................................ 79 6.4.1 Consultation Stages and Methods ................................................................. 80 6.4.2 Consultation Meetings ..................................................................................... 81 6.4.3 Written Feedback ............................................................................................. 83 6.4.4 Disclosure Methods ........................................................................................... 83 7 Results of the Scoping Stakeholder Engagement ..................................................... 85 7.1 Stakeholder Engagement during the Scoping Stage ........................................ 85 7.2 Results of the Stakeholder Engagement during the Scoping Stage................. 85 7.2.1 Meetings in Soroti .............................................................................................. 85 7.2.2 Consultation with the Indirectly Affected Stakeholder ................................ 90 7.3 Inclusion of women and the disadvantaged in the ESIA process .................... 91 8 Baseline Conditions ....................................................................................................... 94 8.1 Ecology and Biodiversity ........................................................................................ 94 8.1.1 Flora .................................................................................................................... 94 8.1.2 Fauna ................................................................................................................. 96 8.1.3 Ecosystem services ......................................................................................... 101 8.2 Air Quality and Climate ........................................................................................ 102 8.2.1 Rainfall .............................................................................................................. 102 8.2.2 Temperature, Humidity, Wind and Eva-transpiration ................................. 102 8.2.3 Air Pollution ...................................................................................................... 103 8.2.4 Greenhouse Gas Emissions ............................................................................ 105 8.3 Geology, Soil, Groundwater and Land Contamination ................................... 106 8.4 Noise and Vibration .............................................................................................. 109 8.5 Water Resources & Wastewater Management ................................................ 111 8.6 Solid and Hazardous Waste ................................................................................. 113 8.7 Economic Impacts ................................................................................................ 113 8.7.1 Land tenure and buildings ............................................................................. 114 8.7.2 Income and expenditure............................................................................... 115 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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8.7.3 Agriculture ....................................................................................................... 116 8.8 Social Impacts ....................................................................................................... 119 8.8.1 Demographics ................................................................................................ 119 8.8.2 Sources of water ............................................................................................. 119 8.8.3 Sources of Energy ........................................................................................... 119 8.8.4 Health and Education .................................................................................... 120 8.8.5 Other Social Considerations .......................................................................... 120 8.9 Traffic and Transportation .................................................................................... 121 8.10 Worker Welfare .................................................................................................... 121 8.11 Electromagnetic Radiation ................................................................................ 122 8.12 Cultural Heritage and Archaeology ................................................................. 123 8.13 Landscape and Visual Impact .......................................................................... 123 9 Potential Impacts, Terms of Reference and Recommendations for the ESIA ...... 125 9.1 Ecology and Biodiversity ...................................................................................... 125 9.1.1 Potential Impacts ............................................................................................ 125 9.1.2 Studies and Recommendations for the ESIA ............................................... 126 9.2 Air Quality ............................................................................................................... 128 9.2.1 Potential Impacts ............................................................................................ 128 9.2.2 Studies and recommendations for the ESIA ................................................ 128 9.3 Geology, Soil, Groundwater and Land Contamination ................................... 130 9.3.1 Potential Impacts ............................................................................................ 130 9.3.2 Studies and Recommendations for the ESIA ............................................... 131 9.4 Noise and Vibration .............................................................................................. 132 9.4.1 Potential Impacts ............................................................................................ 132 9.4.2 Studies and Recommendations for the ESIA ............................................... 133 9.5 Water Resources & Wastewater Management ................................................ 135 9.5.1 Potential Impacts ............................................................................................ 135 9.5.2 Studies and Recommendations for the ESIA ............................................... 136 9.6 Solid and Hazardous Waste ................................................................................. 137 9.6.1 Potential Impacts ............................................................................................ 137 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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9.6.2 Studies and Recommendations for the ESIA ............................................... 138 9.7 Economic Impacts ................................................................................................ 140 9.7.1 Potential Impacts ............................................................................................ 140 9.7.2 Studies and Recommendations for the ESIA ............................................... 141 9.8 Social Impacts ....................................................................................................... 141 9.9 Traffic and Transportation .................................................................................... 142 9.9.1 Key Issues ......................................................................................................... 142 9.9.2 Studies and Recommendations for the ESIA ............................................... 143 9.10 Worker Welfare .................................................................................................... 144 9.10.1 Key Issues ....................................................................................................... 144 9.10.2 Studies and Recommendations for the ESIA ............................................. 144 9.11 Electromagnetic Radiation ................................................................................ 145 9.11.1 Potential Impacts .......................................................................................... 145 9.11.2 Studies and Recommendations for the ESIA ............................................. 147 9.12 Cultural Heritage and Archaeology ................................................................. 148 9.12.1 Potential Impacts .......................................................................................... 148 9.13 Landscape and Visual Impact .......................................................................... 149 9.13.1 Potential Impacts .......................................................................................... 149 9.13.2 Studies and Recommendations for the ESIA ............................................. 150 10 Environmental and Social Management System .................................................. 151 10.1 Introduction ......................................................................................................... 151 10.2 Construction Environmental and Social Management Plan (CESMP) ......... 151 10.3 Operational Environmental and Social Management Plan (OESMP) .......... 152 10.4 Environmental and Social Monitoring Plan (ESMP) ......................................... 152 10.5 Emergency Response Plan ................................................................................ 153 10.5.1 Preparedness................................................................................................. 155 10.5.2 Response........................................................................................................ 155 10.5.3 Reporting ....................................................................................................... 157 10.6 Risk Assessment and Management .................................................................. 158 10.6.1 Identification of Hazards .............................................................................. 160 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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10.6.2 Analysis of Risk ............................................................................................... 161 10.6.3 Deciding on Control Measures ................................................................... 162 10.6.4 Implementing the Control Measures .......................................................... 164 10.6.5 Monitor and Review ..................................................................................... 165 10.6.6 Record the Risk Management process ...................................................... 165 10.7 ESMS Grievance Mechanism ............................................................................. 166 10.7.1 Characteristics of the Grievance Mechanism .......................................... 166 10.7.2 Scope ............................................................................................................. 167 10.7.3 Publicizing Grievance Management Procedures .................................... 167 10.7.4 Submitting a complaint................................................................................ 168 10.7.5 Receiving Complaints .................................................................................. 168 10.7.6 Reviewing and Investigating Grievances .................................................. 169 10.7.7 Grievance Resolution Options and Responses ......................................... 170 10.7.8 Monitoring, Internal Reporting, and Evaluation ........................................ 170 10.7.9 External Reporting of Newly identified Impacts, Changes to the ESMP
and Grievances .......................................................................................................... 171 11 References ................................................................................................................. 172 ANNEXES ............................................................................................................................. 173 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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List of Figures
Figure 2-1 Proposed Layout and Alignment of the power lines to the Opuyo
substation ....................................................................................................................... 28 Figure 2-2 Existing Land Uses in the Proposed Site ........................................................... 28 Figure 2-3 Potentially sensitive receptors .......................................................................... 30 Figure 2-4 PV Cell ................................................................................................................. 31 Figure 2-5 PV Cell, Module & Array (left) machine of ramming spikes (right). ............. 32 Figure 2-6 Supporting structure (left) mounted PV array (right). .................................... 32 Figure 2-7 Inverter (left) step up transformer (right). ........................................................ 33 Figure 2-8 5 MW Power Plant Layout (I) ............................................................................ 35 Figure 2-9 Proposed 5 MW Power Plant (II) ....................................................................... 36 Figure 2-10 Alternative sites - Soroti ................................................................................... 43 Figure 4-1: EIA process flow for energy projects .............................................................. 64 Figure 6-1 Educational level of the respondents to the household survey,
disaggregated by gender ........................................................................................... 92 Figure 7-1 Soroti 2011 monthly and long term average rainfall ................................... 102 Figure 7-2 Air Quality Monitoring Locations - Scoping Phase ....................................... 104 Figure 7-3 Seismic zoning of Uganda .............................................................................. 106 Figure 7-4 Soil Sampling Locations................................................................................... 108 Figure 7-5 Noise Monitoring Locations ............................................................................ 110 Figure 7-6 Water Sampling Location and Soil Sampling Location ............................... 112 Figure 7-7 Location of the households surveyed ........................................................... 114 Figure 7-8 Types of Structures in the Project Area ......................................................... 115 Figure 7-9: Household loans ............................................................................................. 116 Figure 7-10: Utilization of crops grown ............................................................................. 117 Figure 7-11: Utilization of livestock reared ....................................................................... 117 Figure 7-12 Rearing of Animals......................................................................................... 118 Figure 7-13: Constraints to Agricultural production ....................................................... 118 Figure 7-14 Proposed alignment for the 33kv power lines ............................................ 122 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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Figure 8-1 Waste Management Hierarchy ..................................................................... 140 Figure 8-2 Proposed and alternative alignment for the 33kv power lines .................. 148 Figure 9-1 Incident Response ........................................................................................... 157 Figure 9-2 Process for EPC and O&M for risk identification and management ......... 159 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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List of Tables
Table 2-1 Environmental and Social Assessments undertaken by BIMCO ................... 17 Table 2-1 Environmental Assessments of energy projects undertaken by 5 Capitals to
WB/IFC standards ......................................................................................................... 19 Table 2-1 Project Location ................................................................................................. 27 Table 2-2 Required staff during the construction phase ................................................ 37 Table 2-3 Project Schedule ................................................................................................ 41 Table 4-1 Environmental Value of Receptor or Resource .............................................. 68 Table 4-2 Criteria for Magnitude of Impacts .................................................................... 69 Table 4-3 Criteria for Determining Significance of Effects .............................................. 71 Table 4-4 Definition of Significance of Effects .................................................................. 71 Table 6-1: Summary of issues raised during a consultative meeting with Soroti District
Local Government officials. ........................................................................................ 85 Table 6-2: Summary of issues raised during a consultative meeting with the Soroti Sub
County chief and LC3 chairman. ............................................................................... 87 Table 6-3: Summary of issues raised during a community meeting with the residents
of Aliedi village. ............................................................................................................. 88 Table 6-4: Consultation with the Aliedi Nursery and Primary School Management.... 89 Table 6-5: Consultation with the LC1 chairperson of Omuron village and the Head
Teacher of the Opuyo Primary School. ...................................................................... 90 Table 7-1 Butterfly species list ............................................................................................. 97 Table 7-2 Bird species recorded ........................................................................................ 99 Table 7-3 Temperature and relative humidity measurements ..................................... 103 Table 7-4 Baseline Air Quality Monitoring Results ........................................................... 104 Table 7-5 IFC Ambient Air Quality Standards (µg/m3 unless otherwise specified) ..... 105 Table 7-6 Groundwater Depth......................................................................................... 106 Table 7-7 Standard Penetration Tests values of soil strata in the boreholes ............... 107 Table 7-8 Soil analysis results ............................................................................................. 108 Table 7-9 Noise Monitoring Results .................................................................................. 110 Table 7-10 IFC EHS General Noise Guidelines (At off-site receptors) .......................... 111 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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Table 7-11 Water Analysis Results .................................................................................... 112 Table 7-12: Income/expenditure in the surveyed households ..................................... 115 Table 7-13 Highest level of education attained by household members .................. 120 Table 8-1 Electric and Magnetic Fields - Main Power Substation ................................ 146 Table 8-2 Electric and Magnetic Fields - Main Power 66 kV power line ..................... 146 Table 9-1 Probability of Occurrence ............................................................................... 161 Table 9-2 Risk Assessment Matrix ...................................................................................... 161 Table 9-3 Hazard Controlling Measures .......................................................................... 163 Table 9-4 Hazard and Safety Hierarchy of Controlling Hazards .................................. 164 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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Acronyms
ALARP
As Low As Reasonably Practicable
CEMSP
Construction Environmental and Social Management Plan
CSR
Corporate Social Responsibility
DLB
District Land Boards
EMF
Electric and Magnetic Fields
EPC
Engineering Procurement and Construction
ERA
Energy Regulatory Authority
ERP
Emergency Response Plan
ESIA
Environmental and Social Impact Assessment
ESMS
Environmental and Social Management System
GFPPM
GET FiT Premium Payment Mechanism
GHG
Green House Gases
HGV
Heavy Goods Vehicles
HSE
Health, Safety and Environment
HVOTL
High Voltage Overhead Transmission Lines
ICNIRP
International Commission on Non-Ionizing Radiation Protection
IFC
International Finance Corporation
IPP
Independent Power Project
IUCN
International Union for the Conservation of Nature
LCA
Life Cycle Assessment
LRP
Livelihood Restoration Plan
NEMA
National Environment Management Authority
OESMP
Operational Environmental and Social Management Plan
O&M
Operation & Management
PLC
Parish Land Committees
PPA
Power Purchase Agreement
PPE
Personal Protective Equipment
PV
Photo-Voltaic
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RAP
Resettlement Action Plan
RFP
Request For Proposals
SEP
Stakeholder Engagement Plan
UETCL
Uganda Electricity Transmission Company Limited
ULC
Uganda Land Commission
VOC
Volatile Organic Compounds
WBG
World Bank Group
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1 Introduction
The overall Government Policy Vision for the role of renewable energy in the
Ugandan economy is to make modern renewable energy a substantial part of the
national energy consumption. In pursuit of that vision, the goal of Uganda’s
Renewable Energy Policy is to increase the use of modern renewable energy from
the current 4% to 61% of the total energy consumption by the year 2017.
The Government of Uganda, the Energy Regulatory Authority (ERA) and GET FiT are
promoting the introduction of a Solar / PV power production under the GET FiT
Premium Payment Mechanism (GFPPM). ERA has tendered out Solar / PV
concessions on the basis of a reverse auction: developers have been asked to bid a
price per kWh - in addition to documenting compliance with the established
technical, economical, financial, environmental and social as well as legal
requirements under GET FiT.
Concessions will be awarded after a due diligence process to the cheapest eligible
bidder(s). Selected developers will receive a GET FiT Premium Payment to bridge the
gap between a predetermined tariff set by ERA and their offer. Successful bidders
will then enter into a Developer Finance Agreement with the Government of
Uganda (represented by KfW) for the GET FiT Premium Payment and sign a
standardized, 20 year Power Purchase Agreement (PPA) with Uganda Electricity
Transmission Company Limited (UETCL).
ACCESS Advisory is one of the pre-qualified developers bidding for the Solar / PV
power production component of the GET Fit Programme in Uganda. ACCESS is
proposing to develop two 5MW Photovoltaic Power Plants near the Opuyo
Substation in Soroti.
The Request For Proposals (RFP) for the projects includes stringent environmental and
social requirements, to ensure that the projects are in line in International Best
Practice.
ACCESS has engaged 5 Capitals Environmental and Management Consulting, an
environmental consultancy firm specialised in internationally funded power projects,
and BIMCO Consult, an experienced NEMA-registered consultancy with a strong
team of local environmental and social specialists, for the environmental and social
assessment of the project.
The two proposed photovoltaic Power Plants are going to be developed on one site
using the same power line to the Opuyo Substation. In terms of environmental and
social impacts no significant differences are expected, and the cumulative impact
of the concurrent development of both plants will be considered as a worst case
scenario. The Request for Proposals issued by GET FiT / ERA requires two separate
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5MW PV plants instead of a single 10MW PV plant, so two separate licenses are
requested from NEMA.
The primary objective of the Scoping Report is to ensure that the key environmental
elements and sensitive receptors associated with the Project’s construction,
commissioning, operation, (and decommissioning) phases are identified at an early
stage to determine the studies and assessment methodologies (‘Terms of
Reference’), which will be undertaken for the full ESIA.
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2 Environmental And Social Assessment Team
ACCESS has engaged 5 Capitals to assess and manage the environmental and
social risks of the proposed project during the design stage. In Uganda, 5 Capitals
has worked closely with BIMCO Consult, an environmental consultancy based in
Kampala. The relevant experience of 5 Capitals and BIMCO is described below, and
the team members and the roles that they have in the environmental assessment is
outlined.
The appointed team has a strong experience in delivering ESIAs up to international
standards for major power projects in the Middle East and Africa and includes a
group of NEMA registered specialists with extensive experience in Uganda.
2.1 BIMCO
BIMCO Consult Limited is one of Uganda’s leading environmental and social
consultancy firms. The Multi-disciplinary team of Consultants has more than 10 years
experience in offering professional expertise and management support services in
Environmental Management, Environmental and Social Impact Assessments,
Environmental
Audits,
Environmental
Compliance
Monitoring,
Social
and
Environmental baseline surveys, Social Work and Community Development
Interventions, feasibility studies and Engineering Support Services, among others.
Table 2-1 Environmental and Social Assessments undertaken by BIMCO
Client
Description of the Environmental and Social Assessment
KfW
Due diligence on 12 small hydro and cogeneration projects for
compliance with International Finance Corporation (IFC)
Environmental and Social Sustainability standards. This was done in
association with ERM Germany, with BIMCO Consult Ltd staff as
Local Counterpart. Projects included Kakaka, Kakira and SAIL
Cogens, Ndugutu, Sindlia, Nengo Bridge, Siti-1, Siti-2, Waki, Rwimi,
Kakaka, Lubilia, and kikagati. BIMCO was local counterpart to ERM
– Germany.
UMEME Ltd
Social and Environmental Impact Assessments and Audits for
UMEME Capital Expansion projects (included construction of new
substations, power distribution lines, substation safety upgrades,
installation of new switch gear and
UMEME Ltd
Social and Environmental Impact Assessments for reconductoring of
Namanve – Kireka 33kV LINE and upgrade of Kireka substation
INVESPRO (U) Ltd
Environmental Impact Assessment for the Proposed HFO thermal
power plant at Kimaka, Jinja
Tullow
Oil
Plc
Ltd/TOTAL Exploration
Environmental Impact Assessment for East Nile 3D Seismic surveys for
Oil and Gas Exploration Drilling
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and Production
Tullow Oil Plc Ltd
Environmental Impact Assessment for Oil and Gas Exploration Drilling
Ministry
of
Agriculture, Animal
Industry and Fisheries
Environmental
and
social
impact
assessment
for
rehabilitation/reconstruction of Mubuku, Doho, Olweny and Agoro
Irrigation schemes under the Farm Income Enhancement and Forestry
Conservation project
Ministry
of
Government
Local
Environmental and Social Impact Assessment for Community
Agriculture Improvement Project (CAIIP II and III projects) with Arch
Forum, for the Design and supervision of Agro-Processing Facilities for
the Ministry of Local Government, Uganda funded by the African
Development Bank, 2012 – 2014
Ministry of Education
and Sports
Environmental and Social Impact Assessment as part of Design,
Construction and Supervision Services for 7 Technical Colleges and
Teachers College with Arch Forum for Ministry of Education and
Sports, 2013 and 2014. Funding is from the Islamic Development Bank
Catholic
Relief
Services
(CRSUganda Program)
Environmental Impact Assessment for Development Activity
Program (DAP) – Construction of Valley dams for the return strategy
for communities displaced by Civil war in northern Uganda
Ministry
of
Government
Local
Environmental Impact Reviews For Community Access Roads Under
District Livelihood Support Programme (DLSP) For FY 2009/2010 in
Oyam, Masindi, Apac and Yumbe Districts
Jomayi
Property
Consultants
Environmental Impact Assessment for six (6) Proposed Jomayi
Quarry sites
Airtel Uganda Ltd
Environmental Impact Assessment for 64 Airtel Uganda Radio Base
Stations
MTN Uganda Ltd/ATX
Environmental Impact Assessment for 8 MTN Radio Base Stations
e station
Toyota Uganda Ltd
Environmental Impact Assessment for Toyota Arua, Toyota Gulu,
Toyota Nakawa, Toyota and Toyota Nakawa
Libya Oil Uganda Ltd
Environmental Impact Assessment for the Proposed Libya Oil
Uganda LPG and Furnace Oil Depot
Environmental Audits for Libya Oil Service Stations
MGS International Ltd
Environmental Impact Assessment and Resettlemnt Framework for
the Proposed MOGAS Depot at Banda, Nakawa Division, Kampala,
AND Environmental Audit for 22 service stations countrywide
National Housing and
Construction
Corporation (NHCC)
Environmental Impact Assessment for the Proposed Kiwatule and
Naalya Pride Extra Housing Estates
Uganda
National
Bureau of Standards
Feasibility Study for UNBS
Bweyogerere Industrial Park
Municipal Councils of
Jinja, Entebbe and
Busia
Environmental Impact Assessment for the Proposed Waste
Composting projects under the CDM for Jinja Municipal Council,
Busia Municipal Council, and Entebbe Municipal Council
Scoping Report
Headquarters
and
Laboratory,
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2.2 5 Capitals
5 Capitals Environmental and Management Consulting is a company registered in
Dubai (UAE) operating throughout the MENA Region and Sub-Saharan Africa.
5 Capitals is ranked in the Dubai SME 100 (out of more than 70,000 SMEs) and is the
highest listed environmental consultancy in the Emirate. The company is a market
leader in the Power and Water Sector, having undertaken IFC / Equator Principles
Environmental and Social Assessments for projects exceeding 28,000 MW. Major
industrial projects in the Steel and Petrochemicals sectors have also been
successfully completed to international standards by the 5 Capitals team. The
construction value of projects in the Middle East and North Africa alone, in which the
5Cs team has provided either environmental assessment, auditing, due diligence or
technical reviews, exceeds US$50 billion to date.
5 Capitals is one of the most experienced environmental consultancies working in
the MENA region with many approvals from IFIs for power projects, including
renewable solar technologies.
To date, 5 Capitals has worked with the Following IFIs:
• WB (WB Group)
• KfW (German DFI)
•
IFC (WB Group)
•
AFD (French DFI)
•
IDA (WB Group)
•
KEXIM (Korean ECA)
•
AfDB (African DFI)
•
US-EXIM (USA ECA)
•
EBRD (European DFI)
•
JBIC (Japanese ECA)
•
EIB (European Union FI)
•
HSBC (Private IFI)
•
CDC (UK DFI)
•
K-SURE
•
JICA (Japanese DFI)
(Korean
Trade
Insurance)
The table below outlines the environmental and social assessments in the energy
sector that 5 Capitals has successfully led.
Table 2-2 Environmental Assessments of energy projects undertaken by 5 Capitals
to WB/IFC standards
Project Name
Type of ESIA
Year
Country
Shuaibah IWPP Phase III
Full ESIA
2005
Kingdom of Saudi Arabia
Shuqaiq IWPP Phase 2
Full ESIA
2006
Marafiq Jubail IWPP
Full ESIA
2006/7
Shuaibah RO Expansion
Full ESIA
2007
Rabigh IPP
Full ESIA
2009
Analysis of site
constraints for the
2009
Kingdom of Morocco
Safi IPP
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ESIA
Third Independent Power
Plant - Jordan
Scoping phase of
the ESIA
2011
Hashemite Kingdom of
Jordan
ESIA Review and EP
Action Plan
2011
Republic of Turkey
Full ESIA
2011
Scoping phase of
the ESIA
2011
State of Kuwait
Full ESIA
2012
Scoping Phase of
the ESIA
2011/2
United Arab Emirates
Full ESIA
2012
Sultanate of Oman
Preliminary ESIA
2012
Full ESIA
2012
Tanger II Wind Farm
Analysis of site
constraints for the
ESIA
2012
Kingdom of Morocco
Midelt Wind Farm
Analysis of site
constraints for the
ESIA
2012
Kingdom of Morocco
Jbel Lahdid (Essaouira)
Wind Farm
Analysis of site
constraints for the
ESIA
2012
Kingdom of Morocco
Tiskrad (Laayoune) Wind
Farm
Analysis of site
constraints for the
ESIA
2012
Kingdom of Morocco
Boujdour Wind Farm
Analysis of site
constraints for the
ESIA
2012
Kingdom of Morocco
Full ESIA
2012/3
Kingdom of Morocco
Scoping Phase of
the ESIA
2013
Arab Republic of Egypt
Full ESIA
2013
Preliminary ESIA
2013
Mirfa IWPP
Full ESIA
2013
United Arab Emirates
Jeddah South PP
Full ESIA
2013
Olkaria Geothermal Field
SEA – Submission to
NEMA June 2014
2014
Republic of Kenya
Eburru Geothermal Field
SEA – Submission to
NEMA June 2014
2014
Republic of Kenya
Kirikale IPP
Quaryyah IPP
Az Zour North IWPP
Rabigh VI SEC PP
Hassyan I IPP
Barka I Expansion
Shuqaiq SEC PP
Rabigh V - VII conversion
to combined cycle
Noor I (Ouarzazate) CSP
Dairut IPP
Rabigh IPP 2
Qurayyat PP Expansion
and conversion
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Several of the projects outlined above included resettlement and/or economic
displacements (e.g. Noor I IPP, Dairut IPP, Kirikale IPP, Olkaria and Eburru Geothermal
Development Programme, etc) that were handled following WB/IFC requirements.
5 Capitals has undertaken construction, operational and due diligence audits
following WB/IFC requirements for the following power projects:
•
Shuaiba IPP (construction audits, KSA);
•
Qurayyah IPP (construction audits, KSA);
•
Rabigh I IPP (construction and operational audits, KSA);
•
Rabigh II IPP (construction audits, KSA);
•
Rabigh VI PP (construction and operational audits, KSA);
•
Jeddah South PP (operational audits, KSA);
•
Mirfa PP (due diligence audit, UAE);
•
Oyo PP (due diligence audit, UAE);
•
Salala PP (due diligence audit, Oman);
•
Marmara PP (due diligence audit, Turkey);
•
Hussein PP (due diligence audit, Jordan).
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2.3 ESIA Team Members
Name
Company
Otim Moses
(BIMCO)
/
Edith Kahubire
(BIMCO)
Sheba
Ndagire
(BIMCO)
Dr.
James
Kalema
(BIMCO)
Role / Qualification
Experience
Project Director / ESIA
Team Leader
MSc – Environmental
Geosciences
MSc ‘Educational
and Training Systems
Design’
BSc. Industrial
Chemistry
Social
and
Stakeholder
Engagement
BA Social Sciences
MPhil Geography
Public
Health
Specialist/
Noise and Air quality
MSc in Environmental
Science
18 years in ESIA, EA, Geo-Information Sciences and Earth observation, Earth Resources and
Environmental Geosciences, Environmental and Hydrological Modelling, Industrial Chemistry
Capacity building, project management and leadership. GIS/RS, Ecosystems and
hydrological modelling, Industrial Developments, Hydropower Developments, Catchment
Management.
Team leader for various EIAs and Audits for infrastructure and industrial development projects
for upstream oil and gas activities (exploration and appraisal), and for associated facilities –
camps, laydown areas, drilling sites, supply bases, etc.
Moses is a NEMA Certified EIA/EA practitioner as Team Leader.
Certified to practice as Team Leader for Audits and ESIAs with NEMA; 20 year experience in
ESIAs, Social baseline surveys, resettlement studies
Registered EIA Practitioner
Ecologist
PhD, MSc. Ecology
BSc. Zoology and
Botany
20 year experience in biological surveys
7 years experience in ESIA, EAs, chemical contaminants and remediation, noise and air
quality, risk communication, geohazard risk assessments, ecosystem management, climate
change, public health
Registered EIA Practitioner, certified to practice as Team Leader
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Dr.
James
Semuwemba
(BIMCO)
Environmental
Engineering
PhD & BSc in Civil
Engineering
MSc in Environmental
Engineering
15 year experience in Civil Works, Environmental Engineering
Lubega
(BIMCO)
Dr. Pomeroy
Derrek
(BIMCO)
Geologist
BSc. Geology
Ornithologist
PhD (Animal Ecology),
MSc & BSc Natural
Sciences
Invertebrates
and
insects
MSc in Environment
and Natural
Resources
Management
BSc Botany and
Zoology
Herpetologist
PhD (Environment
and Natural
Resources), MSc &
BSc in Zoology
Archeologist and
cultural specialist
A Master of
Philosophy
Archaeology (African
18 years experience in Soil Science, geotechnical surveys, Geology, Hydrogeology.
Akite
Perpetua
(BIMCO)
Dr.
Mathias
Behangana
(BIMCO)
Dismas
Ongwen
(BIMCO)
30 years experience in Ecology, Bird surveys, Natural Sciences, Zoology, Oil and Gas Impact
Assessments, Geology, Botany.
10 years experience in baseline surveys – butterflies and other insect taxa; also mammal
surveys
23 years of experience in Zoology, Climate change, Aquatic ecologist, herpetology,
conservation and management
17 years experience in archaeology, cultural and heritage conservation.
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Arch.),
PgD. Heritage
Conservation,
Bachelor of Arts
(History, philosophy)
Robert Kityo
(BIMCO)
Ken Wade
(5 Capitals)
Terrestrial
Ecologist/Mammal
Expert
PhD, MSc, BSc
Zoology & Botany
MSc Applied
Hydrobiology
Carlos Ponte
(5 Capitals)
ESIA Specialist
MSc Sustainable
Development
Zeina Jokadar
(5 Capitals)
ESIA Specialist
BSc Environmental
Management
27 years experience in Zoology, Ecology, Biogeography, taxonomy
Ken leads 5 Capital’s Environmental Planning team having 35 years experience in the
environmental field both as a Regulator and a Consultant in the UK for >20 years before
moving to the Middle East. He has undertaken Equator Principles ESIAs in MENA for >10 years.
