Buliisa Districts

As part of Advancing Women’s Land Inheritance and Property Rights Project objective of empowering women with knowledge, skills and information to demand for their land rights, their social-economic benefits in oil and gas, and to participate in decision making processes in relation to the developing oil industry, CESCRA has since January 2015 been training women groups in Kyangwali sub-county Hoima district and Buliisa districts; over 120 women and 20 men have been trained since January 2015.

CESCRA introduces a project in the oil areas of Buliisa and Hoima districts, to contribute to increased knowlege and skills on women’s land and property rights. The project is tittled “Advancing Women’s land, Inheritence and Property Rights, and Protecting the Social-Economic Benefits of Women in the Oil and Gas Industry”. Since January 2015, CESCRA has been implementing this project; working particulary with the Women groups and closely with the local leaders in Kyangwali sub-county Hoima district and Ngwedo sub-county in Buliisa district.


CESCRA together with CRED organised a national dialogue meeting in Hoima on the 7th November 2018 on behalf of the Albertine land platform (ARLP) and invited various stalk holders. This meeting’s main objective was to capture views of the communities about the TILENGA Oil Project on (ESIA) Environment Social Impact Assessment report that was given to National Environment Management Authority (NEMA) from the joint venture partners that is Total E&P Uganda (TEPU) and Tullow Oil Uganda (TOUP)

What did we Achieve?

Stakeholders were able to critic the Environmental and Social impact assessment (ESIA) report by Total to NEMA and came with specific recommendations to NEMA depicting the position of grassroots communities as in the table below:







Stake Holder Engagement

consultation and participation


Vol 1, Chapter 5, application of the principle of Free Prior and Informed Consent

The communities are concerned about the non-representative consultations with the Persons Affected by the Project (PAP), and therefore lack information about the project within the community.

Whereas stakeholder engagement relied on FPIC (page 5-3), there is no evidence that:

        i.            That the PAPs got information prior to consultation,

      ii.            That PAPs gave their consent to the project

The ESIA should propose mechanisms for meaningful engagement and participation  of the community through ESIA implementation, monitoring and evaluations


Put in place and roll out an awareness action plan targeting communities.

Pre-project community sensitization



Communities are wondering whether they will have a role to play in the implementation of ESIA. If so, under what form of arrangement.

Propose community awareness through radio

Propose a structure for formal engagement of communities in implementation and monitoring of ESIA alongside formal monitoring structures provided for by the law.

Terrestrial wildlife

Wildlife outside protected areas

Vol 3: Table 13-1, page 13-5

ESIA puts focus on wildlife in PA yet there is going to be substantive habitat destruction for the said wildlife.

In the assessment of potential impacts on terrestrial ecosystems, wildlife on community land (and not community conservation management areas such as Kaiso) is not listed as a receptor (potential sensitivity). Wildlife outside protected areas is a key socio-economic resource, as provided for by the Wildlife Policy, 2014.

The wildlife in the area where the industrial park will be constructed will definitely relocate to neighboring areas increasing human-wildlife conflicts. May also trigger transfer of diseases from animals to people

i)      Review Volume 3 of the ESIA to include wildlife outside protected areas as a potential sensitivity.

ii)    Identify and put in place mitigation measure to protect ‘animal connectivity corridors’ connecting wildlife on community land and PAs.

iii)  The Proposed industrial park has been habitat for such animals. JVP should invest in conserving wildlife outside PA by planting indigenous trees in collaboration with communities.

Loss of vegetation leading to erosion


With increased open spaces, there will be increased surface runoff. Whereas erosion may be controlled in the project area, it might not be controlled in the communities leading to loss of soil fertility, low agricultural production, food insecurity and malnutrition.

