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dam-l IRN letter on Uganda dam/LS

The following is a letter IRN sent to IFC consultants who are studying the
hydropower potential of the Upper Nile. We commented specifically on one
project in Uganda, the Bujagali Falls dam, a private project proposed by
the US company AES. The IFC is a potential funder of the project. The
Parliament has repeatedly rejected the project, but the President continues
to push for it. There have been allegations of corruption on the project
that we are pursuing.



June 24, 1999

Clifford Brown
Acres International Limited
P.O. Box 1001
Niagara Falls, Ontario
Canada  L2E 6WI

By Email and Post

Dear Mr. Brown,

I have recently learned that Acres International Limited, in conjunction
with Kagga and Partners Limited, is undertaking a review of the various
options for meeting the growing electricity demand in Uganda. According to
notices in the New Vision, Uganda's main newspaper, this review will comply
with the International Finance Corporation's Safeguard Policies and
identify any significant environmental and social impacts associated with
potential hydropower projects on the Nile.

I am currently working for International Rivers Network on issues
surrounding the dams proposed for the Nile. My experience includes having
lived in Uganda from January 1997 through July 1998. I spent a good portion
of that time working in the area where the proposed dam would be built. The
comments herein focus on the impacts of the Bujagali Falls Dam, and will be
organised in the following manner:

I. Social impacts of the Bujagali Falls Dam
II. Natural and social environmental impacts of the project
III. Cultural impacts of the project
IV. Tourism impacts of the project
V. Energy demand issues in Uganda

I. Social Impacts of the Bujagali Falls Dam

The Bujagali Falls Dam would have a profound and permanent negative effect
on local communities. The "Source of the Nile" Corridor, stretching 25
kilometres south from the Owens Falls Dam to Kalagala Falls, is a heavily
populated area.  According to the Preliminary Environmental Assessment of
the Bujagali Falls Hydropower Project by Rust, Kennedy, and Donkin (1996),
the Upper Nile Corridor is "an area of intense agricultural land use
verging on land shortage." The report continues: "The east bank is located
in the Jinja hinterland where development pressures on land use are already

The Bujagali Falls Hydropower Project will directly affect 5,700 people,
according to the AES/ Nile Power EIA Draft Final Report. Local residents
have expressed dissatisfaction with the prospect of being resettled for the
project, and the availability of replacement land has yet to be fully
analysed and confirmed by project authorities or the government. There is
very little land available in the area. According to the Donkin report,
"replacement land may simply not be available locally."

As a result of this localised land shortage, communities will be divided as
a result of the project, with severe effects on these communities,
especially the Busoga on the East Bank. The Prelimary EIA clearly explains
the potential impact of dividing the Busoga:

        "Certainly Namizi Parish on the east bank appears a close-knit
community with an active village-level administration and splitting the
community would represent a significant socio-economic impact. The
community has been here for several generations and cultural values and
associations will need to be studied: graves and burial grounds are a case
in point. There will be acute social effects from land take in the area."

The resettlement debate has also brought to light several disconcerting
issues concerning transparency in the consultation process. According to
some potentially affected residents, promises were made by dam officials in
return for their support of the project. The Local Commissioner of Jinja
(LC5), Mr. Muwumba, brought this issue to the attention of the Minister of
Natural Resources, Honourable Sendawula. The two met with the Executive
Cabinet of the LC 5 in August of 1997 to discuss the siting of the proposed
Hydro Electric Power plant at 'Budhagali Falls'.

Below is a summary of Mr. Muwumba's statements, as documented in the
minutes of a meeting of the Busoga Lukiiko, whose members attended the
original meeting with Minister Sendawula. The Busoga adopted these minutes
at Bugembe in Jinja, on August 8, 1997 (we can send you a copy of this
document if you wish).

"The Chairman LC5, Mr. Muwumba, expressed great disappointment that
Government was taking the decisions to destroy Budhagali Falls by building
a Hydro Electric power plant without any discussions or consultations with
the Jinja District Local Government.

"The second disappointment was that the Nile Independent Power Directors
were going to the site talking to the people about the Power Plant, without
directly going through the authority of the area, i.e., the Jinja District
Administration. In order to persuade the people to support the dam, false
promises were made to give them: Free Electricity, free education, free
Hospitals etc. The LCV Chairman pointed out that such false promises, which
cannot easily be fulfilled, may in the future cause unrest and the burden
of keeping peace would fall on the shoulders of the Government including
the local authority.