Ken has experience of planning and leading SEA studies for 5 Capitals as well as extensive
leadership of industrial project EIA, ESIA and SEIA’s on behalf of private clients and lending
institutions, with a combined construction value in excess of US $50 billion.
Carlos has led the Strategic Environmental Assessment of the Olkaria and Eburru Geothermal
Development Programme in Kenya, and worked on the SEA for Local Land Use Plans in Spain
and in the Sustainability Appraisal of the new High Speed Rail network in the United
Kingdom. In the Middle East he has worked in the development of environmental regulations
for the Economic Cities Authority (ECA) in the Kingdom of Saudi Arabia (KSA), as an
Environmental Advisor for King Abdullah Economic City (KSA) and in several Environmental
Impact Assessments of multiple water and power projects for ACWA Power in the MENA
region, including natural gas, heavy fuel oil, solar energy and wind power plants.
Zeina has 14 years of experience in EIA and sustainability, including technical and project
management roles. Her experience includes the preparation of Environmental and Strategic
Impact Assessments (EIAs; SEAs), Planning submissions and Sustainability Appraisals. Zeina
has effectively project managed and overseen SEA projects for multi purpose industrial,
commercial and residential developments exceeding $30 billion. Such notable projects
have included the Palm Jumeirah, World Islands and Dubai Maritime City in Dubai. The
pioneering designs of these multipurpose development projects and respective SEA’s
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Max Burrow
(5 Capitals)
ESIA Specialist
BSc Environmental
Management
included the integration of innovative technologies for power production, desalination and
waste management.
Max is experienced in the preparation and co-ordination of international environmental
studies & plans (e.g. EIA, SEA & CEMP) for major industrial developments; construction
auditing; specialist environmental reviews & surveys; field surveying and reviews of regional
environmental standards. Max’s work at 5 Capitals has been undertaken across the Middle
East and North Africa region in regard to the relevant national and international standards,
including Equator Principles and IFC/World Bank guidelines, where required by the client or
lending institutions.
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3 Project Description
3.1 Project Justification
The energy sector is one of the key sectors in Uganda’s economy. The country has a
total energy consumption of approximately 11 million TOE (tonnes of oil equivalent),
2010. This consumption is partially met by a number of energy resources including
solar power, biomass and fossil fuels. Biomass is the most important source of energy
for 97% of the population, providing for 90% of the total primary energy
consumption, in form of firewood, charcoal or crop residues. This dependence on
biomass is one of Africa’s highest. Electricity contributes only 1.1% to the national
energy balance (121,000 TOE), while oil products (mainly used for vehicles and
thermal power plants) account for 8.9%.
Concerning electricity generation, Uganda has an installed capacity of 835 MW,
mostly consisting of hydropower. The electrification rate in Uganda is very low with
12% at national level (1991: 5.6%; 2006: 9%; 2010: 10%) but only 5% - 6% in rural areas.
Uganda currently has one of the lowest per capita electricity consumption (70
kWh/year) in the world (Africa’s average: 578 kWh per capita, World average: 2,572
kWh per capita, Germany: 7,111 kWh per capita). About 72% of total electricity
supplied by the main grid is consumed by 12% of the domestic population
concentrated in the Kampala metropolitan area and nearby towns of Entebbe and
Jinja. Approximately 1% of rural households use off-grid electrification technologies
(usually diesel generators or solar photovoltaic systems).
Existing solar data shows that the solar energy resource in Uganda is high throughout
the year. With mean solar radiation of 5.1 kWh/m2 per day on a horizontal surface,
the country has a potential of 11.98 x 108 MWh gross energy resources. At an
estimated conversion efficiency of 10%, the country has available power of 11.98 x
107 MWh. For this reason, the Government of Uganda, the Energy Regulatory
Authority (ERA) and GET FiT are promoting the introduction of a Solar / PV power
production under the GET FiT Premium Payment Mechanism (GFPPM). The proposed
power plants aims to be part of the GFPPM.
The two proposed photovoltaic Power Plants are going to be developed on one site
using the same power line to the Opuyo Substation. In terms of environmental and
social impacts no significant differences are expected, and the cumulative impact
of the concurrent development of both plants will be considered as a worst case
scenario. The Request for Proposals issued by GET FiT / ERA requires two separate
5MW PV plants instead of a single 10MW PV plant, so two separate licenses are
requested from NEMA.
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3.2 Project Location
The proposed PV Plant will be located in Soroti District, which is located in Eastern
Uganda. It was formerly part of the Teso District, covering Kumi, Katakwi,
Kaberamaido, Amuria, Bukedea, Ngora, Serere and Soroti. Physically the district lies
approximately on latitudes 1o 33I and 2o 23I North of the equator, 30o 01I and 34o 18I
degrees East of the Prime Meridian and is over 2500 feet above Sea Level. Soroti
borders Serere, to the south, Ngora to the east, Katakwi to the north-east, Amuria to
the north, Lake Kyoga and Kaberamaido in the west.
The proposed plant will be located in Aliedi village, Opuyo Parish, Soroti Sub County,
along Aliedi Opuyo road. The site coordinates are provided below.
Table 3-1 Project Location
Project Site Coordinates
UTM(ARC1960 Zone 36N)
EASTINGS
NORTHINGS
573221.98
186823.47
573209.36
186862.32
572978.04
186894.72
572951.14
186723.05
572923.14
186689.92
572953.51
186572.99
572970.40
186540.63
572891.54
186500.56
572922.75
186446.64
572952.28
186392.25
573022.22
186425.89
573097.92
186476.94
573149.26
186498.96
573165.86
186463.15
573224.71
186452.70
573359.04
186562.02
573226.36
186693.32
573248.38
186710.69
573179.86
186786.34
The map below shows the proposed alignment for the 33kV power line that will
transmit the electricity to the Opuyo substation. It should be noted that even though
in the figure above the boundary appears to overlap with the local road, this road
will not be occupied by the project, the site boundary is adjacent to the road on its
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south site. The Figure below shows the proposed power plant and the proposed
alignment of the 33kV power lines to Opuyo substation.
Figure 3-1 Proposed Layout and Alignment of the power lines to the Opuyo
substation
3.2.1
Existing Land Uses on the Proposed Site
The proposed site is partly cultivated, with some sections covered with grassland
trees, and used for grazing, with no human settlements. The plates below illustrate
the current land uses on the site.
Figure 3-2 Existing Land Uses in the Proposed Site
Part of the proposed site
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Part of the proposed site
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Upper section of the proposed site
Lower section of the proposed site
Each of the sections in Chapter 8 baseline conditions describes the site and the
surrounding areas in relation to specific environmental and social aspects relevant
to the environmental and social assessment.
3.2.2
Sensitive Receptors
This section outlines the main sensitive receptors identified around the project site.
Specific environmental and social sensitivities are described in more detail in each
of the sections of the baseline chapter.
There are no environmentally or culturally protected areas close to the proposed
site.
Social sensitive receptors include the Aliedi Nursery and primary school and the
Opuyo school. The Aliedi School is located about 50m to the north of the site
(N01.68827 E033.65670, 1076m a.s.l) and there are local community settlements
400m away to the west of the proposed site (N01.68762 E033.65499, 1075m a.s.l).
The proposed alignment of the transmission line to the Opuyo substation runs along
a community road leading to Opuyo substation and to the Soroti – Mbale Highway.
The Opuyo Primary School is near the road, a few meters away from the proposed
alignment, and there are some community dwellings close to the road
(approximately 50m away). There are also gardens and cultivated areas along the
road, cultivated mainly with Cassava, fruit trees, millet, and various seasonal crops.
During the scoping phase consultations, the local communities stated that there
were no graveyards or other cultural sensitivities in the proposed project area.
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Figure 3-3 Potentially sensitive receptors
Neighbouring house about 400m from the
Access road to the proposed site and
site
transmission line area.
Proposed
road
reserve
for
the
transmission line near the Opuyo primary
A
road
section
along
which
the
transmission line will traverse.
school
3.3 Project Description
The proposed 2x5MW MW PV Plants will consist of numerous PV cells within modules
arranged in arrays upon mounting structures in a specific arrangement across the
proposed site. The arrays will be designed to ensure the most efficient alignment to
capture solar rays.
The electricity generation process using photovoltaic technology and the main
components required for this process are briefly described below.
PV Cell: A single photovoltaic cell comprises a specially treated semi-conductor
material (typically silicon) with separate front and back electrical contacts (positive
and negative) that are connected to form a circuit. Upon exposure to light,
electrons are knocked from the semi-conductor material under the photoelectric
effect and are transported around the electrical contacts to form a direct current.
PV Module: A module is the assembly of multiple PV cells mounted into a module.
Modules are designed to supply electricity at a certain voltage. PV modules
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typically are covered with an anti-reflective glass or coating to protect the solar cells
and to limit the amount of reflected sunlight.
PV Array: Multiple modules wired together form an array, or ‘panel’ that are then
arranged to form the solar plant. The arrays will be mounted onto a structure to
provide the optimum solar alignment.
Figure 3-4 PV Cell
Source: NASA, How Do PhotoVoltaics Work (2002)
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Figure 3-5 PV Cell, Module & Array (left) machine of ramming spikes (right).
Figure 3-6 Supporting structure (left) mounted PV array (right).
The characteristics of the PV arrays are summarised below for the two proposed
5MW Plants:
•
Number of modules: 16340
•
Number of structures: 4393
•
Alignment direction: N-S
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•
Slope of arrays:10º
•
Distance between rows: 2 meters (minimum for maintenance tasks)
•
The proposed mounting structure allows for 5% ground slope, so the amount
of ground works required will be very limited.
•
The assembly structure will be fixed, not moving during the day to maximize
the panel’s exposure to the sun.
•
The metal foundations for the PV arrays will be rammed into the ground
approximately 1.5 meters.
•
The solar field can be built on any surface, so it will not be necessary to
tarmac the ground to mount the solar panels. The paths between the PV
arrays will not be covered in any way, but the principal inner road will be
covered with a layer of gravel.
In addition to the PV arrays and mounting structures, a number of ancillary facilities
will also be included to the plant layout for electrical conversion and distribution,
including mainly cables and inverters.
Solar panels produce direct current (DC) electricity, so solar parks need conversion
equipment to convert this to alternating current (AC), which is the form transmitted
by the electricity grid. This conversion is undertaken by inverters that typically
provide power output at voltages of the order of 480 VAC. Electricity grids operate
at much higher voltages of the order of tens or hundreds of thousands of volts, so
transformers are incorporated to deliver the required output to the grid.
Figure 3-7 Inverter (left) step up transformer (right).
The interconnection with the Opuyo substation will be through an overhead line. The
proposed alignment of the power lines is shown in Figure 3-1. An alternative
alignment to increase the distance to the school is shown in Figure 9-2.
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The operation of the facility can be remotely monitored on line (via internet or by a
dial-in system). The daily production will be correlated versus the meteorological
data in order to assess potential system malfunctioning.
Further to the ancillary electrical facilities, several support services/facilities will also
be provided at the proposed plant. These will include:
•
Access roads and internal road network;
•
Storm water drainage system;
•
Potable water, stored in a tank and delivered by a tanker;
•
Sanitary facilities: Domestic and sanitary wastewater from the operational
plant will be collected in a septic tank and removed by a licensed
contractor;
•
Security System;
•
Fire Detection and Fighting System (at the step up transformer and
switchgear installation);
•
Lighting;
•
Perimeter fence.
The wastes generated onsite during the operational phase include oil from
transformers maintenance tasks and will be collected in a tank and removed at
regular periods, sanitary wastewater and wastewater from cleaning the panels.
The figures below show the layout of the two proposed 5MW PV Plants within the
proposed project site.
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Figure 3-8 5 MW Power Plant Layout (I)
10 MW Photovoltaic Power Plant in Soroti, Uganda
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Figure 3-9 Proposed 5 MW Power Plant (II)
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3.4 Construction Phases and Workforce Requirements
The construction stage of the 2x5MW Plants will require significantly more staff than the operational phase. The estimated workforce
requirements during the construction phase are outlined in the table below. For the construction phase less staff will be required as
the functioning of the plant will be automated and only maintenance, security and module cleaning are likely to be required. For the
decommissioning phase more personnel will be required, but the exact numbers cannot be estimated at this stage,
Table 3-2 Required staff during the construction phase
Number
of staff
Project activity
Description
Key personnel
Detail
Engineering
• Complete design engineering of the photovoltaic plant.
• Site Assessment.
Project manager, civil engineer,
electrical engineer, mechanical
engineer and HSE manager.
10
Civil Works
Site preparation including:
• Removal of vegetation.
•Earth movement required for land preparation to the needs
required for fixing the structure.
• Foundations to support transformers stations.
• Download and installation of transformers stations.
• Trenches for BT and MT wiring.
• Completion of internal roads in the plant.
• Construction of perimeter security fencing.
• Construction of building operation and maintenance.
• Water Supply System
• Drainage systems.
Project manager, civil engineer
and Constructor manager.
30
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Mechanical
Works
Mounting the fixed structure for PV modules including fixing to the
ground.
Project manager and
constructor manager
30
Electrical Works
• LV and MV wiring.
• Installation of AC boxes.
• Interconnection of the elements of the photovoltaic plant.
• Signals.
• Fire protection system.
• Auxiliary systems.
• Grounding of the installation.
Project manager and electrical
engineer
25
Security System
Installation of video surveillance and monitoring of the plant during
the construction period.
Project manager and electrical
manager
5
Meteorological
station,
monitoring
system and
Control system
• Installation of weather station
• Installation of the photovoltaic plant monitoring
• Installation of PV Plant control system.
Project manager, Control
manager and electrical
engineer
5
Commissioning
Test the correct operation of all plant equipment.
Project manager, constructor
manager and electrical
engineer
7
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3.5 Construction techniques, schedule and equipment
The construction of the proposed project will require limited earthworks to level the
site for the positioning of the different modules, the installation of the mounting
structures and the PV arrays, the construction of the internal roads and paths, the
installation of the required electrical equipment (cables, inverter), fencing, security
equipment.
The EPC contractor, TSK, has a management manual (included in the annexes) that
aims to ensure, inter alia, that HSE risks are properly addressed and mitigated. This
management manual is not site or project specific. The ESIA will include detailed site
and project specific documentation (e.g. CESMP, OESMP, ESMMP…) and an outline
of the principles and contents of these documents is provided in chapter 10 ESMS.
The following aspects relating to construction practices are relevant for this
environmental and social assessment:
•
The laydown area will be placed inside the project plot area, and will not be
paved, with the exception of the bunded areas where vehicle fuel and oils
will be stored;
•
The workers, who will come from outside, will be accommodated in Soroti
(approximately 6 km away);
•
Portable chemical toilets will be provided onsite during the construction
phase. The main chemical products used in this type of toilets are deodorizers
and their principal components are formaldehyde and bromine. Licensed
contractors will change these chemicals regularly.
•
For the drinking water, there will be a regular supply through a tanker.
•
No nighttime works will be conducted.
•
Segregated waste disposal containers will be on site for all the packaging
materials.
It should be noted that the points above are the result of a discussion between the
environmental consultants, the EPC and the project proponent, and reflect the
preliminary analysis outlined in chapters 8 and 9.
3.5.1
Construction equipment
The table below shows the main construction machinery, equipment and ancillary
facilities that will be deployed and used during for the two 5MW projects.
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3.5.2
Project Schedule
The table below outlines the planned project schedule for the construction of the
two 5MW plants.
Table 3-3 Project Schedule
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3.6 Sourcing of the PV panels
Electricity generation using photovoltaic technology has comparatively few impacts
(e.g. air emissions, water requirements, wastewater discharges, noise or the
consumption of non-renewable resources) during the operational phase when
compared to other electricity generation technologies.
However, the Life Cycle Assessment Analysis of photovoltaic technology has shown
that the production of the cells and modules and their disposal/recycling are key
aspects that need to be considered to fully assess the impact of photovoltaic power
production.
The decommissioning phase for the proposed power plant is analysed in relation to
the different environmental and social aspects in chapter 9.
Obtaining information about the impacts related to the sourcing of materials (when
this is not done locally) and the production of the manufactured goods for a project
is not always easy, in particular for a relatively small project like the two 5MW PP
proposed.
However the environmental consultants, Access Advisory and TSK have attempted
to obtain information on the production of the panels that will be used in the plant.
The production of the photovoltaic modules will be undertaken by “Canadian Solar
Inc.” at their factory in their factory in Jiangsu, China. This factory is regularly
inspected by the “VDE Testing and Certification Institute” (based in Offenbach,
Germany). The 2013 inspection certificate is provided in the annexes.
The environmental information obtained to date on the production of the PV
modules is insufficient. The project proponent and the environmental consultant will
attempt to obtain additional documentation on the specific production process for
the proposed modules and assess their environmental impacts. This information will
be provided in the ESIA, including a detailed description of the materials and energy
used in the production process, wastes and by-products generated, and the
environmental and social impacts in the production area.
3.7 Project Alternatives
The consideration of alternatives based on environmental and socioeconomic
considerations in the ESIA allows for the most sustainable alternatives to be identified
and for the most environmentally and socially harmful alternatives to be rejected.
However, the assessment of alternatives is undertaken at the ESIA stage and is
constrained by decisions made earlier in the development process. In this case, the
choice of technology was determined by the GET FiT Programme, and the suitable
locations were constrained to some areas within the country, to a 3km radius of an
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existing substation. This has severely limited the type of alternatives that can be
considered in the environmental and social assessment process. The ESIA will assess
the following alternative options:
•
No Project Alternative: The no project alternative involves not developing the
proposed power plants at Soroti. This would result in no negative impacts on
the environmental and socioeconomic environment, but the positive impacts
in terms of electricity generation and other socioeconomic benefits would
not be achieved.
•
Alternative Location: Potential project locations have been limited by the
areas outlined in the RFP, the distance to a substation, the availability of the
solar resource, environmental and social constraints (resettlement, protected
areas) and the availability of land for sale.
The Soroti area was chosen as solar irradiation and topography are
adequate, there is a suitable substation, it is not a protected area and there is
agricultural land available for sell. For alternative sites were considered, as
shown in the figure below.
Figure 3-10 Alternative sites - Soroti
The main reason for the selection of site 3 was the fact that there was a group
of land owners that had adjacent land of the right size, no conflict over land
tenure and the willingness to lease their land for the duration of the project. In
the other sites there were difficulties finding out who owned some plots and
contacting and bringing together enough owners to make a plot of the
required size.
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The sites showed similar environmental and social characteristics, as the
population in this area have similar livelihood strategies and the habitat on
the sites is similar (i.e. agricultural land using traditional cultivation techniques),
so the selection of an alternative site in the area would have resulted in similar
environmental and social opportunities and constraints.
•
Alternative PV Technology: Different PV technologies result in similar minor
impacts on the project site during the construction and operational phases.
The main differences result from the production and the recycling of the PV
modules. The different impacts of alternative PV technologies will be
described in the ESIA when more information is available about the sourcing
of materials and the impacts related to the production of the modules, as
described in Section 3.6.
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4 Legal Framework, Standards and Guidelines
4.1 National Requirements
4.1.1
The Ugandan Constitution
The Uganda Constitution of 1995 states in articles 39 and 41 that everyone has a
duty to maintain a sound environment. Every person in Uganda has a right to a
healthy and clean environment and as such can bring legal action for any pollution
or disposal of wastes. It also stipulates that Parliament shall by law provide measures
intended to protect and preserve the environment from abuse, pollution and
degradation.
For acquisition of land for development and other purposes, Article 237(1) of the
Constitution vests all Ugandan land in its citizens. However, under Article 237(1) (a),
the Government or Local Government may acquire land in the public interest. Such
acquisition is subject to the provisions of Article 26, which gives every person in
Uganda a right to own property. It provides procedures to follow during the
acquisition of land for public interest and provides for the “prompt payment of fair
and adequate compensation” prior to taking possession of land.
All the laws outlined below are based on the Constitution.
4.1.2
Uganda’s Vision 2040
In ‘Vision 2040’ Uganda Government set goals to achieve by the year 2040 ranging
from political, economic, social, energy related and environmental. With respect to
environmental goals, the Government aspires to have sustainable social-economic
development
that
ensures
environmental
quality
and
preservation
of
the
ecosystems in the country. Vision 2040 recognises energy as a key driver of the
economic development and notes that for Uganda to shift from a peasantry to an
industrialized and urban society, it must be propelled by electricity as a form of
modern energy. It estimates that Uganda will require 41,738 MW of electricity by
year 2040 thus increasing its electricity consumption per capita to 3,668 kWh. The
target for solar powerby 2040 is 5000MW. Furthermore the access to the national grid
must significantly increase to 80 percent.
Vision 2040 seeks to promote other forms of renewable energy including wind, solar
and biomass taking into account the risks of climate change.
The proposed PV plant should have a net positive effect to advance towards Vision
2025. The ESIA will include mitigation measures to ensure that detrimental
environmental and socioeconomic impacts are avoided or minimized and that
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positive impacts are maximized, in order to contribute as much as possible to
advance towards Vision 2040.
4.1.3
Environmental Management
Under the 1995 National Environment Statute NEMA is the Agency for the
management of the environment and shall coordinate, monitor and supervise all
activities in the field of the environment.
The Statute provides tools for environmental management including EIAs. It imposes
a mandatory duty on project developers to have an EIA conducted and approved
before embarking on a project that might have significant environmental impacts.
The National Environment Management Policy, 1994, aims to promote sustainable
economic and social development taking into consideration of the needs of future
generations. EIA is one of the tools it considers necessary to ensure environmental
quality on long-term basis. The policy requires that projects likely to have significant
adverse ecological or social impacts undertake EIA before their implementation. This
is equivalent to Strategic Environmental Assessments.
Section 20 of National Environmental Act requires projects likely to have significant
environmental impacts to have an EIA conducted before their implementation.
According to the Third schedule of Act, any development that involves major
changes in land use is subjected to an EIA. The Act provides for environmental
standards. They include standards for air quality, water quality, effluent discharge,
noise and soil quality. A number of supporting regulations have been developed
under Section 108 of the act to operationalise the act and other support legislations.
The EIA Guidelines stipulate that the EIA process should be participatory, that is the
public should be consulted widely to inform them and get their views about the
proposed project. The developer has the legal obligation to seek the views of the
public, persons that may be affected by the proposed project, as well as all other
stakeholders.
The ESIA for the proposed PV project in Soroti will follow the prevailing environmental
regulations and NEMA’s Guidance. It will also ensure that stakeholders are involved
in the assessment process. All the relevant parameters (e.g. soil, noise, water, social
aspects) will be covered by the assessment following NEMA’s requirements and
guidelines.
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4.1.4 Energy Policy
According to the 2002 National Energy Policy the goal of the energy sector is to
meet the energy needs of the Ugandan population for social and economic
development in an environmentally sustainable manner.
The Ministry of Energy and Mineral Development (MEMD) will ensure that
environmental considerations are given priority by energy suppliers and users to
protect the environment and will put in place a monitoring mechanism to evaluate
compliance with established environmental protection guidelines.
The Renewable Energy Policy for Uganda was enacted in 2007. It aims to increase
the use of modern renewable energy from the current 4% to 61% of the total energy
consumption by the year 2017. The overall effect of this is expected to be the
diversification of the energy supply. The Policy Framework provides a basis for the
formulation of planning, implementation and monitoring of renewable energy
programmes, as well as projects that respond to the needs and priorities of the
population at various levels of the economy.
The 1999 Electricity Act provides for the establishment of the Electricity Regulatory
Authority (ERA) whose functions include: issuing licenses for the generation,
transmission, distribution or sale of electricity; controlling activities in the electricity
sector; liberalizing and bringing competition in the electricity sector.
Section 30 of the Electricity Act requires that before a license is issued, the developer
shall provide NEMA the description of the impact of the project on electricity supply,
socio-economics, cultural heritage, the environment, natural resources and wildlife.
The Act authorizes the ERA to delegate some of its licensing functions to local
governments and to be paid royalties by the developers.
The proposed project aims to provide energy to the grid and needs to be aligned
with the Energy Policy of Uganda. It also needs to comply with the requirements of
the Ministry and of the ERA. The ERA is the Ugandan Authority participating in the
GET FiT Programme and tendering the PV projects.
4.1.5
Water Resources Management
The management framework for water resources in Uganda is spelt out in the Water
Statute, 1995 and the National Water Policy (1997). The Water Statute, 1995 provides
for the use, protection and management of water resources and supply.
The overall objective of the National Water Policy is “to manage and develop the
water resources of Uganda in an integrated and sustainable manner, so as to
secure and provide water of adequate quantity and quality for all social and
economic needs, with the full participation of all stakeholders, and so as not to
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leave the future generations any worse off than ourselves”. The leading institution on
water issues in Uganda is the Ministry of Water and Environment, which implements a
Water Action Plan and the National Wetlands Policy. The plan ensures sustainable
management of water resources.
The 1995 National Policy on Conservation and Management of Wetland Resources
aims at curtailing loss of wetland resources and ensuring that benefits from wetlands
are equitably distributed to all people of Uganda.
In order to operationalize the policy and to provide a legal framework for its
implementation, wetland related issues have been adequately incorporated into
the National Environmental Act, Cap 153.
According to Section 6 of the Act, no person acquires any rights to use water or to
construct or operate any works unless authorized. Thus, unless a person is an
occupier of land on which surface water exists, water may not be used for any
purpose without the approval of an authority. The general rights to use surface water
are limited to domestic use and fire fighting.
Section 31 (1) of the Water Act stipulates that it is an offence for a person to pollute
water through discharge of waste into watercourses. In conformity with this law, the
spillage of petroleum products, disposal of overburden, litter or construction waste
should be avoided during construction and operation activities.
The Act provides for the use, protection and management of water resources and
supply in Uganda. Section 31, Sub-section (1) of the Water Act deals with prohibition
of pollution to water and stipulates that a person commits an offence who; unless
authorised under this Part of the Act, causes or allows:
•
Waste to come into contact with any water;
•
Waste to be discharged directly or indirectly into water;
•
Water to be polluted;
Under Section 107, the Water Resources Regulations of 1998; Water (Waste
Discharge) Regulations (1998); the Water Supply Regulations (1999) and the
Sewerage Regulations (1999) have been put in place to implement the Act and are
aimed at minimising pollution of public waters by developers and other users.
According to Regulation 4 (1) of the Water (Waste Discharge) Regulations (1998):
‘No person shall discharge effluent or waste on land or into aquatic environment
contrary to the standards established regulation 3; unless he or she has a permit in
the format specified in the First Schedule issued by Director of DWRM.’
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The Water Resources Regulations of 1998 stipulates a requirement to apply for a
water abstraction permit or a permit to construct, own, occupy or control any works
on or adjacent the land as per regulation 10.
PV technology has low water consumption compared to other electricity
generation technologies. However, water will still be required during the construction
and operation for the plant, for example for cleaning the PV panels. The sources of
water need to be assessed to ensure that water abstractions are compliant with the
regulations. The project is not located on a wetland but there are wetlands in the
vicinity, so potential impacts need to be considered in this ESIA. Any potential
impacts need to be adequately assessed. There is also potential for the
contamination of water as a result of the mismanagement of hazardous substances
or wastes.
4.1.6
Wildlife Management
The 1996 Uganda Wildlife Statute designates the Uganda Wildlife Authority (UWA) for
the management of wildlife. The purpose of the Statute is to promote the
conservation and sustainable utilization of wildlife throughout Uganda so that the
abundance and diversity of their species are maintained and are in balance with
other forms of land use. The Statute also emphasizes the importance of public
participation in wildlife management.
The Act defines wildlife as any plant or animal of a species native to Uganda. It vests
ownership of wild animals and plants in government for the benefit of all Ugandan
people, a responsibility executed through Uganda Wildlife Authority.
The proposed project is not located in a protected area. It will be developed on
land that has already been severely impacted by human activities, particularly by
agriculture. The ESIA will study the wildlife present in the site and in the area, assess
their sensitivity to the proposed activities and propose if necessary mitigation
measures to avoid or reduce potential impacts.
4.1.7
Waste Management
The 1999 National Environment (Waste Management) Regulations apply to all
categories of hazardous and non-hazardous waste and to the storage and disposal
of hazardous waste and its movement into and out of Uganda. The regulations
promote clean production methods and require the minimization of waste
generation; reducing hazardous emissions and wastes; and recovering, reusing and
recycling of waste.
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The proposed project will generate wastes, in particular during the construction and
decommissioning phases, and the management of waste needs to be compliant
with the regulations.
4.1.8
Forestry
The 2003 National Forestry and Tree Planting Act provides for the sustainable use of
forest resources and the enhancement of the productive capacity of forests and
provides for the promotion of tree planting.
The proposed project is not located at or adjacent to a forest, but there are a few
trees on the agricultural plots. The compensation and mitigation measures could to
include the provision of tree seedlings to the local communities, so the provisions of
the National Forestry and Tree Planting Act might be relevant to this ESIA.
4.1.9
Development Plans
The current National Development Plan covers the 2010/11 to 2014/15 period. It
stipulates the countries medium term strategic direction, development priorities and
implementation strategies. It recognizes electricity as a critical source of energy for
Uganda. The Plan provides for the construction of renewable energy projects. Under
its Objective 5, it provides for the strengthening policy, legal and institutional
framework aimed at regulating and monitoring energy policies/plans.
