Murchison Falls National Park: An Oil Project in a Protected Natural Area, High Risks of Environmental Violations

Total is present in Uganda through its wholly owned subsidiary Total Exploration & Production Uganda B.V (hereinafter Total Uganda), developing an oil project called “Tilenga” on the shores of Lake Albert. Total owns 54.9% of the project and is its operator. Its partners are the Chinese oil company CNOOC, with a 33.33% stake and Britain-based Tullow Oil with a 11.77% share. The oil development is part of a larger project, which includes the construction of a giant oil pipeline (“East African Crude Oil Pipeline”, hereinafter EACOP, developed by Total East Africa Midstream, another wholly owned subsidiary) through Uganda and Tanzania to transport the oil extracted by Lake Albert. According to a presentation by the consortium, the 1,445km-long pipeline will be “the longest electrically heated pipeline in the world”.13

The Tilenga project encompasses six oilfields. Total plans to drill more than 400 wells, mostly in the Murchison Falls protected natural area, in order to produce approximately 200,000 barrels a day. The project also includes related infrastructure such as an industrial zone with an oil processing plant (Central Processing Facility, hereinafter CPF), a pipeline network to connect the wells, CPF and Lake Albert, and a pipeline to transport the oil to a refinery in Kabaale, in the Hoima district, built by the Ugandan government. Tilenga and EACOP involve large-scale land acquisitions that require communities affected by expropriations to receive compensation. Consequently, Total’s operations in Uganda involve risks of serious human rights and environmental violations, detailed in the present report.


Excerpt  from Les Amis de La Terre France report

Serious Breaches of the Duty of Vigilance law: The case of Total in Uganda” 

Oil extraction projects carry inherent risks forthe environment in general (air quality, climate, noise pollution, soil geology, flora and fauna, aquatic life, biodiversity, etc.). The Tilenga project is no exception. This pollution can also affect the rights of local communities, especiallyt heir right to health and their livelihood (access to freshwater, contamination of soils and water used for agriculture, respiratory diseases, etc.).

Firstly, it should be highlighted that the majority of Tilenga project activities are located inside the Murchison Falls National Park. The Victoria Nile flows through the natural park, dividing the Tilenga project in two. An oil pipeline will have to run under the river. The Tilenga project also includes the RAMSAR-classified Murchison Falls-Delta Albert wetlands system, wetlands of international significance.

The Murchison Falls-Delta Albert wetlands system is a critical area for bird conservation, known to provide shelter to rare, vulnerable and threatened species. More specifically, according to the official website of the RAMSAR convention:

“The convergence between Lake Albert and the delta forms a shallow area that is important for waterbirds, especially the Shoebill, Pelicans, Darters and various heron species. The delta is an important spawning and breeding ground for Lake Albert fisheries, containing indigenous fish species; the rest of the site is dominated by rolling savannahs and tall grass with increasingly thick bush, woodlands and forest patches in the higher and wetter areas to the south and east. It forms a feeding and watering refuge for wildlife in the National Park during dry seasons. Murchison Falls are one of the main tourist attractions and recreation areas in Uganda, and the site is of social and cultural importance to the people of the area livestock grazing; fishing, with fish exported to DR Congo and also used to feed the refugees in camps in northern Uganda; illegal hunting for game, etc. Conflicts between fishermen and crocodiles are common. The site has been proposed for UNESCO World Heritage status.”

The company itself states in the ESIA that: “The Murchison Falls National Park (MFNP) is the largest and the second-most visited national park in Uganda and it is ecologically important for a number of globally and regionally threatened species.”

The Tilenga project will trigger an influx of people, which will inevitably have consequences on the fauna, flora and biodiversity. The whole strategy for managing the population influx presented in the ESIA does not seem convincing in regards to effects on the fauna, flora and aquatic biodiversity. It merely includes a list of questions that will be “considered”, “where feasible.” It is unacceptable that the ESIA fails to include any concrete measures to protect the wild fauna and flora as well as aquatic life against oil-related risks.