"The third disappointment was that the Nile Independent Power was claiming
that: 'over 85% of the local residents are completely in favour of the
project and that the vast majority of Central, Local, and District
Political leaders are also in favour of this project.' It is obvious that
the people affected by the destruction of Budhagali Falls are more than the
few Local Residents in the area. This is a local and National issue. The
Chairman stressed that he was aware that Local District Political Leaders
are not in favour of destroying Budhagali Fall, BUT they are in favour of
choosing another site down the river on which to build the proposed Hydro
Electric Power Plant."

The above allegations that bribes of free electricity and free housing were
promised to residents who would support the project are indeed serious.
They call into question the claim by AES Nile Power, stated in the Bujagali
Falls Hydropower EIA, Draft Final Report, that based on stakeholder's
meetings "95% of respondents are in favour of the project." A detailed
independent inquiry needs to be made to discern what exactly residents
expect to receive in the wake of the project. How was this figure of 95%
reached? What exactly does "in favour" mean? Inflated expectations could
directly relate to residents' "approval" of the project.

Furthermore, prior to my joining IRN, Mr. Simon Mulongo, Regional District
Commissioner of Jinja, arrested me at his office in Jinja on July 8, 1998,
for openly speaking to local people about the potential impacts of the
project. Mr. Mulongo's ostensible reasons for putting me in jail were for
"disrupting law and order, inciting hatred among peace-loving Ugandans, and
sowing anti-Governmental sentiments among the local people, the local
authorities, and the cultural leaders." The New Vision  called the arrest
"authoritarian and undemocratic" in its lead editorial on July 11, 1998. In
fact, I had been approached by cultural leaders to relay their concerns
about the dam to project authorities and the press. I was only let out of
jail when I agreed to leave the country of Uganda the following day. Such
undemocratic actions indicate that the project has not been presented to
Ugandans through an open and transparent planning process.

II. Natural and Social Environmental Impacts of the Project

According to the official AES/NIP Environmental Impact Assessment, the
proposed Bujagali Falls Hydropower Project will permanently submerge 191
hectares of land, and "temporarily" destroy 100 hectares. This includes
highly productive agricultural land on the river's banks as well as islands
of extreme biodiversity. Trees on these mid-stream islands, which will be
lost to the reservoir, will reduce roosting sites for the 77 different bird
species found in the area, including 17 species of aquatic birds. Displaced
peoples will increase the stress on land near the reservoir, resulting in
further watershed degradation and deforestation and a loss in soil

As has occured elsewhere in Uganda, excessive weed and algae growth will
occur in the Bujagali reservoir. The most prevalent of these weeds, water
hyacinth, will clog dam outflow, as has occured at Owens Falls Dam, and
increase water loss through transpiration. The reservoir behind Owens Falls
Dam currently contains 1.25 million metric tonnes of water hyacinth, and
the weed doubles in size every two weeks. As a result of this vegetation
sinking and decaying on the floor of the reservoir, water released
downstream from the Bujagali dam turbines will be oxygen-deficient, and may
contain hydrogen sulfide and be of high acidity.

The creation of a reservoir will also increase the prevalence of tropical
diseases in the immediate area. Both malaria and schistosomiasis flourish
in stagnant water environments, and more cases can be expected if the
swift-flowing water of the Nile is dammed. Malaria is the overall leading
cause of death in the country. Increases in malaria deaths are not
mitigable and are unconscionable.

The creation of a reservoir could also permanently harm fisheries. The area
around Bujagali Falls supports a substantial number of subsistence and
commercial fisherman, who depend on the resource for both food and income.
The most commonly caught species are Nile perch and tilapia. On other parts
of the Nile, the Aswan Dam altered the biological cycle of the Nile perch
which had the effect of changing the taste and quality of the fish, and
thus reduced the commercial value of the catch. In addition, according to
the 1996 NEMA EIA, "local fishermen argued that the turbulence due to the
falls helped them catch more fish ...which will not be possible under lake
conditions. They therefore feared loss of income." These concerns do not
appear in official AES/EIA documentation.

