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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT FOR THE

PROPOSED HAKI PURE BUSHERA FOR NTUNGAMO REAL FOODS


LIMITED IN MAWOKOTA COUNTY NORTH, KIRINGENTE SUBCOUNTY,
KAVULE PARISH, MPIGI DISTRICT

Submitted by
Ntungamo Real Foods Ltd
Distributors of Haki Pure Bushera
P.O. Box 70202, Bulenga Wakiso District
Email: abasigye@gmail.com
Tel: 0701948040 / 0782948040

SEPTEMBER, 2018
ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT AUTHORS

Name and qualifications Designation Signature

Grace .K. Birikadde


Team member
MSc-Chemistry
MSc-Energy and Environmental Process analysis/waste and
Management chemicals management
MBA

Brian Muhimbura Team member


(MSc-Environmental Science) Health and Safety, Waste
Management Specialist

Contributing members
Name Qualifications Designation
Ddibya Ronald BSc-Industrial Chemistry/ Chemical Process analysis and design,
Engineering Waste water and Solid waste
MSc- Environment and Natural Resources management
Proscovia Namara Bachelor of Environmental Engineering and Environmental specialist
Management
Anthony Kusiima Bachelor of Statistics Financial analyst

i
Table of Contents
LIST OF FIGURES................................................................................................................................................ v
LIST OF TABLES ................................................................................................................................................ vi
LIST OF ACRONYMS ....................................................................................................................................... vii
EXECUTIVE SUMMARY ................................................................................................................................ viii
1. INTRODUCTION ..................................................................................................................................... 28
1.1 Background ....................................................................................................................................... 28
1.2 Objectives of the ESIA ..................................................................................................................... 28
1.3 Scope of the ESIA Study .................................................................................................................. 29
1.4 Justification of the proposed project .............................................................................................. 29
1.5 The ESIA Process: ............................................................................................................................. 29
1.6 Document/ESIS structure ............................................................................................................... 31
2. ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT METHODOLOGY.......................... 32
2.1. Impact Description ............................................................................................................................... 32
2.2. Defining the Significance of Environmental Impacts ...................................................................... 32
2.3. Impact Evaluation ................................................................................................................................ 33
2.4. Impact Mitigation ................................................................................................................................. 34
3.1.1. National Environment Management Authority (NEMA) .......................................................... 35
3. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK ................................................................ 35
3.2. Institutional Framework ...................................................................................................................... 45
3.2.1. Ministry of Water and Environment (MWE)................................................................................ 45
3.2.2. Ministry of Gender, Labour & Social Development (MGLSD) .................................................. 45
3.2.3. National Water and Sewerage Cooperation (NWSC) ................................................................. 45
3.2.4. Mpigi District Local Government .................................................................................................. 46
3.2.5. Ministry of lands, Housing and Urban Development ................................................................ 46
4. PROJECT LOCATION AND DESCRIPTION ....................................................................................... 47
4.1 Site location ....................................................................................................................................... 47
4.2 Project access road............................................................................................................................ 48
4.3 Land Tenure system......................................................................................................................... 49
4.4 The site ............................................................................................................................................... 49
4.5 Project Description ........................................................................................................................... 49
4.5.1 Project phases ........................................................................................................................... 49
4.6 Operational Facilities ....................................................................................................................... 53
4.7 Waste management .......................................................................................................................... 53
4.8 Water usage....................................................................................................................................... 55
4.9 Energy usage ..................................................................................................................................... 55

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4.10 Labour requirement ......................................................................................................................... 55
4.11 Occupational Health and Safety (OHS) Management ................................................................ 56
5. ENVIRONMENTAL SETTING ............................................................................................................... 57
5.1. Mpigi District Baseline .................................................................................................................... 57
5.1.1. General physical environment ................................................................................................... 57
5.1.1.1. Location .................................................................................................................................... 57
5.1.1.2. Climate ...................................................................................................................................... 58
5.1.1.3. District Land Tenure system .................................................................................................. 60
5.1.1.4. Land cover ................................................................................................................................ 60
5.1.1.5. Topography, Geology and Soils ............................................................................................ 61
5.1.2. Ecological components ................................................................................................................ 61
5.1.2.1. Vegetation ................................................................................................................................. 61
5.1.2.2. Wetlands ................................................................................................................................... 61
5.1.2.2.1. Coverage and Types of Wetlands ......................................................................................... 61
5.1.2.2.2. Wetland Systems ..................................................................................................................... 61
5.1.3. Socio-Economic Profile................................................................................................................ 63
5.1.3.1. Population characterisation ................................................................................................... 63
5.1.3.2. Population Distribution .......................................................................................................... 64
5.1.3.3. HIV/AIDS Analysis and Control .......................................................................................... 65
5.1.3.4. Gender Analysis ...................................................................................................................... 66
5.1.3.5. Education .................................................................................................................................. 67
5.1.3.6. Poverty status ........................................................................................................................... 67
5.1.3.7. Water situation status ............................................................................................................. 68
5.1.3.8. Economic Status ....................................................................................................................... 69
5.2 PROJECT BASELINE ....................................................................................................................... 72
5.2.1 Location .................................................................................................................................... 72
5.2.2 Access road ............................................................................................................................... 74
5.2.3 Land Tenure System ............................................................................................................... 74
5.2.4 Baseline Physical-chemical Environment............................................................................. 74
5.2.5 Flora and fauna ........................................................................................................................ 79
5.2.6 Project area population distribution ..................................................................................... 80
5.2.7 Land use.................................................................................................................................... 80
5.2.8 Utilities ...................................................................................................................................... 82
6. PUBLIC CONSULTATIONS AND DISCLOSURE............................................................................... 83
6.1 Local Community participation ..................................................................................................... 83
6.2 Opinions raised from stakeholder engagement ........................................................................... 83

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6.3 Conclusion......................................................................................................................................... 86
7. POTENTIAL IMPACTS AND MITIGATION MEASURES ................................................................ 87
7.1 ASSESSMENT METHODOLGY .................................................................................................... 87
7.1.1 Impact screening ...................................................................................................................... 87
7.1.2 Impact description ................................................................................................................... 87
7.2 Positive impacts ................................................................................................................................ 87
7.3 Negative impacts .............................................................................................................................. 88
8. ANALYSIS OF ALTERNATIVES ......................................................................................................... 106
9. ENVIRONMENTAL MANAGEMENT PLAN ................................................................................... 110
10. DECOMMISSION PLAN .................................................................................................................. 127
10.1 The Need for Preliminary Decommissioning Plan .................................................................... 127
10.2 Content of the Plan ......................................................................................................................... 127
10.3 Methodology and Schedule .......................................................................................................... 126
10.4 Preliminary Decommissioning Plan ............................................................................................ 127
11. RECOMMENDATION AND CONCLUSION ............................................................................... 128
REFERENCES................................................................................................................................................... 129
Appendices ....................................................................................................................................................... 130
Appendix A: NEMA approval of Scoping and ToR ................................................................................... 130
Appendix B: Stakeholder Consultations ...................................................................................................... 133
Appendix C: Water quality Results............................................................................................................... 135
Appendix D: Land title and agreements ...................................................................................................... 136
Appendix E: Design Site layout ..................................................................................................................... 150
Appendix F: Geotechnical report .................................................................................................................. 151

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LIST OF FIGURES
Figure 1.1: NEMA EIA Guidelines ................................................................................................................. 30
Figure 4.1: Project Site Location ....................................................................................................................... 48
Figure 4.2: Access road to project site ............................................................................................................. 49
Figure 4.3: Process Flow Diagram ................................................................................................................... 52
Figure 5.1: Map showing location of Mpigi district ...................................................................................... 58
Figure 5.2: Land use/Land cover Map of Mpigi District ............................................................................. 60
Figure 5.3: Map of Mpigi Wetlands................................................................................................................. 63
Figure 5.4: Distribution of Population by Sex (Source: Uganda Bureau of Statistics, 2017) ........................ 64
Figure 5.5: Access to safe water in Mpigi district (Uganda Water Supply Atlas, 2018)............................... 69
Figure 5.6: The Uganda Equator Monument at Kayabwe in Mpigi district .............................................. 70
Figure 5.7: Mining sites in Mpigi district........................................................................................................ 71
Figure 5.8: Project site Google maps ............................................................................................................... 73
Figure 5.9: Access road to project site ............................................................................................................. 74
Figure 5.10: Topography and soils at the site ................................................................................................ 77
Figure 5.11: Vegetation impression within the project site .......................................................................... 80
Figure 5.12: Project area Land use types......................................................................................................... 82

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LIST OF TABLES
Table 1.1: Document Structure ......................................................................................................................... 31
Table 2.2.1: Matrix for the evaluation of significant environmental impacts ............................................ 33
Table 2.3.1: Classification of impact severity ................................................................................................. 33
Table 3.1: Policies and legal framework ......................................................................................................... 35
Table 4.1: Utensils that can be used with the CTI grinder ............................................................................ 53
Table 5.1: Land Tenure in Mpigi...................................................................................................................... 60
Table 5.2: Drainage systems in Mpigi district ................................................................................................ 62
Table 5.3: Total population trend of Mpigi District ...................................................................................... 64
Table 5.4: Distribution of Households by source of Energy for Lighting, Sex and District..................... 64
Table 5.5: Distribution of Households by source of Energy for Cooking, Sex and District..................... 65
Table 5.6: Distribution of Children below 18 years By Survival Status of Parents by District ................ 65
Table 5.7: Population Distribution by Disability Status and District ......................................................... 65
Table 5.8: Population Distribution of Children aged (12-17 years) by marital status and Gender ........ 65
Table 5.9: ART services for the period 2005/2006 - 2008/2009 ................................................................... 66
Table 5.10: Gender Analysis in the Mpigi district ......................................................................................... 66
Table 5.11: Number of primary schools by ownership by Sub-county ...................................................... 67
Table 5.12: Access to save water in Mpigi District on a sub-county level.................................................. 69
Table 5.13: Recorded air quality of the project area ...................................................................................... 75
Table 5.14: Recorded noise levels at the project site...................................................................................... 76
Table 5.15: Water quality results...................................................................................................................... 77
Table 5.16: Soil bearing capacities and Consistency ..................................................................................... 78
Table 5.17: Evaluation of Bearing Capacities Basing on the Field DCP values ......................................... 78
Table 5.18: Summary of the shear test results ................................................................................................ 79
Table 5.19: Summary of Classification Test Results ...................................................................................... 79
Table 6.1: Summary of consultations and comments from the public....................................................... 84
Table 9.1: Environmental and Social Management and Monitoring Plan ............................................... 111
Table 10.1: Preliminary Decommissioning Plan .......................................................................................... 127

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LIST OF ACRONYMS
DEO District Education Officer

DWRM Directorate of Water Resources Management

EHS Environmental Health and Safety

ESIA Environmental and Social Impact Assessment

MoGLSD Ministry of Gender, Labour and Social Development

OHS Occupational Health and Safety

NEA National Environment Act

NEMA National Environment Management Authority

NWSC National Water and Sewerage Corporation

MWE Ministry of Water and Environment

NRFL Ntungamo Real Foods Limited

ESIS Environmental and Social Impact Statement

LC Local Council

UBOS Uganda Bureau of Statistics

COD Chemical Oxygen Demand

BOD Biological Oxygen Demand.

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EXECUTIVE SUMMARY
Ntungamo Real Foods Ltd (here referred to as the developer) intends to construct a factory that will
manufacture drinking porridge made from Sorghum and or Millet grains in Mawokota county,
Kiringente Sub County, Kavule Parish, Mpigi District on land with boundary spatial coordinates
32.369192°E, 0.236105°N; 32.369103°E, 0.236572°N; 32.369958°E, 0.237263°N and 32.370838°E,
0.236723°N. The proposed project will be capable of producing drinking porridge from sorghum grains
of 2.14 tons per day. The raw materials as sorghum grains will be crashed using a grinding mill to
produce flour. The flour will then be mixed thoroughly with treated water to form a uniform mixture
which will then be boiled for a few minutes (about 10 minutes of boiling) while continuous mixing is
maintained, and then left to cool. The germinated flour will then be added to initiate fermentation at
ambient temperature (27-30°C). The fermentation period will take around 12-24 hours for a sweet
drinking product or between 2-4 days for a sour drinking product. The product will then be packed in
bottles, branded and then stored ready for the market.

The proposed facility will occupy 4 acres of land being owned by the developer. The area neighbouring
the project area is characterised by tree plantations, scattered homesteads plantations with mainly sweet
potatoes and cassava approximately 100-300m from the project site. Brick making is also carried out by
the locals and such activities were seen south about 50m from the project site. In addition, east of the
project site is a wooden pole treatment plant about 300m from the site. Within the project site is St. Paul
Kavule church and Step by Step Infant school both located in the north about 450m from the project site.
Further still is St. Joseph of Nazareth High School located across the main road in the north about 1km
from the project site. The nearest trading centre is about 780m from the project site.

The proposed project is to be established on a site neared by a swamp to the south-downstream. It is a


government policy and legal requirement that an Environmental and Social Impact Assessment (EIA)
must be carried out for developments that are likely to have significant environmental and social
impacts. The EIA helps in identifying potential impacts and possible mitigation measures to minimise
or even eliminate the likely impacts arising from the construction and operational activities of the
proposed project. It is against this background that an ESIA was carried out following the National
Environment Act Cap 153 and the attendant EIA regulations as well as the approval of the TORs by
NEMA Ref: NEMA/4.5, dated 6th July, 2018.

The assessment was conducted using the following methods: Collection and evaluation of baseline
data, stakeholder engagements, field assessments, sampling and off site analysis, in situ assessments
like air and noise assessments and document reviews among others. All these entailed data collection,
analysing it, identifying and determining the significance of the impacts as well as proposing
mitigation measures. An ESMP was prepared where enhancement measures for positive impacts and
mitigation measures for negative impacts are well articulated.

The assessment revealed that the proposed project will contribute towards the development of
Kiringente Sub County, Kavule Parish, Mpigi District and the entire region. Some of the positive
impacts that are expected to contribute to the development of these areas are:

I. Gender equality and employment opportunities;


II. Local income Generation and Livelihood Improvement;
III. Rural and urban development;
IV. Bridged gap for food security in the region;
V. Agriculture sector will be a key component involved which may lead to its Improvement;
VI. Increased government revenues through different payments for permits, licences,
operational bills, among others; and
VII. Improved human health through nutrition enhancement.

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During the assessment, a number of potential negative impacts that could result from the establishment
of the proposed factory in the project area were identified. Below is a table of summary of the impacts
as well as their proposed mitigations.

Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

Economic ✔ ✔ • Ensure Head of Human • Proportion of


opportunities employment Resource at local people
opportunities on an NRFL employed.
equal basis • Number of
between women complaints
and men; concerning the
• Design/put in jobs
place mechanisms
that will ensure
that the hiring and
recruitment process
is done in a
transparent way
and community
involvement
considered;
• Ensure that the
hiring of unskilled
workers is done
maximally from the
local community;
• Identify those
goods and services
that can be
provided locally by
the community
members such as
raw materials,
food, cleaning
services, etc., and
support and
encourage the
production and
provision of such
goods and services
respectively;
• Ensure that
capacity building
and training
programmes are

ix
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

put in place
especially for the
unskilled workers
to scale up their
skills for better
competitiveness in
the job market
Food security ✔ ✔ • Massive • Managemen • Number of local
sensitization and t of NRFL people who
awareness received the
campaigns will be support.
carryout to • Number of
encourage the locals people/farmer
to keep growing practicing mixed
food crops for cropping
human
consumption.
• The developer will
also continuously
support crop
growing by giving
out seeds to the
locals for planting to
ensure food
security.
• Put in place
awareness
programmes that
teach, support and
encourage the local
community to
practice mixed
cropping so as to
avoid relaying on
one cash (sorghum)
for sale.

Land use change ✔ ✔ • Massive Management of Number people


sensitisation of the NRFL carrying out other
people will be economic activities
other than working
carried out to
in the project facility
encourage them to and growing

x
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

keep on sorghum
participating in
other
developmental
activities like
growing cash crops
like coffee other
than sorghum.
• The developer
should also work
hand in hand with
the local authorities
to ensure that the
locals continue to
practise farming for
environmental
sustainability.

Occupation Health ✔ ✔ • Ensure to register Health and Employees dressed


and Safety with the Ministry of safety in the appropriate
Gender, Labour and officer/engineer PPE
Social Development NRFL Precaution signage
(MoGLSD) under management around the site
the Department of First aid training
Occupational records
Health and Safety
(OHS).
• Develop and put in
place an EHS
system onsite. This
will be well
popularised
amongst the
employees.
• All workers,
including casual
labourers, will
undergo an
environmental,
health and safety
induction from the
EHS manager
before commencing
work on site. This

xi
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

will include a full


briefing on site
safety and rules.
• Conduct regular
tool box meetings
and ensure to keep
records of such
activities.
• Ensure to prepare
incident reports and
well document
them for reference.
• Continually
sensitize employees
to always use PPE
during operation
activities.
• A well designated
emergency
assembly point will
be established for
scenarios where it
may be necessary.
• All employees will
undergo training in
first aid and first aid
kits provided on site
to take care of
accidental
emergencies
• To mitigate fire risk
scenario, fire
fighting equipment
include sand
buckets and fire
extinguishers will
be on site in case of
an emergency.
• Develop and put in
place an HIV/AIDS
Policy and will be
made aware to all
workers.

xii
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

• Ensure to put in
place systems for
referrals.
Emergency
numbers will be
displaced visible to
all workers onsite.
• Developer shall put
in place and Health
and Safety Policy.
• Democratically elect
a competent HS
commit to
implement the
above HS policy.
• Conduct pre-
employment and
periodic
examination of
workers including
medical
examination of food
handlers within the
facility.
• Develop an
emergency plan and
procedures and
ensure that these are
well displaced and
educated to all
workers.
• Carry out a
comprehensive risk
assessment and
develop a risk
management plan.
• Proper and
adequate signage
will be put in place
and promptly made
aware of all
workers.
• Develop and put in

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Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

place a Policy
against sexual
harassment.
• Ensure that there is
no allowance for
child labour.
Fire Risk ✔ ✔ • Oils and all other Developer/EHS • Carbon
combustibles will be Officer Management Plan
isolated. • Presence of fire-
fighting
• Sustainable
equipment.
maintenance for all
• Records of
machinery. trainings.
• Arranging suitable • Fire escape routes
awareness • Fire Emergency
programs for all Management
workers (fire Plan.
combating, suitable • Presence of fire
signage.
clothes to wear,
• Records of
quick emergency maintenance of
evacuation for the electrical
personnel, how to appliances.
use the fire
extinguishers,
calling the fire
brigade).
• Installation of
efficient fire alarm
system (with
automatic water
devices, anti-fire
powder to splash
and sprouting
sufficient fire
extinguishers
evenly in the fabric
spaces).
• Project personnel
will be sensitised on
sources, possible
causes and
prevention of fire
outbreaks and some
staff will be

xiv
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

adequately trained
in fire-fighting
operations.
• Fire hydrant system
of adequate to serve
emergencies
involving large fires
will be installed at
the facility. An
adequate number of
heavy duty fire
extinguishers shall
be placed in all
structures of the
facility. The
extinguishers will
be timely serviced.
• Fire escape routes
shall be provided in
all structures and
clearly marked with
its signals.
• A fire emergency
management plan
shall be developed
and made easily
accessible to all the
people working in
the facility.
• Safety signage e.g.
“Fire Risk Area” or
“No Smoking” will
be provided in
appropriate areas.
• Fire/smoke
detectors, fire
alarms and fire
suppression
systems shall be
installed on all
structures of the
facility.
• Smoking will only

xv
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

be allowed in
designated low-risk
areas which are
adequately
ventilated and have
fire extinguishers.
• Maintenance of
electrical appliances
will only be done by
qualified and
certified personnel.
• Regular fire-fighting
drills will be
undertaken by all
the project
personnel.

Surface water ✔ ✔ • The developer will NRFL Perimeter drainages


pollution ensure that management around the facility
perimeter drains are Environmental
established to officer/water Precautions around
intercept storm- officer the facility to
runoff from the indicate surface
construction site. water conservation
These will be or protection
constructed in
advance of site
formation works
and earthworks.
• Open stockpiles of
construction
materials or
construction wastes
on-site will be
covered with
tarpaulin or similar
fabric during
rainstorms to avoid
run-offs.
• Debris and rubbish
generated on-site
will be collected,
handled and

xvi
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

disposed of
properly to avoid
being flushed or
blown by wind into
the nearby swamp.
• Solid waste bins
will be put
onsite/within the
facility and these
will be managed in
a way that waste is
separated at source.
• The quality of
surface water
downstream will be
monitored by the
developer to ensure
that there are no
contaminations of
this water. These
records will be well
documented and
properly kept for
reference,
evaluation and
management
purposes.
• Carry out routine
maintenance of
operational vehicles.
• Develop and put in
place an adequate
Carbon
Management Plan
to avoid
unnecessary oil
spills.

xvii
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

Ground water ✔ ✔ • Oils and fuels will NRFL Designated areas for
contamination only be used and Management oil and fuel storage
stored in designated Water/
areas which have environmental Contract with the a
pollution officer licensed contractor
prevention facilities for handling sanitary
and all fuel tanks issues
and storage areas
will be provided
with locks and sited
on sealed areas,
within bunds of
storage capacity of
the largest tank to
prevent spillage of
fuels and solvents.
• A licensed
contractor who will
be responsible for
appropriate
disposal of waste
matter and
maintenance of the
sanitary facilities
will be hired.
• Provide sanitary
facilities for worker
and these shall be
gender sensitive.
Properly maintain
and clean them
regularly and more
frequently. The
faecal sludge will be
managed in an
appropriate way
through the septic
tank storage system
which will later be
emptied for
disposal by a
licenced handler.

xviii
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

Soil erosion ✔ - • Sand/silt removal The developer Designated


facilities such as (NRFL) structures for run-off
sand/silt traps and speed
sediment basins
will be provided to
reduce the speed of
running water.
• Exposed slope/soil
surface will be
covered by
tarpaulin as soon as
possible to reduce
the potential of soil
erosion.
• Arrangements
should always be in
place to ensure that
adequate surface
protection
measures can be
safely carried out
well before the
arrival of a
rainstorm to
control erosion.
• The ground of the
site will be
established with
concrete pavers.

