PGD Thesis (1.798Mb)

MAKERERE UNIVERSITY

COLLEGE OF AGRICULTURAL AND ENVIRONMENTAL SCIENCES SCHOOL OF FORESTRY, ENVIRONMENTAL AND GEOGRAPHICAL SCIENCES DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

ESIA OF AERIAL SPRAYING OF SUGARCANE WITH RIPENER AND FERTILIZER AT KINYARA SUGAR LIMITED IN MASINDI DISTRICT

THIS REPORT IS SUBMITTED IN PARTIAL FULFILMENT OF THE REQUIREMENTS FOR THE AWARD OF A POST GRADUATE DIPLOMA IN ENVIRONMENTAL IMPACT ASSESSMENT OF MAKERERE UNIVERSITY BY THE FOLLOWING STUDENTS:

Submitted by: AHABWE Kamusiime^^f^UNTvf^^ 2017/HD02/3380U

SUPERVISOR: PROF. JAMES OKOT-OKUMU JULY 2018 CERTIFICATION The undersigned do certify that he/she has read and here by recommend for acceptance by Makerere University a report entitled, "ESIA of aerial spraying of sugarcane with ripener and fertilizer at Kinyara Sugar Limited Masindi District", done in partial fulfilment of the requirements for the award of a Post Graduate Diploma in Environmental Impact Assessment of Makerere University.

Mb DEPARTMENT OF "rTV'^#lf ENVIR0NMENTAL Prof. Jam^Okot-Gku^^ MANAGEMENT (Supervisor)

1 DECLARATION AND COPY RIGHT I the undersigned declare that this script is my own original work; it has not been presented to any academic institution or place for either academic award or work.

NAME: REG. NUMBER SIGN

AHABWE Kamusiime 2017/HD02/3380U

"This script is copyright material protected under the Berne Convention, in the Copyright Act of 1999 and other relevant Laws of the Republic of Uganda; It may not be reproduced by any means, in full or in part, except for short extracts in fair dealing, for research or private study, critical scholarly review or discourse with an acknowledgement, without written permission of the Director of Postgraduate Studies Makerere University and or the authors".

2 ACKNOWLEDGEMENT 1 wish to unreservedly extend my gratitude to Prof. James Okot-Okumu for the invaluable support during compilation of ideas that make up this ESIA report. He is great and turns on the abilities in students. A thousand thanks to all the lecturers who have delivered the Postgraduate Diploma EIA course in a lucid and applied manner. Our happiness and satisfaction are a true reflection of their high level of smarts. Special thanks to Mr. Raji (Out Grower Manager – KSL) for furnishing me with information about KSL that was crucial in compilation of this ESIA report. Conversely, I am grateful to the technical staffs of Masindi District Local Government, and the various stakeholders who gave insightful comments/submission as I conducted consultations. Lastly, I thank my families, benefactors and benefactresses for standing with me throughout the journey. To all of you, God bless!

DEDICATION To those who seek satisfaction in themselves and on some land now and forever!

LIST OF ACRONYMS CAA Civil Aviation Authority DAP Diammonium phosphate ESIA Environment and Social Impact Assessment ESIA Environment Impact Assessment ESMP Environmental and Social Management Plan ICAO International Civil Aviation Organisation KSL Kinyara Sugar Limited MAAIF Ministry of Agriculture, Animal Industry and Fisheries MoWE Ministry of Water and Environment MoWT Ministry of Works and Transport MOP Muriate of Phosphate NE Nucleus Estate NEA National Environmental Act NEMA National Environment Management Authority OHS Occupational Health and Safety PPE Personal Protective Equipment SARPs Standards and Recommended Practices TSP Triple Superphosphate

TABLE OF CONTENTS CERTIFICATION ...... I DECLARATION AND COPY RIGHT...... II ACKNOWLEDGEMENT ...... III DEDICATION ...... IV LIST OF ACRONYMS ...... V TABLE OF CONTENTS ...... VI LIST OF TABLES ...... VIII LIST OF FIGURES ...... VIII ABSTRACT ...... X

THE PROJECT ...... X Overview ...... x KEY ACTIVITIES ...... X JUSTIFICATION OF PROPOSED AERIAL SPRAY OF SUGARCANE RIPENER ...... X POTENTIAL IMPACTS ...... XI Expected Positive Impacts ...... xi Key Potential Negative Impacts ...... xi Environmental Management Plan ...... xi 1.0 INTRODUCTION ...... 1

1.1 PROJECT DESCRIPTION ...... 1 1.1.0 Sugar cane ripening ...... 1 1.1.1 The ripening process ...... 1 1.1.2 Factors that influence ripening ...... 2 1.1.3 Proposed fertilizers for aerial application ...... 2 1.1.4 Proposed aerial spraying activities ...... 3 1.2 PROJECT JUSTIFICATION ...... 5 1.2.1 Limiting weather condition ...... 5 1.2.2 Increased productivity ...... 5 1.2.3 Advantages of aerial spraying ...... 6 1.2.4 Proposed project location ...... 6 2.0 BACKGROUND ...... 9

2.1 CHEMICAL RIPENING OF SUGARCANE ...... 9 2.2 USE OF CHEMICAL FERTILIZER IN SUGARCANE PLANTATIONS...... 9 2.3 LAND OWNERSHIP ...... 9 2.4 ALTERNATIVE ANALYSIS ...... 9 2.4.1 The no-action option ...... 10 2.4.2 Technology alternatives ...... 10 2.4.3 Site alternatives ...... 11 2.4.4 Chemical ripener alternatives ...... 11 2.5 NEED FOR ESIA ...... 11 2.6 THIS ESIA/TRANSFERABILITY ...... 12 2.7 THE SCOPE OF ENVIRONMENTAL IMPACT ASSESSMENT ...... 12 2.8 PROJECT GOAL, OBJECTIVES, IMPLICATIONS ...... 12 2.8.1 Project goal ...... 12 2.8.2 Project objectives ...... 12 2.8.3 Project implications...... 12 3.0 METHODOLOGY ...... 14

3.1 LITERATURE REVIEW ...... 14 3.2 THE SCOPING STUDY ...... 14 3.3 SITE VISITS ...... 14 3.4 STAKEHOLDER AND PUBLIC CONSULTATIONS ...... 15

3.5 MAPPING ...... 15 3.6 IMPACT ASSESSMENTS ...... 15 3.7 ENVIRONMENTAL MANAGEMENT PLAN ...... 16 3.8 POPULATION AND SAMPLING ...... 16 3.8.1 Population ...... 16 3.8.2 Sampling...... 16 3.8.3 Ethical Consideration ...... 16 4.0 BASELINE CONDITIONS ...... 17 4.1 PHYSICAL ENVIRONMENT ...... 17 4.1.1 LOCATION ...... 17 4.1.2 CLIMATE ...... 17 4.1.3 GEOMORPHOLOGY, MINERAL RESOURCES AND SOIL TYPES ...... 21 4.2 BIOLOGICAL ENVIRONMENT ...... 21 4.2.1 VEGETATION ...... 21 4.2.2 WATER RESOURCES ...... 22 4.2.3 WETLANDS ...... 24 4.2.4 NATURAL FOREST RESERVES ...... 24 4.3 SOCIO ECONOMICS ...... 25 4.3.1 ADMINISTRATIVE UNITS ...... 25 4.3.2 ECONOMIC ACTIVITIES...... 25 4.3.3 EDUCATION ...... 26 4.3.4 WATER SOURCES ...... 26 4.3.5 HEALTH ...... 27 5.0 REGULATORY AND INSTITUTIONAL FRAMEWORK ...... 28 5.1 POLICIES ...... 28 5.1.1 THE NATIONAL ENVIRONMENT MANAGEMENT POLICY...... 28 5.2 LAWS AND REGULATIONS ...... 28 5.2.2 THE OCCUPATIONAL SAFETY AND HEALTH ACT, 2005 ...... 29 5.2.3 THE PUBLIC HEALTH ACT, CAP 281 ...... 29 5.2.4 THE WORKERS’ COMPENSATION ACT, 2000 ...... 29 5.2.5 THE LAND ACT, CAP 227 ...... 30 5.2.6 THE WATER ACT, CAP 152 ...... 30 5.3 REGULATIONS ...... 31 5.3.1 THE NATIONAL ENVIRONMENT (WASTE MANAGEMENT) REGULATIONS, 1999 ...... 31 5.3.2 THE EIA REGULATIONS, 1998 ...... 31 5.3.3 THE NATIONAL ENVIRONMENT (STANDARDS FOR DISCHARGE OF EFFLUENT INTO WATER OR ON LAND) ...... 31 5.3.4 THE NATIONAL ENVIRONMENT (NOISE STANDARDS AND CONTROL) REGULATIONS 31 5.3.5 THE NATIONAL ENVIRONMENT (NOISE STANDARDS AND CONTROL) REGULATIONS S.I.NO.30/2003...... 32 5.4 INSTITUTIONAL FRAMEWORK ...... 32 5.4.1 CIVIL AVIATION AUTHORITY ...... 32 5.4.2 MINISTRY OF AGRICULTURE, ANIMAL INDUSTRY AND FISHERIES ...... 32 6.0 STAKEHOLDER CONSULTATIONS ...... 34 6.1 OBJECTIVES ...... 34 6.2 STAKEHOLDER ISSUES ...... 34 7.0 IMPACT ANALYSIS AND MITIGATIONS ...... 37

7.1 IMPACT ANALYSIS ...... 37 7.1.1 IMPACT DESCRIPTION ...... 37 7.1.2 IMPACTS EVALUATION ...... 37 7.1.3 RESIDUAL IMPACT ASSESSMENT ...... 39 7.2 POTENTIAL POSITIVE IMPACTS ...... 39 7.2.1 INCREASED SUGAR PRODUCTION AND REVENUES ...... 39 7.2.3 REDUCED COST OF SUGAR PRODUCTION ...... 39 7.2.4 JOB CREATION ...... 39