The proposed project has to be in line with the current National Development Plan,
the Soroti District Development Plans and the Soroti Subcounty Development Plan
(the last two obtained during the consultations). The main contribution of the project
to the Development Plan will be the provision of electricity to the grid. The ESIA will
include mitigation measures to ensure that detrimental environmental and
socioeconomic impacts are avoided or minimized and that positive impacts are
maximized, in order to contribute as much as possible to the development in the
area. The Plant will fully comply with the regulatory requirements for energy projects,
in order to contribute to institutional strengthening.
4.1.10 Land and land acquisition
The 1998 Land Act provides for the ownership and management of land, addressing
holding, control, management and disputes. It provides for four different types of
land tenures (Customary, Leasehold, Mailo and Freehold) and the procedure for
applying for grant of any of the tenures. The Act states that non-citizens of Uganda
may only be granted leases not exceeding 99 years.
The Act states that the construction of electricity transmission and distribution lines
are public works and any person authorized to execute public works on any land
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may enter into mutual agreement with an occupier or owner of the land in
accordance with the Act.
The developer of an energy project should therefore seek to enter an agreement
with the occupier or owner of the land. The Act creates a series of land
administration institutions consisting of Uganda Land Commission (ULC), District Land
Boards (DLB), Parish Land Committees (PLC) and land tribunals. Section 78 of the Act
gives valuation principles for compensation.
Section 40 requires the written consent from the spouse(s) and children before the
household head transfers, sells or enters into contract of land where the household
derives its livelihood. The District Land Tribunals have power to determine any
disputes arising out of compensation for land.
For energy development projects in general, the developer will have to source funds
for resettlement or compensation.
The Land Acquisition Act provides for the procedure and method of compulsory
acquisition of land for public purposes whether for temporary or permanent use. The
minister responsible for land may authorise any person(s) to enter upon the land and
survey it, dig or bore the subsoil or any other thing necessary for ascertaining
whether the land is suitable for a public purpose. The government is expected to
compensate any person who suffers damage as a result of any action. Any dispute
as to the compensation payable can be referred by the Attorney General to court
for decision.
For the proposed project a voluntary land acquisition process has
been undertaken as described in ANNEXES
Annex 1: Discussion of the Land Acquisition Process
Annex 2: Livelihood Restoration Plan
Annex 3: Soil and Water Analysis Results (baseline surveys)
Annex 4: Calibration Certificates (baseline surveys)
Annex 5: Plants lists and forms at the proposed Solar PV area (baseline surveys)
Annex 6: Socioeconomic baseline questionnaire (baseline surveys)
Annex 7: Stakeholder Consultation Letter (stakeholder engagement)
Annex 8: Stakeholder Meeting Hand-out (stakeholder engagement)
Annex 9: Attendance lists for stakeholders consultations (stakeholder engagement)
Annex 10: ACCESS Environmental Policy (ESMS)
Annex 11: TSK Management Policy (ESMS)
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Annex 12: TSK Management Manual (ESMS)
Annex 13: Factory Inspection Procedure: Canadian Solar Manufacturing, Jiangsu
Factory, China (ESMS – LCA impacts)
Annex 14: Attendance sheet for the land demarcation and inspection (Land
Acquisition Process)
Annex 15: Sample application for grant of freehold (Land Acquisition Process)
Annex 16: Non Objection Certificates for the lease of the land – Spouse and eldest
child. Compliance with the land acquisition act will be assessed.
4.1.11 Local Land Use Planning
The 1997 Local Government Act provides for decentralization and devolution of
government functions, powers and services from the central to local governments
and sets up the political and administrative functions of local governments. The local
governments are responsible for the protection of the environment at the district
level. Local governments shall be consulted on projects to be located within their
jurisdiction and on matters that affect their environment.
The Physical Planning Act (2010) was passed to consolidate the law on physical
planning in order to make the whole country a planning area. This Act repeals the
Town and Country Planning Act, Cap 246. The Physical Planning Act establishes a
National Planning board which shall be responsible for physical planning. Clause 32
of this Act provides for a landowner to use services of a qualified planner to prepare
a local physical plan which shall be submitted to the local physical planning
committee for adoption with or without modifications. Part 8 is concerned with
control of development and clause 38 of this part specifies that an applicant for
development permission in a planning area must obtain an Environmental Impact
Assessment certificate in accordance with the National Environment Act.
Consultations with the local government in Soroti are part of the Stakeholder
Engagement Plan (SEP) for this ESIA. The concerns of the local government will be
incorporated into the assessment process.
4.1.12 Roads
The 1949 Roads Act defines a road reserve as that area bounded by imaginary lines
parallel to and not more than fifty feet distant from the centreline of any road. The
Act states that no person shall erect any building or plant trees or grow permanent
crops within a road reserve. However, it allows the roads authorities to dig and take
materials from the road reserve for the construction and maintenance of roads.
The Access to Roads Act, cap 350, regulates the construction of access roads.
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The 1998 Traffic and Road Safety Act provides the requirements for vehicles and
drivers in the country, and determines the relevant penalties for violations.
The current project will use the public roads, having a significant impact during the
construction phase. The construction of the 33 kV power line along the road to the
substation needs to take into consideration he roads act. The EPC and the
contractors need to ensure that all vehicles and drivers comply with the
requirements outlined in the Traffic and Road Safety Act 1998. The Soroti DLG
indicated during the consultations that the roads to the project site is a community
road, not surveyed or gazetted.
4.1.13 Public Health
The main objective of the Public Health Act (1964) is to safeguard and promote the
public health. Section 7 of the Act provides local authorities with administrative
powers to take all lawful, necessary and reasonable measures for preventing the
occurrence with any outbreak or prevalence of any infectious communicable or
preventable diseases. Local Authorities are mandated to exercise powers and
perform the duties in respect of public health conferred or imposed by this act or
any other law.
Section 105 of the Act imposes a duty on the Local Authority to take measures to
prevent any pollution dangerous to the health of any water supply that the public
has a right to use for drinking or domestic purposes. The Act also details the siting of
waste disposal facilities such as solid waste skips in relation to settlements and food.
The 2004 National HIV/AIDS Policy provides the overall policy framework for the
national HIV/AIDS response. It also recognizes special groups, which include migrant
workers. It also recommends the need to identify strategies to address migrant
workers in view of the challenges posed by their mobility and vulnerability to
HIV/AIDS.
This ESIA aims to ensure, inter alia, that the project does not have a detrimental
impact on the health of the local population. Due to the small size of the project the
required workforce will be limited, as will be the influx of workers. In any case, the
potential spread of HIV needs to be considered.
4.1.14 Occupational health and safety
The Factories Act (1964) provided for the health, safety and welfare of persons
employed in factories and other places. Areas of concern under the Act include
overcrowding, ventilation and lighting, housekeeping, and general safety aspects
pertaining to work in confined spaces and fire safety. Workers must have adequate
training for their specific jobs and also in the proper use of protective equipment.
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The Occupational Safety and Health Act, 2006, requires every employer to provide
and maintain safe working conditions, imposing a duty on employers to take
measures to protect workers and the public from risks and dangers of their
undertaking at his or her own cost (Section 13). It also requires employers to ensure
the working environment is kept free from pollution by employing technical
measures applied to new plants or processes and employing supplementary
organizational measures (Section 13). Employers with at least 20 workers should
prepare and often revise a written statement of policy with respect to safety and
health of workers (Section 14). Every workplace must be kept in a clean state, free
from effluent arising from any drains and sanitary facilities (Section 46). The Ministry is
obliged to provide employers with washing facilities, First Aid, facilities for meals, safe
access to the workplaces and safe work practices.
The Workers Compensation Act, Cap. 225 requires the provision of Personal
Protective Equipment (PPE) to employees minimizes accidents and injuries.
All of the Health & Safety requirements in terms of worker protection and welfare
facilities, and housekeeping to ensure a safe working environment are applicable to
the construction and operational phases of the proposed PV plant in Soroti.
The employees that will carry out construction activities in the proposed PV Plant will
require PPE so that the various sections of the Workers' Compensation Act are
complied with.
4.1.15 Employment
Employment Act, 2006 (which repeals Employment Act Cap 219 enacted in 2000) is
the principal legislation that harmonises relationships between employees and
employers, protect workers interests and welfare and safeguards their occupational
health and safety through:
•
Prohibiting forced labour, discrimination and sexual harassment at workplaces
(Part II; Part IV).
•
Providing for labour inspection by the relevant ministry (Part III).
•
Stipulating rights and duties in employment including weekly rest, working
hours, annual leave, maternity and paternity leaves, sick pay, etc. (Part VI).
•
Continuity of employment i.e. continuous service, seasonal employment, etc
(Part VIII).
The Labour Disputes (Arbitration and Settlement) Act, 2006 provides for dispute and
resolution settlement and establishes and industrial court with its functions.
Collective agreements are legal in Uganda and have to be registered with the
Labour Officer. The Labour Unions Act, 2006 regulates the establishment, registration
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and management of labour unions and to provide for other related matters. It
provides for the right of employees to organize themselves in a labour union and the
employer not to interfere with the right of association. It stipulates that an employer
shall not discriminate in regard to the hire, tenure or any terms or conditions of
employment in order to discourage membership in a labour union, discourage an
employee on account of his/her lawful involvement or proposed lawful involvement
in the activities of a labour union, including his/her participation in industrial action
arising in connection with a labour dispute and not in contravention of the Labour
Disputes (Arbitration and Settlement) Act, 2006.
The Project Company and the contractors for the proposed PV plant will comply
with these requirements in terms of labour disputes and union creation and
membership.
4.1.16 Archaeology
The Historical and Monuments Act protects archaeological and cultural sites in
Uganda. The Act provides for the preservation and protection of historical
monuments and objects of archaeological, palaeontological, ethnographical and
traditional interest.
The Act prohibits any person from carrying out activities on or in relation to any
object declared to be preserved or protected. Section 10 of this Act spells out the
procedures and requirement to declare and inspect newly discovered sites that
may
have
archaeological,
palaeontological,
ethnographical,
historical
and
traditional significance for purposes of protection.
The ESIA for the proposed PV plant will check any potential archaeological and
cultural sites near the project site, and include a procedure to deal with chance
findings during earthworks that is compliant with the Act.
During the public consultations, no elements of cultural significance identified by the
community and other stakeholders e.g. no graves or other forms of physic-cultural
resources
4.2 International Treaties and agreements signed by Uganda
Uganda has signed and /or ratified several international agreements relating to the
environment. Those that can potentially be applicable are outlined below:
•
Uganda has ratified ‘The Convention on Biological Diversity (CBD)’. This
Convention’s main objective is to ensure the conservation of biological
diversity and the sustainable use of its components.
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•
Uganda has signed but not ratified the Convention on the Conservation of
Migratory Species of Wild Animals (CMS). The objective of the Convention is
to conserve those species of wild animals that migrate across or outside
national boundaries.
•
Uganda is a party to the Agreement on the Conservation of African-Eurasian
Migratory Waterbirds, or African-Eurasian Waterbird Agreement (AEWA) is an
independent international treaty developed under the auspices of the UNEP's
Convention on Migratory Species.
•
Uganda has ratified the African Convention on the Conservation of Nature
and Natural Resources (1968), signed the Protocol Agreement on the
Conservation of Common Natural Resources (1982).
No impacts on critical habitats are foreseen at this stage. If during the ESIA studies, in
particular during the detailed ecological surveys that are proposed, any impacts on
critical habitats or impacts on migratory or protected species are identified, the
requirements of the four conventions outlined above will be taken into consideration
for the avoidance and mitigation of detrimental impacts.
•
Uganda has ratified the Convention on Wetlands of International Importance
(Ramsar Convention).
•
International treaties and agreements concerning the River Nile.
The project is close to the wetlands system associated with Lake Kyoga. No impacts
on the wetlands are expected at this stage, but if any impacts were identified, the
agreements and conventions relating to the River Nile would be applicable.
Lake Kyoga is not designated as a Ramsar Site but Lake Nakuwa Wetland System
was designated in 2006. If any significant impacts were identified in Lake Kyoga, the
potential secondary impacts on Lake Nakuwa Wetland System would be assessed
taking into account its Ramsar designation.
•
Vienna Convention for the Protection of the Ozone Layer and the Montreal
Protocol on Substances that Deplete the Ozone Layer.
No Ozone depleting substances identified in the abovementioned conventions will
be used as part of the project. This requirement will be included in the CESMP and
OESMP and will be binding for the contractors as well as for the project company.
•
1992 United Nations Framework Convention on Climate Change (UNFCCC)
and Kyoto Protocol to the United Nations Framework Convention on Climate
Change
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Photo voltaic technology is not carbon intensive, as no hydrocarbon fuels are burnt
during the operational phase for electricity production. This will be assessed in the
ESIA.
•
No
Stockholm Convention on Persistent Organic Pollutants.
persistent
organic
pollutants
(POPs)
identified
in
the
abovementioned
conventions will be used as part of the project. This requirement will be included in
the CESMP and OESMP and will be binding for the contractors as well as for the
project company.
•
Convention on the Elimination of All Forms of Discrimination against Women
•
Protocol to the African Charter on Human and Peoples' Rights on the Rights of
Women in Africa
•
International
Convention
on
the
Elimination
of
All
Forms
of
Racial
Discrimination
•
Convention on the Rights of the Child
•
Convention concerning the Prohibition and Immediate Action for the
Elimination of the Worst Forms of Child Labour
•
Abolition of Forced Labour Convention
•
Right to Organise and Collective Bargaining Convention
The HR policy of the Project Company will include provision for elimination of all
types of discrimination, including discrimination against women and racial
discrimination, for the prohibition of child and forced labour, and for the protection
of labour unions and collective bargaining rights. These requirements will be
included in the CESMP and OESMP and will be binding for the contractors as well as
for the project company.
4.3 International Requirements
4.3.1
The World Bank / IFC Environmental Safeguard Policies and Performance
Standards
The World Bank Group / International Finance Corporation (IFC) Environmental,
Health and Safety (EHS) General Guidelines of April 2007 superseded the World Bank
EHS Handbook issue of 1998.
In addition, a number of sector specific guidelines have been revised or are
undergoing peer review. Both the IFC Sustainability Framework, that defines the IFC
approach
towards
sustainability
and
Scoping Report
the
environment,
and
the
IFC/WBG
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performance Standards, that define the clients' responsibilities for managing their
environmental and social risks, have been updated in 2012.
The updated EHS Guidelines serve as a technical reference source to support the
implementation of the Performance Standards.
The Performance standards and how they apply to the proposed PV Project in Soroti
are outlined below.
Performance Standard 1 covers several types of Environmental Assessment
instruments, including ESIAs. These standards require that the Environmental
Assessment is undertaken to a high standard and compliant with International Best
Practice. Specifically, the objectives of PS1 are:
•
To identify and evaluate environmental and social risks and impacts of the
project;
•
To adopt a mitigation hierarchy to anticipate and avoid, or where avoidance
is not possible, minimize, and, where residual impacts remain,
compensate/offset for risks and impacts to workers, Affected Communities,
and the environment;
•
To promote improved environmental and social performance of clients
through the effective use of management systems;
•
To ensure that grievances from Affected Communities and external
communications from other stakeholders are responded to and managed
appropriately;
•
To promote and provide means for adequate engagement with Affected
Communities throughout the project cycle on issues that could potentially
affect them and to ensure that relevant environmental and social information
is disclosed and disseminated.
This scoping report is the initial step for the full Environmental and Social Impact
Assessment and for the design of an Environmental and Social Management System
for the project that will function throughout the construction, operational and
decommissioning phases of the projects.
Performance Standard 2: Labour and Working Conditions aims to promote the fair
treatment, non-discrimination, and equal opportunity of workers; to establish,
maintain,
and
improve
the
worker-management
relationship;
to
promote
compliance with national employment and labour laws; to protect workers,
including vulnerable categories of workers such as children, migrant workers, workers
engaged by third parties, and workers in the client’s supply chain; to promote safe
and healthy working conditions, and the health of workers and to avoid the use of
forced labour.
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Compliance with this performance standard is addressed in this scoping report in
section 9.10 Worker Welfare and will be further considered in the ESIA.
Performance Standard 3: Resource Efficiency and Pollution Prevention, aims to avoid
or minimize adverse impacts on human health and the environment by avoiding or
minimizing pollution from project activities, to promote more sustainable use of
resources, including energy and water and to reduce project-related GHG
emissions.
Compliance with this PS is considered in sections 9.2 Air Quality 0 As a result of the
information gathered during the scoping exercise (review of the project information,
initial site investigations, stakeholder engagement and identification of potential
impacts) a list of preliminary mitigation measures has been compiled for
consideration in the ESIA. This preliminary mitigation measures will be reviewed in
light of the additional information gathered as part of the ESIA preparation,
including the additional baseline surveys and consultations and the systematic
assessment of impacts.
The preliminary mitigation measures identified and recommended for consideration
in the ESIA include the following:
•
Access roads from the entrance to the site will be compacted and sprayed
with water to minimise the dust generated from the vehicles and trucks. This
potential mitigation measure will be discussed to ensure that there is water
available without interfering with the needs of the community;
•
Deliveries of equipment/plant to the site will be efficiently managed to
reduce the number of trips, and therefore the dust generated in the access
road and the vehicular emissions;
•
Ground-works activities will be minimised during high winds periods;
•
Large soil piles will be avoided where possible;
•
A visual assessment of dust emissions (visual monitoring) will be undertaken on
a continuous basis by the EHS team. Dust producing activities will be stopped
and screened or undertaken in periods of low wind;
•
Designated roads will be made clear to the drivers and signs for the directions
and speed limit will be placed all along the roads;
•
Where sand and other dusty material (e.g. cement) is transported to the site,
trucks will not be overloaded and will be appropriately covered / sheeted;
•
Sand and other dusty materials (e.g. cement) will be stored in specific
designated areas and covered while in storage.
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•
Exhaust fumes and particulates emitted from trucks and vehicles will be
minimised by assuring the use of good condition vehicles and conducting
regular maintenance. The EPC will keep a record of the maintenance and
exhaust emissions of all vehicles.
•
Routine monitoring of the PM levels and wind conditions at the site and at the
nearby sensitive receptors will be conducted, in order to verify that on site
operational activities are not contributing to any potential increases in dust
levels. The frequency of the monitoring will be determined at the ESIA stage.
•
Vehicles will be turned off while waiting on site to minimise gaseous emissions.
Shaded shelters for drivers will be provided for waiting periods and
loading/unloading, so that they don’t keep the engine on for the AC.
•
Fires and material burning will not be allowed on the Project site.
•
Hazardous materials stored and used on site with potential gas emissions (e.g.
VOCs) will be located in well ventilated secure areas away from the
community road.
•
The chemical bathrooms during construction will be emptied following the
manufacturer’s indications, to avoid odour.
Geology, Soil, Groundwater and Land Contamination 9.4 Noise and Vibration 9.5
Water Resources & Wastewater Management 9.6 Solid and Hazardous Waste and
9.11 Electromagnetism. A more detailed assessment and final mitigation measures
will be included in the full ESIA report.
Performance Standard 4: Community Health, Safety, and Security aims to anticipate
and avoid adverse impacts on the health and safety of the Affected Community
during the project life from both routine and non-routine circumstances and to
ensure that the safeguarding of personnel and property is carried out in
accordance with relevant human rights principles and in a manner that avoids or
minimizes risks to the Affected Communities.
Compliance with this PS in relation to environmental impacts to the affected
communities is considered in sections 5.2 Air Quality 5.3 Geology, Soil, Groundwater
and Land Contamination 5.4 Noise and Vibration 5.5 Water Resources & Wastewater
Management 5.6 Solid and Hazardous Waste and 5.11 Electromagnetism. The
safeguarding of personnel is considered in 8.10 Worker Welfare and emergency
preparedness is considered in the draft ESMS provided in Error! Reference source not
found..
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Performance Standard 5: Land Acquisition and Involuntary Resettlement. Land
acquisition for the land has been undertaken on a voluntary basis. The agreement
was voluntary and no expropriation process would have been triggered if a
voluntary agreement had not been reached. Even though there is no involuntary
resettlement, a Livelihood Restoration Plan has been prepared to anticipate and
avoid, or where avoidance is not possible, minimize adverse social and economic
impacts from land acquisition or restrictions on land use by (i) providing
compensation for loss of assets at replacement cost and (ii) ensuring that
resettlement activities are implemented with appropriate disclosure of information,
consultation, and the informed participation of those affected; and to ensure that
there is a restoration and improvement of the livelihoods and standards of living of
the economically displaced persons;
Performance Standard 6: Biodiversity Conservation and Sustainable Management of
Living Natural Resources. The project is not expected to impact critical ecosystems,
but the objectives of this PS will be taken into consideration. This standard aims to:
•
Protect and conserve biodiversity;
•
Maintain the benefits from ecosystem services; and
•
Promote the sustainable management of living natural resources through the
adoption of practices that integrate conservation needs and development
priorities.
Performance Standard 7: Indigenous People. The project does not trigger this PS as
the proposed project lies within an area where there are no tribes that comply with
the required characteristics in terms of internal organization and cultural and
historical attachment to the land to be classified as indigenous peoples. However,
this PS includes requirements in terms of establishing and maintaining an on-going
relationship based on Informed Consultation and Participation (ICP) with the local
communities affected by a project throughout the project’s life-cycle that will be
complied with.
Performance Standard 8: Cultural Heritage. The PS aims to Protect cultural heritage
from the adverse impacts of project activities and support its preservation and to
promote the equitable sharing of benefits from the use of cultural heritage The
project is not expected to affect any cultural heritage.
4.3.2
KfW
KFW Development Bank Sustainability Guidelines
Sustainability Guidelines (April 2014) state
that the
objective
of the
environmental and social assessments and climate change assessments required by
KfW is to anticipate and appraise any foreseeable impact a project may have on
the environment, the climate and/or on social factors, and to identify and prevent
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any negative impact, or limit it to a tolerable level and (provided that the negative
impact is inevitable but still tolerable) introduce compensation measures. In
addition, the assessments should identify, monitor and manage any residual risks. The
objective of the climate change assessment is also to recognise climate change
impacts that may impair the achievement of objectives in due time so that, if
applicable, required adaptation measures can be taken into consideration in the
project conception.
The sustainability guidelines state that when several lenders take part in a project,
the ESIAs will apply internationally recognised environmental and social standards
(e.g. World Bank Safeguard Policies, IFC Performance Standards, Environmental,
Health and Safety Guidelines of the World Bank Group, ILO Core Labour Standards,
EU Environmental Legislation), as KfW Development Bank aims to improve donor
harmonisation in accordance with the Paris Declaration.
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5 ESIA Methodology
This chapter justifies the need for an ESIA, outlines the methodology that will be used
to describe the environmental baseline and to identify, predict & assess the
environmental impacts of the project on each relevant environmental component.
It also covers the methodology for the identification of mitigation and monitoring
measures that will be recommended to address these impacts.
5.1 Need for an ESIA
5.1.1
Ugandan Legal Requirements
The Third Schedule of the National Environmental Act, Cap 153 (1995) lists the
projects to be considered for environmental impact assessment. This includes
(a) An activity out of character with its surroundings;
(b) Any structure of a scale not in keeping with its surroundings; and
(c) Major changes in land use.
And in relation to Electrical infrastructure, it includes
(a) Electricity generation stations; and
(b) Electrical transmission lines.
The proposed plant is an electricity generation station that will require new 33 kV
transmission lines and will be out of character with its agricultural surrounding. The
scale of the development is small and the land use change affects only a small
area.
NEMA published in 2004 Environmental Impact Assessment Guidelines for the Energy
Sector. This guidelines aim to provide detail guidance to energy developers on how
to ensure full compliance with the Ugandan EIA regulations. The guidelines include a
list of projects normally exempt from EIA, including solar energy (PV) < 10 kW and
single phase power distribution lines. So due to the size of the plants (two adjacent
5MW plants) a full EIA will be required.
5.1.2
IFC/WB Project Categorisation
The IFC Project categorization assigns an environmental and social category to an
investment project after appraisal and before public disclosure during the IFC
project/investment cycle. Projects are assigned a category of A, B, or C, in
descending order of environmental and social sensitivity.
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Category A includes projects expected to have significant adverse social and/or
environmental impacts that are diverse, irreversible, or unprecedented. Category B
includes Projects expected to have limited adverse social and/or environmental
impacts that can be readily addressed through mitigation measures. Category C
includes Projects expected to have minimal or no adverse impacts, including certain
financial intermediary projects.
The Environmental and Social impacts of the proposed project are limited, localised,
reversible and can be readily addressed through mitigation measures, so it is
considered to be a Category B project.
5.1.3
KfW Project Categorisation
According to KfW project categorisation and taking into consideration the criteria
outlined in appendix 1 of the April 2014 guidelines, the project will be a Category B,
as it may have a potentially negative impact on the environment and on the social
conditions of those concerned, which, however, is less severe than that of category
A projects and can usually be mitigated through state-of-the-art countermeasures or
standard solutions. Typically, the potential consequences of category B projects are
limited to the local area, are in most cases reversible and are easier to mitigate
through appropriate measures.
For Category B projects, the need to undertake a full ESIA is decided on a case-bycase basis.
5.2 ESIA Requirements
The international requirements for this ESIA have been outlined in section 4.3 above.
The Environmental Impact Assessment guidelines 1997 and the EIA regulations 1998
recognize the following stages for EIAs in Uganda.
•
Project brief formulation
•
Screening
•
ESIA study
•
Decision making
•
Environmental Monitoring and Auditing
An overview of the EIA process, responsibilities and necessary inputs and outputs for
a typical energy project is provided in the figure below.
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Figure 5-1: EIA process flow for energy projects
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5.3 Scoping Report
The primary objective of the Scoping Report is to ensure that the key environmental
elements and sensitive receptors associated with the Project’s construction,
commissioning, operation, and decommissioning phases are identified at an early
stage to determine the studies and assessment methodologies (‘Terms of
Reference’) which will be undertaken for the full ESIA.
To elaborate further, the Scoping Report has the following key objectives:
•
Design of the Stakeholder Engagement Plan and initiation of the consultations
with local regulatory authorities, stakeholders and consultees;
•
Identification of relevant local, national and international environmental
standards and legal requirements;
•
Identification of relevant environmental planning policies;
•
Identification of areas where data required for the study is available, or
conversely, where it is lacking or insufficient;
•
Identification of the key environmental constraints and opportunities,
including the collection of site specific environmental and social baseline
data to identify the issues that require additional surveys during the
preparation of the full ESIA;
•
Determination of the primary social and economic issues to be covered in the
Social and Environmental Assessment;
•
Establishment of assessment criteria and methodologies for each of the
environmental issues;
•
Identification of required studies, modelling, investigations and environmental
assessment for the study area; and
•
Scoping out of any issues unlikely to be significant;
•
Submission of the Scoping Reports to the local authorities and to international
lenders to get their feedback prior to the preparation of the full ESIA;
The initial list of potentially significant environmental and social impacts used in this
scoping report were based on the following:
•
Capitals’ and BIMCO experience in similar energy projects;
•
A detailed study of the construction techniques and the photovoltaic power
generation process proposed;
•
A review of best practice guidelines for the assessment of PV plants;
•
A review of secondary information on the area;
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•
An initial site survey including the identification of sensitive receptors; and
•
Consultations with the local communities to inform them about the proposed
project and collect their concerns.
The identified environmental and social aspects that may be affected by the
proposed projects include Ecology and Biodiversity; Air Quality; Geology, Soil,
Groundwater and Land Contamination; Noise and Vibration; Water Resources &
Wastewater Management; Solid and Hazardous Waste; Economic Impacts; Social
Impacts; Traffic and Transportation; Worker Welfare; Electromagnetic Radiation;
Cultural Heritage and Archaeology and Landscape and Visual Impact
For each of the identified environmental and social aspects, the baseline situation is
described in chapter 4 and the potential impacts are described in chapter 9. In this
chapter the ‘Recommendations for the ESIA’ sub-section describe the additional
studies (baseline surveys or monitoring), consultations, impacts assessment and
recommendation of mitigation measures for inclusion in the ESIA report. These
establish the terms of reference for the ESIA.
5.4 ESIA Approach
The ESIA will follow the recommended scope outlined in this report and any
feedback provided by NEMA, ERA, MEMD and KfW.
If any new environmental or social aspects are identified as a result of additional
baseline surveys undertaken for the ESIA, as a result of new stakeholder input or from
other sources, it will be included in the ESIA.
The sub sections below describe the significance criteria that will be used in the ESIA
report to ensure a systematic and consistent approach to the assessment of impacts
and the mitigation measures and management plans that will be included in the
ESIA report.
5.4.1
Impact Assessment Significance Criteria
In order to obtain a credible assessment of environmental impacts, the assignment
of an ‘impact significance’ to each identified impact needs to be a robust,
consistent
and
transparent
process.
The
methodology
to
significance’ is outlined below and follows an International Best
assess
‘impact
Practice1
based on
the assumption that the significance of an impact on resources or receptors is
considered to result from an interaction between three factors:
See for example Scottish Natural Heritage (2009) A handbook on environmental impact assessment or
Highways Agency (2008) Assessment and Management of Environmental Effects design manual for
roads and bridges HA 205/08 Volume 11, Section 2, Part 5.
Page 67 of 173
Scoping Report
1
•
The nature and magnitude of the impact or change;
•
The number of resources or receptors affected; and
•
The environmental value (sensitivity) of those resources or receptors to the
change.