Traffic accidents ✔ ✔ • Flags men will be Health and Availability of the


stationed at the safety officer signage, humps and
different road points The flags men along the
to direct truck management of roads
drivers to reduce NRFL
traffic accidents.
• Road signage will be
installed at different
road sections like
sharp corners and
trading centres to
minimize on the
traffic accidents.

xix
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

• Humps will be
constructed in the
trading centres to
help reduce on over-
speeding hence
minimizing traffic
accidents.
• Develop and put in
place a traffic
management plan
and ensure that all
drivers and workers
are made
aware/sensitised of
it.
• All vehicles will be
regularly
maintained/serviced
to ensure their
smooth operations.
• Sensitisation
programmes on road
usage will be
conducted to both
workers inclusive of
drivers and the local
community.
Noise emission ✔ ✔ • Ensure that high Sound • Erected noise
noise producing assessment barriers around
machinery are officer the project site.
fitted with NRFL • Records of Noise
silencers. management levels
• The boiler will be assessments
installed with a
noise control
equipment to
minimise high level
noise emissions.
• All machinery
equipment will be
regularly serviced
to ensure high
operation efficiency

xx
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

thus less noise and


vibration.
• Construction phase
shall use quiet
machinery of good
mechanical
condition.
• Ensure that noise
barriers like screens
are erected around
machinery during
the operation or
production phase.
• A barrier around
the facility will be
established to
reduce on the noise
levels experienced
by the
neighbouring
residents.

Population influx ✔ ✔ • Sensitization NRFL • Records of all the


campaigns will be employees with
carried out by the their
developer identification.
(Ntugamo Real • Availability of
Foods Limited) to condoms at the
encourage the locals site for the
to grow food crops employees.
to maintain the
supply of food for
the increased
population.
• The developer will
also give out or
supply condoms to
the employees and
the locals for free to
reduce/ prevent the
easy spread of
Sexually
Transmitted

xxi
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

Diseases like
HIV/AIDS.
• Also ensure that all
the employees at the
site provide their
identification
initials to the local
leaders to maintain
security in the area.
Air pollution ✔ ✔ • Ensure to carry out Air quality • Presence of bio-
regular proper and assessment filters and other
adequate officer pollution control
maintenance of all Developer measures around
machinery/equipm the facility.
ent including the
boiler. • Records of PPE
• All fine earth issuance
materials must be • Complaints from
enclosed during the community
transportation to • Onsite air quality
the site to prevent assessment
spillage and records.
dusting. Trucks
• Records of
used for that
maintenance of
purpose should be
machinery/equip
fitted with tailgates
ment inclusive of
that close properly
operational
and with tarpaulins
vehicles and the
to cover the
boiler.
materials
• The developer will
have trees planted
along the boundary
of the plot, which
will intercept the
dispersing fumes.
• Good mechanical
condition
maintenance of
trucks will avert
emission of exhaust
fumes into the
atmosphere during

xxii
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

the construction
phase.
• The internal roads
of the plant will be
asphalted to reduce
the speed of
moving trucks
which will
minimise dust
emission.
• There will be water
trucks to sprinkle
water in areas
where dust
emission is
expected within the
plant.
• Mixing of
ingredients at a low
speed will
minimize on
powder dust.
• Adequate and
proper ventilation
will be put in
facility structures to
minimize on VOC
exposure.
• The developer
should also adapt
to greener
technology for such
material
processing/prepara
tion.
• Using hydro
fluorocarbons
(HFC) during
storage and
transportation of
finished products
and prevention of
the refrigerant

xxiii
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

leakage will
minimize on the
effect of
refrigerants on the
ozone layer.
• Application of
biological filters
and scrubbers will
minimize on the
rate of VOC
emission.

Waste Management ✔ ✔ • Develop a Waste Developer • Training records.


Management system • Sanitary facilities
for the facility
construction and • Presence of skips
operational and bins well
activities. covered labelled
• Training and for waste
instruction of staff separation.
shall be given at the • Proof of licence of
facility to increase a waste handler.
awareness and draw • Waste
attention to waste Management
management issues Procedures.
and the need to
minimise waste
generation.
• Adopt/apply the
waste minimization
strategies through
source reduction by
recycling and re use
of some waste.
• Ensure that waste is
properly segregated
for proper disposal
in appropriate
designated areas.
• Designate a place for
collection of solid
waste and should
hire a licensed

xxiv
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

company to collect it
after a certain period
of time and dispose
it at the proper
disposal sites.
• Avail Trash bins at
different areas
within the facility
premises.
• Wastes shall be
handled and stored
in a manner, which
ensures that they are
held securely
without loss or
leakage thereby
minimising the
potential for
pollution.
• Waste storage areas
should be regularly
cleaned and
maintained.
• Waste collection
points should be
properly signalled to
enable worker
dispose waste in the
right places.
• Ensure maintenance
of records of
quantities of wastes
generated, recycled
and disposed,
including disposal
location.
• Conduct regular
maintenance and
cleaning of the waste
storage areas.
• Develop and put in
place a Carbon
Management Plan to

xxv
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

adequately handle
used oils that might
be generated after
machinery
maintenance/servici
ng.
• Temporary toilets
will be installed
during the
construction period.
• Put in place sanitary
facilities during
operational phase
and shall be gender
sensitive. In
addition, a septic
tank system will be
constructed to be
part of the sanitary
facilities, where the
sludge waste will be
collected/managed.
• A licensed faecal
sludge handler will
be contracted to
collect and dispose
off faecal waste to a
designated licenced
disposal facility.

✔ ✔ • Ensure to put in • Gender based


Gender Based place a gender based Developer violence policy
Violence violence • Records of
management policy Community
complaints
Liaison Officer
and popularising it
to the employees.

• Gender equality will


be considered
during
employment/recruit
ment process.

• Regular awareness
campaigns will be

xxvi
Environmental/Socia Mitigation measures Responsible Performance

Construction

Operation
l Issue taken or to be taken party/ Indicator
Implementer

conducted both
within the project
facility and the
community at large.

- - • Decommissioning
• Decommission
Impact as a result of shall be undertaken Developer
decommissioning report
in accordance with
the legislation
prevailing at that
time, in liaison with
the relevant
regulatory
authorities and
adhere to Industrial
safety guidelines to
ensure that the
decommissioned
facilities do not
deteriorate to the
point where they
become a hazard to
the public or the
environment.
• Decommissioning
Plans shall be
prepared and shared
with NEMA for
approval.
• All
decommissioning
wastes shall be
managed in
accordance with the
National
Environment (Waste
Management)
Regulations, 1999.

xxvii
1. INTRODUCTION

1.1 Background
Ntungamo Real Foods Ltd (here referred to as the developer) intends to construct a factory that will
manufacture drinking porridge made from Sorghum and or Millet grains in Mawokota county,
Kiringente Sub County, Kavule Parish, Mpigi District on land with boundary spatial coordinates
32.369192°E, 0.236105°N; 32.369103°E, 0.236572°N; 32.369958°E, 0.237263°N and 32.370838°E,
0.236723°N. The proposed project will be capable of producing drinking porridge from sorghum grains
of 2.14 tons per day. The raw materials as sorghum grains will be crashed using a grinding mill to
produce flour. The flour will then be mixed thoroughly with treated water to form a uniform mixture
which will then be boiled for a few minutes (about 10 minutes of boiling) while continuous mixing is
maintained, and then left to cool. The germinated flour will then be added to initiate fermentation at
ambient temperature (27-30°C). The fermentation period will take around 12-24 hours for a sweet
drinking product or between 2-4 days for a sour drinking product. The product will then be packed in
bottles, branded and then stored ready for the market.

The proposed facility will occupy 4 acres of land being owned by the developer. The site is
neighboured by a swamp in the south. East to the site is a tree treatment for energy facility and St.
Lawrence School located in the far South to the site. Nearly homesteads are neighbouring the project
site within 200m. However Brick making and farming are the main economic activities within the area.

The proposed project is to be established on a site neared by a swamp to the south-downstream. It is a


government policy and legal requirement that an Environmental and Social Impact Assessment (EIA)
must be carried out for developments that are likely to have significant environmental and social
impacts. The EIA helps in identifying potential impacts and possible mitigation measures to minimise
or even eliminate the likely impacts arising from the construction and operational activities of the
proposed project. It is against this background that an ESIA was carried out following the National
Environment Act Cap 153 and the attendant EIA regulations as well as the approval of the TORs by
NEMA Ref: NEMA/4.5, dated 6th July, 2018.

The assessment was conducted using the following methods: Collection and evaluation of baseline
data, stakeholder engagements, field assessments, sampling and off site analysis, in situ assessments
like air and noise assessments and document reviews among others. All these entailed data collection,
analysing it, identifying and determining the significance of the impacts as well as proposing
mitigation measures. An ESMP was prepared where enhancement measures for positive impacts and
mitigation measures for negative impacts are well articulated.

1.2 Objectives of the ESIA

The main objective of the ESIA study was to assess the potential environmental and social impacts that
may arise out of the proposed project’s activities and operations. The ESIA seeks to provide sufficient
information on the proposed project to enable NEMA to make a decision on whether or not to approve
the project in its current proposed form.

The specific objectives of the ESIA are to;

• Provide a detailed description of the proposed project development;


• Review of existing government legislation in order to identify laws, regulations and standards
relevant to the proposed project;
• Acquire baseline data on the physical, biological and socio-economic setting of the proposed
project area;

28
• Ascertain and evaluate potential environmental and social impacts likely to result from the
implementation of the proposed project and subsequent operational activities;
• Inaugurate feasible and cost-effective mitigation measures for significant impacts identified;
• Present the ESIA findings in a format that can guide informed decision making;
• Propose an Environmental Management Plan (EMP) to guide environmental and social
management of the proposed project during implementation of proposed mitigation
measures.

1.3 Scope of the ESIA Study

The environmental impact assessment was conducted at the proposed site and the surrounding areas.
The ESIA process was undertaken with physical examination, interviews with neighbouring
community within the project area, relevant consultants and government agencies. The ESIA covered
the following project activities:

• Preconstruction investigations;
• Site preparation and construction activities;
• Operational activities including;
- Process / production activities
- Packaging and Distribution
- Loading and offloading activities
- Storage of both raw materials and finished products
- Quality control measures
• Solid and liquid waste management
• Human waste management
• Site decommissioning and restoration activities

1.4 Justification of the proposed project

According to the Uganda Bureau of Statistics 2017, the population of Mpigi has increased exponentially
since 1991 to 2017 with a percentage increase of 40.9%. The increase in population has significantly
influenced the increase in demand for basic needs and services. Among these are the need for
nutritional foods to take care of the health of the people, as well as the employment opportunities for
economic status improvement.

The establishment of this project in Kiringente Sub-county will bridge the gap mentioned above. This is
so because the developer intends to obtain raw materials and supplies both during construction and
operational phases, from the local supply market and at the time provide direct/indirect employment
to over 80 individuals within the project area. In addition, such crops such as Millet and Sorghum have
high nutritional value, with high levels of unsaturated fats, protein, fibre, and minerals like
phosphorus, potassium, calcium, and iron (Tenywa et al., 2018). The high nutritional value and other
health benefits in these crops have enhanced their recommend as replacements for rice or corn among
the general agricultural sector (Pontieri et al., 2013). Sorghum has been found to be gluten-free and a
suitable alternative grain for people with gluten intolerance (Tenywa et al., 2018; Pontieri et al., 2013).

1.5 The ESIA Process:

The ESIA process was undertaken in accordance with the Environmental Impact Assessment
Regulations (1998), and was guided by the EIA Guidelines (NEMA, 1997). As part of the feasibility
study, a scoping exercise was conducted and an Environmental Scoping Report (ESR) and terms of
reference was prepared for the proposed project. The purpose of ESR and ToRs was to address specific

29
recommendations to elaborate on in the ESIA which was carried out subsequently. The scoping report
and terms of reference was then submitted and subsequently approved by NEMA in a letter Ref
NEMA/4.5 and dated 6th July, 2018. The approval provided conditions that guided a comprehensive
study for the ESIA for the proposed project.

Figure 1.1: NEMA EIA Guidelines

30
1.6 Document/ESIS structure

This report was arranged based on the following chapters;

Table 1.1: Document Structure

Executive summary

Chapter 1 Introduction and Background to the Project.

Chapter 2 Provides the assessment methodology

Chapter 3 Policy, Legal and Institutional Framework.

Chapter 4 Project Location and Description

Chapter 5 Project Environmental Setting

Chapter 6 Stakeholder consultation and Public Disclosure

Chapter 7 Potential Impacts and Mitigation Measures

Chapter 8 Analysis of Alternatives

Chapter 8 Environmental and Social Management and Monitoring Plan

Chapter 9 Decommission Plan

Chapter 10 Conclusions and recommendations

References

Appendices

31
2. ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT METHODOLOGY

In general, the ESIs was prepared in line with the National Environment Act Cap 153, The
Environmental Impact Assessment Guidelines, 1997 as well as the Environmental Impact Assessment
Regulations, 1998.

The following methodology was used during the development of this ESIS:

• Document reviews that determined the policy, legal and administrative framework and
requirements primarily through desk review of legal documents, guidelines and planning
procedures which ensured that the relevant statutes, regulations and standards were
incorporated into the project design and implementation plan;
• Site visits that identified the current environmental setting of the project area;
• Key stakeholder consultations.
• Development of an environmental social management and monitoring plan to eliminate,
reduce and/or offset significant adverse impacts.

2.1. Impact Description

Describing a potential impact involves an appraisal of its characteristics, together with the attributes
of the receiving environment. Relevant impact characteristics may include whether the impact is:

• Adverse or beneficial;
• Direct or indirect;
• Short, medium, or long-term in during; and permanent or temporary;
• Affecting a local, regional or global scale; including trans-boundary; and
• Cumulative (such an impact results from the aggregated effect of more than one project
occurring at the same time, or the aggregated effect of sequential projects. A cumulative
impact is “the impact on the environment which results from the incremental impact of the
action when added to other past, present and reasonably foreseeable future actions”).

Each of these characteristics was addressed for each impact. Consideration of the above gives a sense
of the relative intensity of the impact. The sensitivity of the receiving environment was determined
by specialists based on the baseline data collected during the study.

2.2. Defining the Significance of Environmental Impacts

While there is no statutory definition of what constitutes a significant impact, it is clear that the
preliminary purpose of identifying the significant impacts of the project is to inform decision makers
such that a balanced and robust consent decision can be reached. On this basis, a significant impact
has been defined for the purpose of this project, as an impact that, either in isolation or combination
with others, should be taken into account in the decision making process.

There are three stages involved in the analysis of the significance of impacts:

a) The impact severity: how severe is the impact (negligible, low, medium, and high). The
severity of an impact is a function of a range of considerations including:

• impact magnitude;
• impact extent;
• impact duration; and

32
• Receptor sensitivity.

b) The likelihood of occurrence: how likely is the impact to occur (none, low, medium and
high); and

c) Identification of the impact significance which is as a result of a combination of the above


two variables.

The process of aggregating the severity of the impact with the likelihood of occurrence of the impact
to determine the impact significance is shown as a colour-coded matrix in Table 2.1. Table 2.2 shows
indicative examples of impact significance.

Table 2.2.1: Matrix for the evaluation of significant environmental impacts

Impact Impact Likelihood


Severity
None Low Medium High

Negligible Negligible Negligible Negligible Negligible

Negligible –
Low Negligible Negligible Minor
Minor

Minor –
Medium Negligible Minor Moderate
Moderate

High Minor Moderate Major Major

2.3. Impact Evaluation

The severity of each impact will be evaluated using the criteria listed in Table 2.1.

Table 2.3.1: Classification of impact severity

Classification Description

1 Extent: Evaluation of the area of occurrence/influence by the impact on the


subject environment; whether the impact will occur on site, in a limited
area (within 2 km radius of the site); locally (within 5 km radius of the
site); regionally (district wide, nationally or internationally).

2 Persistence/Duration: Evaluation of the duration of impact on the subject environment,


whether the impact is temporary (<1 year); short term (1 – 5 years);
medium term (5 – 10 years); long term (>10); or permanent.

3 Ecological or Social for Assessment of the impacts for sensitive receptors in terms of ecological,
Context /Sensitivity or social sensitivity and such things as rare and endangered species,
Potential unusual and vulnerable environments, architecture, social or cultural
setting, major potential for stakeholder conflicts. The sensitivity

33
Classification Description

Stakeholder Conflict: classification is shown below;

High sensitivity: Included very sensitive ecosystems in the area (like


game parks, Ramsar sites, protected wetlands, and water masses),
endangered species, entire community displacement, destruction of
world heritage and important cultural sites, large scale stakeholder
conflict etc.).

Medium sensitivity: included threatened species, important ecosystem,


displacement of some households, moderate level of stakeholder
concern,

Low sensitivity: included evaluating an environment with rapid


ability to recover, no displacements, no potential for stakeholder
conflict.

4 Regulatory and Legal Evaluation of the impact against Local and International legislative
Compliance: requirements.

High: Prohibition terms for specific activities/emissions. Major

Breach of regulatory requirements resulting in potential prosecution or


significant project approval delays.

Medium: Potential breach of specific regulatory consent limits e.g. 30


ppm oil in water resulting in non-compliance.

Low: No breach of specific regulatory consent limits anticipated.

5 Overall Impact rating Using a combination of the above criteria, the overall severity of the
(Severity): impact was assigned a rating Severe, Substantial, Moderate, Minor and
negligible. Refer to Table 2.1 for broad categories of impact for each
rating.

Note: These are just guidelines that will constitute professional


judgment required in each individual case.

2.4. Impact Mitigation

Measures to avoid, reduce, eliminate, or compensate for adverse environmental and social impacts
were proposed and these form the Environmental Management Plan (EMP). Identification and
analysis of potential impacts and mitigation measures are presented in the EMP (chapter 9).

34
3.1.1. National Environment Management Authority (NEMA)

Following the enactment of the National Environment Act, Cap. 153, National Environment
Management Authority (NEMA) was established in May, 1995 and became operational in December,
1995 as the principal agency in Uganda charged with the responsibility of coordinating, monitoring,
regulating and supervising environmental management in the country. Besides being under the
Ministry of Water and Environment (MWE), NEMA has a mandate to oversee the process of carrying
out the EIAs through issuance of guidelines, regulations and registration of environmental
practitioners. It reviews and approves environmental impact statements in consultation with any
relevant lead agencies, coordinates the monitoring and supervision of environmental conservation
activities by the National Environmental Act, Cap 153. NEMA works with District Environmental
Officers and local environment committees at local government levels who also undertake inspection,
monitoring and enforce compliance on its behalf and above all NEMA works with Environmental
Liaison Units to ensure that they effectively integrate environmental issues in their activities, policies
and programs.

3. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK


Policies and regulations below are directly related to the proposed project and are intended to ensure
that its development and operation are in agreement with the national environmental standards.

Table 3.1: Policies and legal framework

POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE


FRAMEWORK

Policy Framework
The overall policy goal is to promote sustainable
The National Environment Management
economic and social development mindful of the
Policy, 1994
needs of future generations and EIA as one of the
vital tools considers it necessary to ensure
environmental quality and resource productivity on
long-term basis. It appeals for integration of
environmental concerns into development policies,
plans and projects at national, district and local
levels. Hence, the policy requires that projects or
policies likely to have significant adverse ecological
or social impacts undertake EIA before their
implementation as reaffirmed in the National
Environment Act, Cap 153, which makes EIA a
requirement for such projects. Therefore, the EIS
preparation process was aimed at identifying
environmental and social concerns of the proposed
project and putting forward measures to ensure that
the construction and operation activities are done
along a sustainable path.

The Uganda Food and Nutrition Policy, This policy exists on the basis of the overall national
2003 (UFNP) development policy objective, which is to eradicate
poverty as detailed in the Poverty Eradication

35
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
Action Plan (PEAP). The policy is also in line with
the Plan for Modernization of Agriculture (PMA),
which pursues to ensure food security, create
gainful employment, increase incomes and improve
the quality of life of the rural people.
The overall goal of the UFNP is to ensure food
security and adequate nutrition for all the people in
Uganda, for their health as well as their social and
economic well-being.
The overall objective of the policy is to promote the
nutritional status of the people of Uganda through
multi-sectorial and coordinated interventions that
focus on food security, improved nutrition and
increased incomes.
This is to be attained by:
• Ensuring availability, accessibility, affordability
of food in the quantities and qualities sufficient
to satisfy the dietary needs of individuals
sustainably;
• Promoting good nutrition of all the population
• Incorporating food and nutrition issues in the
national, district, sub-county and sectorial
development plans;
• Ensuring that nutrition education and training
is incorporated in formal and informal training
in order to improve the knowledge and
attitudes for behavioural change of
communities in food and nutrition-related
matters;
• Ensuring food and income security at
household, sub-county, district and national
levels for improving the nutrition as well as the
socio-economic status of the population;
• Monitoring the food and nutrition situation in
the country;
• Forming an effective mechanism for multi-
sectoral co-ordination and advocacy for food
and nutrition;
• Promoting the formulation and/or review of
appropriate policies, laws and standards for
food security and nutrition;
• Ensuring a healthy environment and good
sanitation in the entire food chain system;
• Safeguarding the health of personnel associated
with agricultural chemicals, food processing
inputs and products, consumers and any other

36
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
third parties likely to be affected;
• Promoting gender-sensitive technologies and
programmes;
• Attaining maximum production with minimum
effort; and
• Promoting technologies that are user-friendly
to people with disability.

The Second Uganda National Health Policy, The policy is intended to ensure universal access to
2010 quality the Uganda National Minimum Health Care
Package (UNMHCP) consisting of promotive,
preventive, curative and rehabilitative and palliative
services for all prioritised diseases and conditions, to
all people in Uganda, with emphasis on vulnerable
populations.
This policy objective is to be attained by;
• Prioritising interventions that are proven
effective against diseases targeted for control,
elimination or eradication, and in conjunction
with the private sectors provide in an integrated
manner promotive, preventative, curative and
rehabilitative services that have been proven
effective, cost effective and affordable;
• Ensuring that all people in Uganda, both users
and providers of health services, understand
their health rights and responsibilities through
implementation of comprehensive advocacy,
communication and social mobilisation
programs;
• Improving people’s awareness about health and
related issues in order to bring about desired
changes in knowledge, attitudes, practices and
behaviours regarding the prevention and
control of major health and nutrition problems
in Uganda;
• Reinforcing responsible self-care, especially at
primary care level, for selected health problems
and patient categories through carefully
planned and evaluated pilot phases; and
• Reinforcing community health services.
The policy is meant to manage and develop the
The National Water Policy, 1999
water resources in an integrated and sustainable
manner so as to secure and provide water of
adequate quantity and quality for all social and
economic needs of the present and future
generations with the full participation of all
stakeholders. Hence, misuse of water resources

37
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
during the development or operation of the project
would conflict with this policy.