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7.3 PROPERTIES OF FUSILDE FORTE ...... 40 7.3.1 HARZADOUS COMPONENTS ...... 40 7.3.2 PROPERTIES AND HEALTH AND SAFETY PRECAUTIONS ...... 40 7.3.3 PROPERTIES OF PROPOSED FERTILIZERS ...... 41 7.4 POTENTIAL NEGATIVE IMPACTS ...... 43 7.4.1 DRIFT SPRAY...... 43 7.4.2 HEALTH AND SAFETY ...... 43 7.4.3 HAZARDOUS CHEMICAL WASTE ...... 44 7.4.4 NOISE POLLUTION ...... 45 7.4.5 CONTAMINATION OF OPEN WATER SOURCES ...... 45 7.5 MANUFACTURER’S RECOMMENDATIONS ...... 46 7.5.1 APPLICATION OF FUSILADE FORTE ...... 46 7.5.2 THE APPLICATION OF UREA 46% ...... 47 8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN...... 48 8.1 SCOPE ...... 48 8.2 RESPONSIBILITIES ...... 48 8.3 SUMMARY OF ESMP ...... 48 9.0 ENVIRONMENTAL MONITORING PLAN...... 51

9.1 ENVIRONMENTAL MONITORING ...... 51 9.1.1 OVERVIEW ...... 51 9.1.2 MONITORING OBJECTIVES...... 51 9.1.3 DURATION OF MONITORING ...... 51 9.1.4 THE MONITORING TEAM...... 51 10.0 CONCLUSION AND RECOMMENDATIONS ...... 54 10.1 CONCLUSION ...... 54 10.2 RECOMMENDATIONS ...... 54 11.0 REFERENCES ...... 55 LIST OF TABLES Table 1.1: Activity per personnel and their roles ...... 4

Table 1.2: Trends in sugar produced (in tons per hectare) due to chemical ripening ...... 5

Table 4.1: Major Crops Grown in Different Soil Types ...... 21

Table 6.1: Key issues raised by stakeholders ...... 34

Table 7.1: Determination of Impact Significance ...... 38

Table 7.1: Key hazardous ingredients in Fusilade Forte ...... 40

Table 8.1: Environmental Management Plan ...... 49

Table 9.1: Environmental Monitoring Plan ...... 52 LIST OF FIGURES Fig. 1: Map of Kinyara Sugar Limited ...... 6

Fig. 2: Nucleus Estate Map ...... 7

Fig. 3: Kinyara Sugar Limited Nuclear Estate where the aerial spraying shall be conducted on selected fields ...... 8 LIST OF PLATES

Plate 4.1: vegetative cover in the project vicinity ...... 22

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Plate 4.2: Kyabinyindo protected spring ...... 23

Plate 4.3: Borehole at Kasongoire Primary school ...... 23

Plate 4.4: Siba Wetland System in the NE ...... 24

Plate 4.5: Kisagura Forest Reserve within the NE ...... 25

Plate 4.6: Ebenezer Christian School. One of the schools near the Nucleus Estate ...... 26

ABSTRACT THE PROJECT OVERVIEW Kinyara Sugar Limited has ever executed commercial chemical ripening of sugarcane using Fusilade Forte between 1997 and 2005 and beneficial outcomes were recorded out of processing chemically ripened cane. The previous achievements have inspired KSL to re-do aerial spraying of the chemical ripener and fertilisers (Diammonium phosphate, Triple Superphosphate, Urea 46% and Muriate of Potash (MOP) onto selected fields within the nucleus estate twice a year; to a maximum of 2000 hectares/annum. KSL will execute the proposed project in tandem with the established legal and institutional framework requirements.

KEY ACTIVITIES The series of activities in the ripening exercise will include:

. Setting up of a shade for security personnel, two days before the exercise, including security guards at the key points to control village onlookers from accessing the air strip; . Assembling of Materials and equipment to be used is done one day before the exercise (Water trucks/ Bousers, Water pumps, Water drums, Horses, chemicals, Avigas, First Aid boxes, etc.); . Landing of the plane; . Spraying will start in the morning (7:00am) if the skies are clear and no rains expected in the next two hours; . Mixing: the plane capacity is 300 liters of spraying mixture that will cover 30 hectare per trip. Ten liters of chemical ripeners will be mixed in 200 liters of water and then fed to the plane by pumping it through a horse pipe . The remainder of the spraying mixture will be drawn from the plane, and stored for later use

JUSTIFICATION OF PROPOSED AERIAL SPRAY OF SUGARCANE RIPENER Climatic conditions, which include a gradual drop in temperature and a decrease in precipitation until it is completely dry in the middle of the year, are decisive in the maturation process. However, in many areas like Uganda, during the ripening period, these conditions do not occur simultaneously or completely. In such situations, the use of ripeners in the sugarcane crop is designed to increase productivity and to project/synchronise the harvest, thus allowing essential crop management in a modern production system. Aerial application will be more efficient as the aircraft can treat fields when the soil moisture is too great for the operation of ground application equipment and can also apply the chemicals when the sugarcane canopies become too tall or are too thick for ground application equipment. Given the commercial size of the Nucleus Estate, an agricultural airplane or helicopter can accomplish more in one hour than ground equipment can in a single day. In addition, by introducing aerial fertilizer application, workers can be spared for specialized and highly paid tasks (e.g., harvesting) that have not yet been mechanized.

POTENTIAL IMPACTS EXPECTED POSITIVE IMPACTS The project will lead to increased sugar production as the ripening at the required time will lead to juice with high sugar content. The ripeners should increase recoverable sugar per ton of cane, while minimizing decreases in tons of cane per acre. Increased sugar production will directly translate into increased revenues to the Company. Consequently, increased sugar production due to the project will lead to increased revenue generated to Masindi District and the country in general in the form Value Added Tax (VAT) on sugar, income tax, license fees, and royalties among others. The cost of sugar production will be highly reduced because of high quality of cane harvested from the nucleus estate. It is cheaper to extract sugar from quality cane that will have high concentration of sucrose, and low concentration of non-sucrose components such as other sugars. The project is anticipated to create short-term employment opportunities for both skilled and unskilled labour during the exercise; and long-term employment opportunities at the factory. Skilled personnel that will be employed such as pilot, HSE specialists, spray mixers, supervisors, and in other technical positions whereas unskilled laborers will be required as support staff to perform non-technical tasks such as security.

KEY POTENTIAL NEGATIVE IMPACTS  Spray drift which involves the movement of chemicals outside the intended target area, most commonly through small driftable droplets (less than 150 μm) being blown off- target through the effects of wind and air movement;  The workers may be exposed during the application process that will include; storage, transportation, mixing, spraying the chemical and cleaning of the equipment after application;  Fertilizer loss from agricultural land to adjacent surface water. Appropriate nutrient management practices can minimize this risk;  The plane may cause excitement among the neighbouring communities especially schools such as Kasongoire Primary School and Ebenezer Christian school and might disrupt classes.

ENVIRONMENTAL MANAGEMENT PLAN Several factors are critical for successful aerial application; the whole process of ripener and fertilizer procurement ought to be synchronise with the field application program. The physical quality specifications of fertilizer (must be granular) material will be adhered to ensure uniform distribution over the field. Blending will be monitored closely when two or more fertilizers are applied at the same time. Administrative requirements for the pilot, aircraft, and airstrip, as well as flight authorization will be arranged accordingly.

A team will be put in place to manage the project. An aerial fertilizer coordinator, responsible for all operational logistics, the work program and coordination with Estate Manager, the control of fertilizer preparation and application, the control of operational security, as well as progress reporting to estate and agronomy department; one senior engineer for aircraft maintenance and spare part inventory management; one experienced pilot per aircraft; loader

xi and driver teams (one per aircraft). Environmental issues will be managed and monitored daily by KSL Environmental Officer. The Health and Safety Manager will continuously assess risks of the aerial spraying exercise including those not covered by this ESIA and will work closely with the Agronomist and Estate Manager to ensure that all workers handling chemicals have adequate protection. Contractors for waste management, public liaison etc. will be outsourced or individual from existing staff will be selected by KSL management. Monitoring will be undertaken for water quality and compared with baseline levels to detect any cases of pollution because of the aerial spraying exercise.

It is recommended that the Developer should, through their Public Relations Office, actively engage the local and district authorities. This will be help in monitoring and enforcing the relevant legislations and further help to address any concerns from the public. It is also recommended that the proponent provides a telephone line through which concerns of the public regarding the project will be forwarded. Conclusion Aerial fertilizer application has been used for years in the U.S., Australia, New Zealand, Malaysia, and in Uganda including at Kinyara Sugar Limited. The Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) has no objection on importation of adequate Fusilade Forte for use on the 5000 ha of sugarcane at Kinyara for ripening of sugarcane. Aside, the CAA has no objection to the aerial spraying project so long as the preparation is in tandem with the established legal and institutional framework.

The potential environmental impacts of the proposed project have been assessed and are found to be minor to negligible and can be effectively mitigated. With successful implementation of the Environmental Management Plan presented in this ESIA, the proposed project will not have any environmental issues of concern. KSL is committed to adhering to the necessary laws and regulations to ensure smooth implementation of the project.

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1.0 INTRODUCTION The consumption of Sugar in Uganda has in the last 10 years doubled to 240,000 tonnes per annum. The USCTA (2012) noted that there is plenty of opportunity to meet the growing domestic and regional demand. The target markets for Ugandan sugar are Democratic Republic of Congo, South Sudan, Burundi and Rwanda because of their proximity and large populations. As a result, sugar producing companies such as Kinyara Sugar Limited (KSL) are devising means of meeting this steadily growing local and regional demand, through sustainable agricultural practices. Established in the 1960s, Kinyara Sugar Limited (KSL) is the second-largest manufacturer of sugar in Uganda, producing an estimated 120,000 metric tonnes annually, accounting for more than 30% of national sugar output. The sugar produced meets Ugandan quality standards and is therefore suitable for direct consumption without further treatment or refining. The Company is located at Block 9 & 10 in Bujenje, Masindi District. KSL owns a Nucleus Estate (NE) of about 8,500 hectares (ha) of sugarcane from which about 35 - 40 % of KSL factory cane requirements is supplied. The other 60 - 65% of the cane requirements is sourced from Out Growers. KSL is intent on adopting technologies that can enhance improved sugar productivity so as to capture a bigger market share and increased profitability. The technology that has been carefully vetted is the aerial application of sugar cane ripeners and fertilizers. This activity can only be implemented after an ESIA and post approval by NEMA/MAAIF.