A three-step approach has been used to determine the significance of
environmental effects, as follows:
•
Step 1 – evaluation of value / sensitivity of resource;
•
Step 2 – assessing the magnitude of the impact on the resource; and
•
Step 3 – determining the significance of effects.
The environmental value (or sensitivity) of the resource or receptor has been defined
by using the criteria below:
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Table 5-1 Environmental Value of Receptor or Resource
Value
Description of Value
(sensitivity)
Very High
•
High importance and rarity on an international scale and
limited or no potential for substitution.
•
The receptor has already reached its carrying capacity, so any
further impact is likely to lead to an excessive damage to the
system that it supports.
•
Locations or communities that are highly vulnerable to the
environmental impact under consideration or critical for society
(e.g. indigenous peoples, hospitals, schools).
High
•
High importance and rarity on a national scale, and limited
potential for substitution.
•
The receptor is close to reaching its carrying capacity, so a
further impact may lead to a significant damage to the system
that it supports.
•
Locations or communities that are particularly vulnerable to the
environmental impact under consideration (e.g. residential
areas, vulnerable/marginalized groups).
Medium
•
High or medium importance and rarity on a regional scale,
limited potential for substitution.
•
The receptor is already significantly impacted, but it is not close
to reaching its carrying capacity. Further impacts will get
increase the stress of the underlying system, but evidence does
not suggest that it is about to reach a critical point.
•
Locations or groups that are relatively vulnerable to the
environmental impact under consideration (e.g. commercial
areas).
Low
Lower)
(or
•
Low or medium importance and rarity on a local scale.
•
The receptor is not significantly impacted and shows a large
spare carrying capacity. Impacts are not likely to generate any
noticeable stress in the underlying system.
•
Locations or groups that show a low vulnerability to the
environmental impact under consideration (e.g. industrial
areas).
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Very Low
•
Very low importance and rarity on a local scale.
•
The receptor is not impacted and shows a very large spare
carrying capacity. Impacts are very unlikely to generate any
noticeable stress in the underlying system.
•
Locations or groups that show a very low vulnerability to the
environmental impact under consideration (e.g. industrial
areas).
The existence of receptors that are legally protected (e.g. designated areas,
protected habitats or species) will be taken into consideration for the assessment of
the sensitivity of the receptors.
The magnitude of the impact is defined where possible in quantitative terms. The
magnitude of an impact has a number of different components, for example: the
extent of physical change, the level of change in an environmental condition, its
spatial footprint, its duration, its frequency and its likelihood of occurrence where the
impact is not certain to occur.
The criterion that has been used for assessing the magnitude of impacts includes the
geographical scale of the impact, the permanence of impact and the reversibility
of the impacted condition. A brief description of the magnitude of the impacts is
provided in Table 3-2 below.
Table 5-2 Criteria for Magnitude of Impacts
Magnitude of
Description of Magnitude
Impact
Major
Adverse: Loss of resource and/or quality and integrity; severe
damage to key characteristics, features or elements. A major
impact is usually large scale, permanent and irreversible.
Beneficial: Large scale or major improvement of resource
quality;
extensive
restoration
or
enhancement;
major
improvement of attribute quality.
Moderate
Adverse: Significant impact on the resource, but not adversely
affecting
the
integrity;
Partial
loss
of/damage
to
key
characteristics, features or elements. Moderate impacts
usually extend above the site boundary, and are usually
permanent, irreversible or cumulative.
Beneficial: Benefit to, or addition of, key characteristics,
features or elements; improvement of attribute quality.
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Minor
Adverse: Some measurable change in attributes quality or
vulnerability; minor loss of, or alteration to, one (maybe more)
key characteristics, features or elements. Minor impacts
usually are only noticeable within the site and are temporary
and reversible.
Beneficial: Minor benefit to, or addition of, one (maybe more)
key characteristics, features or elements; some beneficial
impact on attribute or a reduced risk of negative impact
occurring.
Negligible
Adverse: Very minor loss or detrimental alteration to one or
more characteristics, features or elements.
Beneficial: Very minor benefit to or positive addition of one or
more characteristics, features or elements.
No change
No loss or alteration of characteristics, features or elements;
no observable impact in either direction.
In addition to the factors outlined in the table above, the possibility of any standards
being breached will be taken into consideration in the determination of the
magnitude of the impact.
The significance of effects is a combination of the environmental value (or sensitivity)
of a receptor or resource and the magnitude of the project impact value (change).
The table below shows the criterion used for determining the significance of effects.
Definitions of each significance categories are provided for in Table 3-4.
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Table 5-3 Criteria for Determining Significance of Effects
High
m
High
Mediu
Very Low Low
Environmental value (sensitivity)
Very
Magnitude of impact (degree of change)
No change
Negligible
Neutral
Minor
Neutral
Minor
Neutral
Neutral
Neutral
Negligible
or minor
Minor
Moderate
or Major
Minor
Major
Major
Major
Moderate
moderate
or Major
Minor
Moderate
Negligible
Negligible
or minor
or minor
Negligible
or
Moderate
Negligible
or minor
Minor
Minor
Major
Moderate
or Major
Minor
or
moderate
Minor
Table 5-4 Definition of Significance of Effects
Significance
Criteria
Category
Very Large
Only adverse effects are assigned this level of importance as they
represent key factors in the decision-making process.
Effects are
associated with sites and features of national or regional importance.
Effects exceed statutory limits. Mitigation measures are unlikely to
remove such effects.
Large
Important considerations at a local scale but, if adverse, are
potential concerns to the project and may become key factors in
the decision making process.
Mitigation measures and detailed design work are unlikely to remove
all of the effects upon the affected communities or interests.
Moderate
These effects, if adverse, while important at a local scale, are not
likely to be key decision-making issues. Nevertheless, the cumulative
effect of such issues may lead to an increase in the overall effects on
a particular area or on a particular resource.
They represent issues where effects will be experienced but
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mitigation measures and detailed design work may ameliorate or
enhance some of the consequences upon affected communities or
interests. Some residual effects will still arise.
Minor
Local issue unlikely to be of importance in the decision-making
process. Effects do not exceed statutory limits. Nevertheless they are
of relevance in enhancing the subsequent design of the project and
consideration of mitigation or compensation measures.
Neutral
Negligible
or
No effect or effect which is beneath the level of perception, within
normal bounds of variation or within the margin of forecasting error.
No mitigation is required.
5.4.2
Mitigation Measures and Management Plants
Preliminary mitigation measures are included in this scoping report as a result of the
identification of the opportunities and constraints identified and the review of
international best practice. The identification of opportunities and constraints has
been undertaken based on the review of the project design, the site investigations
and the consultation meeting undertaken during the scoping process.
The ESIA report will include a detailed and systematic assessment of potential
environmental and social impacts, will include additional measures to mitigate this
impacts and the proposed mitigation will be subject to a public consultation process
as described in the Stakeholder Engagement Plan (Chapter 6).
The ESIA will specify who will be responsible for implementing each mitigation
measure, the implementation schedule, and where possible, the associated cost.
The ESIA will outline the Environmental and Social Management System for the two
proposed 5MW PV Plants. The key characteristics of the ESMS are outlined in chapter
10. It will include a Construction Environmental and Social Management Plan
(CESMP) and Operational Environmental and Social Management Plant (OESMP)
and an Environmental and Social Mitigation and Monitoring Plan (ESMMP). The ESIA
documents will include an Occupational Health and Safety Plan, Labour force
Management Plan, Waste Management Plan, and a Public Consultation and
Disclosure Plan.
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6 Stakeholder Engagement Plan
6.1 Objectives
Stakeholder engagement can be described as the systematic effort to understand
and involve stakeholders and their concerns in the project activities and decisionmaking processes. Stakeholders are defined as any group or individual who can
affect, or can be affected by, the project. This Stakeholder Engagement Plan (SEP)
has been prepared as part of the Environmental and Social Assessment process. It
identifies and analyses the projects stakeholders and outlines the methods that will
be used to engage with them during the ESIA process.
The main objectives for stakeholder engagement are:
•
To inform the relevant stakeholders about the proposed project;
•
To capture views and concerns of the relevant stakeholders with regard to
the proposed project;
•
To enhance ownership of the project within the host community;
•
To provide a basis for stakeholder participation in impact identification and
mitigation.
For projects that have environmental and social impacts, consultation is not a single
conversation but a series of opportunities to create understanding about the project
among those that are likely to be affected or might have an interest in it, and to
learn how these stakeholders view the project and its related risks, impacts,
opportunities, and mitigation measures. Listening to stakeholder concerns and
feedback can be a valuable source of information to help identify environmental
and social risks (real and perceived) and improve project design and outcomes of
the ESIA and the project.
The stakeholder engagement plan has incorporated the comments form the
consultation meeting at the scoping stage and will take into consideration further
comments from stakeholders that may be received during the ESIA preparation.
Following the best practice requirements outlined in the IFC handbook on
Stakeholder Engagement, this SEP aims to:
•
Identify and prioritize key stakeholder groups;
•
Provide a strategy and timetable for sharing information and consulting with
each of these groups;
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6.2 Stakeholder Engagement Requirements
6.2.1
Ugandan Requirements
Stakeholder consultation/engagement was undertaken as part of the scoping
activities to gather views and concerns of the stakeholders with regard to the
proposed photovoltaic power plant in Soroti. Under sub-regulation (1) of regulation
(12) of the Environmental Impact Assessment regulations for Uganda (1998), the
developer is supposed to take all measures necessary to seek the views of the
people in the communities which may be affected by the project during the
process of conducting the EIA study.
6.2.2
WB / IFC Requirements
All the IFC Performance Standards mention stakeholder engagement. The first
performance standard “Social and Environmental Assessment and Management
Systems” describes the stakeholder engagement requirements in more depth. It
states the following:
6.2.2.1 Stakeholder Engagement
The WB/IFC states that stakeholder engagement is the basis for building strong,
constructive, and responsive relationships that are essential for the successful
management of a project’s environmental and social impacts.
Stakeholder engagement is an on-going process that may involve, in varying
degrees, the following elements: stakeholder analysis and planning, disclosure and
dissemination of information, consultation and participation, grievance mechanism,
and on-going reporting to Affected Communities. The nature, frequency, and level
of effort of stakeholder engagement may vary considerably and will be
commensurate with the project’s risks and adverse impacts, and the project’s phase
of development.
6.2.2.2 Stakeholder Analysis
The WB/IFC require clients to identify the range of stakeholders that may be
interested in their actions and consider how external communications might
facilitate a dialog with all stakeholders. Where projects involve specifically identified
physical elements, aspects and/or facilities that are likely to generate adverse
environmental and social impacts to Affected Communities the client will identify
the Affected Communities and will meet the relevant requirements described
below.
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The WB/IFC guidance on stakeholder consultation state that the client will develop
and implement a Stakeholder Engagement Plan that is scaled to the project risks
and impacts and development stage, and be tailored to the characteristics and
interests of the Affected Communities.
Where applicable, the Stakeholder
Engagement Plan will include differentiated measures to allow the effective
participation of those identified as disadvantaged or vulnerable. When the
stakeholder
engagement
process
depends
substantially
on
community
representatives, the client will make every reasonable effort to verify that such
persons do in fact represent the views of Affected Communities and that they can
be relied upon to faithfully communicate the results of consultations to their
constituents.
In cases where the exact location of the project is not known, but it is reasonably
expected to have significant impacts on local communities, the WB/IFC require the
client will prepare a Stakeholder Engagement Framework, as part of its
management program, outlining general principles and a strategy to identify
Affected
Communities
and
other
relevant
stakeholders
and
plan
for
an
engagement process compatible with this Performance Standard that will be
implemented once the physical location of the project is known.
6.2.2.3 Disclosure of Information
The WB/IFC SEP requirements include the disclosure of relevant project information,
to help Affected Communities and other stakeholders understand the risks, impacts
and opportunities of the project. The WB/IFC require the client will provide Affected
Communities with access to relevant information on:
•
The purpose, nature, and scale of the project;
•
The duration of proposed project activities;
•
Any risks to and potential impacts on such communities and relevant
mitigation measures;
•
The envisaged stakeholder engagement process;
•
The grievance mechanism.
6.2.2.4 Consultations
The WB/IFC require that when Affected Communities are subject to identified risks
and adverse impacts from a project, the client will undertake a process of
consultation in a manner that provides the Affected Communities with opportunities
to express their views on project risks, impacts and mitigation measures, and allows
the client to consider and respond to them. The extent and degree of engagement
required by the consultation process should be commensurate with the project’s
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risks and adverse impacts and with the concerns raised by the Affected
Communities. Effective consultation is a two-way process that should:
•
Begin early in the process of identification of environmental and social risks
and impacts and continue on an on-going basis as risks and impacts arise;
•
Be based on the prior disclosure and dissemination of relevant, transparent,
objective, meaningful and easily accessible information which is in a culturally
appropriate local language(s) and format and is understandable to Affected
Communities;
•
Focus inclusive engagement on those directly affected as opposed to those
not directly affected;
•
Be free of external manipulation, interference, coercion, or intimidation;
•
Enable meaningful participation, where applicable; and
•
Be documented.
The WB/IFC require the client to tailor its consultation process to the language
preferences of the Affected Communities, their decision-making process, and the
needs of disadvantaged or vulnerable groups. If clients have already engaged in
such a process, they will provide adequate documented evidence of such
engagement.
6.3 Project Stakeholders
This section of the SEP identifies the key stakeholder groups and analyses how they
are likely to be affected by the project. These should include persons or groups who:
•
Are directly and/or indirectly affected by the project;
•
Have “interests” in the project that determine them as stakeholders;
•
Have the potential to influence project outcomes or company operations.
Examples of potential stakeholders are affected communities, local organizations,
NGOs, and government authorities. Stakeholders can also include politicians, other
companies, labour unions, academics, religious groups, national social and
environmental public sector agencies, and the media.
A systematic approach to identifying affected stakeholders is considered best
practice. First the project’s geographic sphere of influence was delineated in the
Scoping Report. This included not only the project site, but also all related facilities,
including associated facilities, main transport routes and areas potentially affected
by cumulative impacts, or unplanned but predictable developments. This analysis,
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detailed in the Scoping Report, was used to establish and articulate the project’s
area of influence and determine who might be affected.
In addition, there are stakeholders outside the affected area, which can be
identified
through
“interest-based”
analysis.
These
are
usually
government
authorities, NGOs and national social and environmental public sector agencies
whose area of interest is related to the project.
Consultations for the ESIA will be undertaken at the scoping stage and at the ESIA
preparation stage.
After the initial consultation at the scoping stage additional stakeholders may be
identified and included in the SEP.
Stakeholder identified
Project interest /
Engagement mechanism
information requirements
The local community within
Issues
of
concern
with
Aliedi and Omuron villages
regard to the proposed
including the Local Council 10MW PV power plant.
1 Executive.
Baseline
Socio-economic
survey
questionnaire.
environmental,
socio
Community meeting.
economic
Focus group discussions.
information about project
area,
expectations
of
local community from the
development
and
anticipated impacts.
Land
owners
leaders
of
and
the
clan
Land acquisition process
project and compensation.
Land acquisition process
undertaken
affected area.
as
Ugandan
per
and
International
Requirements
and
documented in the ESIA.
The
Aliedi
Nursery
and
Potential impacts on the
Meetings with the school
Primary School and the
school
management
Opuyo Primary School
safety
Soroti Sub county.
Issues
operations,
road
/
head
teacher.
of
concern
with
regard to the proposed
Formal meeting and key
informant interviews.
10MW PV power plant.
Requirements for approval
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and smooth operation of
the
project
and
its
associated facilities in the
area.
Socio-economic baseline
information about the sub
county.
Soroti
District
Local Land
government.
acquisition,
area
infrastructure,
social
Formal meeting and key
informant interviews.
services and security
Requirements for approval
and smooth operation of
the
project
and
its
associated facilities in the
area.
Socio-economic baseline
information
about
the
district.
Issues
regarding
the
project sitting and local
physical
planning
provisions.
Electricity
Regulatory
Authority.
Environmental and Social
Consultation
requirements
Formal meeting
installation
of
for
a
Letter
/
Letter
/
Letter
/
power
plant including standards
and licensing.
Ministry
of
Energy
and
Mineral Development.
Policy
issues
renewable
related
to
energy
Consultation
Formal meeting
investments
Uganda
Transmission
Limited (UETCL).
Electricity
Company
Opuyo
substation
is
owned by UETCL and thus
Consultation
Formal meeting
issues of connection of the
10MW PV plant to the
substation are paramount.
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UMEME
Issues of connection of the
Consultation
10MW PV plant to the
Formal meeting
Opuyo
substation,
Letter
/
Letter
/
Letter
/
Letter
/
or
alternative routing to the
substation
Occupational Health and
Occupational Health and
Consultation
Safety
Safety Issues concerning
Formal meeting
Department
–
Ministry of Gender Labour workers.
and Social Development.
TESO Cultural Union
Land
Civil Society
•
acquisition
guidelines
Formal meeting
Environmental Protection
Consultation
Uganda
Land
Conservation
rights issues; Governance;
Fundation
Consultation
acquisition,
land
Formal meeting
Local benefits;
•
Nature Uganda
•
Child
Social services including
Fund
water
and
sanitation,
International
health and HIV/AIDS;
•
CFI,
Poverty eradication;
•
SOCADIDO,
Livelihood support;
•
Health
Need
Institutional development
Uganda – HNI,
•
African
Medical
Research
Foundation
6.4 Stakeholder Engagement Programme
The aim of this section is to describe what information will be disclosed, in what
formats, the types of methods that will be used to communicate this information and
the methods that will be used for consultation with each of the stakeholder groups
identified in the previous section.
In addition, the methods that will be used to facilitate the participation of vulnerable
groups in the process and how the feedback from stakeholders will be incorporated
into the environmental assessment process are described.
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The opinions and views of stakeholders will be gathered through consultation
meetings at the scoping and the draft ESIA stage and through written feedback
collected through letters, emails and during the consultation meetings.
Consultation meetings will be organized at the Scoping and draft ESIA stages. The
venue and timing of the meeting will be chosen to facilitate the participation of the
high priority stakeholders. However, the meetings will be open, so anyone will be
able to turn up and participate freely.
Allowing for the submission of written feedback provides stakeholders with extra time
to review the information provided and adequately research and document their
position. It will also facilitate the participation of those who are not able to attend
the consultation meetings or who find it difficult to speak or discuss certain topics in
public.
Prior to the consultation meetings, information will be disclosed online and in the
following locations in English and Other languages to allow the different stakeholders
to understand the project and prepare the consultation meetings.
6.4.1
Consultation Stages and Methods
As stated in the introduction, for projects that have environmental and social
impacts, best practice consultation is not a single conversation but a series of
opportunities to create understanding about the project among those it will likely
affect or interest, and to learn how these external parties view the project and its
risks, impacts, opportunities, and mitigation measures.
Consultation efforts during the ESIA process will focus on the scoping stage and the
ESIA preparation stage:
•
Scoping: It is best practice to undertake consultations as early as practically
possible in the ESIA process. The aim of the engagement at the scoping stage
is to consult the stakeholders about the adequacy of the Stakeholder
Engagement Plan, to find out what their concerns are regarding the project
and to gather information about the social and environmental characteristics
of the area. Gathering this information early is essential to ensure that it is
taken into consideration in the environmental and social assessment process.
The stakeholder engagement methods that have been used during the
scoping stage included qualitative methods such as key informant interviews,
informal conversational interviews, community meetings and focused group
discussions, consultation letters and formal meetings.
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A key informant guide was developed and this was employed during
stakeholder consultations/engagements.
•
Draft ESIA: The second consultation stage will be undertaken when the
environmental and social assessment report is close to being finalised -i.e.
when baseline data has been collected, impacts have been modelled and
assessed and mitigation and monitoring measures have been designed. The
aim of this consultation round is to describe the results of the ESIA studies, to
show how the concerns raised in the previous consultation have been
integrated into the assessment process, to share the result of the ESIA with the
stakeholders and to get further feedback on all aspects of the report, but
particularly on the proposed the mitigation measures.
Consultation meetings will be undertaken with the local communities, and all
the indirectly affected stakeholders will be engaged for a second time
through consultation letters or one-on-one meetings.
6.4.2
Consultation Meetings
Consultation meetings are one of the central methods to engage with stakeholders
and fulfil the objectives stated above. Meetings have been organized at the
Scoping stage and will be organised at the ESIA preparation stage. The venue and
timing of the meetings is chosen to facilitate participation of the local communities.
However, the meetings are open, so anyone (even if not previously identified as a
stakeholder) can turn up and participate freely.
The identified representatives of the local communities are consulted in relation to
the venue and timing and invited to participate in the meeting. However, engaging
solely with representatives presents several concerns. First, it is not possible to ensure
beforehand that the identified representatives are true advocates of the views of all
of their constituents. In addition, the process can also be subject to manipulation by
those seeking to capture benefits or influence outcomes to serve their own interests.
To counterbalance these risks, an open meeting format and a venue accessible to
the local community is chosen. This has the following advantages:
•
It increases accountability of local leaders, as community members will see
what do their representatives say in the meeting. It also allows community
members to identify their own representatives, preventing illegitimate
representatives from claiming that they speak for communities;
•
It lends transparency to the engagement process, as community members
can witness the process, stay informed about what is being discussed, what is
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agreed on their behalf at each consultation stage and to participate directly
in the process if they wish to do so. In this way, community members are in a
better
position
to
monitor
the
delivery
of
the
agreed
mitigation/compensation measures and corruption is more difficult;
•
It contributes to community members’ feeling of ownership over the
engagement process. The available bibliography shows that community
members say that the opportunity to have input into public meetings gives
them a sense of having a role in the outcome of decisions; and
•
It shows that the project company values the input of communities.
An attendance sheet will be provided in the meeting to document attendance. The
consultation meetings start with a presentation of the project. The aim of the
consultation meeting is stated and the way in which the information gathered is
used in the ESIA process is explained.
At the scoping stage the initial presentation focused on the characteristics of the
project and provided an explanation of the ESIA process. At the draft ESIA stage, the
initial presentation will focus on the results on the ESIA assessment, on the suggested
mitigation measures and on how the stakeholder input had been taken into
consideration in the process.
Next there is a plenary and the attendees will be invited to express their views on
what has been presented and other aspects of the project. The aim is to explore
community-wide issues. Then the meeting is divided into smaller working groups,
including single-sex groups and age specific groups, to explore the concerns or
priorities of those specific groups in greater detail.
As described in the next chapter, at the scoping stage it was not possible to divide
the consultation meeting into smaller groups due to time constraints. This will be
done at the ESIA stage.
During the discussions, each of the issues raised by the stakeholders is noted and if
possible, addressed. If the comment requests additional information, it is provided
on the spot if possible. If the information is not available, when and how will it be
available will be stated. If the comment is factually incorrect (e.g. it refers to the
project posing a risk that, due to the project’s characteristic, it cannot realistically
cause) the misunderstanding is clarified. This is done showing appreciation for the
comment, and avoiding phrasing the clarification in such a way that it can cause
embarrassment to the person that made the remark. If the comment lies beyond the
scope of the meeting, the reason for this is explained. All the comments are
recorded to ensure that they are taken into consideration in the ESIA process.
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6.4.3
Written Feedback
Written feedback will be collected in two different ways:
•
The postal and email address of the consultants is provided in all the
consultation materials and the consultation letters;
•
Written comments can be given to the consultants during the different types
of consultation meetings.
The objectives of allowing the stakeholders to provide written comments are
outlined below:
•
To provide stakeholders with extra time to review the documentation and to
adequately research and document their position;
•
To provide an opportunity to participate to people that are not able to
attend the consultation meeting;
•
Certain topics may be sensitive to discuss in public, or some people may find
it culturally inappropriate to speak in public. Efforts will be made to
encourage attendance and participation in the meeting, but submitting
comments in writing may be a more confortable way for some stakeholders
to express their opinions.
The main limitations of this method are that a level of literacy is required, access to
the Internet is required and there is a small fee to use the post.
When the written comments include the sender’s address, a response will be sent
acknowledging the receipt of the comment and, when relevant, clarifying the issues
raised in the comment or providing the requested information.
6.4.4
Disclosure Methods
The disclosure of project and environmental and social information is an integral part
of stakeholder consultation. Providing stakeholders with complete, accurate and
understandable information is essential to allow for meaningful participation. In
addition, it is crucial to leave sufficient time between the provision of information
and the start of consultations.
An information package has been prepared for the scoping stage and another one
will be prepared for the draft ESIA stage. The information provided in the initial
consultations (consultation letter and consultation meeting hand-out) is provided in
the annexes.
The Ugandan requirements include the disclosure of the ESIA report. However
ACCESS has agreed to the voluntary disclosure of the Scoping Report to comply
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with international best practice. The report will be uploaded onto ACCESS website
after submission of the bid and submission to NEMA.
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7 Results of the Scoping Stakeholder Engagement
7.1 Stakeholder Engagement during the Scoping Stage
The stakeholder engagement methods that have been used during the scoping
stage included community meetings, interviews and focused group discussions with
the stakeholders around the project area and consultation letters and formal
meetings with the indirectly affected stakeholders.
7.2 Results of the Stakeholder Engagement during the Scoping Stage
7.2.1
Meetings in Soroti
Meetings with the stakeholders in the Soroti Area were undertaken in the week of
the 7th of July 2014. These meetings included:
•
A consultative meeting with Soroti District Local Government officials.
•
A consultative meeting with the Soroti Sub County chief and LC3 chairman
•
A community meeting with the residents of Aliedi village
•
Consultation with the Aliedi Nursery and Primary School Management
•
Consultation with the LC1 chairperson of Omuron village and the Head
Teacher of the Opuyo Primary School, that are partially affected by the
proposed alignment of the proposed transmission line
Table 7-1: Summary of issues raised during a consultative meeting with Soroti District
Local Government officials.
Stakeholders consulted
Consulting team
1. Opolot
FrancisSoroti
District
Otim Moses - Team leader
Environment Officer
Kaliba K Joshua
2. Okitui Paul- Soroti District Planner
3. Egwangu Richard- Soroti district E/A
Bldgs
Key issues raised
• Have you already had a meeting with UETCL and UEDCL? How will the returns
from consumers be shared?
• Where will the distribution line pass? If it’s along a road reserve of a community
road, then it’s not demarcated and people will have to be compensated, for
example when working on roads compensation is normally done.
• There should be a provision for compensation of people along the transmission
line.
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•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
The Pamba road is a community road and some element of compensation will
have to be put in place because the road is not surveyed and mapped and the
reserve has to be acquired.
The borrow pits should be restored because normally contractors don’t comply
with environmental requirements and there should be an environmental person
to monitor the implementation of environmental requirements.
There’s Ochulo barrow pit where materials can be sourced during construction.
What is the life span of these panels because these parts will be damaged and
need to be replaced and such waste should not be dumped in villages? How will
damaged panels be disposed off? Because normally business people don’t mind
about the effects of waste and for them they mind much about operational
costs.
You will lay bare an area of 30 acres and that area has been a habitat to insects
that pollinate peoples crops and it is also a habitat to pest eaters, the area is
used as a source of food to the local people and also provides grazing land for
animals. How will you compensate for all these benefits at the area, for example
Bujjagali power project had an offset project for the area.
Semi-skilled labour should be sourced from the local community and we want
local people to be employed in the project say 50% of the jobs should go to the
local community because we have many people who are educated up to
Masters Degree.
I think you will be selling power to transmission and later to distribution.
What will be the height off the ground the ground for the solar panels?
Put security of the area into consideration because people might steal the solar
panels.
The developer could also sell solar panels cheaply to the local community within
the project area.
We are late for this kind of technology because other countries have gone
ahead.
For the project to be approved we need; physical plans, detailed plans, an EIA
approval certificate, clearance by the Electricity Regulatory Authority, land title
and evidence that the land owners have been cleared.
The district compensation rates are low but you will have to use the current
market prices in the area.
We also need a statement that the local people understood the agreement
involved in the acquisition of land.
We also need supporting evidence that the land owners are genuine.
Consider guidelines for land acquisition and some cultural institutions also have
these guidelines. You could also use the GISO to find out the actual owners of
the land.
We advise the land owners to lease the land to the developer.
Otherwise the project is good and we welcome it.
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Table 7-2: Summary of issues raised during a consultative meeting with the Soroti
Sub County chief and LC3 chairman.
Stakeholders Consulted
1. Ideru Winfred- Soroti Sub-county Chief
2. Esegu Edward- Soroti Sub-county LC3
Chairperson
Consulting team
Kaliba K Joshua
Nantaba Olivia
Key Issues raised
• The issue of land ownership should be properly settled, so that land owners do
not start complaining to the authorities about land issues.
• The LC1 of the village should be involved in the land acquisition process.
• The clan leader clarified that land owners have agreed to lease land for 25 years
and a memorandum of understanding between the land owners and the
developer is in place and that the developer will help in processing land titles for
the actual owners of the land.
• Is the project Government or privately owned and have you consulted the
district leadership?
• Ensure that all relevant stakeholders have been consulted, especially the real
land owners.
• Ensure that there are no conflicts between relatives about real land owners.
• Ensure that the land is not in a wetland.
• Apart from the indirect benefits to the local community through, how else will the
community benefit? There should be a CSR program for the project to benefit
the local community.
