The Honorary Wildlife Wardens reviewed the EIA Study Final Report (March 2008) and the Environmental Management Plan and presents the following issues for deliberation at the public hearing session.
- The Oil production with respect to the protected Areas in the Albertine Rift
The Honorary Wildlife Wardens support the oil production in the Albertine Rift for the sustainable development of Uganda. It notes that the oil rich zone in the Albertine Rift is also a rich biodiversity zone for Uganda and the global community. Further, it notes that oil production will be undertaken alongside the biodiversity conservation and management objectives for Uganda and the global community. Honorary Wildlife Wardens wish to take the opportunity of this Oil development to call upon the Country to manage the oil production for the benefit of the country with minimal impact on the rich biodiversity. It further calls upon UWA and other Lead Agencies ( NFA, NEMA, Wetlands Department, Water Resources Department, among others) to provide the required technical leadership and cooperation in ensuring that oil business does not undermine the integrity of biodiversity resources and integrity of the Protected Areas in the Albertine Rift. In this regards, the Honorary Wildlife Wardens request that the Agencies mentioned above develop and publish a Policy and Guidelines for management of biodiversity and protected areas in the Albertine Rift to address Oil production in the region. It is further recommended to develop and publish the proposed Policy and Guidelines before oil production starts, i.e., before end of 2008.
- The Proposed Establishment of EPS in Kabwoya Wildlife Reserve
The Honorary Wildlife Wardens, having reviewed the Selection criteria for constructing the EPS in Kabwoya Wildlife Reserve (section 1.5 page VIII of the EIA Report) and the likely impacts of the location (Section 1.7, page XI of the EIA Report) and notes the following:
- a) the selection criteria assessing the suitability of the Kabwoya Wildlife Reserve is weak in considering the environmental impacts; the criteria favours the capacity of Tullow to manage environmental effects as opposed to identifying the environmental impacts themselves.
- b) approximately 500mX500m size of land within the Kabwoya Wildlife Reserve will be utilized for physical construction of the EPS. Additional land will be utilized to service the facility in form of transport, housing, etc;
- c) Kabwoya Wildlife Reserve is national heritage under custodian of Board of Trustees of Uganda Wildlife Authority with management responsibility entrusted through the Trustees to the Uganda Wildlife authority; and
- d) Kabwoya Wildlife Reserve presently is relatively less disturbed, human use of the reserve is minimum (livestock grazing and fishing activities are predominant human activities) and is evaluated as largely natural wilderness for the good of biodiversity conservation and future opportunities for tourism and other permissible biodiversity uses.
- Issues of Concern
3.1 Establishment of EPS in Kabwoya Wildlife Reserve
The EIA study should review the criteria for selecting the Kabwoya Wildlife Reserve for EPS with the view to strengthen the assessment of likely environmental and biodiversity impacts of the EPS. This will generate sufficient mitigation measures should the decision to establish the EPS in the Reserve be upheld. This recommendation should be mandatory before NEMAs decision on the EIA report is taken.
3.2 Role of managing Authority (UWA)
UWA as the Lead agency responsible for Wildlife and Wildlife Protected Areas should enjoy participation status in the Oil business to the level that guarantees its access and influence on the following decisions:
- a) Proposed establishment of EPS in the Wildlife Reserve
b) Approving the Environmental Management Plan as it relates to aspects of managing the Wildlife and Wildlife Reserve
c) Determining the loyalties and accruing benefits and their administration in relation to use of Wildlife areas.
d) Guaranteeing the integrity of Wildlife Protected Areas
In order for UWA to satisfactorily exercise its mandate, UWA must posses internal capacity or have means to access capacity to monitor and supervise Oil business in the Albertine Rift. We recommend that the Oil business take this responsibility of equipping UWA with the capacity to manage business related Oil industry or avail resources for UWA to acquire and deploy such capacity.
Accordingly, the EAI report should be revised to reflect the Status and role of UWA in the Oil business in order to address these issues.
3.3 Optimizing the benefits from Oil business
Under the Wildlife Act, the UWA is mandated to generate revenues from the Wildlife and to invest these revenues in managing the Wildlife and Wildlife estate. The Wildlife Policy envisage future scenario when UWA’s dependence on Government Treasury for financing its operations stops so that the organization is self financing.
Against this background, the Honorary Wildlife Wardens recommend that granting UWA authority to levy fees/loyalties and other charges to the Oil business as it relates to use of Wildlife estate. It is recommended that establishment of EPS and associated service facilities in Kabwoya Wildlife Reserve attract fees payable directly to UWA. This should be reflected in the economic analysis of the EPS before NEMA’s decision on the EIA report is taken.
3.4 Securing/Guaranteeing security of Biodiversity and integrity of Protected Areas in the Albertine Rift
Further to the recommendation regarding development of Policy and Guidelines for Oil production in the Albertine Rift (section 1), Honorary Wildlife Wardens recommend the following measures for securing the integrity of Kabwoya Wildlife Reserve.
- a) Reject the proposal to establish the EPS in the Wildlife Reserve on grounds of the gravity of its impact on the integrity of the Wildlife Reserve. Further, this proposal should be rejected on grounds of “no-harm” principle. Permitting establishment of EPS in the Wildlife Reserves sets a precedent that carries far reaching consequences and implications to the management to other protected areas in the Albertine Rift in light of Uganda’s Oil industry.
b) In the event that proposal to establish the EPS in the Wildlife Reserve is approved, the location selected should not be degazetted. We recommend that such operation should be permitted on leased land that reverts to UWA at the closure of Business. This recommendation is consistent with other businesses licensed by UWA (e.g. hotels) within Wildlife Protected Areas that operate under leased arrangements. Further, this recommendation will enable UWA implement recommendation #3.4.
c) In the event that the proposal to establish EPS in Kabwoya Wildlife Reserve is accepted, we recommend that Tullow responsibility to clean up and restore the Kabwoya reserve after its operations wind up should be legally “bonded” and interests for such bond entrusted to UWA. This will ensure that clean up and restoration activities will be implemented after decommissioning the EPS.
d) A time table for government of Uganda to ratify identified internal agreements (section 3.6.2 page 3-15 of EIA report) should be negotiated and committed before decision on the EIA report is taken.
Honorary Wildlife Wardens are conscious about the important role Oil industry is envisaged to play in the development of the Country and present these views in the best interest of sustainable development of Uganda.
Further, the Honorary Wildlife Wardens wish to take this opportunity to thank NEMA for permitting the presentation of this statement.
Sir/Madam Chair, the Honorary WildLife Wardens wish to assure you of their interest in this matter and to pledge their capacity to contribute to the current and future deliberations regarding management of Wildlife and Wildlife Protected Areas.