This proposal is a mirage of the aerial application of sugar cane ripener and fertilizers, and the approach for ESIA to approval stage.

1.1 PROJECT DESCRIPTION 1.1.0 SUGAR CANE RIPENING 1.1.1 THE RIPENING PROCESS The physiology of sugarcane ripening has been studied for more than 30 years. Sugarcane ripening is a physiological process that involves the synthesis of sugars in the leaves, translocation of the products formed and storage of sucrose in the stalk (Fernandes, 1982). According to Castro (1999), ripening, also referred to as the process of sucrose accumulation, is one of the most important aspects for sugarcane production.

The quality of sugarcane juice at harvest is determined by the concentration of sucrose, which should be high, and the concentration of non-sucrose components such as other sugars, which should be low. Sugar begins to accumulate in the sugarcane internodes when they start elongating and continues until the elongation ceases. During ripening, the sucrose concentrations along the entire cane increase while the non-sucrose components such as the glucose and fructose decreases.

1.1.2 FACTORS THAT INFLUENCE RIPENING 1.1.2.1 TEMPERATURE Air temperature plays a key role in sugarcane ripening; temperature is responsible for slowing the growth rate, leading to the accumulation of more sugar. Glover (1972) noted that low temperatures increased the sucrose content in stalks. Similarly, Castro (2002) observed that low temperatures lead to a rapid decline in photosynthetic efficiency, and high levels of sugar are not retained; the low temperatures affect the development of the stalk, sugar transport and storage, leading to accumulation of sucrose in the leaves. 1.1.2.2 SOIL MOISTURE Sugarcane plants slow their growth rate to accumulate more sugar under specific conditions involving both temperature and soil moisture content. The physiological ripening process limits the rate of plant growth without affecting the photosynthetic process, such that there is a greater balance of products that are photosynthesized and transformed into sugars for storage in plant tissues. 1.1.2.3 CHEMICAL SUGARCANE RIPENING During rapid growth of sugarcane (nutrient, water, sunlight, and high temperature), most photosynthetic material is used in the production of new leaves and rapid elongation of internodes, and thus, there is little left for storage as sucrose. However, when growth factors are limited, the growth of the crop slows down, and more photosynthetic material is stored as sucrose. Chemical ripeners disrupt the growth of the crop without affecting the process of photosynthesis, thus stimulating the conversion of glucose and fructose to sucrose. In commercial sugar production therefore, chemical ripening is important for improving cane quality and quantity of sugar produced per hectare. All varieties of sugarcane respond to Fusilade. However, the magnitude of response depends on the age and period of harvest and the variety of crops. The chemical ripener works to inhibit sugarcane growth and promote the accumulation of sucrose. This increases the quality and quantity of sugar recovered.

1.1.3 PROPOSED FERTILIZERS FOR AERIAL APPLICATION The fertilizers to be aerial sprayed are as below:

 Diammonium phosphate (DAP)  Triple Superphosphate (TSP)  Urea 46%  Muriate of Potash (MOP)

Phosphorus (P) and potassium (K) are important plant nutrients for sugarcane. Phosphorus is critical in the early stages of sugarcane growth. It stimulates root growth. It is essential in the storage and transfer of energy and is an important component of several biochemicals that control plant growth and development. Phosphate (P2O5) is used by sugarcane at a rate of approximately 1.7 lbs per ton of cane. Of this, about half is in the millable stalk and is removed from the field, and about half is in the tops, trash, stubble and roots and returned to the soil during decomposition.

Potassium is indirectly related to many plant cell functions in sugarcane. Sugarcane is a heavy feeder of potassium. The plants require about 6.7 lbs. of potash (K2O) per ton of cane produced. Of this amount, about 2.9 lbs. are contained in the millable stalk and removed from the field.

The remaining 3.8 lbs. of potash are contained in the tops, trash, stubble and roots and are returned to the soil during decomposition.

Nitrogen is an important plant nutrient and used in fairly large amounts by sugarcane. Nitrogen is supplied to the plant by fertilizers, residual nitrogen in the soil, decomposition of organic matter and atmospheric sources of nitrogen.

1.1.4 PROPOSED AERIAL SPRAYING ACTIVITIES 1.1.4.1 FIELD IDENTIFICATION AND SELECTION Application of sugarcane ripener and chemical fertilisers will depend on the growth stage of sugarcane. Different plant nutrients are required at different stages of growth and this will be a major factor to consider while carrying out aerial spraying activities. However, Sugarcane ripening will be done on actively growing crop that will be identified and selected based on the following factors:

1.1.4.2 AGE The principle is that ripened sugarcane must be harvested between 6-8 weeks after ripening. Sugarcane ripening ranges between 13 and 16 months depending on variety and crop class. Ratoon crops are ripened between 13 and 14 months so that they can be harvested at 14 or 16 months while plant crop are ripened between 14 and 16 months to allow harvesting between 16 and 18 months depending on varieties.

1.1.4.3 LOCATION The sugarcane to be ripened or to receive chemical fertilisers will be that grown within the NE. Fields neighbouring communities and their gardens will NOT be selected for aerial spraying. In addition, fields close to natural resources such as wetlands, forests and water sources will NOT be selected.

1.1.4.4 PROXIMITY Qualifying fields that are close to each other will be selected and clustered for spraying to minimize on flight trips and drifts effects.

1.1.4.5 FIELD INSPECTION AND MARKING  Field inspection is part of the aerial spraying; selected fields will be physically inspected two weeks prior to spraying. The aim is to examine their physical suitability for ripening.  The suitable fields will be marked by digging holes at each corner, which will be later used for placing marking flags at spraying time.

The important factors to consider optimising the response from chemical fertilisers and Fusillade as a ripener include:

. Keeping optimum moisture conditions during and after application, . Respecting the recommended intervals from application to harvest and, . The crop must be actively growing at the time of application.

1.1.4.6 EQUIPMENT TESTING AND PERSONNEL TRAINING

 One week to the spraying exercise, all equipment to be used will be tested by a qualified mechanic;

 All Personnel to be involved will be trained /retrained and will do rehearsals/practices.

1.1.4.7 PROCUREMENT OF MATERIALS Major materials for use are the fertilisers and ripener chemicals (Fusillade Forte) and Avigas. Other materials include proper adequate PPE, flags, flagpoles and water drums that will be mobilized from within the Company.

1.1.4.8 ANNOUNCEMENTS Official letters communicating the exercise will be sent to Masindi District Local Government and to local authorities two weeks prior to the spraying exercise. The general community will be informed through radio announcements on all local FM radio stations, detailing the areas to be sprayed with either fertilisers or the ripener and the precautions that the community must observe during the exercise.

1.1.4.9 ACTUAL AERIAL SPRAYING EXERCISE The series of activities in the spraying exercise will include:

Table 1.1: Activity per personnel and their roles Personnel Roles Estate Head of Agronomy Over all supervisor of the works Agricultural Engineer In charge of machinery & equipment Health and Safety Manager In charge of health and safety for workers and visitors Field Manager Field Supervisor Agronomy Team  Rising marking flags  Drawing water from bowsers/ trucks Measuring chemicals  Mixing the Chemicals  Feeding the chemicals to the plane  Fuelling the plane  Monitoring field spraying  Cleaning equipment

Pilot Aerial spraying Drivers Deliver water and project equipment Security Team To keep away onlookers and provide security

1.1.4.10 POST RIPENING OPERATIONS During ripening, sugarcane stores sucrose starting from the bottom and then in the top of the stalk. Therefore, at the beginning of the season, the lower third of the stalk has higher sucrose content than the middle third, which has a higher content than the upper third. As ripening progresses, the sucrose content tends to equalize in the different parts of the stalk. Two weeks after spraying, maturity sampling will be done to determine the juice quality on weekly basis. Assessment for side shoots, aerial roots and drying stalks will be done four weeks after spraying. Consequentially, harvesting will take place from the sixth week after spraying and the juice quality will be monitored from both the Agronomy and Factory Labs at hourly intervals.

1.2 PROJECT JUSTIFICATION 1.2.1 LIMITING WEATHER CONDITION A gradual drop in temperature and reduced rainfall are crucial for the natural ripening of sugarcane. Climatic conditions, which include a gradual drop in temperature and a decrease in precipitation until it is completely dry in the middle of the year, are decisive in the maturation process. However, in many areas like Uganda, during the ripening period, these conditions do not occur simultaneously or completely. In such situations, the use of ripeners and flowering inhibitors in the sugarcane crop is designed to increase productivity and to anticipate the harvest, thus allowing essential crop management in a modern production system.

Previous cases of sugarcane ripening at KSL noted improved minimum sucrose content (pol) in cane 6 - 8 weeks after treatment and the differences in sugar yields (table 1) were always adequate to cover the cost of application and earn the Company reasonable returns to investment.

Table 1.2: Trends in sugar produced (in tons per hectare) due to chemical ripening Year 1997 1998 2000 2002 2005 Mean Recorded increase in sugar 0.5 0.1 0.4 1.23 0.27 0.5 tonnes/ha

1.2.2 INCREASED PRODUCTIVITY There is a close relationship between the consumption of fertilisers and crop production. Monoculture, the practice of growing one crop on a particular piece of land for a long period, leads to depletion of soil nutrients because of continuous uptake by the crop. This in turn leads to reduced production. Application of synthetic fertilisers serves to replace lost soil nutrients and thus increase productivity. Application of fertilisers has been carried out at KSL for many years. In all cases, the practice has registered positive results in terms of quality and quantity of the sugarcane produced at the Nucleus Estate. Considering the big size of the Nucleus Estate fields, aerial spraying of agricultural fertilisers is more efficient than any other method of application.