• The Sub-county expects the developer to;
o Pay for an operational licence.
o Get involved in CSR programs
o Employ local community especially during the construction phase
(particularly where experience is not relevant) or else the developer will
be chased away.
• The local materials should be sourced from within the project area.
• The developer will pay the sub county for any billboards or sign posts put up
within the sub county.
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Table 7-3: Summary of issues raised during a community meeting with the residents
of Aliedi village.
Community
members
Issues raised
who raised issues
Consulting team members present: Nkuutu David, Kaliba K Joshua, Nantaba Olivia,
Dr. Sande Eric
• I am one of the land owners of the proposed site and
Echomu Charles
am happy for the proposed project. You need to
confirm to us the development of the project and if it
starts we request for power to be connected to our
houses.
• We request that our children be catered for in the
land contract or agreement.
• How far should the panels be from the closet
Opidingi Simon
community houses since the panels are big?
• Since solar panels will be installed on land, will land be
Egwanyu Moses
affected at the end of the project?
• Do these solar panels have any effect on rainfall
because they are going to clear trees where the
equipment is going to be installed?
• How will the developer get water for the project and if
they put in place piped water or borehole, will we be
allowed to use the water?
• When will the project start?
Mzee Esemu Michael
• Assume the project has taken off and after it has
Ekoku William
ended, will the developer take the land?
• When the land lease expires, will the project have any
Ojinga Milton - Vice
effect on the land?
chairperson
Aliedi
village.
• When the project takes off, will the developer only
Elalu Paul
employ educated people or the non-educated as
well?
• In case a school for workers at the solar plant is put in
Ibwonu Caroline
place, will it be for plant workers’ children only or for
the whole community.
• We advise the developer to take into consideration of
Mzee Ario Washington
the local community and the environment within the
Secretary for land –
project area.
Soroti Sub County.
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Table 7-4: Consultation with the Aliedi Nursery and Primary School Management
Consulting team
Achom Naomi -Director Aliedi Nursery
and Primary School
Nantaba Olivia
Dekura Irene
Edoru Richard – Head teacher Aliedi
Nursery and Primary School
Key issues raised
• We are not land owners on the designated 30acres, but we sometimes hire the
said land for agriculture.
• The school is for primary one up to primary seven and currently has 74 pupils.
• The school administration fears are;
o In case noise generating machines are used, won’t they affect the
school’s activities?
o Children are always on the road won’t they get knocked down by
vehicles to and from the site?
• In time we also hope to get connected to power, so that the school also
benefits.
• We also hope to benefit through pupil scholarships.
• Otherwise there are no major school activities likely to be affected by the
project, for instance the children are quiet young so not likely to be disturbed by
workers.
• We only request drivers to drive carefully because pupils are always on the road.
• Hopefully shops will crop up as a result of the solar plant nearby, so that the
whole village grows economically.
• We have observed that during the rainy season storm water goes through the
proposed site, so take note of site drainage and ensure that drainage at the
road side is catered for.
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Table 7-5: Consultation with the LC1 chairperson of Omuron village and the Head
Teacher of the Opuyo Primary School.
Consulting team
Eruu Moses- Lay Leader
Nantaba Olivia
Aeto Leya – LC 1 Omuron Village
Dekura Irene
Aucho Winny Rose – Head Teacher
Opuyo Primary School
Key Issues raised:
Eruu Moses
• This is a good project, because power is brought closer to people.
• Am concerned though, won’t the transmission lines affect people s’ crops
and animals?
Aeto Leya
• Hopefully we will get power in the long run.
• Workers should not be harsh to land owners/users during pole installation.
• Compensate people whose crops/property will be affected.
Aucho Winny Rose
• Do not use dangerous poles which might harm people.
• Work with the school to ensure security of children during the poles installation
and stringing phase.
• Will people’s crops and property be affected, if so they should be
compensated?
• Ensure that all people in both villages are sensitized about the project.
7.2.2
Consultation with the Indirectly Affected Stakeholder
The following stakeholders have been informed of the project and requested to
provide information about the project site that may be relevant to the project ESIA
and any concerns on the potential environmental and social impacts of the project.
The following stakeholders have been engaged through a consultation letter:
•
Electricity Regulatory Authority.
•
Ministry of Energy and Mineral Development.
•
Uganda Electricity Transmission Company Limited (UETCL).
•
UMEME
•
Occupational Health and Safety Department - Ministry of Gender Labour and
Social Development.
•
TESO Cultural Union
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•
Uganda Conservation Foundation
•
Nature Uganda
•
Child Fund International (CFI)
•
SOCADIDO,
•
Health Need Uganda – HNI,
•
African Medical Research Foundation
At the time of submission of this report, no response to the consultation letter has
been received. However it is expected that responses will be received during the
review of the scoping report and during the ESIA preparation, and all the received
feedback will be incorporated into the ESIA report.
7.3 Inclusion of women and the disadvantaged in the ESIA process
The consulting team requested the Aliedi Village Local authorities to mobilize the
people for a community meeting to be held on the 10th 07 2014. The team
requested that all members of the community, male and female, young and old
should be notified, to ensure that all people are represented.
Though a number of women attended the Aliedi Village community meeting, as
can be seen in the plate below, actual participation and involvement in the
question and answer discussion was low.
Only one comment/question from a
woman was recorded.
Three female representatives of the community were consulted in other meetings in
the local area, namely the LC1 Chairperson of Emuron Village through which the
transmission line passes to reach Opuyo National Grid Sub-station, an Administrator
at Opuyo Primary School and another Administrator at Aliedi Primary School.
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Plate 7-1 Aliedi Village Consultation Meeting
During the household survey that was undertaken in the project area it was
determined that the level of education of the female respondents was significantly
lower than that of male respondents. The data is shown in the figure below.
Figure 7-1 Educational level of the respondents to the household survey,
disaggregated by gender
100% 90% 80% 70% Tertiary level 60% 50% Secondary level 40% Primary level 30% None 20% 10% 0% Female respondents Male respondents The results of the survey showed a significantly lower level of formal education
attained by women in the project area.
The small input of women during the community meeting and the results of the
survey in relation to the level of formal education attained by women compared to
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men are consisted with the traditional role assigned to women in rural areas. Women
are considered to be the key disadvantaged group that needs to be specifically
targeted to ensure that their input is adequately represented.
Even though the LC1 Chairperson of Emuron Village, the Administrator at Opuyo
Primary School and the Administrator at Alaedi Primary School are female members
of the community that were actively engaged during the consultations, it is
considered that the low input by women during the community meeting at the
scoping stage is a gap in the consultation process that needs to be specifically
addressed during the ESIA consultations. It is proposed that during the ESIA
consultation meeting the community will be split into different groups, and one of
the divisions will be based on gender, to ensure that the concerns of women is
adequately captured.
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8 Baseline Conditions
8.1 Ecology and Biodiversity
8.1.1
Flora
8.1.1.1 Scoping Survey
As part of scoping activities, the biological team undertook the following tasks:
•
Vegetation characterization into main vegetation types, with sketch map for
project area;
•
Species richness and habitat diversity;
•
Identification of ecologically sensitive sites
•
Identification of degraded areas
•
Species of conservation concern
The aim of this survey was to identify early in the ESIA process critical habitats or
protected species that could potentially require changes in the project location or
design. More detailed surveys in the project area will be undertaken for the ESIA.
8.1.1.2 Methodology
Circular plots of 10m radii were used in this survey. Plots were laid at every 50m and
plants seen recorded within the site and along the proposed alignment for the
power lines.
Within the plot, herbs and shrubs were enumerated in a radius of 2 meters with all
individuals counted and recorded. Trees were enumerated in 10m radius from the
centre of the plots and numbers recorded. Opportunistic sampling was done to
record other species that were not captured within the plots to come up with a total
species list of the area. The GPS position, altitude and vegetation type were taken at
each point and the extent of that type recorded.
A species list was compiled to show the diversity to lesser extent with abundances
using the encounter rate. Plants of any conservation status or importance were
noted.
8.1.1.3 Vegetation in the Soroti Area
The vegetation in Soroti can be described as wooded savannah, grass savanah,
forests and riparian vegetation. The wooded savanna mainly comprises moist
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Acacia savanna associated with hyparrhenia spp and combretum savanna
associated with hyparrhenia spp.
The riparian vegetation comprises certain scattered tree grasslands associated with
Setaria incrassate, Hyparrheria rufa, Accacia sayel, Accacia fistula, Balanities
aegyptica and Terminalia spp. Soroti also has expansive wetlands, which cover vast
areas including Awoja bordering Ngora District in Gweri Sub-county in Soroti County.
Further to the Northeast is a vegetation characteristic of semi arid type with thorny
shrubs. Cyperus papyrus are found in permanently water logged areas along the
shores of lake Kyoga, Awuja and Agu swamp.
8.1.1.4 Vegetation in the project area
The proposed Solar PV site is characterised by distinctive vegetative types that have
been influenced by wide range of factors, including cultivation and grazing. The
vegetation types includes:•
The cultivated areas, which are characterised by food crops and very few
scattered trees and thickets. This includes the proposed project site and some
of the areas that the transmission line will cross;
•
Gardens which are dominated by trees near homes that have been mainly
influenced by the land owners. This covers the area traversed by the
transmission line.
•
Mash
areas
characterised
by
Cyperus
denadatus
(Cyperaceae),
Echichnochloa pyramidalis (Poaceae) and Cyperus latifolius (Cyperaceae).
The marsh area was not adjacent to the project site or the proposed
transmission line alignment, but along the Oteka swamp.
8.1.1.5 Species diversity and conservation status
A total 108 species were recorded in the area, from 34 families. Familiy Poaceae
had the highest number of species (22), followed by Fabaceae (15) and Asteraceae
10 species, while the rest of the families had less than 5 species each (see species list
in Appendices)
Many of the species that were observed in the area are of wide range distribution.
Therefore, there will be minimal impact on biodiversity conservation. Besides much of
the vegetation has been transformed by cultivation.
Two individuals of Milicia excelsia were seen along the community road along which
the transmission line will traverse. Milicia excelsa is listed because of commercial
logging and use for timber, especially for quality indoor and outdoor furniture,
firewood and charcoal and. It is steadily getting rarer in Uganda now, although
Kalema & Beentje (2012) have assessed it as globally Least Concern owing to its
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wide distribution. These trees can be avoided by passing the line on the east side of
the road to Opuyo, since they all occur on the west hand side.
8.1.2
Fauna
The project area is essentially a wooded grassland that is heavily cultivated and
partly a grazing land, with a seasonal swamp downstream of the site to the west
that is also being drained for agriculture (Plate 8-1).
The biodiversity that currently thrives in the project area are those that can tolerate
habitat disturbance and co-exist with humans, and wetland generalists (often found
near water but can live on land).
A transect count method was used to assess the presence of birds, mammals,
reptiles, butterflies and dragonflies. Amphibians were surveyed in the evening at the
swamp to the south of the project site. The selected method allows the surveyor to
cover a large area including as many microhabitats as possible and recording all
the biodiversity that can be seen or heard. Local people asked about the wildlife
that occurs in the area.
Plate 8-1 A seasonal Oteka swamp being drained near the project site
Butterflies
Twenty species of butterflies were recorded (Table 8-1) with Papilio demodocus
(Plate 8-2) being the most common.
There were no butterflies species of
conservation concern recorded. All the species are common and widespread. The
project has little or no impact on the conservation of these invertebrates.
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Plate 8-2 Papilio demodocus
Table 8-1 Butterfly species list
Species
Habitat
Acraea acerata
Ws
Acraea Alicia
Ws
Acraea encedon
Ws
Bicyclus vulgaris
Ws
Danaus chrysippus
O/m
Junonia oenone
Ws
Junonia sophia
Ws
Junonia terea
Ws
Neptidopsis ophione
f
Ypthima albida
f
Ypthima asterope
O
Appias epaphia
f
Dixiea orbona
W
Eronia cleodora
O
Borbo micans
S
Eretis lugens
Ws
Euchrysops malathana
O
Zizeeria knysna
Ws
Zizina antanossa
Ws
Papilio demodocus
Ws
Key:
f-Forest edge/woodland species
O-Open habitat species
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S-Swamp/wetland species
Ws-Widespread species
Dragonfly species list
Three species of dragonflies were recorded namely: Brachythemis lacustris,
Mesocnemis singularis and Trithemis arteriosa. None of these are of conservation
concern. The specialist that undertook the survey considered that the project would
have little or no impact on the conservation of these invertebrates.
Amphibians
Four
species
Ptychadena
of
amphibians
porosissima,
were
identified:
Ptychadena
Ptychadena
oxyrhynchus
and
mascareniensis,
Amietophrynus
steindachneri. None of these is of conservation importance. The project therefore
has little or no impact on the conservation of these vertebrates.
Reptile species
Two species of Lizards were recorded (Striped Skink Mabuya striata and Red-headed
Rock Agama Agama agama) and local residents listed four species of snakes in the
area (Cape Wolf snake Lycophidion capense, Brown house snake Lamprophis
fuliginosus, Black-necked spitting Cobra Naja nigricollis and Puff-adder Bitis arietans).
None of these is listed among IUCN red list species.
Mammals
There are no large wild mammal species in the project area. Only small mammals
(rodents and bats) that are adapted to grassland ecosystem and cultivations exist.
Kingdon (1964a) and Kingdon (1964b), recorded all the rodents and bats that occur
in the project area. Since the habitat is already heavily degraded, the specialist
surveyors considered that the project will not affect the conservation of these small
mammals.
Birds
Seventy-three species of birds were recorded (Table 8-2). The species of
conservation concern recorded was the Grey-crowned Crane. Grey-crowned
Crane is a wetland and grassland species that is globally endangered. . A pair was
heard about 500m west of the site in the wetland area. The Grey-crowned Crane is
a wide ranging species which forages in the grasslands and wetlands.
Although Grey Crowned Cranes and people have long coexisted, the decline in the
species’ population over the last decade reflects widespread threats to their
habitats as a result of rapid human population growth, drought-related changes in
land use, intensified agricultural practices, and other factors. Loss and deterioration
of wetland breeding habitat constitute the most significant threats to the species
(Meine and Archibald 1996).
However, with a large global range in 10 African
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Page 99 of 173
countries with a global population of 47,000-59,000 individuals (BirdLife International
2012). The project activities will not have a significant impact on the wetlands in the
area and will change the land use of a small area of farmland, therefore it will have
a minimal impact on the Grey-crowned crane.
Table 8-2 Bird species recorded
Species
HC
AFRICAN CITRIL Serinus citrinelloides
f
AFRICAN EMERALD CUCKOO Chrysococcyx cupreus
f
AFRICAN FIREFINCH Lagonosticta rubricata
fc
AFRICAN GOSHAWK Accipiter tachiro
f
AFRICAN GREEN-PIGEON Treron calva
f
AFRICAN HARRIER-HAWK Polyboroides typus
f
TC
AFRICAN MOURNING DOVE Streptopelia decipiens
AFRICAN OPEN-BILLED STORK Anastomus lamelligerus
AwG
AFRICAN PALM SWIFT Cypsiurus parvus
AFRICAN PIED WAGTAIL Motacilla aguimp
W
BEAUTIFUL SUNBIRD Cinnyris pulchella
AFRICAN THRUSH Turdus pelios
f
BLACK KITE Milvus migrans
pA
BLACK-AND-WHITE CUCKOO Oxylophus jacobinus
Afc
BLACK-AND-WHITE MANNIKIN Lonchura bicolor
f
BLACK-CROWNED WAXBILL Estrilda nonnula
fc
BLACK-HEADED GONOLEK Laniarius erythrogaster
F
BLACK-HEADED HERON Ardea melanocephala
W
BLACK-HEADED WEAVER Ploceus cucullatus
fc
BLACK-SHOULDERED KITE Elanus caeruleus
G
BLUE-SPOTTED WOOD-DOVE Turtur afer
f
BROAD-BILLED ROLLER Eurystomus glaucurus
Afw
BRONZE MANNIKIN Lonchura cucullata
Fc
BROWN-THROATED WATTLE-EYE Platysteira cyanea
f
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BRUCE’S GREEN-PIGEON Treron waalia
f
CATTLE EGRET Bubulcus ibis
G
COLLARED SUNBIRD Hedydipna collaris
f
COMMON BULBUL Pycnonotus barbatus
f
COMMON WAXBILL Estrilda astrild
wG
COMPACT WEAVER Ploceus superciliosus
fw
COPPER SUNBIRD Cinnyris cuprea
fw
CROAKING CISTICOLA Cisticola natalensis
G
DIEDERIK CUCKOO Chrysococcyx caprius
fc
DOUBLE-TOOTHED BARBET Lybius bidentatus
f
EASTERN GREY PLANTAIN-EATER Crinifer zonurus
fc
GREATER
BLUE-EARED
GLOSSY
STARLING
Lamprotornis
G
chalybaeus
GREY-BACKED CAMAROPTERA Camaroptera brachyura
f
HAMERKOP Scopus umbretta
W
HELMETED GUINEAFOWL Numida meleagris
G
KLAAS’ CUCKOO Chrysococcyx klaas
f
LAUGHING DOVE Streptopelia senegalensis
Fc
LESSER BLUE-EAREDSTARLING Lamprotornis chloropterus
Fc
LESSER STRIPED SWALLOW Hirundo abyssinica
LIZARD BUZZARD Kaupifalco monogrammicus
f
LONG-CRESTED EAGLE Lophaetus occipitalis
f
NORTHERN PUFFBACK Dryoscopus gambensis
f
PIN-TAILED WHYDAH Vidua macroura
G
RED-CHEEKED CORDON-BLEU Uraeginthus bengalus
fc
RED-EYED DOVE Streptopelia semitorquata
f
RING-NECKED DOVE Streptopelia capicola
f
ROSS’S TURACO Musophaga rossae
f
RÜPPELL’S LONG-TAILED STARLING Lamprotornis
SCALY FRANCOLIN Francolinus squamatus
Scoping Report
purpuropterus
fc
f
Page 101 of 173
SCARLET-CHESTED SUNBIRD Chalcomitra senegalensis
f
SINGING CISTICOLA Cisticola cantans
f
SPECKLED MOUSEBIRD Colius striatus
fc
SPECKLED TINKERBIRD Pogoniulus scolopaceus
F
SPLENDID GLOSSY STARLING Lamprotornis splendidus
f
STRIPED KINGFISHER Halcyon chelicuti
F
TAMBOURINE DOVE Turtur tympanistria
F
TAWNY-FLANKED PRINIA Prinia subflava
Fw
VIEILLOT’S BLACK WEAVER Ploceus nigerrimus
F
WHITE-BROWED COUCAL Centropus superciliosus
Fw
WHITE-BROWED ROBIN-CHAT Cossypha heuglini
f
WHITE-CHINNED PRINIA Prinia leucopogon
f
WHITE-HEADED BARBET Lybius leucocephalus
f
WOODLAND KINGFISHER Halcyon senegalensis
Afc
YELLOW WHITE-EYE Zosterops senegalensis
f
YELLOW-RUMPED TINKERBIRD Pogoniulus bilineatus
f
YELLOW-THROATED LONGCLAW Macronyx croceus
G
GREY CROWNED CRANE Balearica regulorum
WG
RED-CHESTED SUNBIRD Cinnyris erythrocerca
W
WHITE-HEADED SAW-WING
F
8.1.3
Psalidoprocne albiceps
G-EN
Ecosystem services
The project site has been greatly transformed, from a savannah ecosystem that was
rich in indigenous plants mainly Euphorbia canderablum to an agricultural
ecosystem and grazing fields. This land use change resulted from the denselypopulated area around the site.
The land remains useful for provision of services like grazing, firewood collection and
wind breaking as well as carbon sequestration. Other important services include
potential erosion control and potential surface water flow regulatory system.
The wetland draining into Awuja has been affected by encroachment of rice
growing fields.
Scoping Report
Page 102 of 173
Some trees or tree branches along the transmission line route may need to be cut.
These trees are used by birds for roosting.
8.2 Air Quality and Climate
8.2.1
Rainfall
Rainfall normally ranges from 1000mm to 1500mm coming in two seasons; March–
July and September November. There is normally a short dry spell between the two
rain seasons during mid June – mid July. The long dry season sets in during late
November through to early March. The distribution is such that areas bordering
Northeast experience earlier dry seasons. The figure below shows the monthly and
long-term average rainfall for Soroti district in 2011.
Figure 8-1 Soroti 2011 monthly and long term average rainfall
Source: UBOS statistical abstract 2013.
8.2.2
Temperature, Humidity, Wind and Eva-transpiration
Soroti district generally records a mean annual maximum temperature of around
31.3o C and a mean minimum of around 18oC. Its extreme highest temperatures are
in the month of February when it records approximately 35oC. The highest ever
recorded was in February 1949 where temperatures reached 40oC.
Relative humidity ranges from 66% to 83% at 0600GMT in the morning. However, it
reduces much in the afternoon (35%-57% at 1200GMT) thereby reducing chances of
rainfall. During the N.E monsoon the area is swept by a wind that has traversed
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Page 103 of 173
Somalia, passed between Abyssinian massif and Kenya highlands and the hills of
Karamoja. The water vapour content of this wind is consequently low. The
southwards passage of the inter-tropical convergence zone in October would
appear to bring no more rain than is sufficient to produce a gradual falling off from
the July peak. There are relatively high rates of evaporation in Soroti District as it lies
near the equator. Evaporations are particularly high in the dry seasons.
Relative humidity, temperature and frequency of wave’s measurements within the
project area were taken using CEM DT-9881M device and results are presented in
the table below.
Table 8-3 Temperature and relative humidity measurements
Location
Coordinates and time
Temperature
Relative
humidity
Aliedi primary school, opposite
the proposed site to the north.
Within
the
community
neighbourhood to the proposed
site.
Within
the
community
site.
Within
the
community
site.
Opuyo base station
N01.68827 E033.65670
35.3oC
50.1%
30.6 oC
43.6%
29 oC
45.2%
27.3 oC
50%
32.5 oC
52.4%
11.07.2014 12:00pm
N01.68762 E033.65499
11.07.2014 5:35pm
N01.6881 E033.6547
11.07.2014 5:55pm
N01.68700 E033.65984
11.07.2014 6:15pm
N01.67756 E033.67712
10.07.2014 12:45pm
8.2.3
Air Pollution
The proposed PV plant will not include any specific air emissions sources as a result of
its operations. The only emissions sources will be minor in regard to vehicle emissions
due to movements to/from and around the site.
The baseline air quality was established through a brief monitoring campaign during
the scoping phase that aimed to identify constraints in relation to air quality and
determine the need to undertake more detailed surveys during the ESIA stage.
The air quality monitoring locations are shown in the figure below, and the results in
the following table.
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Page 104 of 173
Figure 8-2 Air Quality Monitoring Locations - Scoping Phase
Table 8-4 Baseline Air Quality Monitoring Results
Location
Coordinates and
time
Aliedi
school,
primary
opposite
the proposed site
N01.68827 033.65670
Pm2.5
Pm10
VOC
SO2
NO
(µg/m3)
(µg/m3)
ppm
ppm
ppm
7
22
1.9-
0
0
2.3
11.07.2014 12:00pm
to the north.
Within
the
proposed site.
Within
N01.68577 033.65738
9
32
1.1
0
0
9
40
1.3-
0
0
11.07.2014 12:55pm
the
community
neighbourhood to
N01.68762 033.65499
1.6
11.07.2014 5:35pm
the proposed site.
Within
the
community
neighborhood
to
N01.6881 E033.6547
12
64
1.5
0
0
9
35
1.7-
0
0
11.07.2014 5:55pm
the proposed site.
Within
the
community
neighborhood
to
N01.68700 033.65984
11.07.2014 6:15pm
2.1
the proposed site.
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Page 105 of 173
Opuyo
base
station
(Note: ongoing road
N01.67756 033.67712
23
166
2.3-
0
0
3.3
10.07.2014 12:45pm
construction near Opuyo)
The results have been compared with WB/IFC standards, shown in the table below.
Table 8-5 IFC Ambient Air Quality Standards (µg/m3 unless otherwise specified)
IFC EHS General GLs/WHO GLs
Parameter
PM10
PM
2.5
Nitrogen Dioxide
24 hour
Annual
150 (Interim target 1)
50 (guideline)
20 (guideline)
37.5 (Interim target 3)
25 (guideline)
10 (guideline)
200 (1 hour)
40
Sulphur Dioxide
500 (10 minute guideline)
20 (guideline)
No NOx or SOx were detected. This was expected considering that there are no
industrial sources in the region and that vehicles in the area are scarce (with
bicycles being more common that motorbikes).
The only issue was Particulate Matter (PM10 and PM2.5) levels. These are caused by
the nature of the terrain and vegetation cover during the dry season, the dirt
community roads, and the highest level at the substation was caused by the
improvement works at the main road.
8.2.4
Greenhouse Gas Emissions
The PV plant will not burn fossil fuels during the operational phase to generate
electricity. GHG emissions are caused by the production of the PV modules, their
transportation
to
the
site,
construction
and
operational
vehicles
and
decommissioning activities, including PV module recycling.
Scoping Report
Page 106 of 173
As outlined in section 3.6 Sourcing of the PV panels, additional information will be
gathered from the PV panels manufacturers in order to undertake a comprehensive
assessment of the GHG emissions of the facility in the ESIA.
8.3 Geology, Soil, Groundwater and Land Contamination
Most of the areas in Soroti district are under laid by rocks of the basement complex
of Precambrian age that include granites, mignalites, gneiss, schists and quartzites.
There are no rock outcrops at the project site.
The site lies within zone 3 of the seismic zoning of Uganda implying there is a low risk
of earthquake occurrence at the site. (Seismic Code of Practice for Structural
designs; Uganda National Bureau of Standards, First Edition: June 2003).
Figure 8-3 Seismic zoning of Uganda
The soils in Soroti are predominantly ferrallitic type (sandy sediments and sandy
loams). These soils are well drained and friable. Bottomlands contain widespread
deposits of alluvium. The Solar PV site soils vary from sandy loams to sandy sediments
then clay or alluvial soils along a transect across the site westwards towards Oteka
stream, which drains into the Auja wetland system. The site itself is well drained, and
the stream located about 100m away from the site boundary.
A geotechnical survey was undertaken on the site in July 2014 (see plates below).
The depth of the groundwater is shown in the table below.
Table 8-6 Groundwater Depth
Borehole label
BH 1
Depth (m)
1.2
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Page 107 of 173
BH 2
BH 3
BH 4
BH 5
1.5
1.5
0.8
1.0
On the basis of the Standard Penetration Tests conducted in the boreholes as part of
the geotechnical survey, the soil profiles have been categorized into different soil
types as described in the table below.
Table 8-7 Standard Penetration Tests values of soil strata in the boreholes
Borehole
Depth (m)
SPT-N Values
Consistency
Soil Description
BH 1
1.5
29
Medium dense
Clayey sand
3.0
47
Dense
Clayey sand
4.5
54
Hard
Lean clay
1.5
10
Medium dense
Clayey sand
3.0
27
Medium dense
Clayey sand
4.5
23
Very stiff
Lean clay
1.5
12
Medium dense
Clayey sand
3.0
23
Medium dense
Clayey sand
1.5
48
Dense
Clayey sand
3.0
53
Very dense
Clayey sand
1.5
50
Very dense
Clayey sand
BH 2
BH 3
BH 4
BH 5
During the scoping study, up to 5 samples were taken from the proposed Solar PV
plant site with a soil augur at a depth of 30m. The parameters analysed relate to soil
productivity and potential contamination due to agricultural activities. The aim of
this survey at the scoping stage is to identify any potential soil contamination and
design if necessary a soil contamination study for the ESIA stage. It also established a
baseline to assess any contamination resulting from the Project’s activities.
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Page 108 of 173
Figure 8-4 Soil Sampling Locations
The soil samples were analysed in a Ugandan accredited laboratory and the results
are presented in the table below.
Table 8-8 Soil analysis results
Parameters
Soil sample 1
Soil sample 2
Soil sample 3
Soil sample 4
Soil sample 5
N01.68700
N01.68577
N01.68413
N01.68383
N01.68605
E033.65702
E033.65737
E033.65866
E033.65678
E033.65907
Ph
5.74
5.36
6.02
5.18
5.48
EC (µS/cm)
2288
3346
3860
2872
4456
Organic
0.45
0.92
1.46
0.98
0.22
Sand %
66
42
36
44
72
Silt %
18
28
40
34
20
Clay %
16
30
24
22
08
Sodium ppm
34
16.2
42.6
22.8
16.8
Potassium
386
427
57.5
618
502
1120
660
585
848
1260
matter %
(ppm)
Calcium
Scoping Report
Page 109 of 173
(ppm)
Magnesium
120
348
380
227
238
1.46
1.37
1.62
1.54
0.98
84
62
74
48
24
3.67
4.62
2.46
3.74
2.87
Phosphorous 2.48
3.26
3.85
2.98
1.46
1.16
1.25
1.18
0.97
--
3.26
1.48
0.92
1.25
2.84
(ppm)
Chlorides
(ppm)
Sulphates
(ppm)
Nitrates
(ppm)
(ppm)
Nitrogen
(ppm)
Lead (ppm)
The results show slightly acidic pH, predominantly sandy soils, with low organic
content (<1%). The soils also have low levels of key nutrients, N (<0.2%) and P (<5%).