Uganda National Land Policy, 2013 The policy aims to;

Ensure sustainable utilisation, protection and


management of environmental, natural and cultural
resources on land for national socio-economic
development;

Ensure planned, environmentally friendly,


affordable and orderly development of human
settlements for both rural and urban areas, including
infrastructure development.

Legal framework

The Constitution of Uganda, 1995 Article 39 of the Constitution of 1995 provides for a
clean and healthy environment. It stipulates that
every person in Uganda has a right to a healthy and
clean environment and as such can bring action for
any pollution or improper disposal of wastes.
An ESIA was conducted to propose actions against
any misuse of the environment.

National Environment Act, Cap.153 The National Environment Act, Cap.153, the
Guidelines for Environmental Impact Assessment in
Uganda, 1997 and the EIA Regulations, 1998 require
that an EIA be undertaken by the developer, where
the lead agencies, in consultation with NEMA, are of
the view that the project:
▪ May have a negative impact on the
environment
▪ Is likely to have a significant impact on the
environment

This environmental impact assessment was done in


regard to this requirement.
The act also states that every person has a right to a
healthy environment (section 3(1))
Section 43 provides for utilisation of land according
The Land Act, Cap. 227
to various laws. It states that a person who owns or
occupies land shall manage and utilise the land in
accordance with the Forests Act, the Mining Act, the
National Environmental Act, the Uganda Wildlife
Act and any other law.

38
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
Section 31 of the Act provides for Prohibition of
The Water Act, Cap.152
Pollution. Subsection 1 states that a person commits
an offence if, 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.
Section 79 of the Act provides for Certain matters
The Public Health Act, Cap. 281
not to be passed into sewers or drains. Subsection 1
states that no person shall throw, empty or turn, or
suffer or permit to be thrown or emptied or to pass,
into any public sewer, or into any drain or private
sewer connecting with a public sewer;
• any matter likely to injure the sewer or drain,
or to interfere with the free flow of its contents,
or to affect prejudicially the treatment and
disposal of its contents;
• any chemical refuse or waste steam, or any
liquid of a temperature higher than one
hundred and ten degrees Fahrenheit, being
refuse or steam which, or a liquid which when
so heated, is, either alone or in combination
with the contents of the sewer or drain,
dangerous, or the cause of a nuisance, or
prejudicial to health; or
• any petroleum spirit, or carbide of calcium.
Workers’ Compensation Act, 2000 Generally the Act provides for compensation to
workers for injuries suffered and scheduled diseases
incurred in the course of their employment.
Section 4 of the Act provides for Compensation of
fatal injuries. Subsections 1&2 specify that where
the deceased worker leaves any family members
who are dependent on his or her earnings, the
amount of compensation shall be a sum equal to
sixty times his or her monthly earnings and where
the deceased worker does not leave any family
members who are dependent on his or her earnings,
the employer shall pay the expenses of the medical
aid provided and the burial expenses of the
deceased respectively. Subsection 6 specifies that if
the worker is killed as a result of an accident for
which the employer has liability under this Act, the
dependents (if any) of the deceased may recover
from the employer the expenses of medical
treatment of the deceased, burial of the deceased
and expenses incidental to the medical treatment
and burial of the deceased.

Section 5 provides for compensation of permanent


total incapacity. It specifies that where permanent

39
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
total incapacity results from any injury, the amount
of compensation shall be a sum equal to sixty
months’ earnings except where the terms and
conditions of the service provide for a higher
compensation; and in case there is need for the
injured worker to have the constant assistance of
another person on a permanent basis then the
amount of compensation payable shall be increased
by one-quarter.

Section 6 provides for compensation of permanent


partial incapacity. Subsection 2 stipulates that in
case of more than one injury resulting from the same
accident, the amount of compensation shall be
aggregated, but the amount of compensation
payable under this section shall not be greater than
the amount that would have been payable if the
accident had caused the worker to suffer permanent
total incapacity.

Section 7 provides for compensation of temporary


incapacity. Subsection 1, stipulates that where
temporary incapacity, whether total or partial,
results from the injury, the compensation shall be
either a lump sum or periodic payments as the court
may order, having regard to the circumstances in
which the accident took place, the probable duration
of the incapacity of the worker, the injuries suffered
by the worker and the financial consequences for the
worker and his or her dependents. Subsection 2
specifies that the period covered by hospitalisation
or absence from duty certified necessary by a
medical practitioner shall be regarded as a period of
temporary total incapacity irrespective of the
outcome of the injury, and any period subsequent
but preceding final assessment of disability shall be
regarded as a period of temporary partial incapacity,
both periods being continuous with each other,
variations in payments notwithstanding; and the
maximum duration of periodical payments under
this section shall not exceed ninety-six months,
except where in the opinion of a medical
practitioner, the period of incapacity is longer, it
may be extended beyond the ninety-six months.

The Local Governments Act, Cap 243 establishes a


The Local Governments Act, Cap 243
form of government based on the District as the

40
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
main unit of administration. The Districts are given
legislative and planning powers under this Act.
They also plan for the conservation of environment
within their local area. District Environment
Committees established under Section 14 of the
National Environment Act, Cap 153 are supposed to
coordinate the activities of the district council
relating to the management of the environment and
natural resources.

Under part 2 of the functions and services of the


Government and local governments, the act
provides for district councils to assist the
Government in preserving the environment through
protection of forests, wetlands, lake shores, streams
and prevention of environmental degradation.

Occupational Safety and Health Act, 2006 Section 13 of the Act provides for the duty of
employers to protect workers. Subsection 1
stipulates that the responsibility of an employers is
to;

take as far as is reasonably practicable, all measures


for the protection of his or her workers and the
general public from the dangerous aspects of the
employer’s undertaking at his or her own cost;

ensure as far as is reasonably practicable, that the


working environment is kept free from any hazard
due to pollution by employing technical measures,
applied to new plant or processes in design or
installation, or added to existing plant or processes;
and employ supplementary organisational
measures.

Section 14 provides for safety and health measures


of employees. It specifies that an employer with at
least 25 workers at a workplace shall prepare, revise
a written statement of policy with respect to the
safety and health of employees while at work; and
bring the statement of policy and any revision of it
to the notice of all the employees.

Section 18 provides for the employer to monitor and


control the release of dangerous substances into the
environment. It stipulates that where there is major
handling of chemicals or any dangerous substance
which is liable to be airborne or to be released into
rivers, lakes or soil and which are a danger to the

41
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
animal and plant life, it shall be the duty of the
concerned employer to arrange for equipment and
apparatus to monitor the air, soil, and water
pollution and to arrange for the actual monitoring of
these mediums, with a view of rendering them safe
from the dangerous undertaking.

Section 19 provides for the employer to provide


protective gear. It specifies that the employer shall
provide adequate and suitable protective clothing
and protective equipment to the workers of his or
her undertaking where the level of air pollution and
chemical substances in a working environment
exceed the exposure limits specified by an
occupational hygienist.

Section 21 provides for the employer to supervise


the health of workers. Subsection 1 stipulates that
every employ shall provide for the supervision of
the health of workers exposed to or liable to be
exposed to the occupational hazards due to
pollution and other harmful agents in the working
environment.
Section 18 of the Act specifies the depending on the
The Investment Code Act, Cap 92
agreement between the Authority and the Investor,
the investment license may contain the necessary
steps to ensure that the operations of his or her
business enterprise do not cause injury to the
ecology or environment.

The Town and Country Planning Act, 1964 This Act aims at consolidating the orderly and
progressive development of land, towns and other
areas whether urban or rural. The Act provides for
planning areas and regulation on compensation
regarding properties within planning areas among
others.

National Environment (Waste Regulation 5 provides for cleaner production


Management) Regulations, 1999 methods. Sub-regulation (1) specifies that a person
who owns or controls a facility or premises which
generate waste shall minimize the waste generated
by adopting the following cleaner production
methods-

a) improvement of production processes through;


conserving raw materials and energy,
eliminating the use of toxic raw materials and
reducing toxic emissions and wastes;

42
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
b) monitoring the product cycle from beginning to

c) end by; identifying and eliminating potential


negative impacts of the product, enabling the
recovery and reuse of the product where
possible and reclamation and recycling;
d) Incorporating environmental concerns in the
design and disposal of a product.

Regulation 12 provides for duty to treat waste from


industries. Sub-regulation 2 stipulates that a person
operating a factory, who discharges or disposes of
any waste, whether treated or not, into a disposal
site or plant which is not approved or licensed in
accordance with the Regulations commits an
offence.

The National Environment (Standards for Regulation 4 provides for the general obligation to
Discharge of Effluents into or Land) mitigate pollution Sub-regulation 1 states that every
Regulations, 1999 industry or establishment shall install at its premises
anti-pollution equipment for the treatment of
effluent chemical discharge emanating from the
industry or establishment.

Environmental Impact Assessment Regulation 10 provides for terms of reference for


Regulations, 1998 environmental impact assessment. Sub-regulation 3
specifies that an environmental impact assessment
study shall be conducted in accordance with the
guidelines adopted by the Authority in consultation
with the lead agency under sub-section (8) of section
19 of the National Environment Act.

Regulation 12 provides for public participation in


making the study. It requires the developer to take
all the necessary measures to seek the views of the
people in the communities which may be affected by
the project during the process of conducting the
study. Stakeholder consultations were conducted to
gather the views of the people about the project and

43
POLICY, LEGAL AND INSTITUTIONAL DESCRIPTION AND RELEVANCE
FRAMEWORK
thus there was no breach of section 12.

National Environment (Noise Standards & Regulation 9 provides for prohibition of generation
Control) Regulations, 2003 of noise by place and time. Sub-regulation 1 states
that no person shall emit or cause to be emitted, or
permit the emission of noise resulting from any act
specified in sub regulation (2) if that noise is clearly
audible at a point of reception or in the
neighbourhood for more than two minutes or is
within the prohibited time in a residential area of
Noise Control Zone as determined by the local
council. Operation of any equipment in connection
with construction, shouting, playing radio,
detonation of fireworks or explosive devices is
among the acts specified in sub-regulation 2.

Regulation 6 provides for establishment of


permissible noise levels. Sub-regulation 2 specifies
that the maximum noise levels of continuous or
intermittent noise from a factory or a workshop,
specified in column 1 of Part II of the First Schedule,
shall not

exceed 85 dB (A), 50 dB (A) and 75 dB (A) at the


factory/workshops, offices and factory/workshop
compound respectively.

Sub-regulation 4 of regulation 6 stipulates that the


maximum noise levels from a construction site to
which a person in a facility specified in Column 1
Part IV of the First Schedule as “buildings other than
hospitals, schools, institutions of higher learning and
homes for the disabled”, shall not exceed 75 dB (A)
and 65 dB (A) during day and night-time
respectively.
The Water (Waste Discharge) Regulations,
Regulation 4 provides for prohibition on the
1998
discharge effluent or waste. Sub-regulation 1
stipulates that no person shall discharge effluent or
waste on land or into the aquatic environment
contrary to the standards established by the
Authority in consultation with the lead agency
under section 26 of the National Environment Act,
Cap 153 unless he or she has a waste discharge
permit issued by the Director.

44
3.2. Institutional Framework

3.2.1. Ministry of Water and Environment (MWE)

Through its technical arm, the Directorate of Water Development (DWD), MWE’s responsibility is to
regulate the quality and quantity of water resources in the country. The Directorate of Water
Development majorly aims at promoting rational management and use of water resources of Uganda
by coordinating and regulating activities that may impact water quality and quantity. The quality and
quantity of water in water resources is specifically monitored by DWD’s Water Resources
Management Directorate (WRMD), which also issues permits for water abstraction and effluent
disposal.

3.2.2. Ministry of Gender, Labour & Social Development (MGLSD)

The Ministry of Gender, Labour and Social Development (MGLSD) which is the lead agency for the
Social Development Sector (SDS) has a mandate to empower communities to harness their potential
through cultural growth, skills development and labour productivity for sustainable and gender
responsive development. The Social Development Sector (SDS) promotes issues of social protection,
gender equality, equity, human rights, culture, decent work conditions and empowerment for
different groups such as women, children, the unemployed youth, internally displaced persons, the
older persons and persons with disabilities.

The Occupational Health Safety unit in the ministry is responsible for inspection and monitoring of
occupational safety and welfare of workers in workplaces. It is also responsible for issuing out
occupational permits to the different businesses for legal operation. In general, the MGLSD is
mandated to:

• Empower communities to appreciate, access, participate in, manage and demand


accountability in public and community based initiatives;
• Protect vulnerable persons from deprivation and livelihood risks;
• Create an enabling environment for increasing employment opportunities and productivity
for Improved livelihoods and social security for all, especially the poor and vulnerable;
• Ensure that issues of inequality and exclusion in access to services across all sectors and at all
levels are addressed; and
• Improve performance of Social Development (SD) institutions to coordinate and implement
the Social Development Investment Plan (SDIP) at various levels.

3.2.3. National Water and Sewerage Cooperation (NWSC)

The National Water and Sewerage Corporation (NWSC) is a public utility company 100% owned by
the Government of Uganda and was established in 1972 to sustainably and equitably provide cost
effective quality water and sewerage services to the delight of all stakeholders while conserving the
environment.

The Corporation is mandated to manage the water resources in ways which are most beneficial to the
people of Uganda and to:

• Provide water supply services for domestic, stock, horticulture, industrial, commercial,
recreational, environmental and other beneficial uses

45
• Provide sewerage services, in any area in which it may be appointed to do so under the Water
Act, to the extent and standards that may be determined by its corporate plan, any
performance contract, and regulations under the Water Act.
• Develop the water and sewerage systems in urban areas and big national institutions
throughout the country.

3.2.4. Mpigi District Local Government

Mpigi District Local government is mandated under the Local Government Act and the National
Environmental Act to ensure that the operations of any plant/facility within the district are compliant
with the National Environmental requirements.

3.2.5. Ministry of lands, Housing and Urban Development

The mandate of the Ministry of Lands, Housing and Urban Development (MLHUD) is “policy
making, standards setting, national planning, regulation, coordination, inspection, monitoring and
back-up technical support relating to lands, housing and urban development; promoting and
fostering sustainable human settlement; and, managing works on government buildings” in the
country. It ensures that the land on which the facility is to be established is owned by the developer
with the proper documentation (land titles and agreements where necessary).

46
4. PROJECT LOCATION AND DESCRIPTION

4.1 Site location

The project site boarders Kampala and Mukono in the East, Butambala in the west, Mityana in the
North-west, Mpigi and Waskiso in the South.

The proposed manufacturing and packaging factory will be located in Kiringente Sub County, Kavule
Parish, Mpigi District on land with boundary spatial coordinates 32.369192°E, 0.236105°N;
32.369103°E, 0.236572°N; 32.369958°E, 0.237263°N and 32.370838°E, 0.236723°N.

The proposed facility will occupy an estimated 4 acres of land. The site is neighboured by a swamp in
the south. East to the site is a tree treatment for energy facility and St. Lawrence School located in the
far South to the site. Nearly homesteads are neighbouring the project site within 200m.

47
Figure 4.1: Project Site Location

4.2 Project access road

The project site is accessed off Kampala-Masaka Road at Kavule Parish stage on the left hand side off
the main road. The site is about 781m from the main road through a murram straight road.

48
Project site

Figure 4.2: Access road to project site

4.3 Land Tenure system


The Land on which the proposed project is to be established is under a Mailo Land Tenure system
and is a private land owned by the developer. The copies of the land title together with the sale of
land agreement are attached in appendices (Refer to Appendix D).

4.4 The site


The proposed facility will occupy 4 acres of land being owned by the developer. The area
neighbouring the project area is characterised by tree plantations, scattered homesteads plantations
with mainly sweet potatoes and cassava approximately 100-300m from the project site. Brick making
is also carried out by the locals and such activities were seen south about 50m from the project site.
In addition, east of the project site is a wooden pole treatment plant about 300m from the site.
Within the project site is St. Paul Kavule church and Step by Step Infant school both located in the
north about 450m from the project site. Further still is St. Joseph of Nazareth High School located
across the main road in the north about 1km from the project site. The nearest trading centre is
about 780m from the project site.

4.5 Project Description


Ntungamo Real Foods Ltd (here referred to as the developer) intends to construct a factory that will
manufacture drinking porridge made from Sorghum and or Millet grains. The proposed project will
be capable of producing drinking porridge made from sorghum grains of 2.14 tons per day. The
project will make use of the project facilities described in section 4.6:

The execution of the project will follow a number phases as described below:

4.5.1 Project phases


The establishment of the proposed project will be done in phases which will be adequately monitored
and managed. This will follow pre-construction, construction and operational phases. In addition, the
project will also be decommissioned upon end of its lifespan as discussed in section 10 of this ESIS.

4.5.1.1 Pre-construction phase


This will involve ground plan preparation and acquiring necessary approvals from the relevant
authorities. In addition, other activities such as land clearance, soil stripping among others will be
undertaken.

49
4.5.1.2 Construction phase
The developer will execute the construction activities which will involve building the factory blocks,
offices, compound embankment, drainage system, internal access road, among others. The continuity
of this phase will involve other key activities that will be undertaken for successful completion of the
phase. These will include:

• Assembling of the materials and machinery that are required for construction activities,
• Hiring of relevant personnel to execute the activities within this phase,
• Ground water abstraction for use onsite.
• Starting of construction in relation to the site lay out plans/site ground plans,
• Making finishing on the facility,
• Connection to hydro power,
• Operation of the facility.

o Construction Materials and Equipment

During the construction phase, the key materials that will be used will not be limited to Reinforced
Cement Concrete (RCC) together with steel structures. The developer shall ensure that all input
components such as sand, cement, aggregate and steel will be acquired/bought locally to promote the
economic status of the local communities.

The construction works will done using the following equipment:

▪ Spades;
▪ Wheel barrows;
▪ Excavators;
▪ Concrete mixers;
▪ Peak axe;
▪ Welding machine among others.

However, all servicing and equipment maintenance works related to this component will be a
responsibility of the developer.

4.5.1.3 Operational phase


At this point, construction activities will be accomplished and the operation of the plant will be
commissioned. The operational activities at this stage will be highly monitored and adequately
managed in a manner that will not compromise the Health and Safety of workers as well as
protecting and conserving the environment following the National Environment Regulations. The
operational activities will mainly focus on: the production process and control; Occupational Health
and Safety, Waste Management, quality control & Assurance, air quality management, management
of noise levels emitted, Carbon Management (used oil), capacity building programmes such as
training, awareness/sensitisation activities, among others.

The manufacturing process at the facility will be done following a number of stages like raw material
preparation, the process design & control, quality control & assurance, packaging and storage of
finished goods and finally the distribution of these finished good. These are further explained below:

❖ Raw material preparation

The developer will buy clean grain from the local suppliers in order to avoid cleaning prior to
grinding. This will be done in order to reduce on the amount of wastewater to be generated by the
plant activities. Upon receiving the grain, quality control measures will be applied to ensure that the

50
grain being received at the facility is of the right quality and quantity. The grain will then be stored
appropriately, preferably in metal or plastic containers that will be hermetically sealed. This will be
done to permit an efficient application of the pest control fumigant (e.g. aluminum phosphate), and to
keep humidity and insects out. The humidity of the grain will be maintained below 13%. An efficient
pest control is strictly required, because these grains are very susceptible to insect attack. The grains
will be inspected every two months and if something improper is detected, action will be taken in
order to save the grain stored for production.

❖ Production of drinking porridge (Bushera)

The stored gains will be crashed using the grinding mill to produce the flour. The flour will then be
mixed thoroughly with treated water to form a uniform mixture which will then be boiled for a few
minutes (about 10 minutes of boiling) while continuous mixing is maintained, and then left to cool.

❖ Fermentation Process

At this production stage, the germinated sorghum flour/sorghum malt will be added to initiate
fermentation at ambient temperature (27-30°C). Fermentation will be carried out in well-designed
containers/cylinders at an ambient temperature. The cylinders will be covered in such a way to allow
aeration during fermentation. The fermentation period will differ depending on the type of drinking
porridge (Bushera) being produced, targeted consumers or consumer preference. For Sweet drinking
porridge (Bushera), the fermentation period will range between 12-24 hours whereas for Sour drink,
the fermentation time will range between two to four days. The ready produced drinking porridge
will then be packed in sterilised bottles branded ready for storage and later distribution for
consumption.

The detailed process flow diagram is illustrated below:

51
Figure 4.3: Process Flow Diagram

4.4.1.3.1 Machinery/equipment
The production will use a number of machinery/equipment such as:

• CTI Grinder
• Water Treatment equipment
• Boiler and Fermentation Tank
• Filling and sealing machine
• Raw material storage tanks

52
Table 4.1: Utensils that can be used with the CTI grinder

Item Function

Brush, soft and hard Piece of plastic hose Cleaning of the grinder after use. The hard brush to
clean the discs, the hose to blow away flour.

Agitator shaken by the helix. The spring type Moving the flour down when it is already quite fine
is most efficient
Small deposit or scooping deposit Small one to feed the grinder by hand, big one to fill
the hopper or to receive the product.
Metal plate with a small opening Reducing the flow of grain in the first pass.

Hopper, with retaining baffles, and an Storing material and feeding it to the grinder. An
opening at its base opening permits inspection.

Plastic bag fixed to the outlet, opened at the Receives or guides the product from the outlet and
bottom or not reduces the loss of product.
Amp meter Checks the current consumed by the motor.

Sieve Retains coarse particles of the flour.

4.6 Operational Facilities


The implementation of operational activities will be undertaken making use of the following facilities:

▪ Factory structure: where all the manufacturing processes will be done.