1.2.3 ADVANTAGES OF AERIAL SPRAYING Access is one reason why fertilizer is often not applied properly, and the application rate is reduced in the parts of the field most distant from the roadside. This results in spatial variability in the incidence of deficiency symptoms and reduced yield and profitability. Aerial application presents a solution to allow for uniform fertilizer application. Aerial application is often the most efficient and most economical way to apply sugarcane chemical ripeners and fertilisers. Aircraft can treat fields when the soil moisture is too great for the operation of ground application equipment and can also apply the chemicals when the sugarcane canopies become too tall or are too thick for ground application equipment. Given the commercial size of the Nucleus Estate, an agricultural airplane or helicopter can accomplish more in one hour than ground equipment can in a single day. In addition, by introducing aerial fertilizer application, workers can be spared for specialized and highly paid tasks (e.g., harvesting) that have not yet been mechanized.

1.2.4 PROPOSED PROJECT LOCATION Kinyara Nucleus Estate is in Kinyara, Masindi District, in Western Uganda (Figure 1), approximately 200 kilometres from Kampala. The KSL Nucleus Estate is located along Latitude 01038’N and Longitude 31036’E and at an altitude of 1114 metres above sea level (figure 1). The NE covers approximately 8,500 ha and it is partitioned into four areas (area 1, 2, 3 & 4). Each area is about 2,000 ha and divided into various blocks of about 200 – 800 ha each. These are named according to the indigenous village names, for example Kihura and Kisagura. Blocks are further divided into several 20-50 hectare fields depending on the block size. The average field size is about 10 ha (figure 2).

Fig. 1: Map of Kinyara Sugar Limited

Fig. 2: Nucleus Estate Map

Fig. 3: Kinyara Sugar Limited Nuclear Estate where the aerial spraying shall be conducted on selected fields

2.0 BACKGROUND Sugar cane quality depends on many factors including but not limited to; soil type, rainfall, temperature, humidity, sunshine, sugar cane variety, cane husbandry, and mill performance. These weathers and many other factors are not under direct human control. At KSL, there is these occurrences; a decline in sugar productivity, reduction in soil fertility, varying meteorological conditions which are expected to be a result of climate change. The individual occurrences and their interaction are most probably the root cause of the decline in sugar productivity, yet the sugar demand is stiff. This situation can be reversed through strategic approaches like efficient application of ripeners and fertilizers. It is evident that the use of sugarcane ripeners is highly beneficial. KSL carried out commercial chemical ripening of sugarcane using Fusilade Forte for a total of five times in 1997, 1998, 2000, 2002 and 2005 and there was significant sugar productivity recorded. Based on previous achievements from the application of ripener, KSL is intent on aerial spraying of chemical ripener and fertilisers at their Nucleus Estate using Fusilade Forte and other agrochemicals approved by MAAIF. The exercise will be done bi-annually covering approximately 2000ha on the Nucleus Estate.

2.1 CHEMICAL RIPENING OF SUGARCANE The use of ripeners in the sugarcane production system provides greater flexibility in managing the harvest. When natural conditions are not enough for promoting natural sugarcane ripening, the growers can use chemical products to initiate ripening. These chemicals are plant growth regulators or inhibitors known as ripeners and affect the plants in different ways. They can modify the morphology and physiology of the plants, which can lead to quantitative and qualitative changes in production by promoting reduction in plant growth and increase in sucrose content, anticipating the ripening and enhancing the sugar yield.

2.2 USE OF CHEMICAL FERTILIZER IN SUGARCANE PLANTATIONS Application of chemical fertilisers in sugarcane plantations is not a new phenomenon in Uganda. When the soil fertility is not sufficient for sugarcane production, growers can use chemical fertilisers such as urea, phosphates and synthetic ammonia among others. The objective is to improve the growth and productivity of sugarcane. Fertilisers enhance the natural fertility of the soil (revitalise soil chemistry) or enhance chemical elements, such as nitrogen, phosphorus and potassium, depleted by previous crops most especially in monoculture.

2.3 LAND OWNERSHIP The proposed piece of land on which the project is to be established belongs to the developer, Kinyara Sugar Limited. There are no land ownership issues at the proposed project site.

2.4 ALTERNATIVE ANALYSIS Alternatives based on different approaches to the realization of the planned project will be considered. Analysis of alternatives was undertaken by consideration of technological, economic, social and, cultural dimensions. The “no project” option was also considered to assess the impacts of the project against those that would have taken place if the proposed project is not implemented.

2.4.1 THE NO-ACTION OPTION In this option, it is required to be considered as to whether it is more advantageous to KSL and the nation at large not to commence at all the proposed project of aerial spraying of agricultural chemicals at KSL Nucleus Estate. No project option is considered mainly with respect to:

 Utilization of natural resources  Environmental impacts, harmful or beneficial  Benefits of the Company to the society The No Action Option would mean that the following positive impacts anticipated from the proposed project would be missed out. Such benefits include the following:

 Increased sugar production  Reduced cost of sugar production  Increased revenues to the Company  Increased revenue to the government  Increased economic activity of the land  Job creation  Increased levels of skill in sugarcane growth and sugar production

This project aims to address the issue of sugar production shortage in Uganda through enhancing high productivity yields in sugar cane. Application of sugarcane ripener and chemical fertilisers will serve to boost production and quality of the cane at the NE. ‘No-Project’ option is adopted only in an extreme case of negative listing and is not warranted at all in the present case given the above benefits of the proposed project to the Ugandan economy. The proposed aerial spraying of agricultural chemicals at the Nucleus Estate will not cause depletion of natural resources or significant adverse impacts on environment. On the contrary, it will add value to the sugarcane and lead to production of quality cane for the KSL factory. Therefore, “No-Project Option” will not be considered.

2.4.2 TECHNOLOGY ALTERNATIVES The process selection is done based on the following considerations:

 Least stress on the sugarcane plantation  Least stress to the neighboring community  Reduce, Recycle and Reuse of wastes  Least or no pollution from the project  Least or no risk to human and property  Least or no adverse impacts on environment The technology of applying agricultural chemicals to plantation agricultural estates have been studied over years to find the best alternatives to address the above enquiries of technological alternatives. Currently, the technology of aerial spraying is most widely accepted and therefore the ESIA team will recommended it to be adopted.

2.4.3 SITE ALTERNATIVES The exercise will be carried out twice a year and at different fields of the Nucleus Estate. While identifying target fields, the following criteria are considered:

 Age: sugarcane will only be ripened at between 13 and 16 months old, depending on the variety  Location: Aerial spraying will only be done at KSL Nucleus Estate.  Proximity: Fields close to natural ecosystems such as wetlands and natural forests will be avoided. Furthermore, fields near the neighboring communities will not be sprayed.

The proposed site is owned by KSL. The developer is committed to ensuring the above factor considered through the project and all issues are addressed. The expected impact to the natural ecosystems and the neighboring communities is insignificant.

2.4.4 CHEMICAL RIPENER ALTERNATIVES Early season sucrose levels have been improved with the application of glyphosine, glyphosate, ethephon, fluazifop, haloxyfop and trinexapac-ethyl. The ability of a synthetic chemical to increase sucrose levels in sugarcane is dependent on the chemical mode of action and the crops ability to metabolize the chemical. Moddus® (trinexapac-ethyl) has been used to ripen sugarcane in Brazil since 2000. The following glyphosate formulations are available as alternative chemical ripeners: Touchdown Total, Roundup WeatherMAX and Roundup PowerMAX. Some sugarcane varieties are less responsive to glyphosate than others. Higher rates of glyphosate may be needed to obtain the desired increase in the recoverable sugar per ton of cane (TRS) in varieties that are less responsive. Glyphosate can cause serious damage when drifted onto non-target sites (newly planted cane, other crops or residential landscapes). Drift-control agents may be added to reduce drifting potential. However, ripener should only be applied when wind speeds are between 3 and 10 mph and should not be applied when there is a surface temperature inversion. A surface inversion occurs when temperature at the surface is cooler than air above the surface; usually in the evening or early morning. Surface inversions restrict vertical air mixing and cause spray droplets to remain suspended where they can move laterally, reducing effectiveness of application and potentially causing damage to non-target sites. Also, wind direction should be considered when applying glyphosate ripener to avoid drifting onto sensitive non-target sites.

2.5 NEED FOR ESIA The National Environmental Act (NEA) Chapter 153 contains provisions for environmental management and protection including the need to carry out EIA for projects listed in the Third Schedule of the Act. Commercial agriculture is listed in this schedule among projects that are likely to have significant impacts on the environment and therefore require an ESIA approval from the National Environmental Management Authority under the EIA Regulations S.I. No. 13/1998.

2.6 THIS ESIA/TRANSFERABILITY This will be conducted properly, and the findings put in an Environmental Impact Statement (EIS) showing the proposed project, predicted environmental impacts, suggested mitigation measures, project alternatives that were considered, stakeholder concerns and recommended Environmental Monitoring Plan (EMP). The information contained in the resultant EIS shall be used by NEMA and other Lead Agencies to determine whether the project is likely to have significant adverse impacts on the environment and provide the basis for approval for implementation.

2.7 THE SCOPE OF ENVIRONMENTAL IMPACT ASSESSMENT The exercise will be conducted in Kinyara Sugar Limited nucleus estate and the surrounding areas. The entire process including the Environmental Impact Statement will be done in tandem with the National Environmental Impact Assessment Regulations of 1998. It will include an assessment of the potential environmental impacts of aerial spraying of sugarcane chemical ripener and fertilisers and suggestions on how to mitigate them. Time frame - The entire ESIA process is expected to take a period of 6 months (from commencement to completion).

2.8 PROJECT GOAL, OBJECTIVES, IMPLICATIONS 2.8.1 PROJECT GOAL The aerial spray of sugarcane with ripener and fertilizers by KSL is aimed at improving the productivity and profitability of sugar in a manner that is both environmentally sound and sustainable.

2.8.2 PROJECT OBJECTIVES

 To increase productivity of sugar cane in terms of quality and quantity, thus make the venture profitable and the sugar affordable.  To have an efficient and economical way of application of sugar cane ripener and fertilizers.  To identify potential impacts of aerial spraying, enhance the positive impacts and mitigate the negative impacts.