There was no evidence or background pollution, with no inputs (pesticides,
herbicides, chemical fertilizers) reported to agricultural fields in the area.
Uganda has soil quality regulations that focus on the physical and chemical
properties for different types of soil for agricultural purposes. However, no soil
contamination standards have been issued to date.
The Dutch soil standards are widely accepted to be a reference for soil
contaminants on soil requiring remediation (providing both target and intervention
values), and can be adapted to different types of soils. The results of the soil analysis
onsite for lead are within the Dutch guidelines showing no soil contamination above
the optimum level or the threshold requiring action.
8.4 Noise and Vibration
Noise is ‘unwanted sound’ and can be considered a nuisance, particularly when
sensitive receptors are exposed to it at high magnitudes or unusual frequencies.
Vibration can also cause a nuisance, whilst potentially causing damage to
structures.
Noise levels are expressed as micro Pascal (µPa). The human ear can detect sound
levels from 20 µPa to 100,000,000 µPa. A special logarithmic scale is used to
represent this enormous range, namely decibels (dB), which in most cases is A2x5 MW Photovoltaic Power Plant in Soroti, Uganda
Scoping Report
Page 110 of 173
weighed to correspond to a similar range of human hearing sensitivity. The
corresponding unit is dB (A).
A noise monitoring survey was undertaken at the scoping stage to determine
baseline levels and identify potential issues that may require mode detailed studied
during the ESIA preparation. The noise monitoring locations are depicted on the
figure below and the noise monitoring results are shown on the following table.
Figure 8-5 Noise Monitoring Locations
Table 8-9 Noise Monitoring Results
Location
Aliedi
primary
school, opposite the
proposed site to the
north.
Coordinates and
Noise levels
time
dB(A)
N01.68827
E033.65670
11.07.201412:00pm
Within the proposed
N01.68577
site.
E033.65738
11.07.2014 12:55pm
Leq: 54.1
Lmax: 68.0
Lmin: 37.5
Leq: 49.3
Lmax:76.3
Lmin:23.3
Comments
Pupils at school were
talking
during
measurements.
Background
from
noise
birds
and
movement
vegetation
of
due
to
wind.
Within
the
community
E033.65499
neighborhood to the
proposed site.
Within
N01.68762
the
community
11.07.2014 5:35pm
N01.68700
E033.65984
neighborhood to the
Scoping Report
Leq: 54.6
Lmax:65.6
Lmin:28.9
Leq: 50.0
Lmax: 69.5
Background
noise
from kids playing in
community
neighborhood.
Background
noise
from kids playing in
community
Page 111 of 173
proposed site.
Opuyo base station
11.07.2014 6:15pm
Lmin: 29.0
N01.67756
Leq: 52.1
E033.67712
Background
Lmax: 68.1
10.07.2014 12:45pm
neighbourhood.
noise
from the transformer.
Lmin: 48.5
The WB/IFC standards are outlined in the table below.
Table 8-10 IFC EHS General Noise Guidelines (At off-site receptors)
Receptor
Residential,
Institutional,
One Hour LAeq (dBA)
Daytime: 07:00 – 22:00
Night time: 22:00 – 07:00
55
45
70
70
Educational
Industrial, Commercial
If a receptor already exceeds the standards, it is stated within the IFC EHS Noise
Level Guidelines that noise impacts should not result in a maximum increase in
background levels of 3dB at the nearest off-site point of reception.
The Ugandan noise standards are defined in the National Environment (Noise
Standards and Control) Regulations, 2003. This very comprehensive set of standards
are generally more stringent that WB/IFC, with daytime and night-time thresholds at
residential dwellings standing at 45 and 35 dB(A) (Leq) respectively. It also includes
specific maximum permissible noise levels for construction sites and noise levels for
vehicles.
The baseline levels measured around the project site showed that depending on the
activities being undertaken, the noise baseline can already be above the standards
for residential buildings and schools. Additional baseline measures during both day
time and nigh time will be required during the ESIA preparation stage.
8.5 Water Resources & Wastewater Management
The area around the project site is well drained it’s relatively flat. The proposed site
for the PV Power Plant drains to the south to Oteka stream within the neighboring
Auja wetland system. The Lake Kyoga system forms the major drainage pattern
within the district.
A water sample was taken from a lowing section of this stream (Oteka N01.68246
E033.65569) and analysed for parameters that may be affected by the surrounding
land uses.
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Page 112 of 173
Figure 8-6 Water Sampling Location and Soil Sampling Location
There is an ephemeral stream to the west of the project site that could not be
sampled as there was no water flow at the time of the surveys. This ephemeral
stream will be sampled at the ESIA stage.
Table 8-11 Water Analysis Results
Parameter
Units
Surface water sample
National Standards
(Oteka stream)
for portable water
pH
--
6.9
6.5-8.5
Electrical
µS/cm
77
2500
Ammonia -N
mg/l
11
<1.0
Colour: apparent
PtCo
86
15
Total Dissolved Solids
mg/l
49
1200
mg/l
10
0.0
conductivity (EC)
(TDS)
Total
Suspended
Solids (TSS)
Alkalinity:
total
as
mg/l
208
500
Total
as
mg/l
148
500
Calcium: Ca2+
mg/l
8
75
Magnesium: Mg2+
mg/l
3.8
50
CaCO3
Hardness:
CaCO3
Scoping Report
Page 113 of 173
Bi-carbonate:
as
mg/l
59
500
Chloride: Cl-
mg/l
10
250
Carbonate
mg/l
0
<1.0
Ortho-phosphate:
mg/l
0.2
<0.3
Sulphate: SO42-
mg/l
10
200
Nitrate-N
mg/l
0.0
5.0
Biochemical Oxygen
mg/l
0.01
<2.5
mg/l
1.0
Not specified
CaCO3
Reactive
Demand (BOD5)
Chemical
Oxygen
Demand (COD)
The results show good physical-chemical conditions, with the water sample
complying with national standards for potable water. However, potential sources of
pollution upstream will be studied at the ESIA stage and additional chemical,
biological or microbial parameters will be studied during the ESIA preparation stage
if sources of concern are found upstream.
8.6 Solid and Hazardous Waste
The construction of the proposed facility will generate moderate quantities of waste
and also minor quantities during operation. These have the potential to impact the
soils and groundwater if waste treatment and disposal methods are not effectively
implemented.
Two key baseline observations were made during the scoping studies:
•
There is no visible waste in or around the project site;
•
There is no municipal waste collection system for the residential buildings
around the project site;
8.7 Economic Impacts
This section describes the economic baseline in the project area, including issues
such as agriculture and employment.
Soroti district total population was 193,310 (2002 Final census results) of which 94,222
were males and 99,088 female, with a population density of over 150.6 persons per
sq. km. Current projections indicate the district population at 96,600, (UBOS Statistical
Scoping Report
Page 114 of 173
Abstract, 2013). The population of Soroti Sub County is predicted to have grown
from 11,697 in 2002 to 21,600 people in 2014.
During the scoping study, socio-economic information was obtained from review of
literature including the District and Subcounty Development Plans, community
meetings and administration of a questionnaire to households in the two affected
villages of Aliedi and Omuron within Opuyo parish. Up to 30 households were visited
for the socioeconomic baseline survey, and two community meetings were held as
part of the stakeholder engagement process.
The figure below shows the location of the households that participated in the
socioeconomic survey around the project site and around the proposed alignment
of the 33kV power line.
Figure 8-7 Location of the households surveyed
8.7.1
Land tenure and buildings
Land tenure in Soroti is predominantly customary, with that at the project site owned
by two clans and seven families. They work on that land themselves, none of them
leases or hires out their land to someone else.
In addition to land as an asset, community members regard the buildings and
structures that they have as assets, an overview of the type of structures reveals that
most are temporary structures as shown in the figure below.
Scoping Report
Page 115 of 173
Figure 8-8 Types of Structures in the Project Area
Permanent 14% Semi Permanent 13% Temporary 73% In terms of size, on average each of the houses has four rooms. Other assets that
people have include bicycles, motorcycles, farm tools, furniture amongst others.
8.7.2
Income and expenditure
As shown below, agriculture is the biggest income source in the project area. Within
the district, agriculture employs 76% of the population, followed by waged
employment at 16.7%. On average, crops, vegetables and fruit sales generate more
income than animal product sales.
The population in the project area receive no pensions, allowances, social welfare
grants and insurance payments or rents from housing and land.
Table 8-12: Income/expenditure in the surveyed households
Source
Agriculture
Livestock
sales
Amount
Crop, vegetable, fruit sales
120,000
Animal products’ sales
37,800
Palm oil production
0
Other (specify)
Employment
farm)
(non-
5,500
Self-employment
Petty
trading
142,000
(hairdresser,
seamstress,
38,300
carpenter etc), sale of handicrafts
Scoping Report
Page 116 of 173
Salaries
Migrant remittances /
transfers
from
other
households
17,000
From elsewhere in Soroti
7,000
From somewhere else (specify)
0
Pensions, allowances, social welfare grants and insurance payments
0
Housing and land rent
0
Other income sources
9,500
TOTAL ESTIMATED MONTHLY INCOME
377,100
While it is difficult to estimate household expenditure, presence or absence of
household savings reveal a lot about expenditure patterns. On average, 53% of
respondents said that they had savings while 47% said they did not. This means that
for those that do not have savings, they are vulnerable to shocks that are associated
to their means of production. Although most respondents (80%) said that they do not
have loans, some might be depending on informal sources of financing to support
their income deficits.
Figure 8-9: Household loans
Household Loans 20% Yes No 80% 8.7.3
Agriculture
As noted above, agriculture plays an important source of livelihood for many
community members. The main crops grown include cassava, groundnuts and
millet. These are mainly crops that are weather resistant and it was noted that none
of the farmers were using improved management methods to improve their
production capacity as they have never used any inputs such as compost, fertilizers,
etc.
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Slightly more than half of the horticultural production is sold in Soroti Market while the
rest is consumed at home. This suggests that there are few product outlets as most
households do not produce on a large scale. Cassava seems to be the dominant
crop and is not a high value crop compared to maize or beans.
Figure 8-10: Utilization of crops grown
Utlization of Crops Grown Home Consumption 43% 57% Soroti Market Regarding livestock reared at household level, cows, goats, pigs, chicken and sheep
were identified. Considering that livestock are regarded as assets, most are sold
when it comes to paying school fees. This explains why 67% of livestock is sold and
the low uptake of loans in the area.
Figure 8-11: Utilization of livestock reared
Utilisation of Livestock Reared Assets 7% 6% 13% 7% Home Consumption N/A Sale 67% Sale and Home Consumption Most community members rely on communal land for grazing their cows, goats and
sheep, but when it comes to chicken and pigs, it is more likely that these are reared
on family land as shown in the figure below.
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Figure 8-12 Rearing of Animals
Rearing of Animals 18 16 14 12 10 8 6 4 2 0 Communal Land Family Land N/A Series1 Most of the communal areas that were highlighted include close to or within
swamps where animals can get both water and grass for feeding.
Fruit trees
Fruit trees are common in this area and most of the households in the project area
have orange, mangoes and banana fruit trees which in addition to income,
complement the dietary needs of household members.
Constraints to Agricultural Production
The perceived constraints to agricultural production are outlined in the figure below.
Figure 8-13: Constraints to Agricultural production
Perceived Constraints to Agricultural Production Climatic Conditions 10% 7% 10% 20% Lack of Inputs and Equipment Lack of Labor 23% Limited Accest to Inputs 3% 17% 10% 2x5 MW Photovoltaic Power Plant in Soroti, Uganda
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Limited Land Page 119 of 173
Dependence on family labour, limited land and limited access to inputs suggests
that no investments at household level have been made to address these
constraints within their value chain. Contract farming is not common given the small
pieces of land which makes communities vulnerable.
8.8 Social Impacts
During the scoping study, socio-economic information was obtained from review of
literature including the District and Subcounty Development Plans, community
meetings and administration of a questionnaire to households in the two affected
villages of Aliedi and Omuron within the Opuyo parish. Up to 30 households were
visited for the socioeconomic baseline survey, and two community meetings were
held as part of the stakeholder engagement programme.
8.8.1
Demographics
As outlined in the previous section, Soroti District total population was 193,310 (2002
Final census results) of which 94,222 were males and 99,088 female, with a
population density of over 150.6 persons per sq. km. Current projections indicate the
district population at 96,600, (UBOS Statistical Abstract, 2013). The population of
Soroti Sub County is predicted to have grown from 11,697 in 2002 to 21,600 people in
2014.
Most of the people living within the project area are Kumam, and most have always
lived close to the project site, only a few have migrated into the project area.
The average age of household heads is 39 years and the average household size in
Soroti Sub County is 5.6 persons per household, which is slightly higher than the
national average. In terms of dependency, generally, Soroti has a dependency ratio
of 52 which is higher than the national average of 32.9.
Generally, most household members interviewed within Aliedi Village are either
engaged in farming, petty trade or formal waged employment; or at school in
primary, secondary and higher educational institutions.
8.8.2
Sources of water
The main sources of water for the local community are two boreholes shared by the
villages of Omuron and Aliedi. Aliedi village also has a shallow well, but complaints
were raised about its water quality.
8.8.3
Sources of Energy
Fuel wood is the most commonly used source of energy: 99% of the district
population depends on it either directly or indirectly. This is used in the form of
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firewood in rural areas and charcoal that is mostly used in the urban areas. There is
also considerable use of agricultural crop residue. Other energy sources such as
electricity; petroleum, Paraffin, solar and biogas are of negligible use or not in use at
all in some parts of the district accounting for only 1% of the energy used.
The findings of the household survey in the project area show that most households
use firewood for cooking and kerosene for lighting, most collect their firewood from
nearby bushes. No personal woodlots were mentioned and no one mentioned
buying fuel wood to support their household energy consumption.
The village of Aliedi has no electricity distribution line, and no household connected.
A few households had solar panels to provide lighting.
8.8.4
Health and Education
There are a number of primary and secondary schools in the area including Opuyo
Primary School, Opuyo Parents, Soroti SS, Rhema High School that are both
Government and Private.
Table 8-13 Highest level of education attained by household members
Gender
None
Primary level
Secondary level
Tertiary level
Female Hh head
7
3
0
0
Male Hh head
1
14
3
2
Female respondents not
0
9
2
0
0
1
2
0
Hh head
Male respondents not
Hh head
Regarding health, the predominant diseases reported during the household surveys
include malaria, respiratory infections and diarrhoea. When seeking for medical
services, communities in the project area have access to Soroti Main Hospital and
Opuyo Health Centre.
8.8.5
Other Social Considerations
Regarding community networks, most interviewed members of the local community
belong to an informal group from which they get social support especially while
burying family members, credit and savings.
Regarding security in the area, most community members were mainly concerned
about petty theft, other than that, no serious concerns were raised.
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8.9 Traffic and Transportation
The Soroti district is linked to the rest of the country and Africa through the Great
North road, running from Kampala to Tororo through Mbale to Soroti, then to Lira in
the north. The Soroti-Moroto road is the second highway linking Soroti to Karamoja.
The Soroti-Lalle and Soroti-Serere roads are highways linking Soroti to the south
Western part of Eastern Uganda. The old Mbale Road also provides access from
Soroti to Mbale via Ngora and Kumi. Soroti is also linked by railway from Mombasa to
Tororo, then through Soroti to Lira and Gulu to Pakwach. The line is currently under
rehabilitation.
Soroti also has an airplane runway, run by the Soroti Flying School, that links Soroti to
Entebbe international airport.
The results of the household baseline survey show that the main mode of transport in
the project area is the bicycle. However, the majority of the people walk to most of
their destinations within the community. Some challenges regarding transportation
mentioned during the survey and the public consultations include high costs of
public transport fares, poor roads, and that earth roads often cause accidents.
The Soroti-Mbale road is currently being upgraded, while the community roads that
lead from the Soroti-Mbale road to the project site are earth roads with very little
traffic. However, pedestrians and bicycles, including children from nearby schools,
use these community roads.
8.10 Worker Welfare
The EPC Contractor for the proposed project, TSK, is a Spanish company that
currently has no employees in Uganda. If the project is awarded to the ACCESS-TSK
consortium, a project company will be created that will be staffed by Ugandan and
International experts. TSK is likely to bring PV specialist to oversee the specialists tasks
of the construction and operational phases and to engage local contractors to
provide most of the workforce not requiring specific PV expertise during the
construction and operational phase. The contractors that will be appointed are not
known yet.
The assessment and mitigation in relation to worker welfare will ensure that all
employees, working for the project company, TSK or the subcontractor, are treated
in accordance to the Ugandan Legislation and the best practice outlined in the
WB/IFC guidelines.
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8.11 Electromagnetic Radiation
The only potential existing source of electromagnetic radiation is the existing
substation. The proposed alignment of the 33kV power lines that will connect the
proposed power plant with the Opuyo substation is illustrated below. A school
(shown in the plate below) and five residential buildings are in close proximity (<20m)
from the proposed alignment.
Figure 8-14 Proposed alignment for the 33kv power lines
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Plate 8-3 School near the proposed alignment for the 33kv power line
8.12 Cultural Heritage and Archaeology
There are numerous sites of archaeological and cultural importance within Uganda
of which the preservation and protection of such resources is vital in maintaining the
culture and heritage associated with the nation. Although considered unlikely, it is
prudent to consider the possibility of archaeologically or culturally important
artefacts, features, or landscapes to be present and/or affected by the Project
construction and operation.
During the site investigations undertaken during the scoping stage, no signs or visual
evidence of cultural/archaeological facets were identified on the site itself or in the
surrounding areas. It is likely that due to previous agricultural activities at the site any
surface, or immediate sub-surface archaeology would have already been
unearthed.
8.13 Landscape and Visual Impact
Impacts upon the landscape typically occur in situations where the visual horizon is
disturbed by a development.
Such impacts may include the anthropogenic
intrusion of the landscape by buildings/structures where no intrusion previously
existed; or the change in the landscape character of an area, which could arise
from new/out of place development or from the removal of natural vegetation.
Changes in the landscape character can occur when the landscape is changed
out of it current context.
Visual impacts may occur when the line of sight to and/or from a receptor (e.g.
residential areas, area of natural beauty) is intersected or blocked.
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The proposed site is located in a flat area. The immediate local landscape is
characterised by agricultural land and some trees. The brown soils and the green,
yellow and brown colours of the vegetation during different seasons characterise
the landscape and provide the key colouring for the local area. The nearby
wetlands have a different vegetation and landscape character, but there is no
direct line of sight to the proposed site for the two 5MW PV Plants.
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9 Potential Impacts, Terms of Reference and Recommendations
for the ESIA
This section outlines the potential impacts on each identified environmental and
social parameter and the proposed terms of reference for the ESIA study based on
findings of the scoping activity. It describes the ESIA methodology, required
resources and personnel and key outputs/deliverables, where relevant. These draft
terms of reference have been prepared for review by and approval by NEMA. An
ESIA study will then be conducted based on the approved terms of reference.
When potential mitigation measures have been identified during the scoping
process, these are briefly described and recommended for further consideration
during the preparation of the ESIA.
9.1 Ecology and Biodiversity
9.1.1
Potential Impacts
9.1.1.1 Construction:
Grading activities will be undertaken within the proposed site area to facilitate
construction works. Earthworks will also take place in order to prepare the site for
foundations, infrastructure and structural works. These activities will cause direct and
indirect disturbance to the flora and fauna within the site and the loss of the existing
habitat.
The use of areas adjacent to the site as laydown areas or construction site offices
can also potentially have a significant negative impact on biodiversity.
Uncontrolled construction waste may also impact upon the fauna and flora, by
altering the habitat and contaminating the soils. Such wastes may also introduce
pest species into the site and adjacent areas.
9.1.1.2 Operation
The operational activities will prevent the natural re-establishment of flora and the
crossing of the site by large fauna, as it will be fenced.
Landscaping in non-PV areas, using native vegetation, may increase biodiversity on
the site by providing habitats for birds and other fauna. If non native species are
used, there is a risk that these will have an invasive behaviour and cause an impact
on nearby habitats.
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9.1.1.3 Decommissioning
If the site is not adequately restored after decommissioning, the soil and drainage
patterns can be inadequate for resuming horticultural activities or/and for the
recolonisation by natural vegetation.
9.1.2
Studies and Recommendations for the ESIA
The flora and fauna surveys undertaken during the scoping stage have shown that
the major habitat/vegetation types in the project area are not particularly sensitive,
as it has already been heavily impacted by agricultural activities.
However, it is possible for populations of protective or sensitive taxa to be present
near the project area, so more detailed surveys are recommended for the ESIA
stage.
The preliminary survey undertaken during the scoping stage has allowed the field
biological team to:
•
Acquire familiarization with the project area;
•
Evaluate the logistical requirements and arrangements;
•
Rapidly characterize the fauna and flora in project area; and
•
Select the most representative suit of detailed survey for the ESIA stage.
For all the taxonomic groups to be surveyed a literature review will be conducted to
compile all available secondary data that can be accessed. This will help direct the
planning of the field surveys. The Biological environment surveys are planned to
cover six broad taxa (Plants, Invertebrates, Herpetiles – (Reptiles & Amphibians), Birds
and Mammals).
The biological surveys will have the following outputs:
•
Checklists for species occurrence;
•
Information to assess the spatial occurrence of the species in the different
taxa;
•
An indication of relative abundance of different species in the different taxa;
•
An indication of any temporal patterns due to seasons or general habitat
dynamics;
•
Maps of occurrence of the different taxa;
•
Lists of rare, endemic, threatened, IUCN or otherwise listed species that will
have been recorded in different areas for the different taxa;
•
Identification of critical habitats for the different taxa;
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•
Indicator species for future monitoring, and frequency of monitoring;
As a result of the information gathered during the scoping exercise (review of the
project
information,
initial
site
investigations,
stakeholder
engagement
and
identification of potential impacts) a list of preliminary mitigation measures has been
compiled for consideration in the ESIA. This preliminary mitigation measures will be
reviewed in light of the additional information gathered as part of the ESIA
preparation, including the additional baseline surveys and consultations and the
systematic assessment of impacts in the ESIA report.
•
Avoid unnecessary clearing of vegetation.
•
The laydown areas will be placed within the site boundary, not affecting
adjacent land uses.
•
Construction workers will be accommodated in Soroti, no contractor
accommodation will be placed in the nearby areas to the construction site.
•
The EPC will assist in facilitating the process of re-vegetation after construction
in places where colonisation is difficult or in the interest of an accelerating the
process by replanting native species.
•
No non-native species will be planted onsite.
•
If as a result of earthworks invasive species are introduced into the area, the
contractor will eradicate these and dispose the biological waste in a safe
way that avoids further spreading.
•
Any auxiliary construction roads that will not be used during the operational
phase will be removed once construction is completed, the gravel will be
removed and waste taken to an appropriate waste landfill facility, and the
soil will be scarified to facilitate the re-vegetation process.
•
At the construction stage, the topsoil should be removed and stored safely
and spread over the suitable areas of the site once construction has been
completed.
•
Any excess cut that will not be used in the cut/fill balance of the site should
be disposed at an appropriate location, where no damage to natural
habitats may occur. The farmers in the surrounding plots will be consulted, to
check if they can use the soil.
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9.2 Air Quality
9.2.1
Potential Impacts
9.2.1.1 Construction
During construction, the ambient air quality at local receptors may potentially be
affected by increased dust, particularly during the earthworks phase, and by the
exhaust fumes of construction vehicles and power generators. The typical air
emissions resulting from these activities include: Particulate Matter (PM10 & PM2.5),
Nitrogen Oxides, Sulphur Dioxide, VOCs, and BTEX.
9.2.1.2 Operation
The proposed PV plant will not include any specific air emissions sources as a result of
the electricity generation process. The only emissions sources will be minor in regard
to vehicle emissions due to movement’s to/from and around the site. The typical air
emissions resulting from these activities include: Particulate Matter (PM10 & PM2.5),
Nitrogen Oxides, Sulphur Dioxide, VOCs, and BTEX.
Decommissioning impacts on air quality will be similar to construction impacts due to
the presence of construction vehicles and earthworks, however the required
earthworks will be significantly reduced when compared to the construction phase.
9.2.2
Studies and recommendations for the ESIA
The ambient air quality monitoring undertaken for this scoping report has shown that
the air shed in the area is not degraded (as per IFC categorisation), with
undetectable quantities of NOx and SOx and but higher PM levels due to dust from
soils and earth roads. PM levels were found to be higher in the Opuyo substation due
to its proximity to the road where upgrade works were being undertaken.
Given that the PV plant will have no operational air emissions other than emissions
from vehicles and that the monitoring undertaken showed no unexpected levels of
airborne pollutants, no additional air quality monitoring is proposed for the ESIA.
project
information,
initial
site
investigations,
stakeholder
engagement
and
systematic assessment of impacts.
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•
Access roads from the entrance to the site will be compacted and sprayed
with water to minimise the dust generated from the vehicles and trucks. This
potential mitigation measure will be discussed to ensure that there is water
available without interfering with the needs of the community;
•
Deliveries of equipment/plant to the site will be efficiently managed to
reduce the number of trips, and therefore the dust generated in the access
road and the vehicular emissions;
•
Ground-works activities will be minimised during high winds periods;
•
Large soil piles will be avoided where possible;
•
A visual assessment of dust emissions (visual monitoring) will be undertaken on
a continuous basis by the EHS team. Dust producing activities will be stopped
and screened or undertaken in periods of low wind;
•
Designated roads will be made clear to the drivers and signs for the directions
and speed limit will be placed all along the roads;
•
Where sand and other dusty material (e.g. cement) is transported to the site,
trucks will not be overloaded and will be appropriately covered / sheeted;
•
Sand and other dusty materials (e.g. cement) will be stored in specific
designated areas and covered while in storage.
•
Exhaust fumes and particulates emitted from trucks and vehicles will be
minimised by assuring the use of good condition vehicles and conducting
regular maintenance. The EPC will keep a record of the maintenance and
exhaust emissions of all vehicles.
•
Routine monitoring of the PM levels and wind conditions at the site and at the
nearby sensitive receptors will be conducted, in order to verify that on site
operational activities are not contributing to any potential increases in dust
levels. The frequency of the monitoring will be determined at the ESIA stage.
•
Vehicles will be turned off while waiting on site to minimise gaseous emissions.
Shaded shelters for drivers will be provided for waiting periods and
loading/unloading, so that they don’t keep the engine on for the AC.
•
Fires and material burning will not be allowed on the Project site.
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•
Hazardous materials stored and used on site with potential gas emissions (e.g.
VOCs) will be located in well ventilated secure areas away from the
community road.
•
The chemical bathrooms during construction will be emptied following the
manufacturer’s indications, to avoid odour.
9.3 Geology, Soil, Groundwater and Land Contamination
9.3.1
Potential Impacts
The proposed PV plant will not require deep foundations for the PV array mounting
structures. Due to the relatively shallow foundations for the proposed plant, impacts
will only be limited to the topsoils, without intrusion to underlying groundwater,
bedrock or any geological features.
Soil and groundwater will be susceptible to contamination from various sources
during the construction process. The main sources of contamination are typically
those places along the handling of products where liquid waste and hazardous
materials can escape into the soil and groundwater. Hazardous materials and
wastes include fuels, lubricants and sanitary wastewater. These are commonly
associated with the transport, handling and storage of such materials and the
potential threat of releases and spills into the ground.
9.3.1.2 Operation
Impacts upon geology, soil and groundwater quality are generally not anticipated
to occur during operation due to the operational processes not interacting with
theses receptors.
The only hazardous liquids on-site that could cause contamination during the
operational phase will be the oils in the transformers, leaks and spills from vehicles
and sanitary wastewater.
Potential impacts during decommissioning include leaks and spills from vehicles,
waste being left onsite impacting the soil and groundwater and soil erosion if the
drainage is not adequately restored and the natural vegetation cannot recolonise
the site.
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9.3.2
The soil analysis undertaken by an accredited laboratory has been described in the
baseline section. The results indicate that the soils onsite are not contaminated. A
geotechnical investigation has been conducted for the proposed site and no
further constraints were identified.
Since no soil contamination has been detected onsite, no further soil testing is
proposed for the ESIA preparation stage. Due to the predominantly greenfield
nature of the site in relation to industrial activities and the lack of underground tanks
as part of the project no contamination baseline studies in relation to groundwater is
proposed in the scope of works.
project
information,
initial
site
investigations,
stakeholder
engagement
and
•
Wherever possible, reduce the quantity of chemicals and fuel stored on site
to minimum practical level. Infrequently used chemicals will be ordered
before they are needed;
•
Storage of hazardous chemicals (i.e. fuels, lubricants) on dedicated locations
such as paved ground surfaces to prevent leakage into the ground. The
storage areas and the containers will be inspected regularly inspection of
containers;
•
The movement of hazardous liquid chemicals will be done on drip trays to
avoid spillage to the ground;
•
Washing and maintenance of equipment, machineries, and vehicles will only
be permitted onsite on designated hard-standing surfaces and bunded areas
of the site, equipped with adequate drainage and oil traps to avoid spills in
the event of rain, or in similarly designed areas offsite.
•
Refuelling will only be carried out in designated areas following specified
procedures, not at machinery work locations, to reduce potential spillages. A
dedicated refuelling area at the vehicle servicing area will be established.
