Monitoring and Inspection of Environment Aspects of Oil, Gas and Minerals in Uganda

Recognising that Uganda is endowed with a wide range of extractives resources in the form of Oil, Gas, minerals as well as Geothermal Resources. Uganda’s vision 2040 and the National Development Plan III aim at building a strong mining (including Oil & Gas) industry that will contribute to the country’s economic and social development.

The regulation of environmental aspects of oil and gas activities in Uganda is essential for promoting sustainable development, protecting public health and safety, ensuring fair socio-economic benefits, and upholding legal and ethical responsibilities. These regulations help balance the exploitation of natural resources with the need to preserve the environment and improve the quality of life for current and future generations. Specifically, during the Financial Year, the Authority played its assigned role of supporting the extractives sector through, review of environment assessment and compliance monitoring and inspections, that is, review of ESIA reports and Environmental Audit (EA), and development of critical regulatory tools.

Oil & Gas

The development phase of the country’s Oil & Gas Sector is now fully under implementation – in line with the third National Development Plan (NDP III) which lists several development strategies for the period 2020/21-2024/25 and prioritized the fast-tracking of interventions aimed at facilitating the production and processing of oil/gas as well as mining and mineral beneficiation. With the country targeting first oil in 2025, there has been an exponential increase in the level of activity in the Albertine Graben. Accordingly, a lot of work is ongoing with the Tilenga Project (Bulisa and Nwoya), Kingfisher Project (Kikuube & Hoima) and the East African Crude Oil Pipeline (EACOP) Project covering 298km through 10 districts; yet all this has serious implications on the environmental (and social) resources. NEMA has had a close monitoring and inspection of these developments to ensure that they are done in a sustainable manner.

Mining & Geothermal Developments

Uganda’s mining and geothermal sector is steadily growing, a lot of exploration and mining is taking place. With the opening of the tin processing plant in western Uganda, there has been an increase in ESIA reports in exploration and mining of tin especially in the areas of Ntungamo and Mitooma where most deposits are. Iron ore and critical minerals like lithium, Rare Earths and graphite are also taking shape. Sand mining and other extractives such as marrum and stone quarries have also continued to come in. Sand mining is mainly in the areas of Rwampara and Mpigi, Marrum in Bulisa and Wakiso districts and stone quarries in Mukono District.

Artisanal and Small-Scale Miners continue to exist though largely not regulated. These are mainly in stone quarries, gold and tin mining, there no ASMs in critical minerals probably due to their location and the technology requirements to mine such minerals. The Ministry of Energy and Mineral Development is now focusing on sensitisation of the ASMs to mainly form associations and submit requests for mining licences under the new Mining and Minerals Act of 2022 and other regulations under this act like the Artisanal and Small-Scale Mining Regulations of 2024. NEMA has sensitised these groups in environment management to attract them to carry out ESIA studies.

Geothermal development is still in the exploration development, the advanced one being in Panyimur which is at Deep Exploration Wells Development. Other potential areas like Kibiro and Buranga are still at Thermal Gradient Wells development, however, their ESIAs are still pending due to many factors including stakeholder consultation and the sensitivity of the proposed areas. Geothermal potential has also been established at Kibiro in Hoima District, Panyimur in Pakwach District, Buranga in Bundibugyo District, and Katwe-Kikorongo in Kasese.

Monitoring and Inspection of Albertine Graben Activities

1. Oil Spill Contingency Planning. NEMA has spearheaded the establishment of an oil spill contingency framework that is tiered, to be commensurate with the level of risk and resources required to respond to oil spills.
   • Tier-1 Preparedness (National Level). The Authority coordinated the implementation of the National Oil Spill Contingency Plan (NOSCP) by facilitating capacity building programmes for regulatory entities. Officials of NEMA, PAU, UWA, OPM, Buliisa DLG, Hoima DLG, and Kikuube DLG attained IMO Level -1 training (organizing response teams safely, minimizing environmental damage, and using effective strategies and equipment for oil spill response). A Training of Trainers (TOT) was also conducted for these institutions to enable knowledge and skills transfer on the management of oil spills.
   • Tier-2 Preparedness (Lead Agency). The Authority supported the development of Tier-2 Oil spill contingency plans for the frontline district of Hoima, Kikuube and Buliisa. The international oil companies (IOCs) operating in the country (CNOOC and Total Energies) prepared OSCPs for their operations in Uganda. The Tier-1 plans were submitted to the Authority as required by the Law and are under consideration.
2. Strategic Stakeholder Collaboration. The Authority facilitated several meetings aimed at establishing an Oil Spill Mutual Aid Group (OSMAG) and strengthening capacity to handle oil spills at national level including initiation of review of the international frameworks to incorporate/include elements of management of oil spills. NEMA hosted a delegation from the National Environment Management Council (NEMC) of the United Republic of Tanzania – led by the Director General of NEMC, Dr. Samuel Gamwaka Mafenga. The team was hosted by the Executive Director and guided a trip to EACOP route through the districts of Hoima, Kikuube, Kakumiro, Kyankwanzi, Mubende, Gomba, Ssembabule, Lwengo, Rakai, and Kyotera. The major activities within the EACOP project were in respect of the RAP activities.
3. Capacity Building. In FY2023/2024, NEMA trained officers from 14 DLGs (Hoima, Kikuube, Kyankwanzi, Lwengo, Gomba, Ssembabule, Rakai, Kyotera, Ntoroko, Nwoya, Buliisa, Masindi, Mubende, Kakumiro); to build capacity on effective monitoring and enforcement of oil and gas development. In addition, a team of government officials (NEMA, PAU, OPM) was supported to undergo hands-on-training on oil spill response in Norway and later to Kisumu in Kenya.