 Plant trees and practice ago-forestry


Promote sustainable land management practices


Promote better agricultural system

Loss of benefits from plants and animals

Vol 3

Habitat destruction will have direct impacts to communities such as:

-    Loss of herbs resulting into increased cost of medication

-    Loss of firewood resulting into walking long distance in search of firewood hence risking sexual and gender based violence, increase inter-community conflicts over resources

-    Loss of poles and grasses for construction of houses

-    Loss of wild fruits (tubers, grapes, and vegetables) compromising nutrition.

-    loss of Sacred sites


Funding for re-afforestation and afforestation is required within the communities

Social and economic

Livelihoods analysis in the project area

Vol 4 Section (16-126)  and (page 16-194)

The community is concerned that a livelihoods analysis of the study area was undertaken indicating that they are ‘mainly subsistence based and are primarily centred on agricultural activities, livestock rearing, fishing and natural resource exploitation, with some employment generated by the tourism industry’. The ESIA does not make mention of the potential increase in cost of living despite a shallow mention of the living threshold on Page 16-158. There are speculations about the lucrative nature of oil developments causing unprecedented increases in pricing of commodities. For example, in Kasinyi, Ngwedo sub-county the cost of heifer increased from 0.5m to 1m after the rest of the community members learnt that the CPF PAPs had been compensated with cash by Total E&P and MEMD.

Displacements will remove the communities from nearby social services like schools, churches, markets, hospitals

Review the analysis of social impacts to include abrupt changes in cost of living and design appropriate mitigations that guard against impacts of that nature.


Train the community on livelihood adaptation as result of displacement

Land tenure

Vol 4: Section 16.6.7 Land Tenure and Land Use (Page 16-161)

The community is concerned about the impact of change from traditional customary land tenure system (where ownership of land is by tribes, clans and families) to individualization of land yet this land is a resource and property to families/clans. This is leading to loss of cohesion at family, clan and tribe level. There is no management option proposed.

1.       Need to provide a solution to the potential impact arising from the change in land tenure system


2.       Leasing land as opposed to land acquisition should be presented as a mitigation measure to land conflict.


CSR arrangements or requests or benefits

Vol 1 (p. 5-20)

In the past phase of oil development, CSR related benefits were informal arrangements between companies and communities. Chauvinistic political leaders manipulated this either to benefit themselves or their regions.  Now a formal mechanism is proposed in this ESIA but details of how it will function are not provided.

Provide information on how CSR will function. Effort should be made to align CSR to specific impacts so that it is considered a mitigation measure rather that a casual arrangement.

Infrastructure development

Unnecessary infrastructure


The community is concerned about proposed volume of infrastructure and whether the proposals are cost effective. Some are permanent and others are temporally. There will be loss of habitat for flora and fauna. There is extravagancy in the design of railway lines, roads, airports, staff accommodation and these escalate the impact of the project on the environment.

The ESIA should be reviewed to reduce the number of proposed infrastructure (railway lines, roads, airports, staff accommodation) and demonstrate cost effectiveness. For example limit roads to upgrades of existing marrum roads and tourism roads where they will pay access fees.

Water resources utilization

Volume of water abstracted

Vol 2.  (section 10.11.6) Page 10-90


The communities are concerned about the lack of clarity by the JVP and drafters of ESIA to inform the community of volumes of water to be abstracted from the lake and aquifers. Districts like Buliisa are already declared as water scarce districts and this is an additional scare. Will petroleum development leave enough water for current and future generations? Won’t there be conflicts/war over water utilization?

ESIA should clarify water demand, at least monthly demand to enable other water users/stakeholders plan appropriately. These will also alley fears of other actors.

Communities are concerned about the potential/possible contamination of water sources during abstraction and use in case of any eventuality (the lake, boreholes, springs). The feared impacts are diseases and miscarriages. 


ESIA should provide management options for residual impacts – in the event that there are contamination at water sources, bore holes and wells where communities fetch water.

 Empower communities to identify and reporting any changes in contamination and indicators of pollution.

Why is it that there were no tests carried out to benchmark water quality in springs from where communities draw water? 

