Partners of Shared Resources, Joint Solutions (SRJS) programme in Uganda submitted an objection to the Electricity Regulatory Authority – ERA to the establishment of a hydropower plant on the Victoria Nile River.  SRJS is a Partnerships and advocacy programme seeking to promote food security, water provisioning and climate resilience amidst oil exploitation and forest degradation challenges in Uganda.  The SRJS partners in Uganda comprising of; IUCN UCO, NAPE, AFIEGO & ECOTRUST submitted an objection letter based on the following observations;

  1. Ecologically Sensitive Landscape: The proposed site of the power plant; The Victoria Nile is within a biodiversity hot spot of ecological sensitivity. The Victoria Nile bisects Murchison Falls National park from Karuma Falls to the delta at its confluence with Lake Albert, with over 50 distributaries, which flow through thick papyrus (Cyperus papyrus) swamp. The negative impact resulting from the variation in hydrological regimes as a result of the plant is likely to extend to the entire wetland system, including all the 50 tributaries, Lake Albert and beyond. This will be a significant disruption of biota in this great riparian ecosystem, which is an Important Bird Area, a Ramsar site and a Key Biodiversity Area that has been proposed for UNESCO World Heritage Listing.
  2. Area of very sensitive Flora & Fauna; The wetland system associated with the Victoria Nile, extending from the top of Murchison Falls to the delta at its conflux with Lake Albert was declared a wetland of International Importance under the Ramsar Convention partly due to the presence of sensitive flora and fauna (Ramsar site no. 1640). The Delta in particular, is comprised of a shallow area that is significant for aquatic bird species including the herons, shoebill storks and darters among others in addition to being a wonderful breeding and spawning site for indigenous fish species in Lake Albert fisheries including a local favorite – Angara.
  3. Likely Loss of biodiversity and/or change in species composition: The proposed hydropower plant is likely to result into loss and/or changes in species of biodiversity of global significance. The Victoria Nile is inhabited by species of global significance. For example, the stretch of river between Murchison Falls and the delta has one of the highest concentrations of Crocodylus niloticusin the world. In addition, the convergence zone between the lake and the delta forms a shallow area that is an important migratory stopover for waterbirds, including the IUCN Red listed Shoebill Stork (Balaeniceps rex). Other globally near-threatened birds that have also been recorded include several globally threatened species of vultures e.g. the Lappet – Faced Vulture (Torgos tracheliotus), Lesser Flamingo (Phoenicopterus minor) and the Great Snipe (Gallinago media).  In addition, the Park supports 20 bird species with restricted biomes: eleven species of the Guinea–Congo Forests, six species of the Afrotropical Highlands and three of the Somali–Masai biome.
  4. World Heritage: Due to the scenic beauty of the Murchison Falls, The Park was proposed by Uganda to be a UNESCO World Heritage Site. It does qualify under two of the four required criteria: ‘superlative natural phenomenon’ (the falls) and ‘the most important and significant natural habitats where threatened species of animals and plants of outstanding universal value survive’ like Crocodylus niloticusand Balaeniceps rex.
  5. Socio-ecological resilience of the Landscape: The Victoria Nile is of ecological significance to the landscape in general as well as of social and cultural importance to the people of the area. For example, it forms a feeding and watering refuge for wildlife in the National Park during dry seasons. In addition MFNP is the only Park in the world, where one is almost certain of seeing the Shoebill Stork. Furthermore, the Murchison Falls are one of the main tourist attractions and recreation areas in Uganda. The landscape in general and the park in particular is already under stress from the oil and gas and related developments. The introduction of a hydropower plant among these developments will further compound the situation, compromising the ecological integrity/resilience of the landscape.
  6. Dam Load along River Nile Uganda already has more than 5 dams along River Nile and each development is assessed in isolation and lacks consideration for the cumulative environmental and social impacts of the other existing and planned developments. Moreover, the Nile is a trans-boundary resource, the cumulative impacts of the current and proposed developments on the Nile have far reaching impacts beyond the boundaries of Uganda. The general process under which the likely impacts of hydropower developments along the River Nile are being evaluated also concerns us. It is important not to look at each development in isolation but consider the cumulative impact of the current and proposed developments

The development of a hydropower plant on any of the falls on Victoria Nile will inevitably result into irreversible ecological impacts due to changes in the quantity and quality of aquatic habitat resulting from variation in the hydrological regimes that normally accompany dams. The expected environmental alterations such as changes to the quantity and timing of water flow will for example result into inundation of this very critically important area.  This will alter the ability of the riparian system to provide suitable habitat for these critically endangered wildlife. EIA guidelines for the energy sector in Uganda, specifically earmark areas with aquatic resources of high biodiversity value as well as areas with sensitive habitats or containing highly valued ecological resources as areas that should be avoided.

We believe that there is no mitigation measure that has potential to safeguard this natural heritage from the impacts of the dam other than avoidance.

It is upon this background therefore that we call upon the government of Uganda to reject the application to establish a power plant on the Victoria Nile River.