This will be a hard-standing and bunded area of the site, equipped with
adequate drainage and oil traps to avoid spills in the event of rain.
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Alternatively, an area meeting these conditions offsite could be used.
Refuelling areas will be communicated to all site personnel by signs and
notice boards.
•
No hazardous materials (e.g. fuel or lubricant drums) will be stockpiled.
•
The EPC will also be required to carry out dedicated risk assessment sessions
to identify risks relevant to particular activities involving the use of hazardous
materials and, put in place, appropriate risk reducing measures. The section
on Risk Assessment and Management in the ESMS chapter provides an
overview
of
the
methodology
for
risk
assessment
with
regards
to
contamination.
•
Mandatory training program for employees to increase their awareness of
chemical management protocols including proper handling and storage of
chemicals, emergency response, contingency plans and appropriate PPE.
The EPC will also put in place adequate procedures and safety induction
sessions with regards to the transportation and handling of hazardous
materials, and in particular in relation to refuelling using drip trays and vehicle
maintenance practices.
•
Procedures for emergency response and contingency plan will be in place. A
mechanism will be provided to immediately remediate the affected area in
the event of a spill or leakage of chemicals, fuels, and any hazardous
material. A structure for emergency response and contingency plan is
provided in the Environmental and Social Management System section.
•
Contaminated aggregate wastes or excavation material shall be disposed
through registered/approved waste vendor at appropriate facilities.
•
In order to avoid the risk of cross-contamination, any identified contaminated
soil will be excavated separately, and stored or disposed in accordance with
environmentally adequate measures for waste management. Furthermore, if
contaminated soil is observed during construction activity, the same protocol
must be taken with separate excavation, in order to ensure that cross
contamination does not take place.
9.4 Noise and Vibration
9.4.1
Potential Impacts
Construction activities typically result in temporary and short duration increases in
the noise levels, particularly during the daytime when construction activities tend to
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peak. Night time construction activities also have the potential to result in significant
noise impacts due to the quieter ambient conditions of the surrounding environment
and the sensitive time of day.
Construction noise has the potential to be created and emitted to the surrounding
environment via a range of processes, specifically from those activities involved with
earthworks, piling, site levelling, ramming of the mounting structures for the PV
panels, etc. Increases in traffic during the construction phase may also result in
increased noise levels adjacent to local roads.
9.4.1.2 Operation
Noise is not anticipated to be a significant impact during operation, as the PV
technology will not generate noise. Low-level noises may result from the transmission
of electricity at connection points and where electricity is transferred to the grid.
Such noises are likely to be insignificant.
Noise will also be generated by vehicles used for the transportation of operational
staff to the plant, however this is also unlikely to be significant due to the small
number of operational staff required.
The decommissioning process will generate noise as heavy machinery will be
required and metal structures will be disassembled. However, this will be a temporary
impact of lower magnitude than construction impacts.
9.4.2
A noise baseline survey has been undertaken at the proposed site and at the
identified sensitive receptors to benchmark the existing acoustic levels prior to the
start of construction. The survey showed that some of the areas and receptors are
close to the prevailing noise standards. An additional survey will be performed at
the ESIA stage to monitor noise levels for both daytime and night time periods to get
more information on baseline noise levels.
Potential noise impacts will be detailed within the ESIA for the construction and
operational phases of the project. The machinery that will be used during
construction will be listed and typical noise emissions provided.
A vibration survey is also not recommended, as the operational PV plant will not
include moving parts, and will not have the potential to create significant vibration.
project
information,
initial
site
investigations,
stakeholder
engagement
and
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•
No night-time construction work will be undertaken;
•
Activities with highest noise emissions will be undertaken between Monday
and Friday and not during official holidays;
•
Diesel engine vehicles and compression equipment will be equipped with
effective silencers;
•
Electrically
powered
plant
will
be
preferred,
where
practicable,
to
mechanically powered alternatives. All mechanically powered plant will also
be fitted with suitable silencers;
•
Where appropriate, bored piling techniques will be considered in preference
to impact piling;
•
Delivery vehicles will be prohibited from waiting within or near the site with
their engines running. The movement of heavy vehicles during the night will
be avoided;
•
Noise monitoring will be undertaken to demonstrate that noise levels at the
site boundary and sensitive receptors are acceptable and within the
specified limits. The frequency will be determined at the ESIA stage in
consultation with NEMA and the stakeholders in Aliedi Village and the local
school;
•
Loud machinery operating intermittently will be shut down in the periods
between uses;
•
Where appropriate, noise barriers /attenuation to be employed (e.g. for
generators) to ensure that the maximum noise level at 1 m distance from a
single source will not exceed 85 dB(A);
•
Where noise levels exceeds 85dB(A) noise protection devices shall be
provided to personnel on-site;
•
If particularly noisy works are scheduled, the nearest sensitive receptors (Aliedi
Village and School) will be informed to the timing and duration of the
nuisance. If the Ugandan construction noise standards are exceeded, the
EPC will apply for a noise permit for that particular activity;
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•
Operators of vibrating hand held machinery will be provided with
appropriate PPE (e.g. protective gloves) and be given suitable breaks from
using such equipment to reduce the impacts of vibration.
9.5 Water Resources & Wastewater Management
9.5.1
Potential Impacts
Water is likely to be used for several purposes including drinking, sanitation and
cleaning. The water will be tankered to the site during the construction period.
Wastewater typically produced during construction includes sanitary/domestic
wastewater, cement wash down, other plant cleaning/rinsing effluents, vehicle
maintenance and the mixing of oils/lubricants in the wastewater, including
oils/greases in drip trays etc.
Although construction activities are considered short term and temporary, the
impacts from poor wastewater management could lead to long-term and
significant impacts to the soils/groundwater if wastewater is exposed to these
receptors. This could be particularly pertinent if the contaminants include high
concentrations of bacteria, heavy metals, PCBs and/or hydrocarbons.
9.5.1.2 Operation
The operational processes of the PV Plant will not entail the use of significant
quantities of water and as a result this will not generate significant quantities of
wastewater. Water during operation is only likely to be used for sanitary/domestic
purposes, as well as PV panel cleaning and general cleaning/maintenance
activities. In addition, there will be storm water during periods of rainfall.
Sanitary and domestic wastewater will be handled separately and will be stored in a
septic tank prior to removal and treatment at a licensed wastewater treatment
facility. Storm water systems will be implemented and will include oil/grease traps to
eliminate these within water runoff to the environment.
No water will be required for decommissioning other than for workers and, if
considered necessary, for road wetting for dust suppression. Sanitary wastewater will
be generated and managed in a similar manner to that of the construction period.
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9.5.2
If possible, during the ESIA stage the water on the ephemeral stream to the west of
the proposed site will be collected and analysed. Analysing this ephemeral stream
was not possible at the scoping stage as it was dry during the site investigations.
The only wastewater streams during the operational phase are expected to be
sanitary wastewater and water used for cleaning the mirrors. The assessment of
potential impacts associated with the operational phase will relate to the volumes of
wastewater generated, the streams and concentrations of contaminants.
Provisions for the containment of the first flush of storm water will be considered in
the ESIA if the characteristics of the water used for cleaning the mirrors is expected
to require containment and treatment. Such provisions may include the inclusion of
settlement ponds or other Sustainable Drainage Systems (SUDS) to the storm water
drainage system.
All wastewater streams with different characteristics will be managed separately
according to their origin and/or type of pollution and the type of treatment that
they require. Any effluent discharges from the proposed facility will be required to
comply with Ugandan and IFC wastewater discharge standards in respect to the
intended discharge receptors.
project
information,
initial
site
investigations,
stakeholder
engagement
and
•
Mixing effluent streams of different characteristics – rain water, vehicle wash
water, domestic grey water, sewage effluent etc., is prohibited and shall not
be permitted anywhere on-site.
•
The mitigation measures to prevent soil and groundwater contamination will
be taken into consideration for the design of the drainage system.
•
The drainage system and the discharge of rainwater will be fully described in
the ESIA report, as the design of the drainage system was not available at the
time of writing of this report.
•
Plant native vegetation on slopes and embankments;
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•
Avoid steep gradients to prevent increased erosion or landslides. The
proposed gradient of 5% is considered acceptable.
•
Construct gabions and concrete barriers for containment, use metal mesh
and nets, drains and gutters if any steep slopes are required, for terrain
stability. However, given the relatively flat topography of the site it is not
considered likely that this will be required. The final drainage plan will be
analysed in the ESIA.
9.6 Solid and Hazardous Waste
9.6.1
Potential Impacts
Construction of the proposed project will involve activities such as site clearance;
excavating and back filling; constructing the boundary fence, etc. The types of
waste generated during these activities will be various, with the main constituents
consisting of concrete, rock, soil and fines, lumber, steel scrap, plastics, general
rubbish and domestic waste from the construction labourers as well as certain
hazardous waste streams, including fuel and lubricants for vehicles.
Except for the hazardous fraction of construction waste, the remaining material is
likely to be mainly inert and does not pose a threat to human health or the
environment. Proper management of inert wastes is required in order to reduce
associated secondary impacts such as resource use, dust emissions and habitat
destruction at stockpile areas. Domestic wastes can attract pests to the project site.
Hazardous waste streams have the potential to result in contamination to the site
soils and potentially groundwater if not stored, handled or managed properly.
9.6.1.2 Operation
The nature of the proposed PV plant means that few wastes will be generated from
everyday operations. The equipment used in the operational processes (e.g. PV
arrays, enclosures and electrical connections) does not generate waste, unless
components are specifically replaced during maintenance activities. Small amounts
of domestic wastes may be generated during the operational phase.
In addition, the list of wastes generated during the decommissioning phase might be
generated due to maintenance at certain times during the operational phase.
The facility will generate the following hazardous and non-hazardous wastes waste
streams during decommissioning:
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•
Miscellaneous wastes such as PV arrays/modules, mounting frames, cables,
etc. The management of PV modules after decommissioning has been found
to be one of the key aspects for the Life Cycle Assessment of PV plants, and
will be given particular attention in the ESIA.
•
Used cooling oil from the transformers;
•
General Clean-up materials; and
•
General domestic waste;
The hazardous fraction of the waste can potentially cause significant adverse
impacts on human health and the environment if not managed properly.
9.6.2
The ESIA will consider a desk-based assessment of the waste streams, waste
quantities, potential waste collection and hazardous waste treatment options
necessary
for
the
facility
during
both
the
construction,
operational
and
decommissioning phases.
The impacts arising from the generation of waste will be assessed with reference to
the existing regulations on waste management and relevant international guidelines
and waste management principles.
Mitigation measures ensuring appropriate storage/handling/transport of waste at
the site and measures to reduce volumes of waste otherwise destined for existing
landfills, will be highlighted. These measures will be sourced from international
industry best practice and will conform to NEMA waste management requirements.
A Framework CESMP and OESMP within the ESIA will address the responsibilities,
mechanisms and options for waste reduction, re-use, recycling and disposal. An
outline waste management plan will be developed to provide a mitigation,
monitoring and implementation plan to demonstrate compliance with the relevant
environmental requirements. The outline waste management plan will need to be
further developed by the EPC Contractor and operational team, to ensure that it is
specific to each of the wastes that will be generated.
project
information,
initial
site
investigations,
stakeholder
engagement
and
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•
As stated above, the management of PV modules after decommissioning has
been found to be one of the key aspects for the Life Cycle Assessment of PV
plants, and will be given particular attention in the ESIA. The recycling silicon
based PV – which commonly contains up to 80% glass – involves three main
steps:
o
Preparation phase – removal of the frame and junction box
o
Shredding
o
Processing in the flat glass recycling line
Output fractions of this process are ferrous and non-ferrous metals, glass,
silicon flakes and plastics with an average recycling quota of approximately
85% (input weight, depending on recycling technology). The glass resulting
from the recycling of PV modules is mixed with standard glass cullet, and
partly reintroduced in glass-fibre or insulation products and partly in glass
packaging products. The metals and plastics can be used for the production
of new raw materials.
•
Establish waste management priorities at the outset of activities based on an
understanding of potential;
•
Identify EHS risks and impacts and consider waste generation and its
consequences;
•
Avoid or minimize the generation of waste materials, as far as practicable;
•
Identify where waste generation cannot be avoided but can be minimized or
where opportunities exist for, recovering and reusing waste; and
•
Where waste cannot be recovered or reused, identify means of treating,
destroying, and disposing of it in an environmentally sound manner.
The mitigation measures outlined above are based on the Waste Management
Hierarchy. The waste management hierarchy is a key element of waste
management. Minimising the amount of waste to be stored and disposed not only
protects the environment but also has the potential to reduce costs that may be
incurred by the main contractor or the proponent for handling and disposing of the
waste.
The waste hierarchy, typically expressed in the “3 R’s” of waste management
(Reduce, reuse, recycle) is illustrated in the figure below.
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Figure 9-1 Waste Management Hierarchy
Initially, options to prevent or reduce waste will be considered. Where waste
generation cannot be avoided or further reduced at source, opportunities for reuse
of materials will be explored, either for use for the same or a different purpose.
Disposal to landfill is the least favoured option in the waste hierarchy and is the last
resort after all other options have been considered.
9.7 Economic Impacts
9.7.1
Potential Impacts
During the construction phase positive opportunities may result from increased local
employment, dissemination of skills within the local workforce, use of local materials
and resources and the multiplier effect.
The leasing of land for the project has resulted in the availability of financial
resources to the local community.
9.7.1.2 Operation
The project itself provides a beneficial impact to the economy due to the increased
provision and diversification of the Ugandan energy supply, subsequently reducing
the country’s reliance on fossil fuels.
An economic impact upon nearby communities during operation will result from the
employment opportunities created by the Project and the dissemination of skills to
the workforce, even thought the number of staff at the operational stage will be
limited.
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During the decommissioning phase, temporary employment will be created but this
will cease once the decommissioning is complete. The land owners will receive their
land back as the land lease will expire and may choose to start cultivating it again.
9.7.2
This scoping study has obtained specific socioeconomic data on the communities
around the project site through the means of a household socioeconomic survey.
Additional research will be conducted to source literature with information on the
location of sensitive social receptors around the proposed project site. Background
literature will also be sourced to investigate tourism in the area and relevant
economic indicators.
The ESIA study will look at key indicators relating to factors such as the labour market,
income, agricultural practices and tourism in the area to complement the
information obtained through the socioeconomic questionnaire. The purpose of
these efforts is to establish the context of the development within the economic
environment in which it will proceed and consequently to provide a basis for the
assessment.
Once the baseline has been established a more detailed consideration to the
implications and impacts of the development at both a strategic and local level will
be given. The analysis during this stage will draw upon experience gained by the
consulting team during visits to the development area.
The ESIA will include mitigation measures specifically addressed to maximize the
employment generated within the project area and the transfer of skills to local
workers. In addition, any potential secondary impacts on agriculture will be assessed
in detail, as this is the main source of living for the local population. The impact of
the lease of the land for the project will also be discussed.
9.8 Social Impacts
During the construction phase the potential exists for a variety of impacts to occur
primarily in relation to the welfare of the local communities. Impacts relating to
health, safety and welfare of the local communities may arise as a result of traffic,
noise, air quality, pollution issues, influx of outsiders, etc.
There is a school close to the project site and another school close to the proposed
alignment of the power lines. Both could be negatively impacted by changes in the
environmental aspects outlined above.
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The project can result in positive impacts through the dissemination of knowledge
and technical knowhow, through the meaningful participation of the community in
the ESIA process and in the ESMS, and through the establishment of a CSR
programme that could provide socioeconomic benefits to the communities.
Compensations and CSR actions are generally proportionate to the risks and
impacts on the community. In the proposed project the risks and impacts are very
limited, however it is considered useful to undertake CSR actions that could benefit
the community, making use of the machinery that will be mobilised to the project
site for the construction of the project and of the engineering knowledge of the
consortium to undertake work that could benefit the community. This could include
the construction of a livestock watering point, the construction of latrines at the
school or other similar actions.
Chapter 10 describes the key characteristics of the Environmental and Social
Management System. Some of the elements of the ESMS, such as the grievance
mechanism, are key for the management of social impacts.
9.9 Traffic and Transportation
9.9.1
Key Issues
Construction activities will likely lead to an increase in vehicle to the project site and
a negligible increase of vehicles in the Soriti - Mbale road. Such vehicles are likely to
include Heavy Goods Vehicles (HGV) associated with construction and delivery
activities. Given the low number of vehicles in the local road and the short distance
of the local road that will be transited by the vehicles, it is highly unlikely that it will
result in congestion, longer journey times or increased levels for stress of drivers.
Secondary impacts of additional vehicles may include impacts upon air quality and
increased noise, particularly in the vicinity of the site and around associated routes.
However these impacts will be temporary and the severity will be dependent on the
pace of construction.
Road safety is a key issue during the construction stage as the community road is
used by school children.
9.9.1.2 Operation
The traffic impacts from the operation of the PV plant are likely to be negligible,
mainly due to the limited number of trips required for day-to-day operations. Trips to
the site may be required for the following reasons:
•
Operational staff commutes;
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•
Maintenance Activities;
•
Waste and wastewater removals;
•
Miscellaneous Deliveries.
The decommissioning of the plant will require an increase in the number of vehicles
to remove all equipment form the site.
9.9.2
The ESIA will qualitatively assess the current levels of traffic in the area (if sufficient
data is available) and compare this against the anticipated levels of vehicle
movements for the proposed project.
The assessment will determine the potential significance impact from associated
plant traffic during construction, operation and decommissioning. Vehicle related
Impacts on air quality, noise, and local infrastructure will be assessed in these
specific sections of the ESIA. The evaluation will also take into consideration any
future plans for road expansions in the local area and assess any elevated risk in the
vicinity of the sensitive receptors identified.
Where appropriate, mitigation measures relevant to the identified impacts will be
recommended to reduce or eliminate these potential issues. The mitigation
measures that are recommended for the ESIA at this stage include the following:
•
Demarcating or taping an area of the road for pedestrians during
construction.
•
Schedule major vehicular traffic (deliveries or arrival/departure of workers) at
different times to school access and entrance times. Otherwise, ensure that a
member of the EHS team is ensuring safety at the road near the schools.
•
Encourage car pooling by site workers or provide buses or vans for workers to
commute to and from Soroti.
•
Designate parking/staging areas. Provide adequate parking stations for the
estimated numbers of visitors to the site (workers and suppliers).
•
Clearly identify truck routes and entry points for heavy vehicles entering the
site.
•
Develop a Traffic Management Plan (construction).
•
Clearly post site entry / exit signs. Use 24hr security and document all vehicles
entering/exiting the site.
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•
Clearly post on-site speed limits, recommended 5Km/hr during construction
and 10Km/hr during operation.
9.10 Worker Welfare
9.10.1 Key Issues
During the construction, operational and decommissioning phases the potential
exists for a variety of impacts to occur primarily in relation to the welfare of site
workers. Impacts relating to health, safety and welfare of the construction workers
may arise as a result of traffic, noise, air quality, etc.
There is potential for plant personnel to be exposed to contaminated materials
existing on the site or brought onto the site as part of the construction, operation or
decommissioning process. Workers may also be exposed to contaminants
emanating from poor management of sanitary wastewater and from dustsuppression activities.
9.10.2 Studies and Recommendations for the ESIA
The ESIA will include a number of measures aimed at protecting the workers form a
large number of secondary impacts. These include impacts from noise, air pollutants,
hazardous materials and wastes, etc. The sections above recommend mitigation
measures for these impacts.
In addition, the mitigation measures in the ESIA will ensure that the rights of workers
are guaranteed. These include, inter alia:
•
Non discrimination;
•
Provision of PPE and a healthy and safe working environment;
•
Adequate management of the relationships with workers including:
•
o
A grievance mechanism;
o
Fair treatment;
o
The possibility to form or join labour unions;
Not employing any child or forced labour.
These measures will apply also to workers engaged by third parties, and as much as
possible workers in the supply chain. At the ESIA stage the local subcontractors
would have been appointed and their working practices and compliance gaps will
be assessed.
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9.11 Electromagnetic Radiation
9.11.1 Potential Impacts
9.11.1.1 Operation
As described in the baseline section, the proposed 33 kV power line will be adjacent
close (<20m) to a school and five residential buildings. As there are no Ugandan or
WB standards for electromagnetism, the existing scientific evidence is reviewed
below.
Review of available evidence on electromagnetic impacts
There is a significant amount of scientific research studying the effect of
electromagnetic radiation from power lines and other anthropogenic sources. A
number of epidemiology studies drew attention to an increase in incidence of
leukaemia and other cancers among children living close to sources of extra-lowfrequency (ELF) magnetic fields. The scientific studies show conflicting results. The
work published by Savitz (1988) and Wertheimer and Leeper (1979), for example,
showed a relationship between both factors, while the work published by other
authors such as Fulton et. al. (1980) did not show any correlation.
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) issued
guidelines on exposures in 1998, that have been reviewed since 2009 for different
types of radiation. The Guidelines for Limiting Exposure to Time-Varying Electric and
Magnetic Fields (2010) states that even though epidemiological studies have shown
that chronic low intensity power frequency magnetic field exposure is associated
with an increased risk of child leukaemia, no casual relationship has been
established, nor have any other long term effects been established.
The Cross Party Inquiry into Childhood Leukaemia and EMF was set up in the United
Kingdom in 2006 to consider in detail the evidence for an association between
Electric and Magnetic Fields (EMF) from High Voltage Overhead Transmission Lines
(HVOTL) and an increased risk of childhood leukaemia. The conclusions of the inquiry
recognised the potential risks to children’s health caused by exposure to EMF and
introduce a moratorium on the building of new homes and schools within at least 60
metres of existing High Voltage Overhead Transmission Lines (HVOTL) of 275 kV and
400 kV and on the building of new HVOTL within 60 metres of existing homes and
schools and the same within 30 metres from 132 kV, 110 kV and 66 kV lines. No
recommendations were included for 33kV lines.
Heaton and McCallum (1992) concluded following a review of the existing literature
that the lower limit of the magnetic field strength for detrimental chronic effects was
approximately 250 mAm-1. Experimental measurements of ELF magnetic field
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distribution in an urban environment showed that fields above 250mAm-1 were found
as far away as 60m from a 275kV line and 15m from a 132kV power line. Fields near a
33kV power line were below 250mAm-1.
Site measurements of electromagnetic fields for low voltage electricity distribution
lines on a rural setting are also available. In late 2004 Main Power engaged the
National Radiation Laboratory to carry out electric and magnetic field recordings at
an existing 33kV to 11kV substation and in the vicinity of an existing 66kV overhead
line. A summary of the findings is presented below:
Table 9-1 Electric and Magnetic Fields - Main Power Substation
Location
Electric field
% of ICNIRP
Magnetic
% of ICNIRP
Guidelines-
field
Guidelines-
(Microtesla)
100 microtesla
(metres from
(Volts per
(5,000Volts per
substation)
metre)
meter)
1
99.6
2.0
0.24
0.2
5
70.2
1.4
0.11
0.1
10
41.4
0.8
0.07
0.1
15
17.3
0.3
0.05
0.1
20
8.7
0.2
0.03
<0.1
25
6.1
0.1
0.03
<0.1
Line measurements were also taken at one metre intervals perpendicular to the
66kV line. Results showed a substantial drop in readings with distance.
Table 9-2 Electric and Magnetic Fields - Main Power 66 kV power line
Location
Electric field
% of ICNIRP
Magnetic
% of ICNIRP
Guidelines-
field
Guidelines-
(Microtesla)
100 microtesla
(metres from
(Volts per
(5,000Volts per
line)
metre)
meter)
1
73.6
1.5
0.21
0.2
5
72.4
1.4
0.21
0.2
10
56.4
1.1
0.19
0.2
15
34.7
0.7
0.17
0.2
20
21.1
0.4
0.14
0.1
25
14.5
0.3
0.12
0.1
The survey of this operational facility showed that the electric field was always below
2% of the ICNIRP Guidelines and the Magnetic Field below 0.3% of the guidelines. It
should be noted that the proposed power line will be 33kV, not 66kV as in the Main
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Power case study, so the electric and magnetic fields are expected to be even
lower..
In conclusion, there is mixed evidence regarding the impact of High Voltage
Transmission Lines on health, but there is consensus regarding the lack of risks
associated with 33 kV lines like the one proposed, even for children or other sensitive
groups.
The 33kV interconnection line proposed will not have a significant electromagnetic
impact on the sensitive receptors near the alignment, including the school and the
residential buildings.
Following the review of the proposed line and of the available evidence, it can be
stated that the 33kV interconnection line proposed will not have a significant
electromagnetic impact on the sensitive receptors near the alignment, including the
school and the residential buildings. For this reason, it is not considered necessary to
survey the baseline electromagnetic fields in the ESIA.
However, it is recommended to take a precautionary approach and avoid power
lines being directly overhead or in close proximity to schools or residential buildings.
This is not only preferable in relation to electromagnetism but also in relation to
safety.
The identified school and houses are located on the western side of the road, while
no sensitive receptors are adjacent to the road on its eastern site. It is
recommended to build the power line on the eastern side of the road to increase
the distance between the proposed 33 kV line and the identified sensitive receptors.
The alternative alignment is illustrated in blue in the figure below.
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Figure 9-2 Proposed and alternative alignment for the 33kv power lines
9.12 Cultural Heritage and Archaeology
Construction activities, particularly those relating to earthworks and excavations
have the potential to cause disturbance or damage to any unknown buried
archaeological or cultural features. The resulting impacts may result in the loss of
such features or degradation of their preserved quality.
9.12.1.2 Operation
Impacts during operation are not anticipated, as there will be no further excavation
or earthwork activities at the project site.
1.1
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A Ugandan Archaeologist, Dismas Ongwena, will also undertake a site survey and
observations to identify potential sensitivities not identified during the scoping surveys
and desk study of the archaeological potential of the area. In addition the
stakeholders may raise additional issues regarding cultural heritage in the area.
The impacts on archaeology and culture heritage associated with both the
construction and operational phases will be assessed and where required,
appropriate mitigation measures will be recommended. Guidelines regarding
artefacts being unearthed during the construction phase will also be included in the
outline CESMP, which will detail a best practice procedure if any finds are made.
The EPC and the subcontractors will also be required to follow and consider the
Standards and Guidelines for an Archaeological Watching Brief, Institute of Field
Archaeologists, Revised Version, 2008. The Archaeological Watching Brief is a formal
programme of observations and investigations that are carried out for nonarchaeological projects. It can be undertaken in any site where possibilities to find
any archaeological deposits exist. The brief will be adapted to the size of the
project.
Training and awareness programmes will be provided to ensure that construction
staff and labourers are aware of the procedures relating to the Archaeological
Watching Brief will any artefacts or anthropogenic finds be uncovered. In the
unlikely event of any artefacts being found/uncovered, the construction work would
be ceased immediately and the relevant authorities contacted by the Site
Manager, and the artefacts will be assessed before construction in the area is
resumed.
9.13 Landscape and Visual Impact
A key change will result from the loss of the view to the characteristics bright
orange/brown soils, as these will be replaced with a view of dark coloured flat PV
arrays, occupying an expansive area.
Due to the low-lying design of the PV Plant, with the PV Arrays not exceeding 3-4m
and other site structures not exceeding 5m, views across the surrounding landscape
are unlikely to be significantly impacted, particularly from distant receptors. Few
nearby receptors are present at much of the surrounding land is attributed to the
future expansion of the industrial zone, which is unlikely to be a sensitive to
landscape or visual impacts.
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9.13.1.1 Operation
Further impacts to those encountered during construction are not anticipated
during operation as the proposed project will not be altered or expanded. Impacts
due to lighting may however result in changes to the night time landscape
character and views of the site. It is envisaged that only minimal lighting will be
required for security purposes.
A landscape character and visual impact assessment survey will be undertaken to
establish the existing condition and character of the landscape on and immediately
surrounding the site, as well as existing sensitive visual receptors and potentially
sensitive views. This will be undertaken via site walkovers and desk study
investigations (e.g. satellite imagery and terrain data) to determine the closest
receptors to the visual aspect of the facility outline. Photographs will be taken at
suitable locations around the site and analysed with regard to the visual impacts.
The output of this will include the a discussion of observations and findings in the
context of the existing commercial, residential and recreational developments, with
maps showing the locations of identified sensitive receptors; and photomontages of
visual impacts.
Where appropriate, suitable mitigation measure will be detailed, with specific input
to the outline CESMP & OESMP in terms of how to implement these during the
different stages of the project. The mitigation measures considered will include the
planting of vegetation around the project fence and the avoidance of flood
lighthing.
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10 Environmental and Social Management System
10.1 Introduction
An Environmental and Social Management System (ESMS) is key in ensuring that the
environmental quality does not deteriorate due to the construction and operation of
the proposed project. The ESMP comprises a set of measures to be taken in different
stages (construction, operation and decommissioning) to eliminate, offset or reduce
adverse environmental impacts to acceptable levels.
Elimination, prevention, or enhancement can be achieved by reducing the scale of
the activities, which results in a minimisation of negative impacts, or increase of
positive impacts. Repairing or restoring particular features of the environment, which
have been adversely affected by the activity, will be achieved by remediation.
Offsetting a negative impact can be achieved by providing additions to or
substitutes for the environment affected by the environment. The ESMS needs to be
implemented at the preliminary design stages through construction, operating and
will continue until decommissioning.
