The Threat of Environmental Corruption via Huge Dam Projects

A Memorandum to the World Bank on the proposed Bujagali falls projectby Ugandan NGOs.

Dr. R.J. A. Goodland, Environmental Advisor At The World Bank
P.O. BOX 7062
Kampala, Uganda

The Save Bujagali Crusade (SBC) and the National Association of Professional Environmentalists (NAPE) are honoured to meet you during your visit to the Bujagali Dam Project.

For your information SBC and NAPE have been accepted nationally and globally as the leading environmental advocators in Uganda and East Africa against environmentally bankrupt energy projects and politico–corporate crime in the energy sector.

We have recently formalised our partnership in this noble crusade and are set to work solidly together to convert our two organisations into "the nucleus of the global struggle against huge dams" in East Africa.

Within just over a year our contacts have grown enormously and now punctuate all continents and countries. It is probably because of this achievement of our struggle that you took notice of it and chose to come and meet us.

The meeting is significant for many reasons. It is taking place when:

1. Uganda has some of the; most corruption–generating laws in the world, ostensibly meant to motivate private investment but in reality promoting politico–corporate crime;
2. Uganda is submerged in a sea of corruption with major decision–making processes on virtually anything being both products and victims of political corruption at the highest level.
3. A recent report of the World Bank concluded that the way to control corruption in public procurement (in Uganda) is to ensure that classical principles of open competitive procurement are applied. Bujagali Dam Project was politically excluded from such process. Such exclusion is common in the country, but all the same, the said report "saw" Uganda's environment for new investment as more favourable that any other African country.
4. Recently the Corporate Investment Committee (CIC) of the International Finance Corporation (IFC) made clearances to appraise the Bujagali Falls Dam Project despite our concerns about its being pregnant with politico–corporate crime and corruption of the decision making process leading to its approval by Parliament.
5. The World Bank is parading Bujagali Project as a component of a broader sectoral reform initiative being carried out through a private sector Development Unit (PCDU) within the Bank.
6. The PCDU appears to be a kind of fusion between IDA and IFC staff working on Uganda Power Sector Issues although it is neither IFC nor IDA but an entity in itself.
7. The World Bank is using the Bujagali Project to motivate reform in the energy sector in Uganda in order to improve its financial viability; not its environmental, ecological, social or cultural viability.
8. SBC and NAPE are at a loss as to whether there is no conflict or interest between IFC's "for profit" mission in relation to Bujagali Dam and the Bank's broader energy sector restructuring process. SBC and NAPE are not convinced by the Bank's reasoning that "since" the restructuring process is designed to make the energy sector profitable. There is no conflict of interest in the IFC making a profit of it.
9. The Bujagali Falls Dam Project is yet to be released in IFC's The Monthly Operational Report ( why this is so remains a mystery) and when IFC has created the new position called Advisor/ombudsman as a reaction to increasing rejection by communities, of huge dams, or else it is a symbolic gesture that the World Bank is in fact listening.
10. the Uganda government is fidgeting with plans to introduce legislation to regulate the activities of NGOs, particularly those that have been active again environmentally bankrupt policies and projects.
11. In Uganda, frequent power cuts, which is a desperate manner of handling the power crisis in the country, is being used by government and its preferred energy developer, AES, as a justification for the setting up of large hydropower projects, thereby ignoring other critical aspects related to the patterns of power generation, distribution and consumption and the pervading influence of poverty;
12. The World Bank and the Uganda Government appear to be (perhaps symbolically) accepting the value of alternative renewable energy resources and small hydropower plants, if press reports are to be believed. The well–documented stand of the World Bank and Government, until SBC and NAPE strongly stood for the alternatives, was that these were uneconomical and not with the realm of concern of the Bank. Small dams were rejected primarily because they were not capable of meeting the "inflated demands" of the Government to feed the energy intensive industries and wasteful consumerist lifestyles yet elsewhere, particularly in India, they have met local energy needs effectively.
13. World Bank officials have recently visited the controversial Pak Mun Dam in Thailand. The visit revealed that villagers were deeply mistrusting the intentions of the World Bank and that they perceived the visit as a plot to silence their demands and protests for restoration of the Mun River.
14. Environmental groups, particularly SBC and NAPE, are doubting whether the Environmental Division of the World Bank is empowered enough to reject the money motive and stand by the actual or potential victims of huge dams.
15. Environmental groups are concluding that the Environmental Division of the World Bank may have been the Bank's way of expressing environmental symbolism to hoodwink the victims of environmentally bankrupt projects that the Bank is ready to provide "environmental leadership" for sanity.