▪ Storage facilities: that will include storage rooms for raw materials and finished products
usually put up as warehouses.
▪ Water treatment equipment: that will be used for treatment of ground water abstracted
before feeding it in the process line.
▪ Waste storage facilities: where operation solid wastes will be stored at the site and
collected for disposal by licensed waste handlers/transporters. The staff will generate
black and grey water that will be disposed in a septic tank system. An effluent treatment
plant will be installed on site to handle processes wastewater.
▪ Waste water treatment plant: will be adopted and installed to ensure that all waste water
is treated before discharge to the environment.
▪ Gender sensitive sanitary facilities: will be set up on site for the employees. These will
also include the changing rooms with lockers.
▪ Pump house: that will be used for groundwater abstraction.
▪ Laboratory: to carry out analysis on water to be used and quality of the finished product.
▪ Office block: for administrative purposes.

4.7 Waste management


An effective and adequate management system will be developed to enable the proper handling of
waste generated. The implementation of the operational activities will generate both solid waste and
wastewater as well as human waste. The solid waste will be generated from the grinding process,
office work (paper waste), polyethene waste from packaging, food remains from the kitchen, food
damages and others. These will be stored (bins) at site and later collected by licensed waste
handlers/transporters and deposited in NEMA approved dumpsites.

53
Septic tanks will be installed at the site to handle faecal sludge that will be generated during the
operational phase. This will also be collected and transported by the NEMA approved waste handlers
who will dispose it of at NWSC sewage treatment plant in Lubigi.

Wastewater management

The implementation of operational activities shall involve activities (especially cleaning of equipment)
that will generate wastewater. Wastewater discharged from soft drink beverage industries usually is
contaminated by organic substances, high pH, COD, BOD, nitrates, phosphates, sodium and
potassium. If not treated and discharged directly, would pollute the environment and lead to even
lead to loss of aquatic life in the receiving environment. It is against this background that the
developer will install anaerobic ponds for treating wastewater generated before discharge to the
environment.

The design of anaerobic ponds to treat wastewater is based on the system Volumetric BOD 5 loading.
However, before wastewater is treated, it is important to reduce on the quantities of wastewater
generated as much as possible through application of cleaner production measures. The design of the
treatment ponds be adopted basing on the mass balance below:

The design Mass Balance can be illustrated below;

Li
V

- Volumetric BOD5 loading = Li Q/V......................................1

Li - Influent BOD5, mg/L (= g/m3)

Q - Volumetric flow rate, m3/d

V - Volume = (Area* Depth), m3

Detention time = V/Q, days

Taking an average temperature, T = 25°C for Mpigi District

Sizing up of the Treatment Plant

ʎ = 10T + 100, T=25°C, from Mara equation

ʎ = 350 g/m3/d

Li = 1000 g/m3

Width (W) = 5m Length (L) = 8m (Area (A) = 5*8)

54
A = 40m2 Depth (D) = 2.5m

Volume (V) = (40*2.5), V = 100 m3

Re-arranging equation 1 gives the value of Q = 35 m3/d

Detention time (Td) = V/Q, Td = 3 days

Generally, the treatment plant that will be adopted shall cover an area of 0.01 acre, having a
volumetric BOD loading of 350 g/m3/d with a volumetric flow rate of 35 m3/d, volume of
100,000Litres and detention time of 3 days. The ETP will require two anaerobic plants in parallel to
assist in back-washing while the factory continues to run. The treatment wastewater will be anoxic
hence a weir will be constructed to guide the treated effluent into a natural wetland downstream.

The operation of the facility will be in compliance with the Public Health Act, Cap 281, the
Occupational Safety and Health Act, 2006 and National Environment (Waste Management)
Regulations, 1999.

Quality control

The treated wastewater will be monitored by the developer to ensure compliance of the effluent
quantity and quality with NEMA discharge standards. These monitoring records will be kept
adequately and submitted bi-annually to NEMA.

4.8 Water usage


The implementation of the proposed project will utilise abstracted water from the ground. After
ground water abstraction is done, the water will undergo treatment to a standard required for the
production process.

4.9 Energy usage


The proposed facility will use hydroelectricity power from the national grid and fuel oil for the
standby generators to run the plant and other operational activities.

4.10 Labour requirement


The facility will have at least 30 people in the initial operational phase as its direct personnel. In
addition, about 50 more workers will be recruited in the later stages of operation to carter for all
activities such as transportation, distribution, marketing among other.

The requirement of personnel for the proposed project will be made keeping in view of the following:
• Technical concept of plant, including process control and instrumentation.
• Smooth and efficient operation of the plant.
• Effective co-ordination between the various departments within the plant.
• Optimum organization with well-defined and judicious job distribution
• Optimum utilization of different grades of workmen and supervisory staff and
• Maximum capacity of the facilities.
• A gender sensitive recruitment system: The developer intends to recruit approximately 100
employees during implementation of construction and operational activities/production
stages.

55
4.11 Occupational Health and Safety (OHS) Management
The health and safety impacts of the construction and operation of the project activities are discussed
in section 7. Such impacts would potentially affect the health and output of the workers and hence
affecting production. This would potentially reduce on the performance of the environment. The
workers shall be provided with full protective wear while onsite. In addition, the developer shall
develop a comprehensive and adequate OHS Management Plan that shall incorporate the training
programmes on OHS during project implementation and the records shall be well documented. An
Emergency Response Plan will also be developed and well popularised amongst all workers. Before
commencement of project activities i.e. construction and operational activities, the developer will
register with the Ministry of Gender, Labour and Social Development under the department of
Occupational Health and Safety (OHS).

56
5. ENVIRONMENTAL SETTING
This chapter highlights the data on biophysical and socio-economic characteristics of the proposed
project area with a view of inaugurating the current environmental baseline, against which future
impacts will be measured. It provides information on general topography, climate, rainfall,
temperature, hydrology, groundwater conditions and availability, drainage, existing and future land
use and environmental sensitivities.

5.1. Mpigi District Baseline

5.1.1. General physical environment

5.1.1.1. Location

Mpigi District is one of the districts of Uganda situated in the Central Region of the country, often
referred to as Buganda Region. Mpigi District is bordered by Wakiso District to the North and
East, Kalangala District to the South, Kalungu District to the Southwest, Butambala District to the
West and Mityana District to the Northwest. The District lies on the shores of Lake Victoria, the
largest fresh water lake on the Continent of Africa. The Equator, a natural spectacular phenomenon
traverses the district at Nabusanke in Nkozi sub-county and River Katonga, one of Uganda’s longest
rivers that joins Lake Victoria to Lake George traverses the district in Nkozi Sub County. The town
of Mpigi, where the district headquarters are located, lies approximately 37 kilometres (23 mi), by
road, west of Kampala, Uganda's capital and largest city. The coordinates of the district are: 00 14N,
32 20E.

57
N

Mpigi District

Figure 5.1: Map showing location of Mpigi district

5.1.1.2. Climate

Mpigi district lies within the Lake Victoria basin. The climatic conditions in Mpigi are warm, muggy,
and overcast with relative humidity. Over the course of the year, the temperature typically varies
from 62°F to 82°F and is rarely below 59°F or above 87°F.

❖ Rainfall

The District experiences a bi-modal rainfall pattern with first rains occurring between March and May
and second rains coming between September and November with an average rainfall amount of 1320
mm though in many areas around the Lake zone it is between 1750mm and 2000mm. The bi-modal
type of rainfall is conducive for rain fed agricultural production throughout the year and crops
mainly grown include bananas, tobacco, coffee, maize, beans and tea. Up-land rice and cocoa are
increasingly gaining importance in the District.

❖ Temperature

Mpigi District has an average annual maximum temperatures ranging between 22.5 0C and 27 0C.
Average relative humidity ranges between 80% and 95% especially in forest areas. The average
monthly days of rainfall are 11. The minimum temperature in the district is 11 0C while the maximum
recorded is 27 0C.

58
❖ Clouds

In Mpigi, the average percentage of the sky covered by clouds experiences significant seasonal
variation over the course of the year. The clearer part of the year in Mpigi begins around June 7 and
lasts for 3.7 months, ending around September 29. On August 27, the clearest day of the year, the sky
is clear, mostly clear, or partly cloudy 54% of the time, and overcast or mostly cloudy 46% of the time.
The cloudier part of the year begins around September 29 and lasts for 8.3 months, ending
around June 7. On April 18, the cloudiest day of the year, the sky is overcast or mostly cloudy 85% of
the time, and clear, mostly clear, or partly cloudy 15% of the time.

❖ Precipitation

A wet day is one with at least 0.04 inches of liquid or liquid-equivalent precipitation. The chance of
wet days in Mpigi varies very significantly throughout the year. The wetter season lasts 9.1 months,
from August 24 to May 27, with a greater than 59% chance of a given day being a wet day. The chance
of a wet day peaks at 85% on April 11. The drier season lasts 2.9 months, from May 27 to August 24.
The smallest chance of a wet day is 32% on July 3. Among wet days, we distinguish between those
that experience rain alone, snow alone, or a mixture of the two. Based on this categorization, the most
common form of precipitation throughout the year is rain alone, with a peak probability
of 85% on April 11.
❖ Sun

The length of the day in Mpigi does not vary substantially over the course of the year, staying
within 8 minutes of 12 hours throughout. In 2018, the shortest day is December 22, with 12 hours, 7
minutes of daylight; the longest day is June 21, with 12 hours, 8 minutes of daylight. The earliest
sunrise is at 6:31 AM on November 3, and the latest sunrise is 31 minutes later at 7:01 AM on February
12. The earliest sunset is at 6:37 PM on November 1, and the latest sunset is 31 minutes later at 7:08
PM on February 11.

❖ Humidity

Mpigi district experiences extreme seasonal variation in the perceived humidity. The muggier
period of the year lasts for 10 months, from August 23 to June 26, during which time the comfort level
is muggy, oppressive, or miserable at least 52% of the time. The muggiest day of the year is May 5,
with muggy conditions 91% of the time. The least muggy day of the year is July 20, with muggy
conditions 39% of the time.

❖ Wind

The wind experienced at any given location is highly dependent on local topography and other
factors, and instantaneous wind speed and direction vary more widely than hourly averages. The
average hourly wind speed in Mpigi experiences mild seasonal variation over the course of the year.
The windier part of the year lasts for 3.3 months, from May 5 to August 15, with average wind speeds
of more than 5.8 miles per hour. The windiest day of the year is July 3, with an average hourly wind
speed of 7.3 miles per hour. The calmer time of year lasts for 8.7 months, from August 15 to May 5.
The calmest day of the year is November 3, with an average hourly wind speed of 4.4 miles per hour.

The predominant average hourly wind direction in Mpigi varies throughout the year. The wind is
most often from the south for 8.3 months, from January 26 to October 3, with a peak percentage
of 81% on July 3. The wind is most often from the north for 1.1 months, from October 3 to November
5, with a peak percentage of 30% on October 12. The wind is most often from the East for 2.7 months,
from November 5 to January 26, with a peak percentage of 34% on January 1.

59
5.1.1.3. District Land Tenure system

Freehold land tenure is the largest land ownership system in the district followed by Mailo and
customary land ownership (Table 5.1). The average size of holdings varies, in Mawokota and parts of
Butambala counties holdings range from 1-3 acres while in Gomba County holdings range from 4
acres to as many as 200 acres in Maddu Sub-County that lies in the cattle corridor. The environment
conservation practices and interventions thus vary, for instance in Mawokota and Butambala due to
inadequate land, fallows are not practiced.

Table 5.1: Land Tenure in Mpigi

Area specific Free hold % Mailo % Leasehold % Customary %


Mpigi District 27 23 5 22
Butambala 26 18 6 29
Gomba 23 30 7 26
Mawokota 31 20 3 17
Source: Mpigi District Local Government, 2007

5.1.1.4. Land cover

The District has a total land area of 3075.7 km2 of which 1025 km2 is arable land. Area under crop
cover is approx. 37.5% and area covered by forests is approximately 1099.6 km2. With an average
rainfall of 1320 mm p.a. and temperatures ranging between 22.5 – 27°C, the district has favorable
climate for agriculture and forest growth. Land cover is therefore a combination of tropical high
forests, woodland, grassland, wetlands and arable land (Figure 5.2). About 90% of the people in the
district live in rural areas and depend on agriculture (subsistence). Land therefore supports
livelihoods, plant and animal life.

Figure 5.2: Land use/Land cover Map of Mpigi District

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5.1.1.5. Topography, Geology and Soils

The district lies in the central plateau of Uganda, which comprises undulating hills with deeply
incised valleys. The hill summits lie between 1,182 and 1,341 meters above sea level. Seasonal and
permanent streams drain much of the low-lying areas. The underlying rocks mainly comprise rocks
of Precambrian age that are highly weathered. The most dominant rocks being of the Buganda-Toro
system. In addition, most of the sub counties have undulating flat topped hills that have presented a
range of opportunities including enabling rain formation and construction of Gravity Flow Schemes
(GFS) for instance in Mpigi Town Council and Muduuma sub counties (Bujuuko Trading Center). The
topography and geology provides abundant gravel and rocks resources used in construction. In areas
with relatively flat terrain, it presents an opportunity for large scale animal rearing as in the area of
Maddu and Kabulasoke sub counties.

Soils are mainly of the Buganda Catena and are combinations of clay and sandy loams resulting in
sandy clay loams. The soils are relatively fertile and favorable for crop production. Most soils
however require soil engineering and vegetative soil conservation. Soils on hills tend to be thin and
unsuitable for cultivation and are therefore mainly used for grazing under natural vegetation. Poor
farming practices have resulted in loss of fertility in most parts of the district thus reducing on
productivity.

5.1.2. Ecological components

5.1.2.1. Vegetation

Mpigi District is characterized by evergreen vegetation with many seasonal wetlands and few areas
with savannah type of vegetation. The savannah vegetation is typical for human activities. The thick
forests especially those on private land are being used for timber harvesting although this poses a
threat of environmental degradation since reforestation and afforestation are very limited.

5.1.2.2. Wetlands

5.1.2.2.1. Coverage and Types of Wetlands

Wetlands cover 719 km2 of the district total area. Majority of wetlands in the district are permanent in
nature and lie in the fringes of Lake Victoria and the seasonal wetlands are found in forest areas and
grasslands. Wetland types may be characterized by reeds (papyrus), palms and thickets, forest
woodlands and non-papyrus bushes.

5.1.2.2.2. Wetland Systems

The available broad categories are lacustrine and riverine wetlands. These form one major wetland
drainage system, the Lake Victoria Drainage System. The lacustrine includes areas bordering Lakes
Victoria and Wamala. Wetlands to the Lake Victoria drainage system form a very extensive periphery
to the north western shore of the lake. The riverine wetlands include mainly Katonga region and
rivers with indefinite water courses embedded in deeply incised valleys examples are Nakeitema,
Nawandigi, and Kibukuta. These form part of the Lake Victoria catchments and have a close link with
the lake in terms of hydrology and soils.

Flora in the permanent wetlands mainly comprises of papyrus while the seasonal wetlands have got
spear grass scattered with thickets and palms. The permanent swamp forests are dominated by
Raphia sp. palms and in some areas Calamus sp (rattan canes) with Albizia sp, Piptadeniastum sp. and

61
Celtis sp. on the fringes with some forested areas. Fauna in the permanent wetlands includes sitatunga
and bushbuck. Plenty of monkies can be found in the swamp forests such as the Red-tailed and the
Black and White Colobus. Wetland fish includes catfish and lungfish. Major bird found in these areas
is the crane.

Table 5.2: Drainage systems in Mpigi district

Wetland name Area (km2) Type Location/sub-county


Buyinja 50.5 P Maddu
Degeya 2.7 P Mpigi
Kabasuma 10.5 P Kyegonza
Kalungi 8.0 P Kammengo/Budde
Kasemulamba 3.9 P Nkozi/Kituntu
Katonga 273.4 P/S Maddu/Kabulasoke/Ngando/Kituntu/Nkozi
Kibimba 134.0 P Kyegonza/Kabulasoke
Kibukuta 23.5 P Buwama/Nkozi/Kituntu
Kinyika 2.6 P Kituntu/Nkozi
Muyanga 25.1 P Ngando/Kituntu/Bbulo/Kyegonza
Nabakazi 47.2 P Mpigi/Mubende boundary
Nakyetema/Lutindo 32.0 P Kammengo/Mpigi
Nawandiga 22.0 P Budde/Buwama/Kammengo
Sembula 24.5 P Ngando/Kabulasoke/Kyegonza
Kibiga Buwama
Mutokowe Buwama
Kabengere Mpenja
Namulondo Kyegonza
Kamirango Kyegonza

*P- Permanent; S –Seasonal

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Figure 5.3: Map of Mpigi Wetlands

5.1.3. Socio-Economic Profile

5.1.3.1. Population characterisation

According to the Uganda Bureau of Statistics 2017, The National Population and Housing Census
2014. Area Specific Profile Series, Kampala, Uganda. Mpigi district has a population of 250,548
comprising of 128,203 males and 122,345 females. The district has a sex ratio of 104.8 (males per 100
females) implying that for every 104.8 males, there are 100 females. The district also has a total of
60,521 households of which the majority (70.6%) are headed by males followed by youth (aged 18-30)
with 29.8%, females with 29.4%, older persons (aged 60 and above) with 16% and the rest headed by
children (aged 10-17).

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Table 5.3: Total population trend of Mpigi District

The population of Mpigi district has had an exponential increase as of 1991 to 2017 with a percentage
increase of 40.9% as well as a percentage change of 2.11% per year.

Population census Population census Population Census Population


Name 1991 2002 2014 estimate 2017

Mpigi 157,368 187,771 250,548 266,400


district

Area: 1,541.13 km2 (595.03 sq. mi) – Density: 172.86 people/Km2 – Change: 2.11%/year [2014-2017]

Elevation: 1,207m (3,959.97ft)


Source: Uganda Bureau of Statistics, 2017

5.1.3.2. Population Distribution

Population distribution portrays the way people are spread out across the proposed project region.
Below is a depiction of how the population is distributed according to sex, source of energy, survival
status, disability status and marital status.

Females
Males
49%
51%

Figure 5.4: Distribution of Population by Sex (Source: Uganda Bureau of Statistics, 2017)

Table 5.4: Distribution of Households by source of Energy for Lighting, Sex and District

Mpigi Electricity Gas Paraffin Paraffin Candles Firewood Others Total


district Lantern Tadooba

13,314 388 9,140 31,103 2,398 590 3,588 60,521

(Source: Uganda Bureau of Statistics, 2017)

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Table 5.5: Distribution of Households by source of Energy for Cooking, Sex and District

Electricity Gas Paraffin Charcoal Firewood Others Total


Mpigi district stove

1,008 269 635 14,621 42,417 646 60,521

(Source: Uganda Bureau of Statistics, 2017)

Table 5.6: Distribution of Children below 18 years By Survival Status of Parents by District

Both Mother alive & father Father alive & Both Total
Mpigi alive dead mother dead dead
district
122,337 6,879 3,071 1,738 134,025

(Source: Uganda Bureau of Statistics, 2017)

Table 5.7: Population Distribution by Disability Status and District

Disability Type of disability


Mpigi
district Without a With a Seeing Hearing Remembering Walking
disability disability

210,160 22,763 13,648 6,079 8,009 9,702

(Source: Uganda Bureau of Statistics, 2017)

Table 5.8: Population Distribution of Children aged (12-17 years) by marital status and Gender

Currently married Ever married (including currently married)


Mpigi district
Male Female Total Male Female Total

1.0 4.5 2.7 1.2 5.2 3.1

(Source: Uganda Bureau of Statistics, 2017)

5.1.3.3. HIV/AIDS Analysis and Control

The Local Government has been implementing activities to reduce the speed at which HIV/AIDS
spreads among the people of the district. According to the Mpigi District Development Plan II for the
Years 2015/2016 to 2019/2020, HIV/AIDS still remains a big problem in Mpigi District. Although
there was tremendous decline in the prevalence rate since 1993, Mpigi district still has a stagnated
prevalence rate of around 12% since 2005. The prevalence rate is unacceptably still very high
compared to the National average of 6.5 per cent. HIV/AIDS has affected the productive and
reproductive segments of the population, creating a big population of HIV infected individuals and
creating a crisis of orphans when their parents/guardians die.

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According to the 2009 Mpigi District Statistical Abstract, HCT/VCT services are offered in all the
hospitals, HC IVs and a few HC IIIs. HCT/VCT services however have not been extended to HCIIs.
Mpigi district has 27 HIV-counselling centres and 5 VCT service centres. The district recorded 1,228
HIV- positive people as being on ARVS treatment and the number of health facilities offering PMTCT
(Prevention of Mother to Child Transmission of HIV) services is 27.

Table 5.9: ART services for the period 2005/2006 - 2008/2009

2005/2006 2006/2007 2007/08 2008/09


Indicators
<5yrs >5yrs <5yrs >5yrs
M F Total M F Total Total Total
No. 4 203 303 510 24 304 545 873 1650 1228
eligible
for ART
No. 2 127 235 364 11 129 219 359 721 551
enrolled
for ART
% 50% 62.56 77.56% 71.37% 45.83% 42.43 40.18 41.12 43.7% 44.87%
enrolment % % % %
Source: Mpigi District Development Plan II for the Years 2015/2016 to 2019/2020

5.1.3.4. Gender Analysis

Gender development is considered a key component of the general development of the district.
Despite the district being gender responsive in the top district management where positions are
equally distributed with for instance the District Chairperson being a male and the Chief
Administrative Officer being a female, gender issues are still alarming when it comes to other
departments and sectors.

Table 5.10: Gender Analysis in the Mpigi district

Sector / Department Gender Issues and Concerns


Administration and Management The ratio of male to female employees is 7:3 of the total work
force in the Department.
Finance Fewer women than men are in gainful employment in the
District. The approximate ratio is 3 women to 7 men.
Production and Marketing Reduced adoption of new agricultural technology due to high
illiteracy rate among women compared to men and low
participation of women in agricultural training; inadequate
involvement of women in agricultural investment due to their
limited control of productive resources especially land and
capital; reduced agriculture production due to unequal sharing
of roles and responsibilities between men and women; unequal
sharing of means to production and proceeds contributing to
domestic violence.