2.8.3 PROJECT IMPLICATIONS Whereas the aerial spray of sugar cane ripener and fertilizers has plausible socio-economic benefits, it poses several environmental threats including, inter alia,

 Spray drift which involves the movement of chemicals outside the intended target area, through minute (micro) droplets (< 150μm) being blown off-target through the effects of wind and air movement;  The workers may be exposed during the application process that will include; storage, transportation, mixing, spraying the chemical and cleaning of the equipment after application;  Fertilizer loss from agricultural land to adjacent surface water;  The aerial spray aircraft may cause excitement among the neighbouring communities especially schools thus disrupting classes.

The likely negative impacts ought to be systematically examined, their significance determined, and mitigation strategies developed.

3.0 METHODOLOGY 3.1 LITERATURE REVIEW Desktop research to obtain information on environmental, occupational health and safety legislation, policies, guidelines, manuals, procedures, practices, international best practices related to aerial spraying of fertilisers and chemical ripeners was be undertaken. Detailed literature review was also conducted to understand the chemistry of the proposed synthetic fertilisers and chemical ripener including their toxicity data. Data collection commenced during the scoping stage and continue through the report compilation stage. These are some of the literature that were reviewed; The constitution of the republic of Uganda, 1995 The occupational safety and health act, 2006 The public health act, CAP 281 The workers’ compensation Act, 2000 The Land Act, CAP 227 The Water Act, CAP 152 The National Environment (waste management) regulations, 1999 The EIA regulations, 1998 The National Environment (standards of discharge of effluent into water or land) regulations The National Environment (noise standards and control) regulations

3.2 THE SCOPING STUDY At the commencement of the assessment, a scoping exercise was undertaken to determine project alternatives and to identify the key issues that require further assessment in the detailed ESIA and to develop the ToR for the ESIA that would be submitted and duly approved by NEMA. Scoping was designed to inform the public, interest groups and government agencies of the project (including opportunities for public involvement) and to present the proposed actions, alternatives and impacts for public and agency review early in the process. The scoping process helped to eliminate detailed study of those issues that were not significant and those issues that have been addressed by prior (similar) studies. The scoping process included public meetings, Focus Group Discussion (FGDs), Rural Rapid Appraisal, at which stakeholders and reconnaissance tour of the sites. Participatory approaches were preferred here because they have been tested and proven effective in gleaning data from communities in a short temporal scale, just like for this very ESIA where time will be one of the limited resources. Focus was also on the need to consider the alternatives and probable significant environmental impacts for detailed assessment. The ToRs ‘approved’ by NEMA guided the team of novice consultants to conduct the environmental studies and prepare a comprehensive ESIA report.

3.3 SITE VISITS These were carried out to identify key environmental and social issues on selected sites. The experts observed, interviewed, and recorded information on spot. They used tools to guide them especially the interviews. Site visits will be comprised of;

 Reconnaissance trips and Scoping field visits to the sites with the objective of the inter- facing with the stakeholders and gleaning site information in terms of social- acceptability, biodiversity issues;  Interviews with the communities neighbouring the Nuclear Estate and consultations with the Management of Masindi District Local Government.  Socio-economic data capture and documentation, covering social and economic dimensions (demographic, economic activities and livelihood sources among others). Socio-economic aspects focussed on soliciting specific socio-economic views from the local authorities, and the communities to be affected regarding land-use practices around the Nuclear Estate.  Physical geographic aspects such as landforms, climatic conditions, and  Ecological aspects such as the status of flora and fauna of the area, and ecosystem interactions.

Precisely, site visits enabled the ESIA team to compile a valid baseline situation for the proposed project area which of paramount importance as a reference point for impact monitoring.

3.4 STAKEHOLDER AND PUBLIC CONSULTATIONS A comprehensive process of stakeholder identification and consultations which was all- inclusive, open and transparent was done to gather stakeholder views. This was hinged on the Environmental Impact Assessment Regulations (1998) through which the Government of Uganda set minimum requirements for stakeholder consultation and engagement during an ESIA process. Stakeholder consultation were undertaken with the aim of:

 providing stakeholders with an overview of the proposed operations and activities, as well as an understanding of the ESIA process;  Identifying and documenting the views, concerns and expectations of affected communities, political and cultural leaders, non-governmental organizations, and government agencies relating to the proposed operations.  Understanding local expectations of the project;  Characterizing potential environmental, socio-economic impacts;  Developing effective mitigation recommendations. Several stakeholders were consulted notably; KSL officials, NEMA, MAAIF, Masindi District Local Government Officials, Lower Local Government leadership, and the communities adjacent the Nucleus Estate.

3.5 MAPPING The KSL nucleus estate was mapped using a GPS. Spatial analysis was done using ArcGis10.3 and the resultant maps have been used in the ESIA reports.

3.6 IMPACT ASSESSMENTS Anticipated impacts that may emanate from the project were analyzed against the baseline conditions and were fully established during the detailed fieldwork and information obtained

15 from the documentary reviews. Effects of the project to the environment and social well-being were evaluated against issues such as vegetation cover, land and soil, environmental pollution, health and safety, cultural integration and overview of benefits to the community and country.

3.7 ENVIRONMENTAL MANAGEMENT PLAN Upon identification of the potential impacts from the project, appropriate measures were drawn to mitigate the impacts. This then lead to the development of the environmental management plan to guide the project implementation. Having established the impacts and the mitigation measures, integration of the impacts in the project implementation is crucial. The monitoring plan would serve as a supervisory schedule with respect of the environmental aspects.

3.8 POPULATION AND SAMPLING 3.8.1 POPULATION The ESIA exercise involved a cross-section of stakeholders with different levels of interest, power, and possibly importance to the project. The stakeholder includes some of these; the developer, the lead agency, the competent authority, the environmental activists, the community, academia, and others. The sample size has not been determined prior but the ESIA team endeavoured to contact a representative and balanced sample based on prevailing circumstances.

3.8.2 SAMPLING The ESIA team employed both probabilistic and non-probabilistic sampling techniques. Random sampling was used to select the specific communities to reach out to so as to avoid criticism of bias. Purposive sampling was used to identify/select some of the stakeholders especially the leaders and government institution. Convenience sampling was applied on the randomly selected communities. Word of mouth was used to mobilise selected communities for dialogue sessions with the ESIA team.

3.8.3 ETHICAL CONSIDERATION During the entire ESIA process, ethical requirements were upheld notably; informed consent, privacy and confidentiality, anonymity, and researcher’s responsibility. The ESIA team will strive to uphold all the ethical requirements during the entire process.

4.0 BASELINE CONDITIONS 4.1 PHYSICAL ENVIRONMENT 4.1.1 LOCATION The proposed project site is Kinyara Sugar Limited Nucleus Estate located in Budongo Sub- county, Masindi district. The nucleus estate covers approximately 8,500ha and is approximately 15 kilometres from Masindi town. Masindi district is in the Mid-western part of Uganda, with its headquarters 216 Kilometres away from Kampala. It borders Kiryandongo in the North, Kyakwanzi in the South- East, Hoima in the South West and Buliisa in the West. The District is at an average altitude of 1295 meters above sea level, situated between 10 22’ and 20 20’ North of the Equator, longitude 310 22’ and 320 23’ East of Greenwich.

By size, the district covers an area of 7,443.0 Square Kilometres of which 456 Square Kilometres is open water, 197.5 Square Kilometres is permanent/seasonal wetlands 6446 Square Kilometres is an area excluding open water and swamps and of which 6332 square Kilometres is arable land.

4.1.2 CLIMATE . Rainfall Masindi has a bimodal rainfall pattern of an annual long-term average rainfall of 1304mm. The highest rainfall is always received in March – May and August – November. The district has suitable agro-ecological conditions and based on the amount of rainfall received, the district can be divided into three major climatic zones.

- High rainfall zones: These areas receive more than 1000 mm of rainfall per annum. These include, Budongo, Pakanyi, Karujubu and Nyangahya sub- counties. Other areas include: Bikonzi and Kahembe Parishes in Bwijanga Sub County and Kigulya Parish in Miirya Sub County. - Medium rainfall zones: These areas receive rainfall ranging between 800 mm – 1000 mm per annum. Areas, which fall under this zone, include, Bigando and Isimba Parishes in Miirya Sub County. - Lower rainfall zones: These areas receive less than 800 mm of rainfall per annum. These include Kimengo Sub County and Ntooma parish in Bwijanga Sub County. At KSL, mean annual rainfall over a period of 5 years is 127.7 mm. The month of January and April receive the lowest and highest amount of rainfall, at 9.5 mm and 230.0 mm respectively. However, the meteorological data (from the company’s meteorological station) over the past five years shows that there was no uniform distribution of rainfall meaning severe drought and excess rainfall affecting cane growth, production and quality. . Temperature: Records from KSL meteorological station show a mean maximum temperature of 29.4oC and mean minimum temperature of 16.8oC over the past five years. The highest mean temperature is 32.3oC recorded in February and lowest at 15.7oC in January.

. Relative Humidity (RH): Five year mean RH in the morning (0900 hours) is 81.2%, 53.8% in the afternoon (1500 hours). Morning mean RH is highest at 88.8% in August and lowest in February at 69.6%. Afternoon mean RH is highest in October at 63.4% and lowest at 34.5% in February. . Wind speed: The annual mean wind speed recorded at 74 kilometres per day (km/day). The highest daily mean wind speed is 3.7 km/hr in February and lowest in 2.8 km/hr in September and July (Table 4).