1. Albertine Graben and EACOP Sensitivity Atlas. The Authority developed sensitivity atlas and carried out sensitivity mapping in the Albertine Graben and other areas to determine the potential for significant environmental impacts. Environmental sensitivity analysis provides a framework for systematically and objectively determining the potential for significant environmental impacts. The higher the natural or acquired sensitivity of the receiving environment, the less capable it is to cope with human-induced change. Sensitivity mapping of the various types of environments and resources potentially exposed to oil spills enables the identification of the most sensitive sites or resources, thus providing a basis for the definition of priorities for protection and clean-up, and information to plan the best-suited response strategy.

The Authority through its regulatory, supervision and monitoring mandate carried out a specialized monitoring and supervision to the oil, gas and mining projects in the country for effective management of the environmental aspects of extractives in the country. Compliance monitoring and inspections for the extractives developments were carried out for key mining projects (sand mining, Wagagai Gold mine, Makuutu Rare Earth Elements, Iron ore mining, Gold mining in Ibanda/Rubirizi, Limestone in Moroto/Dura, Sukulu Phosphate mining, Marble mining in Moroto, Pozolana mining, and Artisanal Gold mining in Mubende/Kasanda/Busia); while the environmental monitoring of Oil & Gas projects in respect to the Kanywataba area, the Kingfisher field development area, Tilenga Project and East African Crude Oil Pipeline (EACOP), was also undertaken during the year.

The Authority also monitored the geothermal exploration drilling (Temperature Gradient Holes) in Panyimur; while the developments in Kibiro continued to be stayed/suspended (under the Authority’s instruction) following the blow out incident of 2020.

Emerging Compliance Issues in the Albertine Graben Area

1. The Kingfisher Development Area (KFDP) operator has not done proper reporting – especially on waste management (both in the statutory reports and in the environmental audit). Relatedly, poor general waste management practices were observed at various locations within the KFDP.
2. Absence of systems/equipment for continuous monitoring of air quality as require
3. The Kingfisher Well pads (1, 2 and 3) were constructed within the Lake Albert Buffer Zone (within less than 200m) and very prone to flooding as was the case in 202
4. The escarpment road in the Kingfisher area has a delicate hilly terrain and needs continuous monitoring. Some members of the Buhuuka community had started extracting aggregate from the rocks along the road but these have been stopped. Nonetheless, rocks keep falling from the road boundaries and thus pose a serious hazard to road use
5. In Kingfisher, there were inadequate measures put in place to protect the project impacted shoreline of Lake Albert from effects of erosion which results into siltation of Lake Albert, especially at well pad-1 contrary to condition 2 (vii) of the ESIA Certificate of approval NEMA/ESIA/13178.
6. Records availed onsite indicated that some of approvals/permits expired g., the wastewater discharge permit H01521140/3WDJW2019 for Bugoma drilling camp expired on August 11, 2022, Abstraction permit for Bugoma Drilling camp H01503343/15WHDW2019 expired on 2nd April 2021, License to own and operate an STP WD/HW/125/2018 expired on 21st November 2019; and these need to be renewed as appropriate.
7. Environmental monitoring records indicated that some physical chemical parameters such as Electrical Conductivity (EC), Total Suspended Solids (TSS), Total-Nitrogen, Nitrates, Turbidity, EC, Total Dissolved Solids (TDS), Total-N, Total Phosphate, Ammonium-N, and Chloride were above permissible limits in the National Environment (Standards for Discharge of Effluent into Water or Land) Regulations, S.I No. 144/202
8. There was poor management of chemicals evidenced by chemical spills including at well pad-3 and near the CPF area.
9. Communities continue to establish unplanned structures within the project areas – which not only endangers them but also exposes the project to other risks.
10. With the EACOP project coming into stream, the districts of Kakumiro, Kyankwanzi, Mubende, Gomba, Ssembabule, Lwengo, Rakai and Kyotera will urgently need to have the respective Tier-2 OSCPs as they too now become frontline stakeholders.