Health The male involvement in most of the health programmes is


relatively low compared to the female especially in reproductive
health services, community participation/involvements and
community sanitation and hygiene promotion programmes.
Education and Sports Only 41% of the teaching work force is female, 48% of children in

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schools are girls. There is low attendance and high dropout rate
(35 %) among the girls in the rural primary schools compared to
boys.
Works and Technical services Low participation of women compared to men in road works
due to the general misconception that roads and building works
are for male only. The level of women participation in building
works is relatively lower, there is under representation of women
in planning for road projects.
Natural Resources Management • Derived from the culture and customs of the people, land
ownership in Mpigi District is dominated by men. Women,
widows and children are denied ownership and control over
land which affects production at household level and
generating land disputes.
• Largely men control proceeds from natural resources (forest,
wetlands, farms etc.) which has contributed to increased
conflicts in the family, degradation of forests and wetlands.
Source: Mpigi District Development Plan II for the Years 2015/2016 to 2019/2020

5.1.3.5. Education

The education sector is one of the best funded sectors in Mpigi district. According to the Education
Department, Mpigi district Local government, the district has 110 government aided and 193
privately owned primary schools.

Table 5.11: Number of primary schools by ownership by Sub-county

Sub county Government Aided Private


Buwama 19 45
Kammengo 22 33
Kiringente 10 17
Kituntu 11 17
Mpigi Town Council 17 29
Muduuma 13 23
Nkozi 18 29
Total 110 193
Source: Education Department, Mpigi district local government (2017)

According to the Uganda Bureau of Statistics 2017, the number of persons aged 6-12 attending
primary school is 45,077 of which 23,146 are males and 21,931 are females. The number of persons
aged 13-18 attending secondary school is 14,285 of which 6,615 are males and 7,670 are females.
Furthermore, the number of persons aged 6-15 not attending school is 5,037 of which 2,906 are males
and 2,131 being females.

5.1.3.6. Poverty status

According to the Mpigi District Development Plan II for the Years 2015/2016 to 2019/2020, there has
been a declining trend in absolute poverty evidenced by the general increase in expenditure on non-
food goods and services such as household radios, bicycles, improved houses and entertainment. The
general decline in absolute poverty was observed and noted in both rural and urban areas. However,
the gap between the rural and the urban areas has been increasing as reflected by levels of and

67
differentials in unemployment, patterns of expenditure and consumption of the people in the
different areas. Thus, the percentages of people in urban centres above the poverty line were at a
relatively higher percentage than their counterparts in the rural sector with respect to the poor and
the rich.

The plan further reveals an increasing gap in earning money income and a declining gap with respect
to real income. This is due to the introduction and increasing public expenditure on PHC, UPE, rural
water supply, rural feeder and access roads, agricultural extension, security and FAL which benefit
the majority poor in the district. While the rich with more money income access services in private
schools, health units and luxury firms, the poor have access to basic public services of life (Primary
education, health care, transport, water and extension).

5.1.3.7. Water situation status

According to the 2018 Uganda Water Supply Atlas, water access rates in Mpigi vary from 62 % in
Mpigi TC Sub-County to 95 % in Muduuma Sub-County. Mpigi has 1,046 domestic water points
which serve a total of 218,490 people of which 189,328 are in rural areas. 286 water points have been
non-functional for over 5 years and are considered abandoned. Mpigi has 1 piped scheme. Of the total
population in Mpigi district, 80 % have access to safe water, 84 % and 62 % of the rural and urban
households respectively have access to safe water, 72% of the rural water points are functioning, 64
water points are equally distributed among the households and 94% of the district water points are
properly managed. The Atlas also reveals that water access in Mpigi district is 86% gender
responsive.

In regards to technology, 16% of the population is served by protected springs, 69% by shallow wells,
13% by deep boreholes and the rest by public taps. Of the 1046 domestic water points, 80% are
communally managed, 8% are institutionally managed, 8% are managed by private operators and the
rest are individually managed. In addition, 53% of the water points are funded by the local
government, 30% by NGOs, 7% by central government, 6% by others and the rest are privately
funded. The non-functionality of the 286 water points is majorly attributed to technical breakdown
which accounts for 48%, water quality with 17%, low yield with 13%, vandalism with 6% and the rest
is attributed to WSC NF, leaking, alternative nearby and others which account for 4% each.

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Figure 5.5: Access to safe water in Mpigi district (Uganda Water Supply Atlas, 2018)

Table 5.12: Access to save water in Mpigi District on a sub-county level

Divisions/sub-counties Percentage of population Population

Buwama (BWM) NWSC NWSC

Kammengo (KMM) 95% 40,327

Kiringente (KRN) 95% 23,572

Kituntu (KTN) 95% 22,988

Muduuma (MDM) 95% 31,755

Mpigi TC (MTC) 62% 29,162

Nkozi (NKZ) 76% 34,766

Source: Uganda Water Supply Atlas, 2018

5.1.3.8. Economic Status

❖ Tourism:

The district has diverse core attractions but unexploited for tourism such as the L. Victoria shoreline,
Equator, Forests, cultural sites, river spots and sceneries. The following are the tourist sites found in
the district; the Uganda Equator Monument at Kayabwe, Mpanga Eco Tourism site, Katebo Crocodile
Site, Landing Sites and Beaches on Lake Victoria, Cultural Sites (Kibuuka Omumbaale and Baganda
Clan sites, Namirembe cultural site), Nsamizi Institute of Socio Development, Nkozi University, River

69
Katonga, Nkozi Hospital and Bird Watching. In addition, the district has got hospitality centres which
include resorts, guest houses and restaurants.

Figure 5.6: The Uganda Equator Monument at Kayabwe in Mpigi district

❖ Fishing & Fish farming:

Mpigi district boarders with Lake. Victoria and has a number of streams where fishing is done. The
major types of fish include; Nile perch, tilapia, lung fish, silver fish, and many others. Capture fishing
is the main fishing activity in the district which has 24 landing sites and 17 beach Management Units
(MU). The Katonga Bay which contributes much to fish catch in the district has four main fish landing
sites; Katebo in Buwama Sub County, Namirembe, Namugeye and Kiwami Landing sites in Nkozi
Sub County. The Sanya Landing site in Kammengo on Mabamba wetlands in the Lake Victoria basin
is also another important fishing area. Some wetland fish species including Clarias spp. and Protopterus
spp. have been found common in landing sites with large expanse of wetlands such as Sanya in
Kammengo and Namirembe and Kiwami in Nkozi Sub County. Fish farming is mainly done by the
private sector.

According to the Mpigi District Development Plan II for the Years 2015/2016 to 2019/2020, there is
slight increase in fish supply from natural water bodies. However, due to population increase over
the years, the demand of fish continues to shoot up beyond supply level, which resulted in decrease
in per capita consumption from 8Kg/year to 5Kg/year between 2010 and 2014. This higher demand
in fish consumption can only be bridged through fish farming (aquaculture) given the resources
within the district.

70
❖ Economic Infrastructure:

The district is traversed by two great roads that connect to neighbouring countries of Tanzania,
Rwanda and DRC Congo (Kampala-Masaka-Katuna Road and Kampala-Fort portal Highways) and a
well-developed road network of feeder and community access roads. Many parts of the district are
connected to national power grid and the district has four rural gross centres and Town council that
have access to piped water. There are 14 established markets which deal in various food stuffs and
merchandise. The district is well covered by all telecommunication networks and as a wider coverage
of both community and regional radios.

❖ Training Institutions:
The district has two universities (Uganda Martyrs University and Nsamizi Institute of Social
Development) and one technical school (Katonga Technical Institute). The district also has vocational
training institutions in various sub-counties.
❖ Financial Services:

The district’s financial sector is composed of both local and multi-national Commercial Banks
(Centenary Bank and Stannic Bank), Micro-Finance Institutions (Vision Fund, Mwodet, and Mednet),
Savings and credit cooperative societies (SACCOs). Given the micro and small scale operation of
businesses in the district, Micro-Finance and SACCOs take up the biggest financial services clientele.

❖ Mining:

Mpigi district is enriched with minerals with the notable ones being clay and sand. Sand and clay
mining are among the economic activities undertaken in the district but those have reached to an
extent of being declared illegal given the outcomes of sand mining. Sand mining is being majorly
carried out in Lwera wetlands in Nkozi sub-county which has hindered fish farming because of
encumbrances in the wetland drainage which hinder easy flow of water out of the ponds and the fact
that sand mining interferes with fish ecology. Besides fish farming, sand mining coupled with climate
change lower the water tables which eventually lead to the drying up of some water sources. Other
mining sites in Mpigi district include Kyabadaaza-Kabuye, Budde Sub-county, Nsumba North Sand
pits, Kammengo Sub-county, Nsumba South Sand pits, Kammengo Sub-county and others.

Kammengo
Lwera mining Mining site
site

Figure 5.7: Mining sites in Mpigi district

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❖ Industry:

The industrial sector of the district is pre-dominantly engaged in agro-processing (coffee


processing, maize milling and fruit packing), floriculture, power generation, plastic recycling, brick
making and concrete products, drum making and crafts.
❖ Agriculture:

Agriculture is the dominant economic activity in Mpigi with 79% of the Households deriving their
livelihood from it. The main agricultural activities include Crops farming; Livestock management,
Poultry and Fish farming. The Main crops grown include Banana, Coffee, Cassava, Sweet Potatoes,
Maize, Millet, Beans, Ground Nuts, Rice, Sim-sim, Cowpeas, Sorghum, Pigeon Peas, Onions, Irish
Potatoes, Field Peas and others. According to the Mpigi District Development Plan II for the Years
2015/2016 to 2019/2020, agriculture employs 85% of the population that practice integrated farming
systems comprising of crop growing, livestock, aquaculture and apiculture.

❖ Energy:

Mpigi district is renewable and non-renewable sources of energy talk of biomass, hydropower, solar
energy, natural gas, petroleum and others. According to the 2014 National Population and Housing
Census, 66.49% of 60521 households in Mpigi district use paraffin as a source of energy for lighting,
22% use electricity, 0.64% use gas, 3.96% use candles, 0.97% use firewood and the rest use other
sources of energy for lighting. When it comes to using energy for cooking, 70.09% of the households
use firewood, 24.16% use charcoal, 1.7% use electricity, 1.05% use paraffin, 0.44% use gas and the rest
of the households use other sources of energy for cooking.

5.2 PROJECT BASELINE

This section presents the project area/site prevailing characteristics / information as per its current
status. These are discussed as follows:

5.2.1 Location

The project site boarders Kampala and Mukono in the East, Butambala in the west, Mityana in the
North-west, Mpigi and Waskiso in the South.

The proposed plant will be located in Mawokota County, Kiringente Sub County, Kavule Parish,
Mpigi District on land with boundary spatial coordinates 32.369192°E, 0.236105°N; 32.369103°E,
0.236572°N; 32.369958°E, 0.237263°N and 32.370838°E, 0.236723°N. The facility will occupy an
estimated 4 acres of land. The site is neighboured by a swamp in the south. East to the site is a tree
treatment for energy facility and St. Lawrence School located in the far South to the site. Nearly
homesteads are neighbouring the project site within 200m.

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Figure 5.8: Project site Google maps

73
5.2.2 Access road

The project site is accessed off Kampala-Masaka Road at Kavule Parish stage about 781m using the
murram road to the left hand side of the main road. This murram road is a straight road to the project
site.

Project site

Figure 5.9: Access road to project site

5.2.3 Land Tenure System


The Land on which the proposed project is to be established is under a Mailo Land Tenure system
and is a private land owned by the developer. The copies of the land title together with the sale of
land agreement are attached in appendices (Refer to Appendix D).

5.2.4 Baseline Physical-chemical Environment


This section provides the scientific physical and chemical characteristics of the project site.

5.2.4.1 Air quality


The proposed site is currently vacant with no significant green vegetation. However, it is
neighboured by a swamp in the south and a tree treatment for energy facility in the east. The area is
sparsely populated with no significant industrial activities taking place. Onsite air quality

74
measurements were carried out and results captured and recorded. The results are illustrated in Table
5.13 below;

Table 5.13: Recorded air quality of the project area

Sampling locations* CO CO2 (%) SO2 NO NO2 HC Possible


(ppm) (ppm) (ppm) (ppm) (mg/ sources
Nm3)

Draft Air Quality


Standard for Ambient 2.0 - 0.15 0.10 0.10 5.0
Air

Northern part to the Motor


site cycle
ND 0.10 ND ND ND 0.2
emissions

Western part(Last point None


ND ND ND ND ND ND
of the land)

Southern point Burning of


ND 0.1 ND ND ND 2.5
(Adjacent swamp) Bricks

Middle of the site Motor


ND 0.01 ND ND ND 0.2 cycle
emissions

Eastern Boundary Motor


cycle
emissions
& activities
ND 0.15 ND ND ND 0.4
from the
tree
treatment
plant

ND – Not detected

Overall, the observed values in the areas sampled were within background concentrations typical of
an undisturbed environment, and were within the Draft National Air Quality Standards.

5.2.4.2 Noise Levels


During the site visit, measurement of ambient noise levels was conducted to establish the project site
baseline noise levels that will guide the implementation and monitoring of project activities. The
obtained results from different point locations of the project site were captured and recorded as
follows:

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Table 5.14: Recorded noise levels at the project site

Noise Recorded noise level Existing noise sources


limit
Location Start (dB(A)
description time End LEQ)** LEQ L90 L50 L10 Natural Anthropogenic

Near to the 8:50 9:05 45 30.0 32.9 30.0 30.1 Birds, Moto-cycle,
Northern insects human chatter
boundary of the
site at the entrance
to the site

Approximately 20 10:11 10:26 45 31.1 33.2 35.0 35.2 Birds, Moto-cycle,


metres from the insects (distant)
northern part of the
site

Last point on 11:01 11:16 45 28.6 29.3 29.1 35.1 Birds, Moto-cycle,
western side of the wind (distant)
site gust animal farm
house

Last point of the 12:21 12:36 45 36.5 35.9 37.4 34.3 Birds, Local members
land on the insects, making bricks
southern part of the dog near the
proposed site sampling point

Approximately at 12:60 13:10 45 29.56 29.8 30.2 30.9 Birds, Barking dog,
the centre of the insects
land

Background noise levels were generally within levels normally expected of the rural setting within
which the proposed site is located. During measurement, LEQ levels at all sampled sites were within
maximum permissible daytime noise levels prescribed in the national regulations.

5.2.4.3 Surface water quality


A water sample was taken from the swamp located south of the project site and taken for analysis at
Makerere University. The assessment of surface water quality was undertaken to establish the
baseline physio-chemical prevailing water characteristics which shall be used to guide the
implementation and monitoring of project waste management activities during the pre-construction,
construction and operational phases. The results attained during the laboratory analysis were noted
and well recorded (Table 5.15).

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Table 5.15: Water quality results

S/N Parameter Units Results


1 EC µS/cm 344
2 pH 7.22
3 TDS mg/L 172
4 Colour Pt-Co units 150
5 Turbidity NTU 4
6 TSS mg/L 14
7 Total Hardness mg/L as CaCO3 140
8 Total Alkalinity mg/L as CaCO3 48
9 Chloride mg/L 14
10 Sulphate mg/L 4
11 TP mg/L 3.64
12 TN mg/L 1.44
13 COD mg/L 55
14 BOD5 mg/L 17

5.2.4.4 Soil and topography


The proposed site is flat and underlain with both silt and clay soils.

Figure 5.10: Topography and soils at the site

5.2.4.4.1 Soil characteristics


A geotechnical investigation was carried out by Teclab Limited to assess the strength and bearing
capacity of the project site as well as the level or presence of groundwater within the site. Excavation
of two trial pits was done and the soil sample was analysed for Dynamic Cone Penetration (DCP) test
and other Laboratory work was conducted such as Classification test and Shear Strength test
(Appendix F).

77
Dynamic Cone Penetration Tests
Based on the DCP results, the soil characteristics/properties have been categorised as described in
Tables 5.16 & 5.17 below. The allowable bearing capacities were in the range from 41.5KPa to
397.3KPa (Geotechnical report, appendix F).

Table 5.16: Soil bearing capacities and Consistency


TRIAL PIT DEPTH (m) APPROXIMATE ALLOWABLE CONSISTENCY
“N” VALUE BEARING
CAPACITY

1.8 3.7 41.5 soft


TP01(1.5m) 2.1 15.9 178.4 Very stiff
2.4 29.3 328.8 Very stiff
2.7 33.9 380.4 Hard
3.0 29.8 334.4 Very stiff
3.3 33.9 380.4 Hard
1.8 3.9 43.8 Soft
2.1 13.6 152.6 Stiff
TP02 (1.5M) 2.4 25.9 290.7 Very stiff
2.7 34.7 389.4 Hard
3.0 32.4 363.6 Hard
3.3 35.4 397.3 Hard

Table 5.17: Evaluation of Bearing Capacities Basing on the Field DCP values
TP no Depth Penetration Approximate Unconfined Undrained Ultimate Allowable Average
(m) index N-value Compressive Cohesion bearing bearing Allowable
value Strength qu Cu (KPa) capacity capacity bearing
(mm/blow) (KPa) (KPa) (KPa) capacity
(KPa)
1.80 64.0 3.7 48.5 24.2 124.6 41.5
2.10 14.5 15.9 208.3 104.1 535.3 178.4
TP1 2.40 7.4 29.3 383.8 191.9 986.4 328.8
274.0
(1.5m) 2.70 4.9 33.9 444.1 222.0 1141.3 380.4
3.00 7.1 29.8 390.4 195.2 1003.3 334.4
3.30 4.9 33.9 444.1 222.0 1141.3 380.4
1.80 59.0 3.9 51.1 25.5 131.3 43.8
2.10 18.0 13.6 178.2 89.1 457.9 152.6
TP 2 2.40 9.2 25.9 339.3 169.6 872.0 290.7
272.9
(1.5m) 2.70 4.5 34.7 454.6 227.3 1168.2 389.4
3.00 5.7 32.4 424.4 212.2 1090.8 363.6
3.30 4.1 35.4 463.7 231.9 1191.8 397.3

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Shear Strength Test

The detailed computation of the shear strength test parameters (un-drained cohesion and angle of
internal friction) are presented in the Appendix 5 of the Geotechnical report (Appendix F). In
addition, a summary of the shear test results are illustrated in Table 5.18 below.

Table 5.18: Summary of the shear test results


Trial Pit No Depth (m) Cohesion (kPa) Angle of Internal
Friction (deg)
Tp1 1.5 36.4 24.3
Tp2 1.5 27.7 25.1

From the Table 5.18 above, it’s observed that the un-drained soil cohesion, с ranges from 27.7KPa to
36.4KPa and the soil angle of internal friction, is between 24.3° and 25.1°. The shear strength, s may
be evaluated from the empirical formula; s = с + tan.

Classification test

From appendix 4 in the geotechnical report (Appendix F), the classification results indicate that the
plasticity index ranged between 24.5% and 30.1% as shown in Table 5.19 below. Further still, the
particle size distribution results show that the site is underlain by mainly silts and clays.

Table 5.19: Summary of Classification Test Results


USCS Soil Index Properties Direct
Classification Shear
Depth (m)

Plasticity (%) Chemical tests


TP No_

Cohesion
Chloride Sulphate

angle (o)
Friction
Plastic limit

(kPa)
Content Content
shrinkage

Group Group
pH
%NaCl Ppm Mg/ISO42-
Liquid

Plastic
Linear

symbol Name
index
limit

(mg/L)
Cl-
TP01 MH Sandy 11.5 50.40 30.07 20.33 0.068 410.0 >400 5.64 36.4 24.3
Elastic
SILTS
2.0
TP02 CL Sandy 10.7 41.64 24.45 17.19 0.068 410.0 >400 5.98 27.7 25.1
Lean
CLAY

Where: MH-Silts of High Plasticity. CL- Clays of Low Plasticity. LL- Liquid Limit

PI- Plasticity Index. LS- Linear Shrinkage

5.2.5 Flora and fauna


The project site is covered by clustered vegetation of short shrubs especially in the south, west and
northern parts. No major food crop was observed growing within the project site. In addition, a few
cows were observed grazing in the nearby shrubs (approximately 100m). The vegetation impression
within the project is illustrated in Figure 5.9 below.

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North of the site Southwestern view

West of the site Southern view

Figure 5.11: Vegetation impression within the project site

5.2.6 Project area population distribution


This section will focus on the area population distribution with respect to general total population,
education, access to the nearest health facility, inaccessibility to safe water and According to the
Uganda Bureau of Statistics 2017, The National Population and Housing Census 2014 – Area Specific Profile
Series, Kampala, Uganda, Kirengente sub-county where the proposed project lies has got a population
distribution of 22,725. In addition, the percentage distribution population aged 6-12 not in school is
25.6%, that of the youth aged 18-30 not in school and not working is 23.2%. The percentage
distribution of households within the sub-county that are 5Km and over to the nearest health facility
is 18.3%. Households that do not have access to the safe water account for 23.2% and similarly those
households with no toilet facility account to 1.8%.

5.2.7 Land use


This sub-section illustrates the relationship that exists between the people and the land more
specifically, how the physical project area is adapted, modified, or put to use for human purposes.
The area neighbouring the project area is characterised by tree plantations, scattered homesteads
plantations with mainly sweet potatoes and cassava approximately 100-300m from the project site. A
few animal rearing is also carried out in the vicinity of the project site. Brick making is also carried out
by the locals and such activities were seen south about 50m from the project site. In addition, east of
the project site is a wooden pole treatment plant about 300m from the site. Within the project site is St.
Paul Kavule church and Step by Step Infant school both located in the north about 450m from the
project site. Further still is St. Joseph of Nazareth High School located across the main road in the
north about 1km from the project site. The nearest trading centre is about 780m from the project site.

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Wooden poles treatment plant located about 300m east of the project site

Homesteads about Cow grazing south of the site


400m from site

Brick making south about 50m from the site St. Paul Kavule church

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Step-by-Step Infant School St. Joseph of Nazareth
High School

Kavule stage-trading centre

Figure 5.12: Project area Land use types

5.2.8 Utilities
The proposed project will use three (3) phase electricity from the national grid (UMEME) that already
exists in the project area and a standby generator as sources of energy. The developer also intends to
abstract ground water to be used as a water source.

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6. PUBLIC CONSULTATIONS AND DISCLOSURE
As per the requirements of the National Environmental Act, CAP 153, the National Environment
(Impact Assessment) 1998, National Environment (Certification and Professional Conduct of
Environmental Practitioners) Regulations (2003) and Guidelines for EIA in Uganda that all key
stakeholders with a significant involvement in any proposed project should not only be informed
about the project but also consulted for their views about the likely impacts and any other concerns
about the proposed project, these Key Stakeholders in the proposed project were identified and
involved in the EIA process. Both primary and secondary stakeholders were consulted.