KSL monthly rainfall (mm)

Yea Marc Apri Total / S/N r Jan Feb h l May June July Aug Sept Oct Nov Dec Year Average 192. 125. 100. 163. 1 2010 23.7 62.2 161.2 0 0 97.6 2 3 112.2 186.6 74.7 108.1 1406.8 117.2 172. 223. 138. 105. 259. 2 2011 10.0 3.3 111.0 7 2 3 2 1 206.8 224.6 132.2 51.5 1637.9 136.5 314. 100. 125. 126. 3 2012 1.1 14.4 76.1 2 0 4 9 91.0 163.4 162.6 115.6 178.3 1469.0 122.4 203. 197. 102. 137. 4 2013 5.0 36.3 178.5 0 8 6 90.1 1 183.1 161.5 133.9 29.6 1458.5 121.5 268. 164. 199. 131. 153. 5 2014 7.8 4.1 181.5 3 4 7 2 3 122.8 220.3 210.0 25.8 1689.2 140.8 228. 124. 6 2015 0.0 38.3 124.3 0 0 514.6 42.9 Marc Apri Jan Feb h l May June July Aug Sept Oct Nov Dec 5 yr' 230. 162. 132. 110. 160. LTM 9.5 24.1 141.7 0 1 7 7 8 157.7 191.1 133.3 78.7 1442.1 127.7 Cum . 425. 587. 720. 831. 991. 1340. LTM 29.8 53.9 195.5 6 6 4 1 8 1149.5 6 1473.9 1442.1 //////////// Source: KSL Meteorological Station

KSL monthly wind speed (km/hr)

Year Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Mean 2010 2.8 3.5 3.3 3.6 3.1 2.8 3.0 2.7 2.8 2.9 2.5 2.7 3.0 2011 2.9 3.8 3.7 3.7 3.2 3.0 2.8 3.0 3.0 3.0 2.8 2.8 3.1 2012 3.2 4.1 3.8 4.0 3.5 3.2 2.8 2.9 3.0 3.2 2.9 3.1 3.3 2013 3.0 3.8 3.8 3.7 3.5 3.1 2.8 2.9 2.9 2.7 2.8 2.9 3.1 2014 2.9 3.4 3.5 2.9 3.0 2.8 2.6 2.8 2.5 2.6 3.0 2.8 2.9 2015 3.0 3.4 3.8 3.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.3 5 years' LTM 3.0 3.7 3.6 3.6 3.3 3.0 2.8 2.9 2.8 2.9 2.8 2.9 3.1 source: KSL Meteorology Station

4.1.3 GEOMORPHOLOGY, MINERAL RESOURCES AND SOIL TYPES Masindi district is generally a plateau land with an altitude of 1295meters on average above sea level. Undulating hills with some pronounced high points are spread out in the District. To the West is an arm of the great Western Rift Valley, which descends up to Mozambique. There are also several features associated with Rift Valley formation to the West of the district. The land towards Murchison Falls slopes down suddenly and remains flat in the Murchison Falls conservation area. The status of mineral resources in the district is not well established, as there has been no full- scale geological study to determine the mineral potentials of the district. However, companies that have carried out sampling on existence of minerals in the district indicate the following minerals among many do exist. Iron ore, salt, gold, uranium and cobalt.

The nature of soil patterns in Masindi are almost the same district wide. Sandy loam soils predominate with clay loam in a few places. Soil types, determines the type of crops grown in various areas. The most prominent soil types per Sub-County are given in the table 4.1.

Table 4.1: Major Crops Grown in Different Soil Types Sub- Type of Soil Major Crops county/Divisions Budongo Sandy Loam, Clay loam Sugar cane, Finger millet, beans, Tobacco, G/nuts Karujubu Divison Sandy Loam Sugarcane, Vegetables, Fruits, Maize ,Rice Pakanyi Sandy Loam Maize, Cassava, G/nuts, Sunflower, beans Nyangahya Divison Clay Loam and Sandy G/nuts, Sunflower, Fruits, Rice, beans ,Maize Loam Central Divison Clay Loam and Sandy Vegetables, Fruits Loam Kigulya Division Sandy Loam Sunflower, Vegetables, Fruits, Maize, Bananas, Rice Kimengo Sandy Loam Cassava, Potatoes Miirya Sandy Loam Sunflower, Vegetables, Fruits, Maize, Bananas, Rice Bwijanga Sandy Loam Bananas, Coffee, Maize, Sunflower, Rice

4.2 BIOLOGICAL ENVIRONMENT 4.2.1 VEGETATION The natural vegetation of Masindi comprises of forest, dry and humid Savannah with Elephant grass prolific throughout the area. This type of vegetation provides a diverse habitat for a variety of birds and animals. The proposed site is a sugarcane estate with patches of wetlands and natural forests. There are woodlots Eucalyptus and Pine trees along some of the access road within the Nucleus Estate. The vegetation outside the NE is dominated by sugarcane owned by out growers. The other part of the land is occupied by farmers who practice subsistent agriculture, dealing in crops such as maize, cassava, matooke and fruits like mangoes. There are no plants or animals of ecological significance that will be lost due to project development.

Less productive land within the NE is planted with trees all over the estates. These forests provide sanctuary for wildlife within the estates. Wetlands and gazetted forest reserves within the catchment area at KSL are only reserved for natural conservation and cultivation is prohibited. KSL works in partnership with several local, national and international nature conservation bodies to protect and conserve wildlife and the environment in general.

Maize & Cassava garden in the vicinity of Cassava, Ground nuts, Banana garden the NE Plate 4.1: vegetative cover in the project vicinity

4.2.2 WATER RESOURCES Masindi District is endowed with several water bodies which are currently not optimally conserved, developed and tapped by the business community with support from the district authority. The water bodies are Victoria Nile in Masindi Port, Kiryandongo and Mutunda Sub Counties, Lake Maiha (small satellite) in Bwijanga sub county, Lake Kiyanja (small satellite) in Miirya Sub County and River Kafu in Kimengo and Bwijanga Sub counties and River Waki in Budongo. The Kasokwa River forms part of the larger drainage of Budongo Sub-county. It is a permanent river and is one of the most important rivers in Budongo sub-county stretching over 8km. It originates from Miria Sub-county via Masindi town and then through several villages such as Karijuba, Nyamusese, Zebra/Katuruga trading centre next to Kinyara Sugar factory, which factory pumps up some of the water from the river for their use. The river consequently flows through various villages to Kapeka 2 where it enters Budongo Forest in which it flows and meets River Sonso among other small streams that together form one big river i.e. River Sonsio, this emerges out of the forest at Busingiro flowing gradually into Lake Albert in Bulisa district which lies northeast of Masindi district. The proposed project area has several open water sources such as micro-catchments, sub- catchments, catchment areas, and forests. However, protected springs and boreholes are the main sources of water for domestic use (figures … and …. at around coordinates N01035'46.5" E031033'41.4" and N01035'00.8" E031033'21.4" respectively).

Plate 4.2: Kyabinyindo protected spring

Plate 4.3: Borehole at Kasongoire Primary school

4.2.3 WETLANDS Siba wetland system is the main wetland within the Nucleus Estate. Masindi district has several wetlands constituted by seasonal rivers and big water bodies. However, the local communities have not adequately utilised most of these wetlands to improve on their household incomes to combat poverty. Where the local community has tried to utilize the wetlands, poor methods of utilization have been employed rendering a risk of degradation and unstable biodiversity.

Plate 4.4: Siba Wetland System in the NE

4.2.4 NATURAL FOREST RESERVES A variety of trees species do exist in Budongo Forest which is situated in the district especially Mahogany which is of high value. Additionally, there are potentials of forest vegetation, such as Kisagura Forest Reserve at around coordinates N01036'50.0" E031034'28.6" in the Siba wetland system, which can be used to develop medicinal herbs to cure some diseases. Fields near such sensitive natural ecosystems ought to be avoided.

Plate 4.5: Kisagura Forest Reserve within the NE 4.3 SOCIO ECONOMICS 4.3.1 ADMINISTRATIVE UNITS Administratively, Masindi district is divided into three constituencies (Masindi Municipality, Buruli, and Bujenje), eight Sub Counties and 41 parishes. Kinyara Nucleus Estate is in Budongo Subcounty in Bujenje County which is located 1.625758°N and 31.602173°S neighboring Murchison falls national park from the North, Municipal Council from the East, Bwijanga Sub County in the south and Buliisa District on the western side.

4.3.2 ECONOMIC ACTIVITIES The area is predominantly agrarian, and it is famous for sugar production in Kinyara the second largest sugar estate in Uganda. Kinyara Sugar Limited as well employs thousands of people both directly and indirectly. This implies that without KSL, Uganda would suffer a huge sugar deficit and the level of unemployment would escalate beyond the current recorded level. Aside from sugar production, the over 90% of the populace produce large quantities of food like Maize, matooke (bananas), cassava, rice, potatoes, millet, sorghum, beans, and groundnuts. These are utilised locally, nationally, and across the East African region. The other economic activities carried out in the area are tobacco growing, pit sawing, rearing of animals (cattle, goats, pigs, and poultry). The snapshot of the area around the KSL nucleus estate shows the economic activity is basically subsistence farming and out-growers of sugar cane supplying Kinyara Sugar factory.

At least 50% of the total area in the immediate neighbourhood is under out-grower sugarcane production while less than 35% of the total area is under food crop production.

4.3.3 EDUCATION Considering Bujenje county where KSL is situated, there is a total of 38 government aided primary schools, and a few community and private primary schools. In addition, there are four secondary school of which three are government aided that is; Ikoba Girls, Kinyara and Bwijanga Secondary Schools. Budongo Secondary School is community operated and Kinyara High is a private secondary school. The main concern is the school(s) near the nucleus estate where we have; Ebenezer Christian School.

Plate 4.6: Ebenezer Christian School. One of the schools near the Nucleus Estate

4.3.4 WATER SOURCES There are at least three streams used by the neighbouring communities for watering livestock. The water sources used for household use/human consumption are protected and they are approximately fourteen (14) in number. There are three probable watering points in the area. Kihura-Zebra crossing in the North, Bulyango-Kisagura crossing in the West and Ndeke- Bujenje crossing on Masindi Road to the East. The largest open water surface body is Lake Albert which is about 100km from Kinyara.

4.3.5 HEALTH In Masindi district there is one general Hospital and one Sub-District hospital (Masindi, and Bwijanga respectively), 16 health centres of level III and 26 health centres of level II.