ESIA should take samples from springs.

Whereas localised mitigation measures are provided against pollution, in the event that it occurs, trans-boundary measures are not provided in case the effect crosses districts (through rivers) and countries (lake Edward)

Review ESIA to include measures

Environment and livelihoods

Concern over air quality

Vol 2 Section 6.7.1

The impact assessments misses out on the fact that pollutants in the air (dust, particulate matter, aerosols among others) present a potential impact in terms of causing acidic rains that in turn affect  aquatic life (fisheries), agriculture (reduced yield) and soils (soil fertility). The ESIA is silent about this nexus.

 There will be health issues, respiratory diseases affecting communities directly

 In addition this presents an opportunity  to escalate catastrophes related to climate change which directly impact on communities

Review the analysis to include this direct impact on communities and propose mitigation measures.


Tree planting


Air quality assessments


Air purification plan

Human rights

Rights and basic needs of the communities

Vol 4. Section, chapter 16 page 16-270 and 16-271, Table 16-56

The potential impact concentrates on the community needs (social services) rather than community rights in general. This will affect the enjoyment of rights that will be overshadowed by social needs.

Review the table to establish rights-based impacts rather than needs-based impacts.


Compensation for land still a challenge

Vol 5, Page 5-32

Communities are still embroiled in discussions relating to fair compensation and these issues are not fairly captured in the ESIA.

®      The right to fair compensation is still lacking (currently some PAPs are not yet compensated and yet project activities are about to commence).

®      Earlier cases of gender-based challenges to compensation are not referred to and therefore no potential measures proposed.

®      Financial literacy training to people receiving cash compensation  is not the major solution to “domestic violence” (p. 5-26)

Drafters of the ESIA should review proposals for compensation in consultation with the PAPs.

Employment expectations:

Employment and Economic Development

Vol 4:

There is an observation that there are limited jobs in the sector. Most jobs will be skilled jobs. The concerns are that:

        - Only form of employment for the ’local’ communities is ‘unskilled’ and no clarity about training opportunities for them to qualify for other categories of jobs is proposed.

      -   Gender dimension of employment is not addressed. The question is ‘what will be set to promote gender balance?’, “how will they curb issues of child employment in the sector?”

      -   Employees of sub sub-contractors will work under different terms and condition but on the same site and this reflects double standards.

       -  Cultural changes due to a mix of workers with different culture and behaviour  resulting into tribal conflicts

 The investment is for a long period and therefore needs to design mechanisms for training and capacity building for local people to take up skilled jobs, take care of gender concerns and balance terms and conditions to level subcontractor employees with those of the industrial park.





  Propose mechanisms for bridging new comers with local community


Occurrence of natural disasters

Not sure where to find this in the document

The project area is prone to earth quakes and the communities are concerned whether this has been factored into the ESIA

 The neighboring DRC is a hub of diseases such as hemorrhagic fever, Ebola among others. Locally, there are disease outbreaks such as cholera. There might also be new disease (oil related) resulting from spillages and contamination.

 These can sweep or wipe out vulnerable communities now that some are living in settlements (in Kyakabuga) similar to camps.

Propose Disaster Management Plan to take care of these eventualities.




Noise,  vibration, light in excess of what the communities are used to


Vibration caused by moving tracks will cause cracks in buildings as it happened in 2014 in Kisomere village

Adequate compensation to victims.


There will be associated noise pollution for communities

Use of modern sound proof technology.

Where there are organised settlements, construct embankments to prevent sound reaching the communities

Disruption of animal movements and breeding

Minimise light and sound

Low fish production due to noise

Construct fish ponds for communities far from the project area



Values and Commitments

  • Equality of all persons including gender equality and social inclusion
  • Transparency and accountability in all levels of engagements
  • Democracy
  • Participation of all levels of society
  • Engagement through mutual dialogue
  • Respect for all voices of society and actors
  • Models of excellence in all CESCRA undertakings