On 9th July, 2018, the proposed site was visited and consultations held with the project area
community members to ensure their full participation in the proposed project. The local leaders
together with other relevant stakeholders in Kavule Parish, Kiringente Sub-County, Mpigi District
local government were also consulted to capture their views on the likely potential impacts that may
arise from the implementation of the proposed project. The main methods that were employed to
collect data were key informant interviews with the mentioned stakeholders and focus group
discussions with the local community. The details of the field outcomes are discussed here within and
evidence of stakeholder engagements presented in Appendix B.

6.1 Local Community participation

The purpose of consultations at community level was to stimulate participatory information,


gathering and sharing to help avoid potential possible conflicts as well as raise awareness about the
proposed project. The consultation process concentrated more on providing information about the
proposed project in a manner that would ease its comprehension by the potential beneficiaries and
affected communities.

The consultations were purposively meant to:

• Inform communities about the proposed project,


• To inform the neighbours about the benefits and the negative impacts of the project
• To seek the views, suggestions, concerns, fears and issues from the community about the
project.
• To fulfil one of the crucial requirement of the EIA process
• Obtain suggestion from public on possible ways that they feel potential negative impacts can
be effectively mitigated.

6.2 Opinions raised from stakeholder engagement


The community members interviewed were particularly happy with the project as it will create
employment opportunities as well as acting as a source of income.

Among the few mentioned negative impacts were; nuisance that will be brought about by the
construction activities, dust emissions during construction and operation phases, increased spread of
diseases, insecurity resulting from increasing population influx within the project area. The list of
consulted stakeholders is attached in Appendix B.

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Table 6.1: Summary of consultations and comments from the public

NAME DESIGNATION COMMENT RESPONSE

Emong SGSL-Principle • The developer should • Registration with OHS will


Okwakol Inspector, register with OHS before be done.
Ministry of implementation of project • Project design drawing will
Gender, Labour
activities. be taken to the Ministry for
and Social
Development • The drawing for the approval.
proposed project/site • Good record keeping shall be
should be approved by the implemented and monitored.
MoGLSD. • Workers welfare will be
• Ensure good record adequately provided putting
keeping. Records of in consideration, gender
trainings and incident based factors.
investigations should be • Examination of workers will
well documented and kept be carried out regularly to
well. determine their ability to
• Consider adequate work. Records of
provision of welfare to examination shall be filed
workers such as gender and used for reference.
sensitive sanitary • Adequate emergency
washrooms, designs response plan and
incorporating people with procedures will be
disabilities, changing rooms developed. These shall be
with locks, safe drinking well popularised to the
water. employees.
• Ensure proper employee • An HIV/AIDS policy will be
examination especially on put in place and well
production sector as well as sensitised to the workers.
food handlers. • Machinery will be properly
• Examination of food guarded
handlers should be done • Inspection will be conducted
every after 6 months and for safety of machinery
records kept. onsite during project
• Put in place a proper implementation.
system of referral for
proper communication and
emergency numbers.
• The developer should put
in place an HIV/AIDS
Policy, proper designated
times for meals, Policy on
sexual harassment.
• Ensure that the machinery
is properly guarded.
• Inspection for safety of
machines/equipment onsite
should be done.

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• Carry out induction
regularly for both workers
and visitors.
• Put in place gender
sensitive sanitary facilities,
adequate in number.
• Meal areas should be well
furnished.
Ssebalamu Resident Well comes the project • Developer shall ensure that the
Timony because it will provide local members are provided
employment and business with jobs.
opportunities to the locals.
Moses Standards Ensure that the project process • Noted
Matovu Officer- UNBS design is assessed for
recommended standards.
Paul Principal • The products that will be • Product assessment will be
Walakira Standards manufactured require that done for certification.
Officer the products are certified • Waste management has been
by UNBS. handled in section 4.7.
• Wastewater should be
adequately treated before
it is released.

Isiah Resident Welcomes the project because A recruitment system will be


Mubiru it will bring more developed and job first priority
employment opportunities shall be given to the locals
within the area.
Dramuk Resident Welcomes the project because A recruitment system will be
Jonathan it will bring more developed and job first priority
employment opportunities shall be given to the locals
within the area.
Ssebakumba Resident Welcomes the project because A recruitment system will be
Ibrahim it will bring more developed and job first priority
employment opportunities shall be given to the locals
within the area.
Mutesasira Resident • Welcomes the project to the Jobs shall be given to locals as
Paul community. first priority and training shall be
• The project will create jobs done to improve the skills of
for the local community. workers.
• However, the developer
should consider capacity
improvement of the
residents to fit the
development.

Goreti Resident The project will increase trade Noted


Namusoke within the area.

Kikonyogo Resident The project will increase trade Noted


Charles within the area.

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Kalanda Ali QC. Manager Expected improvement in the Noted
development of the area.
Energy Tree
treatment

Mutebi Secretary for Welcomes the project because Has been addressed in section 7
Vicent Defence it will provide employment
and business opportunities to
the locals. The developer
should put security measures
in place to ensure safety of
assets.

Madina Resident Gender based violence should Has been addressed in section 7
Nalunga be considered a serious issue
during project
implementation.

Namagembe Resident The project will reduce on the Noted


Joyce unemployment rate in the
(Nalongo) area as more employment
opportunities will be availed
to the youth.
Matovu Resident Welcomes the project because A recruitment system will be
Joseph it will bring more developed and job first priority
employment opportunities shall be given to the locals
within the area.
Ensure to put programmes The developer shall put in place
that will sensitise the local on an HIV/AIDS Policy on the Plant
HIV/AIDS and how they that will guide workers on the
should conduct themselves. code of work and behaviour.
Namigadde Resident/Farmer • The project will provide Jobs will be provided to the
F employment opportunities locals and also materials bought
to the people. from the local suppliers.
• The project will lead to
agricultural development
because people will grow
more millet and sorghum
due to market availability.

Twesigye Resident The developer should ensure Measures will be put in place
Richard that the noise on the facility is that will enable the minimisation
minimised so that it does not of noise during project
interfere with the community. implementation.

6.3 Conclusion
The public consultations showed that the communities and the authorities had no objections on and
no fears associated with the proposed project. Hence they welcomed it as it has positive objective
towards their way of life and development of their area and district at large.

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7. POTENTIAL IMPACTS AND MITIGATION MEASURES

This section first describes the methodology by which potential project-related impacts are assessed,
and then presents the results of the assessment and the mitigation measures that have been
developed as a result of the assessment process.

7.1 ASSESSMENT METHODOLGY

7.1.1 Impact screening


Mitigation of potential adverse impacts and the enhancement of beneficial impacts has been an
integral part of project planning. The project description in Section 4 identifies some of the
environmental controls already embedded in the project.

The scoping phase of this ESIA resulted in approval of the ToR (Appendix B) and included an initial
identification and screening of impacts which have been subject to detailed evaluation as part of the
ESIA.

7.1.2 Impact description


Potential impacts are considered in detailed by a process of description and assessment, with a view
to the formulation of project-specific mitigation measures to reduce them to acceptable levels, or to
compensate for them where this is not possible.

Describing a potential impact involves an appraisal of its characteristics, together with the attributes
of the receiving environment. Relevant impact characteristics may include whether the impact is:

• Adverse or beneficial;
• Direct or indirect;
• Short, medium, or long-term in during; and permanent or temporary;
• Affecting a local, regional or global scale; including trans-boundary; and
• Cumulative (such an impact results from the aggregated effect of more than one project
occurring at the same time, or the aggregated effect of sequential projects. A cumulative
impact is “the impact on the environment which results from the incremental impact of the
action when added to other past, present and reasonably foreseeable future actions”).

Consideration of the above gives a sense of the relative intensity of the impact. The sensitivity of the
receiving environment is determined by specialists based on the baseline data collected during the
ESIA.

7.2 Positive impacts


The proposed project positive impacts identified include the following;

I. Gender equality and employment opportunities;

With such an investment in the area, the unemployment rate is expected to decline due to the creation
of employment opportunities within the local community. With the implementation of this project,
both men and women inclusive of the youth would be equally availed with these opportunities thus
promoting gender equality.

II. Local income Generation and Livelihood Improvement;

The provision of employment opportunities to the local people is expected to increased monthly
incomes for the locals. This implies that the people will be able to meet their family needs thereby
improving their standards of living.

87
III. Rural and urban development;

The need to transport products to different outlets will lead to infrastructural development in terms
of improved roads besides the factory buildings in the area. This will lead to rural and urban
infrastructural development.

IV. Bridged gap for food security in the region;

Once the project is in place, the local people will be able to purchase the drinks at affordable prices
which is a source of food. This will enhance food availability within the project community.

V. Agriculture Improvement

The establishment of such a factory in the project area will encourage the local area farmers to grow
Sorghum that can later be bought by the developer as a raw material. This will eventually boost
agriculture while at the same time improve the project area farmers’ economic status.

VI. Increased government revenues through different payments

As a requirement for any registered company to have licences and permits, the payments made
towards the acquisition of these documents in addition to the taxes will increase revenue to the
government and the country as a whole.

VII. Improved human health through nutrition enhancement

The provision of processed well branded drinking porridge at factory price/cheaper price to the
project community would help improve on human health through the product consumption by the
local community.

7.3 Negative impacts


The construction, operation and decommissioning of the proposed project is likely to pose potential
negative impacts both to the environment and health of workers as well as the community. The
construction phase will involve both CONSTRUCTION OF THE FACTORY STRUCTURES and the
WASTEWATER TREATMENT PLANT. The construction of the manufacturing plant and the
Effluent Treatment Plant (ETP) will have in common some potential impacts such as impacts on top
soils, air quality, worker’s occupational health and safety, increased noise levels and vibrations, road
traffic, change in land use pattern, ground and surface water quality contamination. Other impacts
that are expected to occur during construction of the manufacturing plant include: population
pressure in the nearby area. During the operation phase, the potential impacts identified are those
that will likely affect the air quality, top soils, surface water quality, Gender Based Violence,
population pressure within the project community, worker’s occupational health and safety.

i. Impact on air quality

This impact is expected to occur in both construction and operation phases.

❖ Construction phase

The major potential source of air pollution as a result of implementation of construction activities for
the proposed project, is generation of fugitive dust measured as Suspended Particulate Matter and
Respirable Suspended Particulates. This dust is expected to be emitted by a number of sources such as
ground disturbance by material and products ferrying trucks, loading and unloading of the materials,
excavations, top soil removal, travel over unpaved access road, wind erosion and combustion by-

88
products such as carbon monoxide, nitrogen oxides and particle emissions that would lead to air
pollution within the project area. However, this will only occur for a short period and hence, no long
term adverse impact on air quality is anticipated under the construction phase.

Impact significance

Due to the short-term nature of construction activities and the area’s sparse population, the impact
likelihood is assessed as low and the impact severity is medium since their occurrence can be averted
and counteracted by the developer. This results into minor impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• All fine earth materials shall be enclosed during transportation to the site to prevent spillage
and dusting. Trucks used for that purpose will be fitted with tailgates that close properly and
with tarpaulins to cover the materials
• Temporary hoarding of sufficient height will be erected all around the project site as barrier
for dust control.
• The site is surrounded by trees upstream and other vegetation that could act as good air
filters to maintain the area free from dust.
• Ensure that vehicle speeds along the murram roads are controlled.
• The developer will have trees planted along the boundary of the plot, which will intercept the
dispersing fumes.
• Good mechanical condition maintenance of trucks will avert emission of exhaust fumes into
the atmosphere during the construction phase.
• Operation of machinery or equipment will aim at using clean fuels and lubricants with
minimal idling of engines. There will be no open burning of waste.
• Soil watering when soil works are being executed and where dust is emitted i.e. during
periods of dry weather, the access road shall be watered during movement of the heavy
trucks.

❖ Operation phase

The implementation of operational activities is also expected to generate pollutants that are capable of
deteriorating air quality within the project area. These will take off different emission forms as
follows:

89
Dust and exhaust fumes emitted into the atmosphere by trucks transporting raw materials to the
plant and products to the outlets. This will expose the atmosphere to CO2, SO2 and NO2 gases as well
as particle emissions especially soot from the standby generator.

The Sorghum powder dust that will be produced during mixing of ingredients can cause serious skin
and respiration diseases if workers are exposed beyond the maximum exposure level.

Usage of refrigerants such as Chlorofluorocarbons (CFCs) and hydro chlorofluorocarbons (HCFCs) in


the chilling, freezing, storage or transportation of finished products can damage the ozone layer.

There is also a possibility of emission of Volatile Organic Compounds (VOC) such as Formaldehyde,
alcohols, among others. Such emissions may have both short-term and long-term effects such as eye,
noise and throat irritation, Headaches, loss of coordination and nausea, dizziness and visual
disorders. The developer proposes to use both firewood and the boiler for boiling of the mixture.
Firewood will lead to particle emissions especially the soot. The boiler will use diesel which will not
emit soot but require regular maintenance.

Odour is also anticipated from the organic waste disposal techniques such as burning. This will lead
to the degradation of the air quality in the area. This will occur for a long period of time which
implies that a long term adverse impact on air quality is anticipated under the operation phase.
However, the disposal of waste is well mitigated in the mitigation measures (sub-section xii). The
boiler to be used in the production of steam will not emit soot unless when in poor mechanical
condition during its operation.

Impact significance

The impact likelihood is assessed as high due to long-term nature of operation activities and also the
daily occurrences of such activities. The impact severity is assessed as high since such emissions
would potentially affect human health most especially the respiratory system and also some gases
could be potential environmental polluters. This results into a major impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Ensure to carry out regular proper and adequate maintenance of all machinery/equipment
including the boiler.
• Mixing of ingredients at a low speed will minimize on powder dust.
• Adequate and proper ventilation will be put in facility structures to minimize on VOC
exposure.

90
• The developer should also adapt to greener technology for such material
processing/preparation.
• Using hydro fluorocarbons (HFC) during storage and transportation of finished products and
prevention of the refrigerant leakage will minimize on the effect of refrigerants on the ozone
layer.
• Application of biological filters and scrubbers will minimize on the rate of VOC emission.

ii. Erosion of top soil

Top soil erosion will be expected under both the construction and operation phases.

❖ Construction phase

During construction, a number of civil excavations will be carried out and heavy trucks loaded with
construction materials may erode off top soils around the construction site. As a result, top soils will
be removed and this may lead to erosion in the area. It should be noted that this will occur for a short
period and hence no long term adverse impact on top soils is anticipated under the construction
phase.

Impact significance

Due to the short-term nature of excavation and construction activities and the area’s flatness, the
impact is assessed as low and the impact severity is medium since their occurrence can be averted
and counteracted by the developer. This results into minor impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• The contractor should ensure that the design plans are properly implemented and excavation
activities done in a manner to minimise any ground damage.
• It should be noted that civil excavations can’t be avoided therefore the developer will ensure
that trucks are not overloaded during the transportation of construction materials which will
minimise the extent of top soil erosion in the area.

Operation phase

During operation, heavy trucks loaded with raw materials and finished products may erode off top
soils within the project area. This will lead to top soil erosion in the area which may be accelerated by
running water in case of heavy rains. This will occur for a long period and hence a long term adverse
impact on top soils is anticipated under the operational phase.

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Impact significance

Due to the gentle sloping nature of the area, the impact likelihood is assessed as medium and the
impact severity as medium. This results into minor moderate impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Ensuring that trucks are not overloaded during the transportation of raw materials and
finished products to the different outlets will reduce on the pressure exerted by the heavy-
weighted trucks on the top soil thus minimising the extent of top soil erosion in the area.
• Asphalting of the internal roads will also reduce on the extent of top soil erosion.

iii. Impact on population

Many people are expected to come into the project area due to the demand for labour which may lead
to a population increase. As a result, there may be increased spread of diseases like HIV/AIDS, food
shortage, insecurity and increased crime rates. This is anticipated under both the construction and
operation phases.

Impact significance

The impact likelihood is assessed as high because the demand for labour and the need to start-up
retail businesses among the people will be high. The impact severity is assessed as medium given that
the developer can easily counteract the impact effects. This results into moderate impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

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Mitigation measures

• Sensitization campaigns will be carried out by the developer to encourage the locals to grow
food crops to maintain the supply of food for the increased population.
• The developer will also give out or supply condoms to the employees and the locals for free
to reduce/ prevent the easy spread of Sexually Transmitted Diseases like HIV/AIDS.
• Develop an HIV/AIDS policy and ensure that all workers are sensitised about it.
• Also ensure that all the employees at the site provide their identification initials to the local
leaders to maintain security in the area.
• Put in place a Workers’ code of conduct and ensure that this is made aware of all workers.

iv. Land use change

The area around the proposed project is majorly being used for mixed food crop cultivation. With the
implementation of the proposed project in the area, many people will be tempted to shift to sorghum
growing due to market availability. This may cause environmental degradation and loss of soil
fertility as only sorghum is grown and other crops neglected that could improve fertility or vegetation
coverage thus environmental enhancement.

Impact significance

The impact likelihood is high because of the need to take full advantage of the project existence by the
people in an attempt to earn more income from their sorghum produce. The impact severity is
assessed as medium because as more people shift to sorghum growing and carrying out other facility
supporting activities instead of other developmental activities. This results into moderate impact
significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Massive sensitisation of the people will be carried out to encourage them to keep on
participating in other developmental activities like growing cash crops like coffee other than
sorghum.
• The developer should also work hand in hand with the local authorities to ensure that the
locals continue to practise farming for environmental sustainability.

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v. Noise levels and vibrations emissions

Construction phase

During construction, a lot of noise and vibrations will be generated from construction machinery like
excavators, generators, agitators and many others. Increased noise levels will cause discomfort to the
neighbours. On the other hand, increased vibrations may lead to generation of earth cracks.

Operation phase

During operation, noise is expected to be generated from vehicles transporting raw materials and
finished manufactured products and production machines while in use and among employees during
their free time. This may cause conflicts between the developer and the locals. In addition, the
operation of the boiler as well as the standby generator will generate noise which could affect the
operator/worker and also the nearby community. This therefore call for the developer to put
measures that address this issue.

Impact significance

The likelihood of the impact is assessed as high especially during construction phase as the activities
at the time will require the machinery. The severity is assessed as medium as the impact is short-term
during construction and during operation noise control strategies will be implemented by the
developer. This therefore is a moderate impact

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Ensure that high noise producing machinery are fitted with silencers.
• All machinery equipment including the boiler will be regularly serviced to ensure high
operation efficiency thus less noise and vibration.
• Construction phase shall use quiet machinery of good mechanical condition.
• Ensure that noise barriers like screens are erected around machinery during the operation or
production phase.
• A barrier around the facility will be established to reduce on the noise levels experienced by
the neighbouring residents.
• The boiler will be installed with a noise control equipment to minimise high level noise
emissions.

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vi. Traffic accidents

During the construction phase, there will be increased traffic as the construction trucks travel to and
from the village to deliver materials. This may result into road accidents if precautions like road
signage are not put in place.

Similarly, the operation phase will involve movement of trucks delivering raw materials and also
transporting finished products to different markets/sell out lets. This will increase traffics within the
project area which may eventually lead to road accidents especially to children if traffic is not
adequately managed.

Impact significance

The likelihood of the impact is assessed as high since traffic will increase the chances of the accidents
occurring. The severity of the impact is assessed as high in the event that the accident occurs, it may
result into loss of lives or broken limbs which are irreversible incidents. This results into a major
impact significance.

Impact likelihood

(-) None Low Medium High

Impact Negligible Negligible Negligible Negligible Negligible


severity
Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Flags men will be stationed at the different road points to direct truck drivers to reduce traffic
accidents.
• Road signage will be installed at different road sections like sharp corners and trading centres
to minimize on the traffic accidents.
• Humps will be constructed in the trading centres to help reduce on over-speeding hence
minimizing traffic accidents.
• Develop and put in place a traffic management plan and ensure that all drivers and workers
are made aware/sensitised of it.
• All vehicles will be regularly maintained/serviced to ensure their smooth operations.
• Sensitisation programmes on road usage will be conducted to both workers inclusive of
drivers and the local community.

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vii. Food security

As the locals shift to growing sorghum and working at the plant, there will be less attention given to
food crop growing for the largest piece of land which will in turn lead to food shortage. This therefore
presents the establishment of the project as a threat to food security of the community and the
country at large.

Impact significance

The likelihood of the impact is high because the people in the community will be tempted to shift to
sorghum growing clearing all the land that is currently used for mixed food crop growing. The
severity is medium because the impact is long term and the developer is aware of the effects and is
willing to adapt all measures to encourage the locals to grow other food crops for agriculture
sustainability. Therefore the impact is moderate.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Massive sensitization and awareness campaigns will be carryout to encourage the locals to
keep growing food crops for human consumption.
• The developer will also continuously support crop growing by giving out seeds to the locals
for planting to ensure food security.
• Put in place awareness programmes that teach, support and encourage the local community
to practice mixed cropping so as to avoid relaying on one cash (sorghum) for sale.

viii. Impact on worker’s occupational health and safety

The facility will have at least 30 people in the initial operational phase as its direct personnel. In
addition, about 50 more workers will be recruited in the later stages of operation to carter for all
activities such as transportation, distribution, marketing among other. This impact will be expected
both under the construction and operation phases.

Construction phase

With the nature of activities carried out during construction, workers may get exposed to falling
debris from heights, sharp construction objects among others. This could be severe if workers are not
dressed in appropriate protective gear. Also noise generated from the machinery at site may be a
concern to the workers as it may cause damage to their ears.

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Accidents could cause considerable ecological damage and harm to human life. While largely
reversible, some impacts such as loss of human life are irreversible and this could be a result of faults
in the machinery.

Operation phase

Operation traffic and machinery may pose accident risks to workers either when operated by
inexperienced workers or when in improper mechanical condition. This will be more evident when
workers operate without protect gears hence risking their health as well as loss of lives. Being a long-
term impact due expected to occur throughout the operational phase of the project, some of the effects
such as loss of lives are irreversible.