III. Cultural Impacts of the Project

There has been much discussion concerning Bujagali Falls as a traditional
cultural site. A 1996 study, "Environmental Assessment, Project Analysis,
and Economic Valuation: The Case of the Proposed Nile Independent Power
Development Program (Budhagali Hydro Power Project)," written by Eugene
Muramira, Environmental and Natural Resource Economist for the National
Environmental Management Authority, states the following: "The Budhagali
Falls are a cultural/religious site where a high priest 'Budhagali' is
reported to occasionally sit on water to intercede with super natural
powers." The report continues that "This religious value ...is likely to
provoke a protest bid." AES/Nile Power claim in their EIA that the Spirit
of Bujagali can be moved elsewhere.

The Spirit of Bujagali has a storied association with Bujagali Falls that
has developed over hundreds of years. Such a connection can not be simply
moved elsewhere. To claim that such a cultural site is transferable is an
insult to the people involved and makes a mockery of the entire "direct
consultation" process. Such remarks display an amazing insensitivity to the
local people, and indicate that cultural concerns will be inadequately and
inappropriately dealt with on this project, causing even more anguish for
affected people.

The Hereditary Rulers of the Busoga have also outlined specifically their
relationship with Budhagali Falls. In the Conclusion of the Minutes of the
1997 Bugembe meeting, the Hereditary Rulers "pointed out to the Honourable
Minister that if the Government is bent on destroying Budhagali Falls this
would be tantamount to destroying Busoga since this is one of the few
remaining SIGNIFICANT CULTURAL site(s) of Busoga." This statement has thus
far not appeared in Nile Power/AES documents describing the project. We
recommend that this information be included, to present a more complete

The cultural traditions of the Falls are irreplaceable, and no realistic
economic value can be attached to them. Their enormous intrinsic value to
Ugandans must be taken seriously for a review of this project to be
considered truly comprehensive. A cultural resource of this magnitude,
which cannot be replaced and whose loss cannot be mitigated, should not be
sacrificed to infrastructure development unless there is widespread support
for the trade-off by Ugandan society. Thus far, such support seems to be

IV. Tourism Impacts of the Project

In discussing other impacts of the Bujagali Falls Dam, the tourism and
recreational value of Bujagali Falls and the "Source of the Nile" should
not be underestimated. According to the NEMA EIA, "The series of falls
including Budhagali falls, Kyabira falls and Idondo falls which are likely
to be submerged under the reservoir are spectacular tourist attractions.
The series of falls are extremely scenic and the willingness to preserve
them though not fully expressed in the market is enormous." The official
documents for the Bujagali Dam have not accurately or adequately reviewed
the present and potential tourism value of the "Source of the Nile"

First, the Bujagali Falls are a very popular destination for Ugandan
tourists. Accessible to the two largest cities in the country, the Falls
are an affordable destination for Ugandans and are often crowded on
weekends and holidays. With the Rippon Falls and the true "Source of the
Nile" having been submerged by the Owens Falls Dam in 1954, Bujagali Falls
is now regarded by residents nationwide as a national treasure.

The AES/NIP EIA, however, finds the "scenic quality" of Bujagali
"attractive but not exceptional." This contradicts common sense, as well as
the 1996 Donkin EIA which states that "The falls are an attraction for
Ugandans themselves and are important in that context. Owens Falls has
already been eliminated and now other water features of amenity value
between Jinja and Lake Kyoga would also be eliminated. This is perceived as
degradation in an area with a paucity of natural attractions."

Secondly, Bujagali Falls has recently emerged as the top international
tourist destination in Uganda. Tourism is becoming a critical source of
foreign exchange in Uganda. It should be noted that the figures listed in
the AES Bujagali Falls Hydropower Project EIA concerning tourism in Uganda
are grossly inaccurate. According to the AES EIA, "Overall Uganda's tourism
industry is very small with a maximum of about 15,000 tourists per annum."
And yet, according to the "State of the Environment Report for the Republic
of Uganda: 1996" published by the National Environmental Management
Authority, Uganda welcomed 193,000 tourists in 1996. Earnings from tourism
were over $90 million in 1996 and are expected to increase dramatically in
the near future.