The ESMS draws on the conclusions of the ESIA, that analysis in detail all the
environmental and social opportunities and constraints and outlines mitigation
measures.
10.2 Construction Environmental and Social Management Plan (CESMP)
As part of the environmental process for construction, companies are required to
prepare and follow a Construction Environmental and Social Management Plan
(CESMP) to ensure environmental impacts are avoided or minimised. The ESIA will
generate clear and concise mitigation measures recommendations for the
construction phase so that these can be integrated into a CESMP.
This
environmental management plan serves as a basis for the preparation of the
dedicated CESMP for the proposed project. This will ensure that the project
proponent will design, construct and operate the proposed project in accordance
with the applicable national and international environmental laws and standards.
Similarly, a CESMP will need to be prepared by the contractor and all subsubcontractors will be obliged to follow all rules and procedures that are outlined in
the document. This includes not only engineering mitigation measures but following
and enacting proper management structures and procedures.
The key benefits of a CESMP are that it:
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•
Includes a baseline (building on the ESIA data) against which environmental
performance can be assessed;
•
Provides a system for the formal identification of potential environmental
impacts associated with construction processes;
•
Enables the identification of objectives and targets; and
•
Provides a framework for monitoring and measuring of performance during
construction.
As part of this, 5 Capitals will prepare a framework for the CESMP within the ESIA that
will be incorporated within the full CESMP and to be followed during the
construction phase. The framework will also provide procedural mitigation measures
and other procedures that need to be incorporated within the CESMP and
implemented on-site.
The CESMP will be developed on the basis of best practice techniques in Uganda
and internationally.
10.3 Operational Environmental and Social Management Plan (OESMP)
The environmental and Social management plan for the operational phase serves
as a general tool for managing all environmental aspects related to the operation
processes of the proposed plant.
The OESMP establishes a framework for the identification and implementation of
environmental protection, mitigation, monitoring and institutional measures that will
be taken during the operational phase of the proposed project, which will be in
accordance with the procedures outlined in the WB / IFC EHS Guidelines and
Ugandan Legislation. The purpose of preparing and implementing the OESMP is to
eliminate the potential adverse environmental and social impacts associated with
the operation of the project that have been identified within the ESIA and then
mitigating them or, at the least, offsetting to acceptable levels.
The OESMP to be finalised prior to the start of the operational phase and will include
all the obligations included in the ESIA. The ESIA will include a framework for the
OESMP that will be followed and further developed during the operations phase. The
plan will be developed on the basis of widely accepted best practice in Uganda
and internationally.
10.4 Environmental and Social Monitoring Plan (ESMP)
The ESMP will also need to identity the relevant environmental aspects, monitoring
objectives, specify the monitoring requirements and measures which will include all
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the parameters required to be monitored, measurement frequency, and detection
limits the threshold where corrective actions are required.
Monitoring and reporting to the Financial Institutions will occur throughout the life of
the project.
The objective of an environmental monitoring plan is to establish the baseline
indicators to assess the overall performance and effectiveness of the environmental
management programs of the facility. The monitoring program has the underlying
objective to ensure that the intended environmental mitigations are implemented
properly and that these result in the desired mitigation to the target environment
and population, causing minimal deterioration to the environmental and social
parameters. Such a program targets proper implementation of the CESMP and
OESMP.
The ESMP will help management to redefine the environmental program objective
and reallocation of the budget for implementing pollution control systems,
employees’ awareness and training programs, implementing pollution prevention
opportunities, etc. as necessary to ensure full compliance.
The broad objectives of Environmental Management Plan are:
•
To evaluate the performance of mitigation measures proposed in the
CESMP/OESMP;
•
To evaluate the adequacy of Environmental Assessment;
•
To suggest on-going improvements in the management plan based on the
monitoring and to devise fresh monitoring on the basis of improving the ESMP
and additional mitigation for the CESMP / OESMP;
•
To enhance environmental quality through proper implementation of
suggested mitigation measures;
•
To ensure compliance with the requirements of the existing environmental
regulatory framework and community obligations.
A general environmental and social monitoring plan for the proposed project that
will be followed during the project phases will be prepared as part of the final ESIA.
The ESMP will be built on and modified as necessary during the construction,
operational and decommissioning phases.
10.5 Emergency Response Plan
Emergency Response Plans (ERP) plans are general action plans to tackle
emergencies that may occur within a construction and operational sites. This will
enable lives to be protected and damage to be kept to a minimum in an
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emergency at the site. Contingency plans also serve as a guide to the workers at
the site to respond to emergencies in an orderly and effective manner.
The most common environmental emergency in a site is an oil and chemical spill,
which is a potential cause for soil contamination, groundwater and water pollution.
Spills of hazardous materials may include:
•
Gasoline;
•
Diesel;
•
Lubricating oil and grease;
•
Concrete from release agents.
The analysis methodology used to address a potential emergency such as a
chemical spill is outlined in detail below. The same methodology will be used in the
full ESIA and by the contractor and operator during the construction, operational
and decommissioning phases to include all other potential risks (please refer to the
risk assessment section below for risk identification methodology).
For addressing a potential risk such as spills, the following specific actions need to be
included in the EPR:
•
Preparedness;
•
Response; and
•
Reporting.
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10.5.1 Preparedness
Each individual will be introduced to their prospective Supervisor and Environment
Coordinator within their site induction and training.
A variety of equipment and personal protective equipment may be needed to
support a chemical or oil spill incident response. A list of equipment is detailed
below:
•
Sand;
•
Sand bags;
•
Buckets and shovels;
•
Storage containers; and
•
Spill kit.
Sand stocks will be dry and buckets and shovels readily available. Storage
containers for contaminated materials and earth will be bunded, located in the
waste storage area, and labelled and treated as hazardous waste. All equipment
will be stored in a safe location on site in close proximity to the storage and waste
areas. This material is to be used to contain and clean up pollution/spills, care will be
taken to dispose of any absorbent materials properly. The Supervisor and
Environment Coordinator will keep stocks well maintained and replenished.
10.5.2 Response
In the event of a chemical or oil spill the following measures will be employed:
•
Notify Supervisor or Environment Coordinator;
•
Only attempt containment and clean-up operations of spilt substances when
it can be performed safely;
•
If spilled material is flammable, eliminate sources of ignition near spill area;
•
Evacuate personnel and neighbours if they are at risk; and
•
Secure the area and establish perimeter control at a safe distance from the
spill.
Remedial action to collect and remove all materials contaminated by the oil
spillage or leakage event is to be taken immediately. The following actions are
required:
•
Any oil remaining on the ground is to be collected using oil spill kit. The spill is
to be surrounded by the kit and then the area of the spill is to be slowly
reduced by enclosing the absorbent. The absorbent pads will be used to
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absorb the oil. Once all of the oil on the ground surface has been collected,
the absorbent agents themselves are to be appropriately stored and
disposed;
•
All contaminated materials are to be handled as hazardous waste. The
contaminated material shall be collected and appropriately stored. A
hazardous waste vendor will collect this;
•
Contaminated materials will be stored in plastic barrels with tightly closing lids.
These barrels are to be stored in a concrete lined bund if available. In
absence of such a bund at the site as a short-term storage alternative, a
double plastic lined bund will be used. Barrels will be placed on plastic or
wooden pallets in the temporary double plastic lined bund and not directly
on the plastic; and
•
Conventional metal barrels will not be used, however if there are no
alternatives the materials may be stored in them providing they are covered
with plastic sheet tightly fastened to prevent Aeolian distribution and again
are stored in an appropriately bunded location to prevent leakage will the
barrels suffer corrosion.
All contaminated materials that cannot be collected and disposed are to be
cleaned in-situ. This cleaning is to be undertaken by an approved service providers.
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10.5.3 Reporting
Any person involved in plant activities that witnesses an incident (accident or near
miss) must be able to report the incident to the responsible supervisor.
The
Environmental Coordinator shall be responsible for ensuring a report is filed
describing the cause of the incident, action taken, the incident and recommended
actions for ensuring the incident will not reoccur. A process flow that will be followed
is shown in figure below.
Response
Spill/
chemical
Pollution
Figure 10-1 Incident Response
START
Spill Event is
identified
on Site
Contact Environmental
Coordinator/Site
Supervisor
Action
Environmental
Coordinator prepares
Incident
response/Corrective
Follow up
&
Recovery
Action Plan
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Project Manager
organise audit against
END
corrective action plan
Page 158 of 173
10.6 Risk Assessment and Management
The content of this chapter will be used as a basic outline of risk assessment
methodology
that
will
be
used
during
construction,
operational
and
decommissioning phases of the Plant.
The risk assessment addresses the impacts to the environment and the communities
that could occur as a result of mishaps or failures during the construction,
operational and decommissioning phases of the project. These could be failure of
equipment or material or processes. Examples of mishaps are:
•
Spills;
•
Leaks;
•
Fires; and
•
Explosions.
To account for, control and avoid such potential hazards, this section provides for a
preliminary outline to:
•
Identify the hazards;
•
Assess and prioritise risks and hazards;
•
Decide on control measures;
•
Implement the control measures; and
•
Monitor and Review.
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Figure 10-2 Process for EPC and O&M for risk identification and management
These steps cover identification of the major hazards to people and the
environment, analysis of the related risks, as well as implementing measures to
control these risks to improve in case these measures fail.
Risk Assessment shall be carried out in the following circumstances;
•
When there is a change in the workplace, e.g. new plant, equipment, etc.
•
When there is a change in procedures and/or processes;
•
Induction of new personnel;
•
Following an incident (accident or near miss);
•
When there is a change in the legislation / requirements;
•
Prior to start of work;
•
At regular intervals; and
•
When carrying out high risk activities.
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10.6.1 Identification of Hazards
The first Risk Assessment Process step is to systematically identify the potential health,
safety, and environmental hazards and effects of activities and operations. Hazards
and effects need to be identified as early as possible and tracked through the life
cycle of each activity. It is imperative that sensitive environmental components and
conditions are identified and priority protection areas delineated.
Hazards can be identified and assessed in a number of ways:
•
Using checklists;
•
By referring to codes and standards;
•
By undertaking more structured review techniques;
•
Previous experience in the area, including that of third parties;
•
General observation and HSE awareness;
•
Audits;
•
Accident / incident investigations;
•
Drills and exercises; and
•
EHS/Environmental meetings.
Action to be taken by individuals on identifying a hazard include –
•
Eliminating or controlling the hazard immediately;
•
Isolating the hazard to prevent an accident; and
•
Reporting the hazard using the standard form.
It must be noted that all hazards are to be reported, including those eliminated or
controlled immediately. Any situation where an Equipment Incident could cause
injury or other significant loss under different circumstances will first be reported as a
Near Miss.
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10.6.2 Analysis of Risk
Every reported hazard is analysed to decide how serious it is, and this is done by
using the risk matrix, based on the knowledge and experience of the person(s)
conducting the analysis.
The risk matrix is used to analyse the probability of occurrence (frequency) and
severity of consequence or potential consequence, producing a rating as a code.
The code is then classified into four (4) risk groups: low, moderate, high, and extreme
risk. The level of risk is indicative of how much effort and urgency must be put in to
controlling the problem.
Table 10-1 Probability of Occurrence
Description
Likely Frequency
Environment
Frequent
Often
Likely
Possible
Rare
Continuous or will
happen frequently
5-12 times per year
1-5 times per year
Once every 5 years
Less than once
every 5 years
Probability
Health and Safety / Risk
to the Community
Occurs several times a
year at location
Occurs several times a
year in similar industries
5
4
Has occurred at least
once in Morocco
3
Has occurred in
industry (World-wide)
2
Never encountered in
the industry
1
Table 10-2 Risk Assessment Matrix
Consequence
Probability
Insignificant 1
Minor - 2
Moderate 3
Major - 4
Catastrophic - 5
Rare-1
1
2
3
4
5
Possible-2
2
4
6
8
10
Likely-3
3
6
9
12
15
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Often-4
4
8
12
16
20
Frequent-5
Almost
Certain
5
10
15
20
25
15 to 25
Extreme Risk
Activity or industry will not proceed in current form
8 to 12
High Risk
Activity or industry will be modified to include
remedial planning and action and be subject to
detailed EHS Assessment
4 to 6
Moderate Risk
Activity or industry can operate
management and / or modification
1 to 3
Low Risk
No action required unless escalation of risk is
possible.
subject
to
The Risk Assessment Matrix helps to focus attention on the risks that matter by
considering the following two questions:
•
What is the probability of that incident occurring?
•
What is the likely consequence of that occurrence?
Use of the Risk Assessment Matrix will:
•
Enhance appreciation of HSE risk and achieve “As Low As Reasonably
Practicable” at all levels in all operations at all phases;
•
Assist in setting clear risk based strategic objectives;
•
Provide the basis for implementation of a risk based EHS Management
System; and
•
Provide a consistency in evaluating risk across all PP activities.
10.6.3 Deciding on Control Measures
A 'control' is anything used to manage risks e.g. procedures, work permits, Personal
Protective Equipment (PPE), training, and on-site supervision.
Once the hazards of activities have been identified and assessed, controls must be
put in place to manage the risks. It is also important to put steps in place to be able
to recover from an unplanned hazard and return to normal operating conditions.
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Information on hazards, effects, and the risks connected to these and requirements
to limit ('control') them such as limits of safe operation are prepared and recorded
by Management.
Table 10-3 Hazard Controlling Measures
Control
Use
Preventive
measures
To
reduce
the
likelihood
of
hazards
or
to
prevent or avoid
the release of a
hazards
Improvement
measures
To reduce or limit
the consequences
arising
from
a
hazardous event or
effect
Description and example
a. Examples include guards or shields
(coatings, inhibitors, shutdowns),
separation (time and space),
reduction in inventory, control of
energy release (lower speeds,
safety valves, different fuel sources)
and administrative (procedures,
warning, training, drills).
Active systems:
b. Intended to detect and abate
incidents, for example, gas, fire and
smoke alarms, shutdowns, deluge
Passive systems:
c. Intended to guarantee the primary
functions, for example, fire and
blast walls, isolation, separation,
protective devices, drain systems
Operational (non physical) systems:
d. Intended
for
emergency
management,
for
example
contingency plans, procedures,
training, drills
Recovery
Measures
Includes top events
All
technical,
operational
and
organizational measures which can –
e. Reduce the likelihood that the first
hazardous event or ‘top event’ will
develop into further consequences.
f. Provide life saving capabilities will
the ‘top event’ develop further.
Any hazard and its associated risk are controlled by either reducing probability of
occurrence or by reducing the effects. This may be achieved by one or more of the
following steps shown in the figure below:
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Table 10-4 Hazard and Safety Hierarchy of Controlling Hazards
Eliminate
Replace
Isolate
• Remove the Hazard completely
• Replace the hazardous technique, procedure, or equipment with a safe one to
reduce the level of risk
• Physically separate the hazard form personnel, equipment, environment using
mechanical guards, walls, etc.
Engg. • Use safe work procedures, modify tools, or equipment
Controls
Protect
• Use Personnel Protective Equipment and clothing
Note that these measures are listed from most effective to least effective. Efforts will
be made to use the most effective possible measures to achieve results and several
measures may be for each situation.
Once the control measures have been designed, the hazard can be re-analysed on
the risk matrix to ensure that risk has been reduced to acceptable levels.
10.6.4 Implementing the Control Measures
•
EPC/O&M shall inform all relevant personnel about the control measures
being implemented;
•
EPC/O&M shall provide adequate supervision to ensure that the new control
measures are being implemented and used correctly;
•
Any maintenance in relation to the control measures shall be defined in the
Work Procedures;
•
•
Risk will be reduced to ALARP. Consideration shall be given to;
o
Legal requirements;
o
International standards/guidelines;
o
Availability of resources;
o
Costs and benefits; and
o
The status of scientific and technical knowledge.
The purpose of the implementation plan is to document how the chosen
options will be implemented. These plans shall include;
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o
Proposed actions;
o
Resource requirements;
o
Responsibilities;
o
Timing;
o
Performance measures; and
o
Reporting and monitoring requirements.
10.6.5 Monitor and Review
Monitoring and review is an on-going process and will not be considered as a oneoff activity.
•
Ongoing
review
is
essential
to
ensure
that
everything
planned
is
implemented. It is imperative that the Risk Management be considered a
continuous process since the environment is always changing, e.g. the
consequences of an event could change over time and/or the suitability or
cost of mitigating the event;
•
Monitoring
and
review
also
involves
learning
lessons
from
the
Risk
Management Process; and
•
To compare the plans with the actual implementation provides a good
performance
measurement.
Such
results
shall
be
incorporated
into
Performance Management, Measurement and Reporting System.
10.6.6 Record the Risk Management process
Procedures will be established and maintained to document the process and results
of risk assessment and management. The recording shall include the following:
•
Statutory requirements and codes applicable to the HSE aspects relevant to
operations;
•
Identified hazards and effects in relation to HSE, Production, Services,
Properties, and company reputation;
•
Established risk criteria;
•
Risks of consequence severity and likelihood of identified hazards; and
•
Risk reduction measures.
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10.7 ESMS Grievance Mechanism
This section describes the proposed process by which people affected by the
project in the nearby areas (e.g. Aliedi village, Opuyo, Soroti) can bring their
grievances to the company for consideration during the construction, operational
and decommissioning phases. This proposal will be consulted with the relevant
stakeholders during the ESIA consultation stage, the lenders, NEMA and the ERA, and
the resulting version will be included in the project’s ESMS. This section describes who
will receive public grievances, how and by whom will they be resolved, and how will
the response be communicated back to the complainant. This section draws heavily
on the IFC good practice note “Guidance For Projects And Companies On
Designing Grievance Mechanisms”.
10.7.1 Characteristics of the Grievance Mechanism
It is best practice for the grievance mechanism to clarify at the outset who is
expected to use the procedure, and to assure people that there will be neither costs
nor retribution associated with lodging a grievance. The entire process (i.e. how a
complaint is received and reviewed, how decisions are made and what possibilities
may exist for appeal) will be made as transparent as possible by putting it into
writing, publicising it and explaining it to relevant stakeholders.
Submission of grievances during the construction and operational phases will be
possible in writing, online or verbally at the project site. A register will be kept of the
complaints and the responses provided. These methods will be publicised at the site
gate, at the company website and on public buildings used by the community (e.g.
the school in Aliedi Villige and in Opuyo). All information about the grievance
procedures, grievance forms, and responses will be available in the languages used
by the identified stakeholders, and could include Ateso, Kumam and Swahili. Access
to the mechanism will be free of cost.
Following best practice, consultations on design of the grievance mechanism will
provide for inclusion and participation of women and facilitate women’s access to
the mechanism. The community liaison officer will ensure that staffing of the
company grievance mechanism includes female staff, and that everyone in the
community liaison team is aware of and sensitive to the role of women in local
society and the specific issues they face.
Coming out with a complaint can pose risks for people, especially if it concerns such
issues as corruption, misconduct, monetary compensation, or if it interferes with local
social norms, including gender norms. The grievance mechanism will include
precautions such as a clear policy of non-retaliation, measures to ensure
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confidentiality and safeguarding of personal data collected in relation to a
complaint, and an option for complainants to submit anonymous grievances.
Handling grievances encompasses a step-by-step process as well as assigned
responsibilities for their proper completion. This process is outlined below.
10.7.2 Scope
The scope of the grievance mechanism is to cover all the stakeholder problems and
concerns regarding the project activities and the implementation of the mitigation
and compensation measures outlined at the ESIA stage. Generally, all claims from
affected communities should be accepted and no judgment made prior to
investigation, even if complaints are minor. However, according to the IFC best
practice guidelines, the following claims should be directed outside of project-level
mechanisms:
•
Complaints clearly not related to the project: It is sometimes difficult to
determine which issues are related to the project and which are not. If in
doubt, employees designated to receive grievances should accept the
complaint and assess its legitimacy;
•
Issues related to governmental policy and government institutions;
•
Complaints constituting criminal activity and violence: In these cases,
complainants should be referred to the justice system;
•
Labour-related grievances: A separate mechanism should be established
through human resources policies, unless it has to do with labour conditions
and other factors covered by the EP and IFC Performance Standards;
•
Commercial disputes: Commercial matters should be stipulated for in
contractual agreements and issues should be resolved through a variety of
commercial dispute resolution mechanisms or civil courts.
10.7.3 Publicizing Grievance Management Procedures
The grievance mechanisms will be publicized in the following ways:
•
Printed materials: These materials can be leaflets or posters, and will be made
available at the project gate and on public buildings used by the local
community, such as the schools in Aliedi and Opuyo (if this locations are
considered suitable by the community during the ESIA consultations);
•
Online: The grievance mechanism will be publicised in the project’s
webpage;
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The information provided online and on printed material will be available in all the
relevant languages (e.g. Ateso, Kumam and Swahiliand) will include at least the
following:
•
What project-level mechanisms are capable of delivering, as opposed to
other resolution mechanisms;
•
Who can raise complaints;
•
Where, when, and how community members can file complaints;
•
Who is responsible for receiving and responding to complaints, and any
external parties that can take complaints from communities;
•
What sort of response complainants can expect from the company, including
timing of response; and
•
What other rights and protection are guaranteed.
10.7.4 Submitting a complaint
The grievance mechanism will allow for complaints to be filed in several ways:
•
Through the post;
•
Online: By email and/or through an online form;
•
At the project’s gate:
o
Written complaints will be received at the project’s gate –therefore the
security personnel have to be aware and trained to deal with the
compliant appropriately.
o
For complainants that are illiterate or prefer to submit their complaints
verbally, the community liaison officers will meet them at the company
gate (or could offer them to go into the company offices, depending
on the security restrictions) and will take notes of the details of the
complaint and read the notes to the compliant to confirm that the key
elements of the complaint have been captured.
10.7.5 Receiving Complaints
The company will publicly commit to a certain time frame in which all recorded
complaints will be responded to and to ensure this response time is enforced. This
helps reduce frustration by letting people know when they can expect to be
contacted by company personnel and/or receive a response to their complaint.
Below are some rules that will be followed by the receipt procedure for grievances:
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•
All incoming grievances will be acknowledged as soon as possible. A formal
confirmation—with a complaint number, or other identifier, and a timeline for
response— assures the complainant that the organization is responding
properly, and it gives the project a record of the allegation. If a complaint is
received in person, a good practice is to acknowledge it on the spot;
•
If a more complex investigation is required, the complainant should receive
an update explaining the actions required to resolve the complaint, and the
likely timeline;
•
The company should explain up front what claims clearly are outside the
scope of the mechanism and what alternative avenues communities can use
to address these potential issues.
10.7.6 Reviewing and Investigating Grievances
The approach to the resolution process is just as important as the outcomes.
Acknowledging the issues and initiating a dialogue with communities is the first step
towards a satisfactory solution. If problems are complex and solutions are not
straightforward, on-going discussion and joint monitoring of issues with communities
will help prevent a conflict from escalating and will add transparency and
legitimacy to the system.
To ensure that all grievances are adequately investigated and closed out, a
grievance log will be kept, documenting all the actions taken to address each
grievance.
An extensive investigation may be required when grievances are complex and
cannot be resolved quickly. The company will take full responsibility for investigating
the details of grievances coming through its grievance mechanism, following the
principle of “no cost to communities”.
In cases of sensitive grievances - such as those involving multiple interests and a
large number of affected people - it may help to engage outside organizations in a
joint investigation, or allow for participation by community structures, civil society
organizations or NGOs, or local authorities, if the complainants agree to this
approach.
It may be required for an investigation team to be appointed. If the investigation
team is formed internally, issues that will be taken into consideration include
potential conflicts of interest, qualifications, gender composition, and budget.
Meetings with complainants and site visits can be useful for grievance investigation
and will be undertaken, as appropriate.
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10.7.7 Grievance Resolution Options and Responses
One of the potential advantages of a grievance mechanism is its flexibility. Rather
than prescribe a specific procedure for each particular type of complaint, it a list of
possible options appropriate for different types of grievances will be provided.
Options may include altering or halting harmful activities or restricting their timing
and scope, providing an apology, replacing lost property, providing monetary
compensation, revising the community engagement strategy, and renegotiating
existing commitments or policy.
The grievance investigation team will provide a proposal to resolve the complaint,
which will have the backing of the Senior Management. The community liaison
officer will then contact the complainant to get an agreement on the proposed
solution.
If all parties accept the proposed resolution, the agreed actions will be
implemented in the established timeframe. If the complainant does not accept the
proposed resolution, the company should re-assess the situation and make sure that
all alternatives within the grievance mechanism are explored. If agreeing on a
solution acceptable to all parties is not possible within the grievance mechanism,
the compliant will be referred to external mechanisms.
Following close-up of a complaint, it is good practice to collect proof that the
necessary actions have taken place. For example:
•
If the issue was resolved to the satisfaction of the complainants, get a
confirmation and file it along with the case documentation;
•
Take
photos
or
collect
other
documentary
evidence
to
form
a
comprehensive record of the grievance and how it was resolved.
10.7.8 Monitoring, Internal Reporting, and Evaluation
The effectiveness of the grievance mechanism and the efficient use of resources will
be monitored and reported upon. In this way, trends and recurring problems can be
identified and resolved before they become points of contention. Monitoring helps
identify common or recurrent claims that may require structural solutions or a policy
change, and it enables the company to capture any lessons learned in addressing
grievances. Monitoring and reporting also create a base level of information that
can be used by the company to report back to communities.
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10.7.9 External Reporting of Newly identified Impacts, Changes to the ESMP and
Grievances
During construction, operation, and decommissioning periodic reports will be
provided to the Affected Communities describing progress with implementation of
the project Action Plans on issues that involve on-going risk to or impacts on
Affected Communities and on issues that the consultation process or grievance
mechanism have identified as a concern to those Communities. If the management
program results in material changes in or additions to the mitigation measures or
actions described in the Action Plans on issues of concern to the Affected
Communities, the updated relevant mitigation measures or actions will be
communicated to them. The frequency of these reports will be yearly, and they will
be published online.
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11 References
AccountAbility, the United Nations Environment Programme, and Stakeholder
Research Associates (2005) The Stakeholder Engagement Manual Volume 2: The
Practitioner's Handbook On Stakeholder Engagement;
BirdLife International (2012) IUCN Red List for birds. http://www.birdlife.org.
Beentje, H., Adamson, J., and Bhanderi, D. 1994. Kenya Trees, Shrubs, and Lianas.
National Museums of Kenya, Nairobi, Kenya.
Department of Immigration and Citizenship (2008) Stakeholder Engagement
Practitioner Handbook. Australia;
Glasson, J. (1994) ‘Life after the Decision: The Importance of Monitoring in EIA’, Built
Environment, 20 (4): 309-320
IFC (2007) The Stakeholder Engagement Manual – Volume 1: The Guide to
Practitioners Perspectives on Stakeholder Engagement. Stakeholder Research
Associates;
IFC (2009) Addressing Grievances from Project-Affected Communities. Guidance For
Projects And Companies On Designing Grievance Mechanisms. Good Practice
Note;
IUCN. (1999). IUCN Red List categories. World Conservation Union
J. Burt. Davy (1938). Classification of Tropical woody vegetation types.
Kingdon, J. (1974a). East African Mammals. An Atlas of Evolution in Africa. Vol II Part
B (Hares and Rodents). Academic Press, London.
Kingdon, J. (1974b). East African Mammals. An Atlas of Evolution in Africa. Vol II Part
A (Insectivores and Bats). Academic Press, London.
Meine, C.D. and Archibald, G.W. (Eds) (1996) The cranes:- Status survey and
conservation action plan. IUCN, Gland, Switzerland, and Cambridge, U.K and
Northern
Prairie
Wildlife
Research
Centre
Online.
Available
at:
http://www.npwrc.usgs.gov/resource/birds/cranes/index.htm
Namaalwa, J. 2006. The growth, use and management of woodland resources in
Uganda. PhD Thesis, Norwegian University of Life Sciences (UMB), Norway.
Slade, Gordon, and K. Weitz. 1991. Uganda Environmental Issues and Options.
Unpublished Masters Thesis, Duke University, Durham, North Carolina, USA.
US EPA (2007) Guide to Stakeholder Engagement;
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ANNEXES
Annex 1: Discussion of the Land Acquisition Process
Annex 2: Livelihood Restoration Plan
Annex 3: Soil and Water Analysis Results (baseline surveys)
Annex 4: Calibration Certificates (baseline surveys)
Annex 5: Plants lists and forms at the proposed Solar PV area (baseline surveys)
Annex 6: Socioeconomic baseline questionnaire (baseline surveys)
Annex 7: Stakeholder Consultation Letter (stakeholder engagement)
Annex 8: Stakeholder Meeting Hand-out (stakeholder engagement)
Annex 9: Attendance lists for stakeholders consultations (stakeholder engagement)
Annex 10: ACCESS Environmental Policy (ESMS)
Annex 11: TSK Management Policy (ESMS)
Annex 12: TSK Management Manual (ESMS)
Annex 13: Factory Inspection Procedure: Canadian Solar Manufacturing, Jiangsu
Factory, China (ESMS – LCA impacts)
Annex 14: Attendance sheet for the land demarcation and inspection (Land
Acquisition Process)
Annex 15: Sample application for grant of freehold (Land Acquisition Process)
Annex 16: Non Objection Certificates for the lease of the land – Spouse and eldest
child
Scoping Report
Page 174 of 174

Now - Access Power MEA

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