Bujenje County has a health sub-district with its headquarters at Bwijanga Health Center IV. The health sub district serves two Sub-Counties of Budongo and Bwijanga and serves 11parishes of which 6 are in Budongo and five in Bwijanga Sub-county. This county has 3Health Center III in Ikoba (Bwijanga Sub-County), Nyantonzi Health Center and Kinyara (a private not for profit) Center (Budongo Sub-county). There are 11 health center II’s namely Kichandi, Mihembero, Kikingura, Kyamaiso, Ntooma, Kiasslizi, and Isimba (prison) located in Bwijanga Sub-county; and Nyabyeeya, Budongo, Kasenene, and Kasongoire located in Budongo sub-county. Every parish in my constituency has at least a health center

Bwijanga Health center IV has an Out-Patient Department (OPD), a laboratory unit, maternity ward, general ward and an air-conditioned operating theatre. It doubles as a health sub-district vaccine store and has an active Anti Retro-viral Therapy clinic (ART)

5.0 REGULATORY AND INSTITUTIONAL FRAMEWORK 5.1 POLICIES 5.1.1 THE NATIONAL ENVIRONMENT MANAGEMENT POLICY The overall goal of the National Environment Management Policy is the promotion of sustainable economic and social development mindful of the needs of future generations and ESIA is one of the vital tools it considers necessary to ensure environmental quality and resource productivity on long-term basis. The policy calls for integration of environmental concerns into development policies, plans and projects at national, district and local levels.

Relevance to the Project The ESIA seeks to investigate how the proposed project affects environment and social dimensions in its areas of implementation.

5.2 LAWS AND REGULATIONS A review of the relevant laws and regulation has been conducted and below are the key legislation and framework.

Key legislations governing the conduct of ESIA in Uganda are the National Environment Act (Cap. 153) and the Environmental Impact Assessment Regulations of 1998. The National Environmental Act provided for the establishment of the National Environment Management Authority (NEMA) as the overall Authority responsible for supervision, coordination and monitoring of environmental matters in Uganda. Other existing laws and regulations applicable to environmental and social management include:

5.2.1 THE CONSTITUTION OF THE REPUBLIC OF UGANDA, 1995 Section XXVII, of the objectives of this Constitution states that: i. The State shall promote sustainable development and public awareness of the need to manage land, air and water resources in a balanced and sustainable manner for the present and future generations. ii. The utilisation of the natural resources of Uganda shall be managed in such a way as to meet the development and environmental needs of present and future generations of Ugandans; and the State shall take all possible measures to prevent or minimise damage and destruction to land, air and water resources resulting from pollution or other causes.

Chapter 15 section 245 seeks to protect and preserve the environment. It states that parliament shall, by law, provide for measures intended a. To protect and preserve the environment from abuse, pollution and degradation; b. To manage the environment for sustainable development; and c. To promote environmental awareness.

Relevance to the project There are several natural resources including forests and wetlands in the proposed project site. The constitution requires sustainable use of natural resources and to keep those natural resources free from pollution.

5.2.2 THE OCCUPATIONAL SAFETY AND HEALTH ACT, 2005 The Act, it explains health and safety responsibilities for both employer and employees. Part III of the Act requires that the employer to: -protect workers, -monitor and control the release of dangerous substances into the environment, -provide protective gears. Section VIII requires the employer to ensure health and welfare for conducive work place environment such as provision of healthy and safe working environment, suitable lighting, first aid, etc.

Relevance to the Project The developer is compelled to provide adequate PPE, put in place procedures and guidance to ensure health and safety for employers and visitors is upheld.

5.2.3 THE PUBLIC HEALTH ACT, CAP 281 Section 54 of this act requires that “No person shall cause a nuisance or shall suffer to exist on any land or premises owned or occupied by him or her or of which he or she is in charge, any nuisance or other condition liable to be injurious or dangerous to health”.

Section 57 further lists nuisance constitutes, some of which are;  Any vehicle in such a state or condition as to be injurious or dangerous to health;  Any dwelling or premises or part of the dwelling or premises which is or are of such construction or in such a state or so situated or so dirty or so verminous or so damp as to be likely to be injurious or dangerous to health.  Any accumulation or deposit of sewage refuse, offal, manure or other matter which is offensive, or which is injurious or dangerous to health;  Any dwelling or premises which are so overcrowded as to be injurious or dangerous to the health of the inmates.  Any factory or trade premises not kept in a clean state and free from offensive smell arising from any drain, privy, water closet, earth closet or urinal, or not ventilated to destroy or render harmless and inoffensive as far as practicable any gases, vapours, dust.  Any dwelling, public building, trade premises, workshop or factory not provided with sufficient and sanitary latrines.

Relevance to the Project The chemical mixing area has to be kept tidy and a mobile toilet facility will be provided for the personnel involved in the exercise. The project equipment such as vehicles will be kept in a good condition and maintained to protect the health of the employee.

5.2.4 THE WORKERS’ COMPENSATION ACT, 2000 The law requires that compensation be paid to a worker who has been injured or acquired an occupational disease or harmed in any way during their work. Section 6 and 7 provide for the compensation for fatal injury as 46 months of earning. For permanent incapacity compensation is 60 and 72 months earning respectively. Section 15 puts medical examination for an injury to be the Employer’s responsibility and prescribes a form of notification of injury to the Commissioner for Labor. The injured worker and employer may agree on the compensation or

29 it can be determined by a court of law when there is disagreement between the parties, and appeals can be made to the High Court for settlement.

Relevance to the project The Act safeguards the workers in the project in terms of ensuring they receive compensation in case of injury during project execution.

5.2.5 THE LAND ACT, CAP 227 Part II section 2 of the Act, talks about Land ownership that, “Subject to article 237 of the Constitution, all land in Uganda shall vest in the citizens of Uganda and shall be owned in accordance with the following land tenure systems;  Customary;  Freehold;  Mailo; and  Leasehold Moreover, part IV section 43 of the Act requires that “A person who owns or occupies land shall manage and utilize the land in accordance with the Forests Act, the Mining Act, the National Environment Act, the Water Act, the Uganda Wildlife Act and any other law. Section 70 of this act discuss about Water rights. Subsections (i) and (ii) states that; (1) Subject to section 44, all rights in the water of any natural spring, river, stream, watercourse, pond, or lake on or under land, whether alienated or un-alienated, shall be reserved to the Government; and no such water shall be obstructed, dammed, diverted, polluted or otherwise interfered with, directly or indirectly, except in pursuance of permission in writing granted by the Minister responsible for water or natural resources in accordance with the Water Act (2) Nothing in this section shall prevent the reasonable use by an occupier of land of any waters referred to in subsection (1) for domestic, small-scale agricultural, or pastoral purposes

Relevance to the Project It has been told that KSL owns the land under Leasehold tenure system.

5.2.6 THE WATER ACT, CAP 152 The objective of the Act is to enable equitable and sustainable management, use, and protection of water resources of Uganda through supervision and coordination of public and private activities that may impact water quantity and quality.

Relevance to the Project Sustainability is safeguarded amongst others by undertaking ESIA to identify potential issues that would otherwise compromise the project.

5.3 REGULATIONS 5.3.1 THE NATIONAL ENVIRONMENT (WASTE MANAGEMENT) REGULATIONS, 1999 Section 5 Subsection 1 requires that "a person who owns or controls a facility or premises which generate waste shall minimise the waste generated by adopting the following cleaner production methods; (a) Improvement of production processes through; (i) conserving raw materials and energy; (ii) eliminating the use of toxic raw materials; (iii) reducing toxic emissions and wastes; (b) monitoring the product cycle from beginning to end by - (i) identifying and eliminating potential negative impacts of the product; (ii) enabling the recovery and reuse of the product where possible; (iii) reclamation and recycling; (c) Incorporating environmental concerns in the design and disposal of a product."

Relevance to the Project KSL will endeavour to manage project wastes responsibly. Chemical wastes for example used chemical bottles will be collected and handed back to the supplier

5.3.2 THE EIA REGULATIONS, 1998 Section 3 (1) (a) of this Act requires that an EIA be done, prior implementation, for all projects in first schedule of the Act. In the first schedule the Act mentions the list of projects that EIA must be done, and this type of project falls under that category.

Relevance to the Project The First schedule, sub-section 4 seek to protect the current land uses and land use potentials in the project area and its neighbourhood

5.3.3 THE NATIONAL ENVIRONMENT (STANDARDS FOR DISCHARGE OF EFFLUENT INTO WATER OR ON LAND) Section 26 and 107 of the Act provides for Standards for effluents (Section 3) or waste water before it is discharged into water or on land; General obligations to mitigate pollution (Section 4) among others. A schedule has been provided with standards for discharge of effluent or waste water with parameters and maximum permissible limits.

Relevance in the Project Aerial spraying Project will comply with the relevant Standards of Effluents when discharging waste from the project activities.

5.3.4 THE NATIONAL ENVIRONMENT (NOISE STANDARDS AND CONTROL) REGULATIONS These Regulations are to prescribe the maximum permissible noise levels from a facility or activity to which a person may be exposed; provides for the control of noise and for mitigating measures for the reduction of noise; and to give effect to the provisions of section 28 of the Act.

Part II of this regulations provide the permissible noise levels among others, while Part III of the First Schedule of the regulations provide for maximum noise levels from impact or impulsive noise.

Relevance in the Project The exercise will be temporary, lasting only two (2) days, and will not have significant impacts due to noise. However, Noise standards will be observed while work is on-going. Attention will be paid to minimize noise during the operation of equipment

5.3.5 THE NATIONAL ENVIRONMENT (NOISE STANDARDS AND CONTROL) REGULATIONS S.I.NO.30/2003. Part III, section 8 (1) of the Act gives " the duty of the owner of machinery or the owner or occupier of a facility or premises, to use the best practicable means to ensure that the emission of noise from that machinery, facility or premises does not exceed the permissible noise levels"

Relevance to the Project The company is committed in avoiding noise pollution and where avoidance will not be possible, protective gears for workers and visitors (e.g ear muffs) will be used.

5.4 INSTITUTIONAL FRAMEWORK The project will be undertaken in the following institutional frameworks which include:

5.4.1 CIVIL AVIATION AUTHORITY The Civil Aviation Authority was established by an Act of Parliament, CAP 354, with the principle objective of promoting the safe, regular, secure and efficient use and development of civil aviation inside and outside Uganda. Civil Aviation Authority (CAA) is a corporate body responsible for regulation of civil aviation in Uganda. It manages Entebbe International Airport and thirteen (13) other upcountry aerodromes. CAA also carries out its work in conformity with the International Civil Aviation Organisation (ICAO) Standards and Recommended Practices (SARPs).