Bujagali Falls could become the cornerstone of Uganda's growing tourism
industry, and an accurate discussion of the impacts of a dam at Bujagali
must take into account the true potential of tourism activities at the
site. The international popularity of the Falls today is mainly due to the
success of whitewater rafting, which began in Uganda in May 1996. By
December 1997, rafting had surpassed Uganda's other major tourism draw, the
mountain gorillas, as the premier attraction  in the country, with over 500
people rafting the White Nile that month alone. If the Bujagali Falls Dam
were built, whitewater rafting would no longer exist in Uganda as it does

The rafting companies currently operating on the Nile, Adrift and Nile
River Explorers, market Uganda internationally as a destination. Their
investment in international publicity for Uganda will continue to draw
foreign visitors to the country. Once in the country, these tourists bring
in much needed foreign exchange to shops, restaurants, and hotels. It is
estimated that whitewater rafters  spend nearly $4 million a year in Uganda
on these ancillary activities not  related to rafting.

Currently, over 6,000 people raft the Nile each year. Adrift and Nile River
Explorers are both in the process of training locals as guides and safety
kayakers, and they already directly employ over 50 Ugandans. Rafting is
still in its infancy in Uganda, but the potential for growth is vast. In
Southern Africa, whitewater rafting on the Zambezi River currently attracts
46,000 tourists each year. The industry there employs over 1,000 people on
a full time basis. Considering the Nile's uniqueness, such numbers are
easily attainable in Uganda's future.

If a dam were constructed at Bujagali Falls there would be a drastic
negative, long term effect on the tourist industry in Uganda. However, the
only mitigation programs included in AES/Nile Power EIA are as follows: "A
variety of tourism measures are proposed including creation of  a community
recreation area, a lake enhancement programme, a visitor centre, and an
Upper Nile tourism development plan."

If the Bujagali Dam is built, there will be no "Upper Nile" left for
tourism. To claim that lake tourism will make up for the loss of the
country's leading tourist activity is not only ridiculous, it is bad
economics. Lakes and reservoirs in Uganda are not suitable for swimming or
recreation because of vector snails, which transmit schistosomiasis. The
Owens Falls Dam created the largest reservoir in the world, Lake Victoria,
yet since 1954 it has never been a major tourist attraction.  The reservoir
created by the Bujagali Dam would be less than one mile from Lake Victoria.
The creation of more stagnant flat water, behind the third large concrete
wall within a ten mile stretch, is not going to draw people to view it.
Bujagali Falls will.

The "Source of the Nile" Corridor is indeed one of the most spectacular
river stretches found anywhere in the world. The Nile at Bujagali braids
into seven separate channels of thunderous falls, each one sandwiched
between thick jungled islands. The parallel succession of seven long
whitewater rapids stretching from bank to bank is truly a unique
phenomenon-- it does not happen anywhere else on the Nile. The EIA of a
hydropower project simply cannot place a monetary figure on the true value
of Bujagali Falls as it exists naturally, not today and certainly not in
twenty years' time, when there are likely to be even fewer free-flowing
rivers on the African continent.

V. Energy Demand Issues in Uganda

There are other ways of increasing the amount of available power without
causing as much negative social and environmental effects as a major
hydropower project. The most obvious is in demand-management. According to
the NEMA State of the Environment Report (1996), over a quarter of the
power generated in Uganda is lost to poor transmission. In 1995
transmission losses were 32.4% of power generated. Before millions of
dollars are spent to generate more power in Uganda, ample investment needs
to be made to reduce losses in the transmission of power. The current
instability of the Uganda Electricity Board, UEB, only reinforces the need
for reform of this institution and the entire power distribution system
before further power projects are developed.

Uganda also has favourable solar conditions, according to a 1996 World
Bank/UNDP study. Uganda's solar potential ranges from 4 to 6 kWh per square
meter per day on average, according to the US Department of Energy. This
technology is already successful in neighboring Kenya, where over 40,000
families use PV systems. More households in Kenya get their electricity
from the sun than from the national grid. Both Solar PhotoVoltaic (PV) and
solar thermal technologies could provide power to rural Ugandans now
without power (90% of the population) much more efficiently than a massive
hydropower project that supplies power only to the grid, which reaches so
few Ugandans.

Thank you for your consideration of these remarks. I look forward to your reply.


Stephen Linaweaver
Africa Program
International Rivers Network
1847 Berkeley Way
Berkeley, California 94703

cc:     Martyn Riddle, International Finance Corporation
        Mary Clare Mervenne, Overseas Private Investment Corporation

      Lori Pottinger, Director, Southern Africa Program,
        and Editor, World Rivers Review
           International Rivers Network
              1847 Berkeley Way, Berkeley, California 94703, USA
                  Tel. (510) 848 1155   Fax (510) 848 1008