From waste of time to valuable resource1 December 2002
An impact assessment carried out to modern standards can more than save its cost in avoiding delays and keeping stakeholders on side, as Lee Doran explains
ENVIRONMENTAL assessment has a long and chequered past amongst project developers. Back in the 1970s, environmental assessment developed a reputation for being obscurely technical, jargon-laden, extremely time-consuming and very costly. Often the information provided through this onerous process could not be related in any obvious way to any real-world decision that needed to be made. Many managers and decision-makers felt it was a colossal waste of time and resources.
Since those days, environmental assessment has undergone some major changes. The state of the art has progressed significantly from a narrow technical focus to include a wider range of disciplines, particularly social, in a much more accessible process (see table below).
The pace of change varies greatly, of course, between and among jurisdictions. The impact assessment (IA) work on the Bujagali hydro power project in Uganda provides a recent example of current practice with particular emphasis on the World Bank Group.
The bujagali project
In the mid-1990s, the Government of Uganda invited private sector power project developers from around the world to help develop its electricity supply and distribution system. The AES Corporation was the successful, if not the sole, respondent to that request. The World Bank Group was also involved, as funding and guidance with project development were anticipated from at least one of the Group's organisations.
A number of earlier studies had been completed on the options and priorities for further power development in Uganda. All these studies had focused on the hydro power resources of the mainstream Nile river. Other possible options were considered, generally, to be too distant in the future, unproven technically, or less economically attractive than the hydropower option. As the country's electricity needs were both dire and pressing, hydro power was the option pursued in more detail.
From amongst a number of hydro power sites and schemes, the Bujagali project emerged as the most likely, least cost option.
Bujagali is a run-of-river development (about 80ha of newly flooded land was involved) of 200MW. It will be located about 9km downstream of the existing hydropower developments (Owen Falls and Owen Falls Extension) at the outlet of Lake Victoria in Jinja, Uganda. To transmit power from the new plant to the major market, at Kampala, a new 100 km transmission line will be built, a new substation will be constructed and an existing substation will be upgraded. Another short transmission line will connect with the existing Owen Falls area distribution system.
When the International Finance Corporation (IFC), the private sector arm of the World Bank Group, became directly involved with the Bujagali project an impact assessment document was already being prepared to submit to the Government of Uganda's National Environmental Management Authority (NEMA). But some extra assessment would be required, as not all of IFC's requirements would have been met by the document being prepared.
IFC's environmental and social review process has a number of elements, all of which must be satisfactorily addressed on its projects. Along with other reference and guidance documents they include environmental and social 'safeguard' policies, and guidelines for each industrial sector (eg the Pollution Prevention and Abatement Handbook).
IFC applies these requirements through its Environmental and Social Review Procedure, which defines the way IFC reviews projects. In parallel, IFC stresses the importance of consultation with stakeholders and disclosure of information to identify issues early in the project cycle. IFC also sets out the form and format for the assessment documentation and the steps in its internal project processing cycle. The specifics of all of these requirements are readily accessible on the IFC web site (www.ifc.org).
Resolving the issues
The impact analysis identified a number of high priority environmental and social issues associated with the Bujagali project. They included:
• Resettlement of people affected by the project, including those both physically and economically displaced at the dam site and along the associated transmission line routes.
• Potential effects on cultural properties, including shrines and spirits in the vicinity of the project.
• Effects on fish and fisheries in the Nile river and affected tributaries.
• Effects on tourism and eco-tourism, including whitewater rafting on the river Nile, which emerged in the late 1990s as a source of foreign exchange revenue for Uganda.
• Implications for the future development of the region as well as the local community, including the potential for hydro power development in the main stem river and its cumulative effects.
• The need for robust Environmental and Social Action (Management) Plans to ensure that the environmental and social commitments be implemented as planned.
Programmes were developed to respond to each of these issues to the level of detail needed for the environmental and social assessment documentation. A variety of groups were involved in the different programmes.
For example, the Fisheries Resources Research Institute, a highly respected fisheries research group based in Jinja, completed specialised technical studies to ascertain the kinds, abundance and likely impacts on a group of tiny fishes adapted to living in the rapids of the Nile. Scientifically significant collections were made and analysed.
In another example, after a false start on the resettlement activities undertaken mostly by consultants, AES decided to set up its own team, staffed largely with Ugandan nationals, to carry out the detailed and complicated field work for the Resettlement Action Plan (RAP). Key tasks included developing a database that documented the thousands of affected people, their holdings and use of impacted lands, valuations of their crops, and the nature and duration of their land uses.
This database provided a basis for negotiating and paying compensation, understanding community issues and values, and designing and implementing mitigation plans, including those for community development.