Impact significance

The impact likelihood is assessed is medium as the developer is aware of all the risks and will take
precautions to ensure that health and safety of the workers is priority. The severity is assessed as high
as some of the effects are irreversible and may lead to damage of human health as well as loss of lives.
This therefore is a major impact.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Ensure to register with the Ministry of Gender, Labour and Social Development (MoGLSD)
under the Department of Occupational Health and Safety (OHS).
• Develop and put in place an EHS system onsite. This will be well popularised amongst the
employees.
• All workers, including casual labourers, will undergo an environmental, health and safety
induction from the EHS manager before commencing work on site. This will include a full
briefing on site safety and rules.
• Conduct regular tool box meetings and ensure to keep records of such activities.
• Ensure to prepare incident reports and well document them for reference.
• Continually sensitize employees to always use PPE during operation activities.
• A well designated emergency assembly point will be established for scenarios where it may
be necessary.
• All employees will undergo training in first aid and first aid kits provided on site to take care
of accidental emergencies
• To mitigate fire risk scenario, fire fighting equipment include sand buckets and fire
extinguishers will be on site in case of an emergency.

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• Develop and put in place an HIV/AIDS Policy and will be made aware to all workers.
• Ensure to put in place systems for referrals. Emergency numbers will be displaced visible to
all workers onsite.
• Developer shall put in place and Health and Safety Policy.
• Democratically elect a competent HS commit to implement the above HS policy.
• Conduct pre-employment and periodic examination of workers including medical
examination of food handlers within the facility.
• Develop an emergency plan and procedures and ensure that these are well displaced and
educated to all workers.
• Carry out a comprehensive risk assessment and develop a risk management plan.
• Proper and adequate signage will be put in place and promptly made aware of all workers.
• Develop and put in place a Policy against sexual harassment.
• Ensure that there is no allowance for child labour.

ix. Fire risks

During construction and operation activities, fires may be caused by electrical short circuits during
operation or throwing smouldering material such as cigarette butts onto dry combustible materials
during construction. A serious fire outbreak could result in loss of equipment or even human life.

Since fires involve the loss of property and life, the impact likelihood is assessed as medium due to
their temporary nature whereas the severity is assessed as high due to high/intense damages that
may be caused and irreversible. Hence the impact is likely to be a major impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Oils and all other combustibles will be isolated.


• Sustainable maintenance for all machinery.
• Arranging suitable awareness programs for all workers (fire combating, suitable clothes to
wear, quick emergency evacuation for the personnel, how to use the fire extinguishers, calling
the fire brigade).
• Installation of efficient fire alarm system (with automatic water devices, anti-fire powder to
splash and sprouting sufficient fire extinguishers evenly in the fabric spaces).
• Project personnel will be sensitised on sources, possible causes and prevention of fire
outbreaks and some staff will be adequately trained in fire-fighting operations.

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• Fire hydrant system of adequate to serve emergencies involving large fires will be installed at
the facility. An adequate number of heavy duty fire extinguishers shall be placed in all
structures of the facility. The extinguishers will be timely serviced.
• Fire escape routes shall be provided in all structures and clearly marked with its signals.
• A fire emergency management plan shall be developed and made easily accessible to all the
people working in the facility.
• Safety signage e.g. “Fire Risk Area” or “No Smoking” will be provided in appropriate areas.
• Fire/smoke detectors, fire alarms and fire suppression systems shall be installed on all
structures of the facility.
• Smoking will only be allowed in designated low-risk areas which are adequately ventilated
and have fire extinguishers.
• Maintenance of electrical appliances will only be done by qualified and certified personnel.
• Regular fire-fighting drills will be undertaken by all the project personnel.

x. Impact on surface water quality

This impact has been predicted under both the construction and operation phases.

Construction phase

A number of activities like site preparation, construction of the structures and many others will be
carried during this phase and these activities have different impacts on the surface water quality
especially the swamp, downstream. The potential sources of surface water quality impact associated
with the construction activities are mainly construction site runoff and drainage;

During site clearance, runoff and drainage from the works area may be the main sources of pollution
of surface water quality in the neighbouring swamp. Site runoff and drainage may contain increased
loads of suspended solids and contaminants. Potential sources of water pollution from site drainage
include: runoff and erosion from exposed soil surfaces, earth working areas and stockpiles; release of
grouting and cement materials with rain wash; wash water from equipment used; fuel and lubricants
from faulty construction vehicles and mechanical equipment. Site runoff and drainage from the
works area if uncontrolled, will contaminate surface water downstream mainly the swamp.

Operation phase

During operation, machine equipment would require water for cleaning and cooling in case of
overheating. If this water is not properly treated before discharge after use, it may contaminate the
surface waters. This therefore calls for proper and adequate functioning of the Effluent Treatment
Plant. Oil leakages from faulty machines and vehicles at the site may mix with rain run-off and
contaminate surface waters downstream. On the other hand, inadequate solid waste management
onsite may result to environmental pollution hence deterioration the quality of the surface water.

Impact significance

The impact likelihood is assessed as high as the surface run off is unavoidable mainly during the
rainy seasons and the fact that the top soil is unstable due to construction works. During operational
phase, surface run off will not be an issue since the developer will have put in place a proper storm
water drainage system. The severity is high as the contamination may lead to easy spread of diseases
among the locals, death of aquatic animals within the swamp, among others. This therefore is a major
impact.

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Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• The developer will ensure that perimeter drains are established to intercept storm-runoff
from the construction site. These will be constructed in advance of site formation works and
earthworks.
• Open stockpiles of construction materials or construction wastes on-site will be covered with
tarpaulin or similar fabric during rainstorms to avoid run-offs.
• Debris and rubbish generated on-site will be collected, handled and disposed of properly to
avoid being flushed or blown by wind into the nearby swamp.
• Solid waste bins will be put onsite/within the facility and these will be managed in a way
that waste is separated at source.
• The quality of surface water downstream will be monitored by the developer to ensure that
there are no contaminations of this water. These records will be well documented and
properly kept for reference, evaluation and management purposes.
• Carry out routine maintenance of operational vehicles.
• Develop and put in place an adequate Carbon Management Plan to avoid unnecessary oil
spills.

xi. Impact on ground water quality

Construction phase

Domestic sewage may be generated from the workforce during the construction phase. Temporary
sanitary facilities will be provided for the site workers. Sewage from the sanitary facilities will have
an impact on ground water quality if it is not properly managed to avoid infiltration. Contamination
of ground water could also be as a result of accidental oil spills and leaks from the construction
machinery and trucks.

Operation phase

Oil leakages from faulty machinery at site could be a source of ground water contamination through
seepage/ infiltration. And water generated from the cleaning and production process may also lead
to ground water contamination if not properly handled before discharge.

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Impact significance

The impact likelihood is assessed as low given the short term nature of the construction activities and
the fact that the developer is aware of the measures to avoid contamination during both construction
and operational phases and the severity as high if there is infiltration of poorly managed sewage and
as such, some of the effects of ground water contamination are wide spread of diseases and death in
the long run. This results into a moderate impact significance.

Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Oils and fuels will only be used and stored in designated areas which have pollution
prevention facilities and all fuel tanks and storage areas will be provided with locks and sited
on sealed areas, within bunds of storage capacity of the largest tank to prevent spillage of
fuels and solvents.
• A licensed contractor who will be responsible for appropriate disposal of waste matter and
maintenance of the sanitary facilities will be hired.
• Provide sanitary facilities for worker and these shall be gender sensitive. Properly maintain
and clean them regularly and more frequently. The faecal sludge will be managed in an
appropriate way through the septic tank storage system which will later be emptied for
disposal by a licenced handler.

xii. Soil erosion

Due to the removal of top soil especially during construction activities like land clearing, excavations
among others this destabilizes the strength of soil which results into erosion of the soil onsite. This
run off may result into top soil removal which results into silting and shallowing of water sources
downstream.

During operational phase, no serious erosion of top is expected to occur since the site will be
established with concrete pavers and no serious works that require land clearing will take place.

Impact significance

The likelihood of the impact is assessed as high because the construction activities do involve removal
of top soil thus erosion. The severity is assessed as medium given the developer is aware of the
precautions to control erosion. This therefore is a moderate impact.

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Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Sand/silt removal facilities such as sand/silt traps and sediment basins will be provided to
reduce the speed of running water.
• Exposed slope/soil surface will be covered by tarpaulin as soon as possible to reduce the
potential of soil erosion.
• Arrangements should always be in place to ensure that adequate surface protection measures
can be safely carried out well before the arrival of a rainstorm to control erosion.
• The ground of the site will be established with concrete pavers.

xiii. Pollution due to inadequate waste management

Waste generation will be evident in both construction and operational phases.

Construction phase

The construction phase will involve site preparations, excavations and construction works. These
activities will generate waste such as soil debris, cement waste papers, plastic bottles, food remains,
and polythene bags, among others. Human waste will also be generated onsite. Poor management of
this waste will render both the environment and Human health as risk. However, this phase will only
occur for a short period of time.

Operational phase

The operational phase will comprise of the production process, packaging, storage, domestic activities
and other facility activities. These activities will generate waste such as off-cuts/trimmings from
packaging, plastic residues, food remains, wastewater from cleaning of machines, human faecal
waste, and office waste, among others. This waste is capable of polluting the environment as well as a
health hazard when not adequately managed.

Impact significance

The impact likelihood is assessed as low due to the fact that the developer is aware of the measures to
put in place for adequate waste management during both construction and operational phases and
the severity as high given that poor waste management may lead to environmental pollution of the
area ecosystem which eventually may contribute to the overwhelming climate change and later
impact on the ecosystem livelihood. This therefore results into a moderate impact.

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Impact likelihood

(-) None Low Medium High

Impact severity Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor Minor

Medium Negligible Minor Minor Moderate Moderate

High Minor Moderate Major Major

Mitigation measures

• Develop a Waste Management system for the facility construction and operational activities.
• Training and instruction of staff shall be given at the facility to increase awareness and draw
attention to waste management issues and the need to minimise waste generation.
• Adopt/apply the waste minimization strategies through source reduction by recycling and re
use of some waste.
• Ensure that waste is properly segregated for proper disposal in appropriate designated areas.
• Designate a place for collection of solid waste and should hire a licensed company to collect it
after a certain period of time and dispose it at the proper disposal sites.
• Avail Trash bins at different areas within the facility premises.
• Wastes shall be handled and stored in a manner, which ensures that they are held securely
without loss or leakage thereby minimising the potential for pollution.
• Waste storage areas should be regularly cleaned and maintained.
• Waste collection points should be properly signalled to enable worker dispose waste in the
right places.
• Ensure maintenance of records of quantities of wastes generated, recycled and disposed,
including disposal location.
• Conduct regular maintenance and cleaning of the waste storage areas.
• Develop and put in place a Carbon Management Plan to adequately handle used oils that
might be generated after machinery maintenance/servicing.
• Temporary toilets will be installed during the construction period.
• Put in place sanitary facilities during operational phase and shall be gender sensitive. In
addition, a septic tank system will be constructed to be part of the sanitary facilities, where
the sludge waste will be collected/managed.
• A licensed faecal sludge handler will be contracted to collect and dispose off faecal waste to a
designated licenced disposal facility.

xiv. Gender Based Violence

Gender based violence (GBV) is generally any harmful act that is perpetrated against a person’s will
on the basis of unequal relations between women and men, as well as through abuse of power. GBV
in particular, sexual and physical violence is widespread in Uganda and is mainly committed against
women and girls. This has been a big issue in the country due to people accumulating wealth and
feeling superior. As the project is going to create employment opportunities for most people, there is
a possibility of their economic status changing. This may increase the rate of alcoholism which is a big

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influence of violence as well as negative behaviour changes in socialism amongst the male. This
impact could lead to serious consequences such as violation of women/child rights due to the men’s
actions, and if not properly managed/controlled, could lead to detrimental effects within the project
area.

Impact significance

The impact likelihood is assessed as medium since the developer is aware of the proper measures to
undertake so as to avoid occurrence of GBV within the project community and the severity as high
since it is bound to occur at any time throughout the project life time causing tremendous damage in
social life which would result into a major impact.

Impact likelihood

(-) None Low Medium High

Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor


Impact severity

Minor
Medium Negligible Minor Minor Moderate
Moderate
High Minor Moderate Major Major

Mitigation measures

• Ensure to put in place a gender based violence management policy and popularising it to the
employees.

• Gender equality will be considered during employment/recruitment process.

• Regular awareness campaigns will be conducted both within the project facility and the
community at large.

xv. Impact as a result of decommissioning

As soon as the Manufacturing Plant has ceased and the project’s operational activities are no longer
required, decommissioning of the project facilities will be a requirement in order to restore back the
natural environment similar to that which would have existed prior to construction.
Decommissioning of the Plant can have negative impact on environment of the area from the dust
emissions, changes in the soil quality as well as Aesthetics.

If the decommissioned areas are not well restored, wastes generated during decommissioning
activities if not well managed will have serious negative impacts to the environment and human
health.

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Impact likelihood

(-) None Low Medium High

Negligible Negligible Negligible Negligible Negligible

Low Negligible Negligible Negligible Minor


Impact severity

Minor
Medium Negligible Minor Minor Moderate
Moderate
High Minor Moderate Major Major

Proposed mitigation measures


• Decommissioning shall be undertaken in accordance with the legislation prevailing at that
time, in liaison with the relevant regulatory authorities and adhere to Industrial safety
guidelines to ensure that the decommissioned facilities do not deteriorate to the point where
they become a hazard to the public or the environment.
• Decommissioning Plans shall be prepared and shared with NEMA for approval.
• All decommissioning wastes shall be managed in accordance with the National Environment
(Waste Management) Regulations, 1999.

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8. ANALYSIS OF ALTERNATIVES
The analysis of alternatives presented here aimed at evaluating the location and design options that
were considered during project design and to what extent environmental considerations were taken
into account. This section also presents a comparative analysis between the action and no-action
alternatives. The action option has been analysed based on siting/location of the project, project
design, and operational practices to be adopted.

a) The No-Action Option

The no-action option would eliminate any possible benefits that would otherwise result from the
implementation of proposed project. In addition, it would also prevent any potential negative impacts
that would arise from the proposed project.

The implementation of the proposed project would create more employment opportunities, bridge a
gap of food security within the project area and also improve the health of the locals. In the “No
Project” scenario, such opportunities would be missed out.

Other long-term opportunities to be missed during both construction and operation phases, include
tax revenue, income to material suppliers and skill training to workers.

Key negative impacts that would not arise if the project were not implemented are generation of air
emissions and solid waste during construction, increased traffic in the community area and land
disturbances during excavations.

b) Action Option
i. Site selection

The site for the proposed project was surveyed and studied to determine its feasibility and was
chosen for its size, strategic location, availability and proximity to the existing main access road. In
addition, other factors were also considered for this option location such as:

• The optimum locations for the proposed siting of project components, taking into account the
environmental and social sensitivities, such as the existence of sensitive ecological systems
(swamp) neighbouring the Project area;
• Environmental Health & Safety Risks associated with the alternative, including potential risks
to human health and surrounding ecosystem;
• Compliance with Ugandan laws, regulations, policy and lenders requirements and guidance
documents;
• Construction practices for the project design, including drilling techniques and approach;
• The availability of alternative technologies or designs during site preparation, construction
and operational production activities; and
• Cost effectiveness, including associated environmental costs and benefits of an alternative.

Alternative location

The other option would be choosing a site that is not close to a swamp/wetland (about 500-600m
from the swamp) upstream. This would require added costs for longer discharge channels that could
be used as passage of treated effluent into the nature swamp. In additional, the alternative location
would be so close to households hence increasing the likelihood and severity of impacts that could
directly or indirectly affect human health such as dust and noise during construction period and
among others.

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Therefore, the project design current location is preferred given the environmental benefits and safety
that it would entail during construction and operation activities.

ii. Germinated grains vis-a–viz non-germinated grains during production

According to the previous study done by Muyanja et al (2003), germinated and non-germinated
grains for both sorghum and millet, contain moisture, fat, protein and carbohydrate whose contents
range from 8.8-12.4 %, 1.8-3.0 %, 7.2-10.8 % and 77.7-85.7%, respectively. The same study indicates
that germinated sorghum flour has lower fat, protein and carbohydrate contents but higher ash and
fibre than non-germinated sorghum flour. However, germinated millet flour has higher moisture,
protein and fibre compared to the non-germinated flour while the latter has higher ash and
carbohydrate contents. The use of germinated grains would result in an increase in the concentration
of sugars in both sorghum and millet grains.

When only non-germinated millet flour is used for production, malt of millet and sorghum is added
which is claimed to act as a sweetener and flavour enhancer. Hence implying the use of germinated
grains would produce a better and health cost effective product that would not require addition of
sugars to improve sweetness.

iii. Design and layout Alternatives

In designing the preliminary facilities layout, minimisation of land requirements for aboveground
permanent facilities has been a strong driver taking into account environmental health and safety
considerations, such as risk of soil and groundwater and surface water contamination; occupation
health and safety; as well as good house-keeping and indoor air quality inside the facility premises.
The Project footprint has been minimized during the pre-project design stage. A preliminary site
layout plan is presented in appendix E. The layout was designed based on the site surveys done and
taking into account the environmental and social considerations. In particular, the layout design also
considered waste management, internal project site roads, sanitary facilities, production facilities and
site greenery.

The design of the facility structures will be made in such a way that all wall surfaces shall be built in a
way to easy the cleaning; using materials such as wall tiling, and all floor surfaces shall be built not
only to be easily cleaned but to resist heavy wear and tear and robust floor tiling will be used. In
addition, ground surfaces will be built in such a way to avoid accidental slippery occurrences.

Alternative

If the alternative for the project site location is taken up, it will imply that the site design and layout
will have to be developed basing on new environmental and social characteristics of the optional site.
The alternative site location would guide the site designs to incorporate advanced measures to protect
the health of humans/locals that would be neighbouring the facilities and also environmental
protection. However, the approval process for such designs/site layout would be hardly reached
following all the terms and conditions laid out by the MoGLSD.

iv. Project technology

The developer will make use of Cleaner Production techniques/initiatives in a way to reduce on the
waste generated while increasing production output and hence increase profits.

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❖ Process design and control:

The production process will employ state of art machinery that utilise/consume less power but
having a high production rate. Wastewater from the cleaning activities will be recycled after
filtering purposely for cooling machine and flashing toilets. The excess treated to correct BOD,
COD, pH, and other parameters before discharge to the environment.

Alternative

The other option is the use of a manual system of process control where materials are fed in a batch
system to boil and then manually transferred for cooling. This would be time consuming and the
production output would not be adequately efficient and effective hence reducing on the output per
day thus reducing on the facility’s profits.

Operation of the process control system manually would increase the exposure of the workers to high
risks that can later cost their lives. In addition, the manual operation of the control process would not
permit the recycling unit hence more waste will be produced and discharged to the environment.
Similarly, more waste would imply added costs of treatment of influent wastewater. In a long run, the
receiving environment (natural wetland) will reach a threshold due to increased rate of pollutants
hence reducing its treatment performance.

❖ Energy

Main power source will be the national grid (UMEME) at the facility premises. However, in order to
supplement the unstable mains supply, the developer will install a standby generator. These will be
used run the facility operational activities that will require such kind of energy. Diesel will be used to
run the generator as well as the boiler since it does not produce soot that would contaminate the air
quality.

Alternative

During the operational phase, the developer could install solar systems that can be used for mainly
lights at nights. Such systems would not be in position to run the factory machines during
production. However, installation of solar system for lighting would reduce on the National grid bill
hence reduction in expenses.

Biogas coud also be another option for biofuel to be used in boiling of the sorghum/millet solvent.
The use of biogas as biofuel is a green energy practice and puts forward an adaptation mechanism to
climate change hence increased ecosystem biodiversity since there are no greenhouse gas emissions
and also reduced impact on other natural resources such as trees for firewood as a biofuel.

In the production process especially during boiling of the mixture, the use of firewood as a biofuel
would also be adopted. Using firewood as a biofuel would imply increase in particle emissions
especially soot would cause health complications to workers as well as the environment as a result of
increase greenhouse gas emission to the atmosphere hence increase in Climate change.

❖ Water Sources

The main water source will be pumped ground water. The abstracted groundwater will require to
undergo treatment before being used for production. This will be done to ensure the right quality of
water is used for production to avoid any contamination.

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Alternative

The project can also make use of NWSC piped water supply line. However, the project site has no
existing water lines, implying that the developer will have to incur high costs of extending the water
supply line to the project site. This would mean added costs of installation and daily/monthly usage
charges. However, less costs would be incurred in water treatment during the production process.

Rain harvesting could also be adopted during operational activities. However, this would not be
appropriate to be used in production due to its intense impurities at exist in the atmosphere. Even the
treatment process would be intense and costly hence cannot be a viable option for use during the
production process. However, the harvested rain water could be used for ground/floor cleaning,
watering of project site plants and also used in the sanitary facilities for cleaning and flashing. Hence
saving on the daily/monthly company’s expenses.

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9. ENVIRONMENTAL MANAGEMENT PLAN

An Environmental Management Plan (EMP) is a stand-alone document which outlines mitigation


measures, accountability, monitoring and institutional arrangements for environmental management
of the Project. The EMP further provides information on environmental decisions which need to be
undertaken during the design, construction and operation phases of the Project. It provides key
performance indicators for evaluating efficiency of mitigation and management measures and
suggests actions that need to be taken to achieve the desired Project outcomes.

Monitoring is necessary to avoid negative effects that may surface during construction and operation
of the proposed project and achieve sustained environmental compliance. Details of the proposed
environmental monitoring plan (EMP) which provides mitigation/enhancement measures and timing
for the relevant actions are presented in Table 9.1 for construction and operational phases,
respectively.

The overall objective of environmental monitoring is to ensure that mitigation measures are
implemented and are effective. Environmental monitoring will enable response to new and
developing issues of concern during project implementation and hence ensuring that project activities
comply and adhere to environmental provisions and standard specifications of NEMA. The
responsibility for the environmental monitoring will largely lie with the developer and NEMA. The
involvement of other stakeholders in monitoring of compliance of the project with other aspects such
as gender and HIV/AIDS throughout the operation phase and may not be much anticipated during
the construction phase of the proposed project given the short term nature of the latter phase.

Some of the key monitoring indicators of focus will include amongst others:

• A Work Place Registration Certificate


• Traffic control measures put in place during construction phase of the project;
• Safety aspects on the project i.e. provision of PPEs for the workers; and
• HIV/AIDS sensitisation meetings held.
• HIV/AIDS Policy
• An emergency preparedness and response plan
• Risk assessment procedures
• A number of sensitisation meeting held and relevant trainings conducted for workers.
• Medical examinations of food handlers
• Wastewater monitoring records.
• Records for PPEs issuance and usage
• Incidents records/reports.
• A recruitment Policy.
• Air quality and noise assessment records/reports.
• Records of vehicle maintenance.