Our view of the Uganda environment is that it is holistic and multidimensional with the dimensions themselves being multi dimensional.

Hence we recognise in our struggle the ecological–biological, the social–cultural the socio–economic and the time dimensions. We view the dimensions as dynamically interconnected and interacting. Therefore, any disruptions in any dimension will necessarily be transmitted and reflected in the others in a dynamic manner. This is why we are opposed to the continuing sectoral approaches to development in Uganda, which ignore the multidimensionality, interconnectedness and dynamism of our environment and its components stressing only growth in the flow of goods and services.

Our struggles and concerns particularly against/with politico–corporate crime/corruption in the energy sector are based on our holistic conception of the environment and the issues, problems and challenges thereof.

We are currently concerned about the spiraling environmental corruption in Uganda via political and corporate/business pathways of decision–making that totally ignore the suffering of the victims of huge hydropower projects.

Although Uganda is being projected by the World Bank as the "angelic icon" of private investment, in Africa at present, the country also displays the highest rates of corruption in all dimensions of its environment. Political corruption at the highest level is dynamically interacting with business corruption to the extent that any decision process regarding investment will most likely be a product of instutionalised corruption.

Recent exercises in law–making appear to have been conducted towards cushioning high–level corrupt decision making from the wrath and scrutiny of its victim– the civil society. For example the National Environmental Management Act 1995 which made almost the entire cabinet of President Museveni the policy committee of NEMA made it easy for political corruption to be used to endorse the Bujagali Dam Project and silence civil society on energy matters.

Such decision making engenders environmental corruption and is a serious threat to the environmental security of Uganda well into the future. Environmentally bankrupt and socio–culturally deficient projects will always be okayed to the detriment of citizens of this country.

We think that if the World Bank does not question such decision rules regarding investment and goes ahead to endorse and support projects so–approved, it will be an actor in the perpetuation and defense of corruption in development efforts. Any investment based on the yardstick of corruption is bound to perpetuate environmental corruption. That is why we are still opposed to the Bujagali Dam Project.

The real issue in Uganda by the way is not electricity but poverty. Currently the majority of Ugandans have no money for electricity for they are below the poverty line. Even those who have money to pay are increasingly finding it difficult to pay for the overpriced electricity. Focus, therefore, should be on poverty reduction; not damming for hydropower for export! Industrial growth responds to market forces rather than energy. The market for hydropower is critically small and dwindling because poverty is on the increase.

For us in SBC and NAPE we are opposed to energy generation that is a product of a corrupt and flawed policy–making process or cycle. We are opposed to raising the issues of energy above the issues of poverty. To us, poverty is the greatest of the greatest of pollutants of the environment of Uganda. The Environmental Division of the World Bank should be putting in place strategies to combat its effect on the environment other than providing environmental cover to environmentally bankrupt projects. The issues of environmental security and peace should therefore be integral to the structure and function of the Environmental Division of the World Bank and not subordinate to the profit motive if human society is to survive.

Our people are ignorant and poor and often do not understand the full implications of being convinced to accept huge dam projects. This is the case of our people at the Bujagali Dam site. Their ignorance and poverty should not be used as resources in the environmentally bankrupt project because doing so would be corruption and inhuman.

We hope that this memorandum will serve as a contribution to the World Bank's genesis as a true rather than a symbolic environmental crusader. We shall be very happy if some or any of our views are used in the rethinking of the mission of the Environmental Division of the World Bank in view of increasing conflicts between the "profit motive" and people's craving for "real development," human rights, environmental security and ecological and cultural integrity and peace.

We think that it does not make much sense erasing natural resources with multipurpose services (such as Bujagali Falls) only to replace them with artificial, nonviable projects (in social, cultural, ecological environmental and other terms). We are calling for sanity and truth–telling in development. The Bujagali Dam Project has lacked sanity and truth telling and must therefore be re–visited.