The ESIA admits that oil operations create multiple risks for the environment and the population (overfishing, poaching, poisoning of fauna and flora, etc.) but provides no concrete information on the laws and the implementation plans necessary to prevent, minimise and mitigate these risks. There is no reference to an “Integrated Management Plan”, although required by the 2013 “Strategic Environmental Assessment.” What’s more, Total Uganda and its partners undertake, in the ESIA, to conduct risk assessment studies before commencing drilling. This means that NEMA has issued the certificate without being fully aware of the risks of the Tilenga project, as the information from risk assessment studies was not included. Yet, under the terms of the 1998 Uganda regulation on environmental impact studies, NEMA must base its decision not on promises but on the concrete information available in the ESIA.

Finally, the ESIA does not mention any provision of national legislations that will govern and ensure compliance with risk assessments, wetland management plans, Ramsar sites protection plans, forest corridor plans, enhanced protection of parks, among others.

What will happen if underground oil pipelines collapse during an earthquake? What will be the consequences if these pipelines are located under the Nile? There is a real seismic risk in Uganda. This has been calculated as “moderate” for the oil area, which means that there is a 10% risk of an earthquake in the next fifty years.

This may sound marginal but the Global Facility for Disaster Reduction and Recovery (GFDRR, managed by the World Bank) states that: “Based on this information, the impact of earthquake should be considered in all phases of the project, in particular during design and construction. Project planning decisions, project design, and construction methods should take into account the level of earthquake hazard.”70

A scientific article in the South African Journal of Geology also concludes that: “The Albertine region of Uganda is characterized by high levels of seismic activity and by many active normal faults. […] We conclude that in the Albertine region, the return period for an earthquake capable of causing damage to engineering structures is, on average, 30 years. It is thus recommended that all important engineering structures in the region should be designed for earthquake resistance.”71

This study was entirely funded by Tullow Oil, partner in the Tilenga project, and should be referred to more explicitly in the ESIA. NCEA recommends that the aforementioned issues be addressed in the emergency intervention plan, still to be developed. The ESIA does not provide any clear answers to the issue of waste management (for instance from well logging, wastewater from wells, etc.).


The risks related to greenhouse gas (GHG) emissions are only briefly mentioned by Total in the ESIA. It is surprising to learn that, for an oil project of such scope (around 200,000 oil barrels per day), “the impact significance of GHG emissions was judged to range between Insignificant and Moderate Adverse.” The GHG assessment includes “account vehicle / machinery emissions, embodied carbon in construction materials, and the loss of carbon stock sources during site clearance activities, as well as GHG emissions during the operations of the Project”.

Thus, it does not take into account the life-cycle GHG emissions of the oil that will be extracted in the Tilenga project, which are by far the most significant GHG emissions, particularly during transport and combustion. The ESIA states that there won’t be any routine gas flaring during normal operations, but does anticipate that flaring will occur in exceptional circumstances, for a maximum period of 48 hours. Yet, flaring – burning the natural gas that escapes from oil wells, which cannot be processed, sold or used for economic and technical reasons – has a very significant climate impact. In addition to the waste of energy and the GHG emissions it produces, gas flaring also has severe health impacts, as documented in Nigeria.72 Ugandan civil society organisations are concerned about potential abuse of socalled “exceptional” flaring, as the specifics of these exceptions are not clearly defined.

Last but not least, the French government itself, directly referring to IPCC reports, has recognized under its so-called “Hulot” law, which bans new fossil fuel exploration projects, that “80% of known fossil fuel reserves must stay in the ground in order to maintain the trajectory of global temperature increase within the objectives of the Paris Agreement.”73 Currently operating fossil fuel deposits are already so big that extracting all their reserves would take the world beyond a 2°C temperature increase.74 Extracting oil and gas from new deposits, as proposed by the Tilenga project, contravenes the Paris agreement and its objectives.


In view of these shortcomings, the ESIA is clearly lacking in terms of risk prevention, and does not provide any guarantee that these risks can be avoided. Given that the oil project is located in an outstanding, protected natural area, it seems obvious that it would be impossible to guarantee that no serious and potentially irreversible environmental damage occurs. This raises the question of whether the project should go ahead at all.

Some of the environmental risks of the Tilenga project may have been identified in the ESIA, but not in a way that meets requirements under the duty of vigilance law, which calls for risk mapping within the vigilance plan itself, not a list of a few risks lacking in context.

Similarly, the actions to mitigate risks and prevent serious environmental violations mentioned in the ESIA are largely inadequate, and are not formally included in Total’s vigilance plan. This is a breach of Total’s obligations under the duty of vigilance law.

Source: Les Amis de la Terre