In an innovative move, AES retained an independent legal team to represent and assist stakeholders in reaching agreement with the project sponsor on compensation and other issues. The company also funded an independent non-governmental organisation to oversee implementation of the compensation activities.
In addition to policy compliance, AES was pro-active in developing a Community Development Plan for the project. Key features included consultation with the wider community and support for social and economic programmes that would bring long-term direct benefit to the people.
IFC and the World Bank (through the International Bank for Reconstruction and Development) were involved in lengthy and complex discussions with the government of Uganda on regional development. Specifically, they reached agreement on setting aside lands downstream of Bujagali (in the vicinity of Kalagala Falls) in perpetuity as an offset for habitats affected by Bujagali, to assure the protection of representative ecosystems over the long term, and to preserve the scenic and tourism values of the Nile.
Members of the study team worked intensively with the EPC contractor selected for the project (the Bujagali EPC Consortium, led jointly by Veidekke and Skanska) to ensure that the Environmental and Social Action Plan commitments would be met on the ground. Careful review of the responsibilities, programmes, timelines and budgets was necessary to ensure that overall project commitments were reflected in the contractual documents being prepared for all contractors and sub-contractors to the project. In addition, Skanska brought its own corporate environmental and social policies, commitments and experience to the table. All these elements had to be combined to ensure that the impact assessment's commitments would be implemented as planned during the construction of the project.
Overall, the various members and sub-groups of the impact assessment team worked long and hard to resolve the issues that had been identified. They were well on the way to being satisfactorily resolved when the final draft of the impact assessment documentation was placed in the World Bank InfoShop and released locally in Uganda in April of 2001, although work on those issues continued after this public disclosure.
The final suite of documentation had seven volumes, of which the Executive Summary was probably the single most important document. It aimed to provide a clear and accessible summary of the project's plans in a highly graphic format. The whole suite of documentation can be accessed at IFC's web site (www.ifc.org) by searching on the project name 'Bujagali' or by visiting www.bujagali.com.
Subsequent consultations on the documentation seemed to confirm that the issues tackled by the impact assessment team were on the way to resolution. The dialogue began to shift, then and subsequently, to other issues that had not been within the mandate of the impact assessment team (such as the economic viability of the project under changed economic conditions, and allegations of corruption).
Though approval for IFC/World Bank participation in the project was given by the IFC/World Bank Board in December of 2001, the project's future is still not clear at the time of writing.
Some lessons learned
The Bujagali project provides some excellent lessons for the practice of impact assessment. These include:
Understand project boundaries
Environmental and social impacts often extend beyond the project's footprint. Ancillary facilities that are an integral part of the project (Bujagali's transmission lines, for example) must be included in the impact analysis.
Consider the broader context
For many projects, regional development implications and cumulative environmental and social effects can be the most contentious and challenging issues. Often, sustainability can only be addressed satisfactorily in this wider context.
Consolidate all regulatory requirements
The final draft of the Bujagali impact assessment addressed all Ugandan, IFC/World Bank, and international standards and requirements in one place, meeting the most stringent in each case.
Engage with stakeholders
Issues can only be defined and resolved through transparent-as-possible communications, on an ongoing basis, with concerned, involved and affected stakeholders, including primarily government agencies and the affected people. Consultation and communication is fundamental to identifying all relevant issues.
Address the issues
Through stakeholder engagement, ensure that the correct issues have been identified and that priorities and resources have been realistically assigned for their efficient resolution. Study teams are often tempted to 'look the other way' when stakeholders raise particularly difficult or contentious issues.
Document, document, document
At each step, careful documentation of the process and its outcomes is essential to maintain the credibility and trust required to resolve issues with a minimum of rancour.
Plan for action.
Understand clearly, and from the start, that the environmental and social impact analysis is only the first step in the process of ensuring that environmental and social requirements are actually implemented, on the ground, during project construction and operation. Complementary government and multi-lateral programmes to build capacity and manage issues in the broader context are often critical to the overall success and sustainability of development plans.
In summary: be realistic
Environmental and social impact analysis is an integral part of good project planning. When its requirements are met, project development can proceed more efficiently, with fewer delays, and as a result more economically, than without it.
But impact analysis is not a panacea. It only deals with issues within its mandate, as broad as that may be. Project delays and uncertainties can still arise due to issues outside the remit of the impact assessment process.
Overall, state-of-the-art environmental and social impact analysis is a necessary component of good project development. When impact assessment is done well, used well - and especially used as early as possible in the development process - it will often save the assessment's cost in delays avoided, stakeholders engaged constructively, and issues resolved. And that is the most significant advance of all from the early days of environmental assessment when delays and further delays, jargon and rhetoric, uncertainty and confusion reigned.
Why not try state-of-the-art impact analysis early - and do it well - on your next project?