110
Table 9.1: Environmental and Social Management and Monitoring Plan

Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

Economic opportunities ✔ ✔ • Ensure employment opportunities on Head of Human • Proportion of local • Ministry Throughout the
an equal basis between women and Resource at NRFL people employed. of Gender, project
men; • Number of Labour implementation
• Design/put in place mechanisms that complaints and Social
will ensure that the hiring and concerning the jobs Developm
recruitment process is done in a ent
transparent way and community • Managem
involvement considered; ent, NRFL
• Ensure that the hiring of unskilled
workers is done maximally from the
local community;
• Identify those goods and services that
can be provided locally by the
community members such as raw
materials, food, cleaning services, etc.,
and support and encourage the
production and provision of such
goods and services respectively;
• Ensure that capacity building and
training programmes are put in place
especially for the unskilled workers to
scale up their skills for better
competitiveness in the job market
Food security ✔ ✔ • Massive sensitization and awareness • Management • Number of local • Ministry Throughout the
campaigns will be carryout to of NRFL people who of Disaster operational

111
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

encourage the locals to keep growing received the preparedn phase


food crops for human consumption. support. ess and
• The developer will also continuously • Number of Refugees.
support crop growing by giving out people/farmer • Managem
seeds to the locals for planting to practicing mixed ent NRFL
ensure food security. cropping
• Put in place awareness programmes
that teach, support and encourage the
local community to practice mixed
cropping so as to avoid relaying on
one cash (sorghum) for sale.

Land use change ✔ ✔ • Massive sensitisation of the people will Management of Number people Management Throughout the
be carried out to encourage them to NRFL carrying out other of NRFL and project lifetime
keep on participating in other economic activities the Local
other than working in government
developmental activities like growing
the project facility and
cash crops like coffee other than growing sorghum
sorghum.
• The developer should also work hand
in hand with the local authorities to
ensure that the locals continue to
practise farming for environmental
sustainability.

Occupation Health and ✔ ✔ • Ensure to register with the Ministry of Health and safety Employees dressed in Health and Throughout the
Safety Gender, Labour and Social officer/engineer the appropriate PPE safety project lifetime
department
112
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

Development (MoGLSD) under the NRFL Precaution signages NRFL


Department of Occupational Health management around the site
and Safety (OHS). First aid training
• Develop and put in place an EHS records
system onsite. This will be well
popularised amongst the employees.
• All workers, including casual
labourers, will undergo an
environmental, health and safety
induction from the EHS manager
before commencing work on site. This
will include a full briefing on site
safety and rules.
• Conduct regular tool box meetings and
ensure to keep records of such
activities.
• Ensure to prepare incident reports and
well document them for reference.
• Continually sensitize employees to
always use PPE during operation
activities.
• A well designated emergency
assembly point will be established for
scenarios where it may be necessary.
• All employees will undergo training in
first aid and first aid kits provided on
site to take care of accidental
113
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

emergencies
• To mitigate fire risk scenario, fire
fighting equipment include sand
buckets and fire extinguishers will be
on site in case of an emergency.
• Develop and put in place an
HIV/AIDS Policy and will be made
aware to all workers.
• Ensure to put in place systems for
referrals. Emergency numbers will be
displaced visible to all workers onsite.
• Developer shall put in place and
Health and Safety Policy.
• Democratically elect a competent HS
commit to implement the above HS
policy.
• Conduct pre-employment and periodic
examination of workers including
medical examination of food handlers
within the facility.
• Develop an emergency plan and
procedures and ensure that these are
well displaced and educated to all
workers.
• Carry out a comprehensive risk
assessment and develop a risk

114
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

management plan.
• Proper and adequate signage will be
put in place and promptly made aware
of all workers.
• Develop and put in place a Policy
against sexual harassment.
• Ensure that there is no allowance for
child labour.
Fire Risk ✔ ✔ • Oils and all other combustibles will be Developer/EHS • Carbon NEMA Annually
isolated. Officer Management Plan
• Sustainable maintenance for all • Presence of fire- Developer/E
fighting equipment. HS Officer
machinery.
• Records of trainings.
• Arranging suitable awareness
• Fire escape routes
programs for all workers (fire • Fire Emergency
combating, suitable clothes to wear, Management Plan.
quick emergency evacuation for the • Presence of fire
personnel, how to use the fire signage.
extinguishers, calling the fire brigade). • Records of
• Installation of efficient fire alarm maintenance of
electrical appliances.
system (with automatic water devices,
anti-fire powder to splash and
sprouting sufficient fire extinguishers
evenly in the fabric spaces).
• Project personnel will be sensitised on
sources, possible causes and
prevention of fire outbreaks and some

115
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

staff will be adequately trained in fire-


fighting operations.
• Fire hydrant system of adequate to
serve emergencies involving large fires
will be installed at the facility. An
adequate number of heavy duty fire
extinguishers shall be placed in all
structures of the facility. The
extinguishers will be timely serviced.
• Fire escape routes shall be provided in
all structures and clearly marked with
its signals.
• A fire emergency management plan
shall be developed and made easily
accessible to all the people working in
the facility.
• Safety signage e.g. “Fire Risk Area” or
“No Smoking” will be provided in
appropriate areas.
• Fire/smoke detectors, fire alarms and
fire suppression systems shall be
installed on all structures of the
facility.
• Smoking will only be allowed in
designated low-risk areas which are
adequately ventilated and have fire
extinguishers.
116
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

• Maintenance of electrical appliances


will only be done by qualified and
certified personnel.
• Regular fire-fighting drills will be
undertaken by all the project
personnel.

Surface water pollution ✔ ✔ • The developer will ensure that NRFL Perimeter drainages DWRM for Throughout the
perimeter drains are established to management around the facility water project lifetime
intercept storm-runoff from the Environmental monitoring
construction site. These will be officer/water Precautions around the records
constructed in advance of site officer facility to indicate
formation works and earthworks. surface water NEMA
• Open stockpiles of construction conservation or
materials or construction wastes on- protection Developer
site will be covered with tarpaulin or
similar fabric during rainstorms to
avoid run-offs.
• Debris and rubbish generated on-site
will be collected, handled and
disposed of properly to avoid being
flushed or blown by wind into the
nearby swamp.
• Solid waste bins will be put
onsite/within the facility and these
will be managed in a way that waste is
separated at source.

117
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

• The quality of surface water


downstream will be monitored by the
developer to ensure that there are no
contaminations of this water. These
records will be well documented and
properly kept for reference, evaluation
and management purposes.
• Carry out routine maintenance of
operational vehicles.
• Develop and put in place an adequate
Carbon Management Plan to avoid
unnecessary oil spills.

Ground water ✔ ✔ • Oils and fuels will only be used and NRFL Designated areas for oil DWRM to Throughout the
contamination stored in designated areas which have Management and fuel storage ensure that project lifetime
pollution prevention facilities and all Water/ Contract with the a water sources
fuel tanks and storage areas will be environmental licensed contractor for are conserved
provided with locks and sited on officer handling sanitary
sealed areas, within bunds of storage issues NEMA
capacity of the largest tank to prevent
spillage of fuels and solvents. Developer
• A licensed contractor who will be
responsible for appropriate disposal of
waste matter and maintenance of the
sanitary facilities will be hired.
• Provide sanitary facilities for worker
and these shall be gender sensitive.

118
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

Properly maintain and clean them


regularly and more frequently. The
faecal sludge will be managed in an
appropriate way through the septic
tank storage system which will later be
emptied for disposal by a licenced
handler.

Soil erosion ✔ - • Sand/silt removal facilities such as The developer Designated structures Environmenta Throughout the
sand/silt traps and sediment basins (NRFL) for run-off speed l officer NRFL project lifetime
will be provided to reduce the speed
Local
of running water.
Government
• Exposed slope/soil surface will be
covered by tarpaulin as soon as
possible to reduce the potential of soil
erosion.
• Arrangements should always be in
place to ensure that adequate surface
protection measures can be safely
carried out well before the arrival of a
rainstorm to control erosion.
• The ground of the site will be
established with concrete pavers.

119
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

Traffic accidents ✔ ✔ • Flags men will be stationed at the Health and safety Availability of the Local Throughout the
different road points to direct truck officer signage, humps and government/ project lifetime
drivers to reduce traffic accidents. The management flags men along the the
• Road signage will be installed at of NRFL roads District of
different road sections like sharp Mpigi
corners and trading centres to
minimize on the traffic accidents.
• Humps will be constructed in the
trading centres to help reduce on over-
speeding hence minimizing traffic
accidents.
• Develop and put in place a traffic
management plan and ensure that all
drivers and workers are made
aware/sensitised of it.
• All vehicles will be regularly
maintained/serviced to ensure their
smooth operations.
• Sensitisation programmes on road
usage will be conducted to both
workers inclusive of drivers and the
local community.
Noise emission ✔ ✔ • Ensure that high noise producing Sound assessment • Erected noise NRFL Throughout the
machinery are fitted with silencers. officer barriers around the management project lifetime
• The boiler will be installed with a NRFL project site.
noise control equipment to minimise management • Records of Noise Local
authorities
120
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

high level noise emissions. levels assessments


• All machinery equipment will be
regularly serviced to ensure high
operation efficiency thus less noise
and vibration.
• Construction phase shall use quiet
machinery of good mechanical
condition.
• Ensure that noise barriers like screens
are erected around machinery during
the operation or production phase.
• A barrier around the facility will be
established to reduce on the noise
levels experienced by the
neighbouring residents.

Population influx ✔ ✔ • Sensitization campaigns will be carried NRFL • Records of all the NRFL Throughout the
out by the developer (Ntugamo Real employees with Management project life time
Foods Limited) to encourage the locals their identification.
to grow food crops to maintain the • Availability of Local
supply of food for the increased condoms at the site authorities
population. for the employees.
• The developer will also give out or MoGLSD
supply condoms to the employees and
the locals for free to reduce/ prevent
the easy spread of Sexually
Transmitted Diseases like HIV/AIDS.

121
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

• Also ensure that all the employees at


the site provide their identification
initials to the local leaders to maintain
security in the area.
• Put in place a workers’ code of
conduct and ensure that this is made
aware of all workers.
Air pollution ✔ ✔ • Ensure to carry out regular proper Air quality • Presence of bio- NRFL/Develo Throughout the
and adequate maintenance of all assessment officer filters and other per project life time
machinery/equipment including the Developer pollution control
boiler. measures around NEMA
• All fine earth materials must be the facility.
enclosed during transportation to the
site to prevent spillage and dusting. • Records of PPE
Trucks used for that purpose should issuance
be fitted with tailgates that close • Complaints from
properly and with tarpaulins to cover the community
the materials • Onsite air quality
• The developer will have trees planted assessment records.
along the boundary of the plot, which
• Records of
will intercept the dispersing fumes.
maintenance of
• Good mechanical condition
machinery/equipm
maintenance of trucks will avert
ent inclusive of
emission of exhaust fumes into the
operational vehicles
atmosphere during the construction
and the boiler.
phase.

122
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

• The internal roads of the plant will be


asphalted to reduce the speed of
moving trucks which will minimise
dust emission.
• There will be water trucks to sprinkle
water in areas where dust emission is
expected within the plant.
• Mixing of ingredients at a low speed
will minimize on powder dust.
• Adequate and proper ventilation will
be put in facility structures to
minimize on VOC exposure.
• The developer should also adapt to
greener technology for such material
processing/preparation.
• Using hydro fluorocarbons (HFC)
during storage and transportation of
finished products and prevention of
the refrigerant leakage will minimize
on the effect of refrigerants on the
ozone layer.
• Application of biological filters and
scrubbers will minimize on the rate of
VOC emission.

Waste Management ✔ ✔ • Develop a Waste Management system Developer • Training records. Environmenta
for the facility construction and l Throughout the

123
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

operational activities. • Sanitary facilities Officer/Devel project lifespan


• Training and instruction of staff shall oper
be given at the facility to increase • Presence of skips
and bins well NEMA
awareness and draw attention to waste
management issues and the need to covered labelled for
minimise waste generation. waste separation.
• Adopt/apply the waste minimization • Proof of licence of a
strategies through source reduction by waste handler.
recycling and re use of some waste. • Waste Management
• Ensure that waste is properly Procedures.
segregated for proper disposal in
appropriate designated areas.
• Designate a place for collection of solid
waste and should hire a licensed
company to collect it after a certain
period of time and dispose it at the
proper disposal sites.
• Avail Trash bins at different areas
within the facility premises.
• Wastes shall be handled and stored in a
manner, which ensures that they are
held securely without loss or leakage
thereby minimising the potential for
pollution.
• Waste storage areas should be
regularly cleaned and maintained.

124
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

• Waste collection points should be


properly signalled to enable worker
dispose waste in the right places.
• Ensure maintenance of records of
quantities of wastes generated, recycled
and disposed, including disposal
location.
• Conduct regular maintenance and
cleaning of the waste storage areas.
• Develop and put in place a Carbon
Management Plan to adequately handle
used oils that might be generated after
machinery maintenance/servicing.
• Temporary toilets will be installed
during the construction period.
• Put in place sanitary facilities during
operational phase and shall be gender
sensitive. In addition, a septic tank
system will be constructed to be part of
the sanitary facilities, where the sludge
waste will be collected/managed.
• A licensed faecal sludge handler will be
contracted to collect and dispose off
faecal waste to a designated licenced
disposal facility.

125
Environmental/Social Mitigation measures taken or to be taken Responsible Performance Indicator Monitoring Frequency of

Construction

Operation
Issue party/ (who) Monitoring
Implementer

✔ ✔ • Ensure to put in place a gender based • Gender based


Gender Based Violence violence management policy and Developer violence policy Developer Monthly and a
popularising it to the employees. ‘’as need’’ basis
• Records of
Community MoGLSD
complaints
• Gender equality will be considered Liaison Officer
during employment/recruitment
process.

• Regular awareness campaigns will be


conducted both within the project
facility and the community at large.

- - • Decommissioning shall be undertaken


• Decommission Developer Decommission
Impact as a result of in accordance with the legislation Developer
report phase
decommissioning prevailing at that time, in liaison with
the relevant regulatory authorities and
adhere to Industrial safety guidelines to
ensure that the decommissioned
facilities do not deteriorate to the point
where they become a hazard to the
public or the environment.
• Decommissioning Plans shall be
prepared and shared with NEMA for
approval.
• All decommissioning wastes shall be
managed in accordance with the
National Environment (Waste
Management) Regulations, 1999.

126
10. DECOMMISSION PLAN
The decommissioning phase provides guidance on prevention and control of environmental impacts
which are most common during decommission activities. Decommissioning of the project activities may
be carried out during closure or conversion of the project to alternative land use. The phase possess
potential impacts that could be experienced during the implementation exercise. These are prone to
affect both the environment as well as health and safety of workers. This chapter therefore gives an
analysis of the decommissioning impacts expected in the proposed Project. This will involve carrying
out inspections to assess the potential for short term or long-term contamination before initiation of
decommissioning activities.

10.1 The Need for Preliminary Decommissioning Plan


The initial plan serves to establish decommissioning as an important consideration from the
inception of the project, during design and throughout the operation of the plant. The plan has the
following purposes:

i) the primary purpose of the preliminary plan is to ensure that the plant designers are
cognizant of decommissioning during the initial design of the project facilities so that design
choices that would enhance decommissioning are available for types of materials and
system components, and location of components;
ii) another purpose of the preliminary plan is to identity the ultimate decommissioning
options and final facilities status which will be evaluated and narrowed to the
decommissioning method of choice as the end of facilities life is approached;
iii) the final purpose of the preliminary plan entails demonstrating to regulatory agencies
that important aspects of decommissioning are considered as early as possible during the
initial design of the project to serve as the starting point to demonstrate that areas such as
decommissioning methods, costs, schedules, and t h e operating impact on
decommissioning will be reviewed and refined throughout the operating life of project.

10.2 Content of the Plan

The preliminary plan provides a general description of decommissioning methods considered feasible
for the proposed project. The description is intended to demonstrate that the methods considered are
practical and that they protect the health and safety of the public and decommissioning personnel.

Design contractor(s) shall study the proposed decommissioning methods and take steps to ensure
that the design incorporates features that will facilitate decommissioning. Considerations include:

i) an estimate of manpower, materials, and costs anticipated to support


decommissioning;
ii) a description of the anticipated final disposition and status of the Plant inclusive of
machinery/equipment and site;
iii) a discussion demonstrating that adequate financing will be programmed for
decommissioning;
iv) identification of records that should be maintained during construction and operation
which might facilitate decommissioning, including a set of “as built” drawings/Plant
designs.

127
10.3 Methodology and Schedule
The developer shall fund and implement all aspects of project decommissioning, including but not
limited to, all engineering, environmental assessment, permitting, removal/destruction and
mitigation activities associated with the removal of the plant, in accordance with this plan and
mitigation of project removal impacts on site. The developer shall monitor environmental impacts
during and after project removal to respond to defined events during the monitoring phase.

The developer shall remove the project structures safely and in a manner that:

• minimises environmental impacts e.g. dust pollution, noise pollution, disposal of unused
chemicals or any hazardous material, providing protective gear to decommissioning
personnel etc.;
• satisfies the obligations under the National Environment Act, 153 and with the National
Environment (Waste Management) Regulations, 1999 or relevant Mawokota
County/Kiringente Sub-county bye-laws;
• restores the site to a condition suitable for multiple use; and
• pays all dues (workers, government, suppliers etc.).

Project removal will begin six months after closure and continue for twelve months. Within the
six months from closure the developer will inventory all components that need to be removed and
or disposed of. This inventory will include building structures, machinery, equipment etc. to be
demolished/dismantled, debtors and creditors to be settled. Also mode of disposal will have to be
finalized. This information will assist in the preparation of the final decommissioning plan, for
approval by NEMA.

After the approval of the decommissioning plan the machinery/equipment will be removed first
within the first three months (this is important to ensure that they are not vandalized). The
second three months of the decommissioning will be used to remove concrete structures and
foundations. Debris will be used as road fills for rural roads. All disturbed areas will be
landscaped and re-vegetated using indigenous trees. Project decommissioning shall employ five
phases including:

a) pre-removal monitoring;
b) permitting;
c) interim protective measures;
d) project removal and associated protective actions, and
e) post-removal activities, including monitoring of environment and socio economic activities

The first three phases will occur prior to removal of the project (i.e. within the first six months).
The fourth phase (project removal and associated protective actions) will take place twelve
months after closing business. The fifth phase will begin after total removal and due to nature of the
project (medium scale, with relatively moderate impacts) removal and continue for at least one year.

Each phase will constitute the following activities:

❖ Pre-removal monitoring: Pre-removal monitoring includes environmental and socio


economic status of the Manufacturing Plant and the surroundings. This monitoring is
essential to identify if there is any environmental or social liability which need to be settled
before the permit for closure is issued. This period will also be used to inventory all assets
and facilities that need to be disposed of and to prepare a final decommissioning plan for
approval by NEMA.

126
❖ Project Removal: As noted above, the removal of the project will be completed within
twelve months.
❖ Post-Removal Activities: Post-Project removal monitoring will continue for about a year.

10.4 Preliminary Decommissioning Plan

Table 10.1: Preliminary Decommissioning Plan

Planed Activities Responsible Duration


Institution
Provide information to workers Developer Three months
on project termination and
create awareness to workers
who are losing employment
about alternative income
generating activities (includes
giving notes of termination of
contracts)
Payment of compensation and Developer One month
terminal benefits to workers
Closure of the Plant (termination Developer Three weeks
of operation services)
Taking out all associated Developer Two months
facilities and assets such as water Contractor
pumps, fuel pumps, production
equipment, boiler, etc.
Demolition/ dismantling project Developer in collaboration with Two months
equipment contractor
Collection and sorting out of Developer in collaboration with One month
wastes for reuse, recycle and for Contractor
disposal
Removal of wastes such as Developer in collaboration with One month
generated solid waste and Contractor
other wastes by transporting
to the Dump site for disposal.
Leveling of land and site Developer in collaboration with One month
restoration to its original contractor
condition

Note: The time frame for commencement of site restoration works shall not exceed one month
following the closure of the project.

127
11. RECOMMENDATION AND CONCLUSION
The developed monitoring and management plan structured out by the consultant is adequate
enough to ensure effective and efficient implementation of the proposed mitigation measures. On the
other hand, these proposed mitigation measures should be tentatively considered by the developer
throughout the project lifespan. The developer also ought to maintain a good relation / a good
behaviour record within the proposed project communities and the neighbouring communities. If the
developer effectively addresses the proposed mitigation measures through adequate implementation
and monitoring throughout the project phases, then the proposed project benefits should overshadow
its costs. The consultant therefore recommends that NEMA approves the Environmental aspects of
the proposed project.

128
REFERENCES

i) Uganda Youth and Women’s Effort Fighting AIDS (UYWEFA), 2017. People Living With HIV.
ii) Mpigi District Local Government, 2009. Statistical Abstract 2008/09.
iii) Ministry of Water and Environment, 2017. Uganda Water Supply Atlas.
iv) Uganda Travel Guide 2017.
v) NEMA, 2003.The National Environment (Noise Standards and Control) Regulations, Uganda.
vi) NEMA, 2006. Draft National Air Quality Standards, Uganda. NERC, 2001 Ground Water
Quality: Uganda, British Geological Survey (report prepared for Water Aid).
vii) Public Health Act, 1964.
viii) The Local Governments Act, 1997.
ix) The Republic of Uganda (1998) Environment Impact Assessment Regulations.
x) The Republic of Uganda, 1995: The Environment Act.
xi) The Republic of Uganda, 1995: The Water Act.
xii) The Republic of Uganda, 1999: The National Environment (Waste Management) Regulations 52.
xiii) The Republic of Uganda, 2001: The National Environment (Minimum Standards for
Management of Soil Quality) Regulations.
xiv) The Water (Waste Discharge) Regulations 1998.
xv) Uganda National Bureau of Standards (UNBS)
xvi) Uganda Bureau of Statistics 2017, The National Population and Housing Census 2014 – Area
Specific Profile Series, Kampala, Uganda.

129
Appendices

Appendix A: NEMA approval of Scoping and ToR

130
131
132
Appendix B: Stakeholder Consultations

133
134
Appendix C: Water quality Results

135
Appendix D: Land title and agreements

136
137
138
139
140
141
142
143
144
145
146
147
148
149
Appendix E: Design Site layout

150
Appendix F: Geotechnical report

151

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