Nov. 2008 Letter to World Bank Executive Directors on Bujagali

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November 24, 2008

Dear Executive Director:

As requesters of the Bujagali Inspection Panel claim, we are very concerned that World Bank Management does not intend to seriously address the problems documented in the Inspection Panel’s recent report. We found the Panel’s report to correspond well with what we know to be key problems with the project on the ground. Yet the recent response by Management makes it clear that they have no intention of addressing the many problems and failures to meet Bank policy as documented by the Panel. We urge you and the other members of the World Bank Board of Executive Directors to use your good offices to require that a serious action plan be drawn up to address and resolve the problems identified by the Inspection Panel.

To us, the most critical issue is the current situation for affected people, both those already resettled for the reservoir and those who will be resettled for the transmission lines. We are especially concerned that the action plan does not address current plans to use eminent domain to take peoples’ lands for the transmission system, including for those who have not been compensated; the fact that the project has not studied ways to reduce the land take for the T-line system; and the shortcomings of management’s efforts to restore the livelihoods of affected people. As the Panel notes, programs for helping those to be resettled for the transmission lines are even more under-budgeted than for already-displaced people in the reservoir area, which the Panel felt was itself under-funded. There are about 342 affected households that have not been compensated for being moved for the T-line; 15 of their representatives have approached us for assistance.

We also believe that the Management Response shows that the Bank is once again standing behind developer’s promises that can too easily be broken, with no consequences for the developer and no recourse for affected people. We believe that the Bank and project developers should take out “performance bonds,” as described by the World Commission on Dams, to ensure that key project obligations are met.

We also see it as a matter of urgency to address issues of project affordability which was well-documented by the Panel but given very little attention in the Management response. As noted by the Panel, the project’s huge increase in costs, the Bank’s poor analysis in this regard, the added risks of climate change, and the downturn in the global economy, could all harm the project’s economic viability and affordability of its electricty. These risks are going to be borne by us Ugandans, not by project developers or the Bank, and yet we feel we have not been listened to on this regard at all.

The Panel’s findings on how the dam will affect Lake Victoria are also critical, and also mostly ignored in the Bank’s response. We urge you to call for a public release of the current water-release policy, and detail how it differs from the Agreed Curve and how it was agreed upon, and by whom. Neutral analysis of the release policy’s implication on lake health is the next step. We want public hearings on this issue, and guarantees that social and environmental considerations are given equal weighting to economic issues in determining the management of Lake Victoria outflows.

We believe that a comprehensive action plan that addresses the Inspection Panel’s findings can make a significant difference for the people and the environment affected by the Bujagali Dam. We would be pleased to offer constructive advice in the framing of such a plan.

Please find attached a summary of key findings raised by the Panel that we think are especially critical, and our recommendations for appropriate responses.

We are available to discuss the issues raised herein at your convenience.


Frank Muramuzi
Executive Director
National Association of Professional Environmentalists (NAPE), Kampala