Relevance in the Project The developer will do aerial spray of agricultural chemicals using an agricultural aircraft operated by certified and reputable service provider. The Civil Aviation Authority (CAA) will give clearance to the developer once MAAIF, NEMA, Ministry of defence are satisfied with the preparations and readiness of KSL to execute the project within the confines of the established laws and regulations.

5.4.2 MINISTRY OF AGRICULTURE, ANIMAL INDUSTRY AND FISHERIES The Ministry is mandated “To promote and support sustainable and market oriented agricultural production, food security and household incomes”. This mandate is derived from the national objectives of the 1995 Constitution of the Republic of Uganda XI (ii), which provides that the state shall “stimulate agricultural, industrial, technological and scientific development by adopting appropriate policies and enactment of enabling legislation” and Objective XXII (a) which provides that the state shall “take appropriate steps to

32 encourage people to grow and store adequate food.” The Constitution therefore bestows responsibility for management of the agriculture sector with MAAIF.

It is strongly believed, the Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) has no objection on the importation of the adequate volumes of Fusilade Forte for use on the 5000 ha of sugarcane at Kinyara for ripening of sugarcane (based on a chat with ministry officer in-charge of importation of agro-chemicals). Conversely, the fertilizers that the developer is intent to use are permissible.

6.0 STAKEHOLDER CONSULTATIONS 6.1 OBJECTIVES Stakeholder consultation was undertaken with the aim of:

 provide stakeholders with an overview of the proposed operations and activities, as well as an understanding of the ESIA process;  Identify and document the views, concerns and expectations of affected communities, political and cultural leaders, non-governmental organizations, and government agencies relating to the proposed operations.  Understand local expectations of the project;  Characterize potential environmental, socio-economic impacts;  Developing effective mitigation recommendations.

6.2 STAKEHOLDER ISSUES During this ESIA study process, consultations were conducted with relevant stakeholders, including KSL staff, local authorities, Masindi district officials, project affected persons (local communities neighbouring the NE), and Lead Agencies (figures 20 to 25). The consultations focused on the project impacts on the bio-physical and socio-economic environment. During the consultations, the ESIA team was interested in gathering views and perceptions of the community and concerns about the proposed aerial spraying of chemical rippener and fertilisers (see table 6). Specific objectives were: . To inform the relevant stakeholders about the proposed project; . To capture views and concerns of the relevant stakeholders . To enhance ownership of the project by the relevant stakeholders and the host community . To provide a basis for stakeholder participation in impact identification and mitigation

Consultations were carried out the following groups of stakeholders: Kinyara Sugar Limited officials, NEMA, MAAIF, Masindi District local government officials and the communities adjacent the Nucleus Estate.

Table 6.1: Key issues raised by stakeholders Stakeholder Designation Issues raised Mr. Nsimiire District  The developer should obtain all the required William Environment approval documents (permits) from the relevant Officer, Masindi authorities such MAAIF, CAA  Provide the right PPE to the workers involved in the spraying activity  Fully sensitize the neighbouring communities about the activity  Provide First Aid facilities during the spraying period  Avoid spraying ecologically sensitive areas like wetlands, forest reserves and water sources

Stakeholder Designation Issues raised  Use the recommended chemical mixing ratios to avoid detrimental impacts. Mr. District  The developer should employ the services of Byaruhanga Agricultural specialized personnel in chemical mixing and Job Officer, Masindi spraying to avoid unnecessary accidents and injuries  The developer should get authorization from MAAIF regarding importation and use of a chemical in Uganda  They should avoid spraying in windy conditions to avoid incidents of chemical drifts into neighbouring community farms and homesteads. Community  The District Community Development Officer Development urged the Developer to always engage his office and Officer, Masindi the district administration in general, to allow for District smooth operation of development activities  He also suggested a need to establish a clear channel of communication between the local communities neighbouring the proposed project site, the local administration and the developer. Dr. Ramesh Estate Approval of activity by relevant authorities Bollampalli Agronomist,  The agricultural chemicals (chemical ripener and Kinyara sugar fertilisers) to be used have been approved by MAAIF  KSL will outsource a reputable aviation company from Kenya to carryout aerial spraying  All required documentation for aerial spraying from relevant authorities will be obtained Negative impacts of Chemicals  Drift sprays will be controlled by only spraying during still conditions  The developer will compensate for any negative impact to the crops of neighbouring communities, accruing from the proposed exercise  The ripener will be sprayed in very dilute form i.e. in a ratio of 1:20 of chemical to water to be sprayed on 40ha, and will therefore not have impacts on either surface or ground water  All personnel involved in the spraying activities are provided with the right PPE. PPE use will be enforced Disposal of empty chemical empty containers  The empty chemical bottles will be collected and handed back to the supplier for proper disposal

Stakeholder Designation Issues raised Mr. Gerenge Asst. Manager Community sensitization Samuel Agronomy  The community will be well informed through local FM radio announcements prior to aerial spraying  Communication letters are also sent to the relevant local leaders to inform their subjects about the activity Negative impacts  Health and safety concerns will be addressed through training personnel who will handle the spraying activities, so no serious negative impacts are expected  No significant negative impacts are expected since the activity will only concentrate on the Company Nucleus Estate Mr. D/Headteacher  They disclosed that past aerial spraying exercises Kasangaki and staff of did not affect the school routine. However, the sound Geoffrey & Kasongoire P/S of the aircraft would excite pupils and they lose Staff of concentration in class the whole day Kasongoire  The school administration recommended that if Primary possible, KSL conducts the exercise over the School weekend or during holidays when school is not in session. Ms. Akello Head teacher,  The head teacher noted that the aircraft brings Dorcus Ebenezer P/S, excitement to the pupils and they lose concentration Kabango in class.  If possible, Kinyara can spray during the weekend to avoid disruption of school activities  No injuries or causality has ever occurred to the pupils during past spraying period.

7.0 IMPACT ANALYSIS AND MITIGATIONS Issues that could not be resolved during the scoping phase and that required further investigations were taken forward into the impact assessment (the final phase of the ESIA process). Specialist input was required mainly during this phase to assess the nature, extent, duration, intensity or magnitude, probability and significance of the potential impacts; define the level of confidence in the assessment; and propose mitigation actions and monitoring requirements. Specialist studies/reports formed the basis of this Environmental Impact Assessment Report.

7.1 IMPACT ANALYSIS 7.1.1 IMPACT DESCRIPTION Impact description helps in the formulation of additional, project-specific mitigation measures to reduce them to acceptable levels, or to compensate for them where this is not possible. Describing a potential impact involves an appraisal of its characteristics, together with the attributes of the receiving environment. Relevant impact characteristics may include whether the impact is:

 Adverse or beneficial;  Direct or indirect  Short, medium, or long-term in duration; and permanent or temporary;  Affecting a local, regional or global scale; including trans-boundary; and  Cumulative: A cumulative impact is “the impact on the environment which results from the incremental impact of the action when added to other past, present and reasonably foreseeable future actions”.

Consideration of the above gives a sense of the relative magnitude of the impact. The sensitivity of the receiving environment is determined by specialists based on the baseline data collected during the ESIA.

7.1.2 IMPACTS EVALUATION The purpose of impact evaluation is to assign relative significance to the predicted impacts associated with the project, and thus determines the order in which impacts are to be avoided, mitigated or compensated. By considering the combination of the magnitude of impact and the sensitivity of the receiving environment, the significance of the potential impact is derived. The determination of significance of an impact is largely subjective and primarily based on professional judgment. Key elements for assessing impact significance are:

 Level of public concern (particularly over health and safety)  Scientific and professional judgment  Disturbance/disruption of valued ecological systems  Degree of negative impact on social values and quality of life  Public perception versus the scientific/professional opinion of the risks/benefits involved To provide a relative significance of different impacts, it is useful to assign numerical descriptors to the impact magnitude and receptor sensitivity for each potential impact. Each impact is assigned a numerical descriptor of 1, 2, 3, or 4, equivalent to very low, low, medium

37 or high. The significance of impact is then indicated by the product of the two numerical descriptors, with significance being described as negligible, minor, moderate or major. This is a qualitative method designed to provide a broad ranking of the different impacts of a project. Table 7.1: Determination of Impact Significance Sensitivity Significance Very low Low Medium High 1 2 3 4 1 2 3 4 Very low 1 Negligible Minor Minor Minor 2 4 6 8 Low 2 Minor Minor Moderate Moderate

3 6 9 12 Medium 3 Minor Moderate Moderate Major 4 8 12 16 High 4 Minor Moderate Major Major

Magnitude

Impact Significance Criteria Nature of the impact – The project can have either a positive or negative effect on the affected environment, or vice versa. This description includes who or what will be affected, and how.

Extent - the impact could:  be site – specific;  be limited to the site and its immediate surroundings;  have an impact on the region (e.g. if communities rely on biodiversity);  have an impact on a national scale (e.g. national biodiversity conservation targets);  have an impact across international borders (e.g. where catchments cross international border, international conventions are concerned or migratory species).

Duration – It is important to indicate whether or not the lifetime of the impact will be:  short term (e.g. during the construction phase);  medium term (e.g. during part or all of the operational phase);  long term (e.g. beyond the operational phase, but not permanently);  Permanent (where the impact is for all intents and purposes irreversible. An irreversible negative impact may also result in irreplaceable loss of natural capital or biodiversity, if it were to result in extinction or loss of a species or ecosystem); or  Discontinuous or intermittent (where the impact may only occur during specific climatic conditions or during a particular season of the year)

Intensity or magnitude – The size of the impact (if positive) or its severity (if negative):  Low, where biodiversity is negligibly affected or where the impact is so low that remedial action is not required;  Medium, where biodiversity pattern, process and/or ecosystem services are altered, but not severely affected, and the impact can be remedied successfully; and

 High, where pattern, process and/or ecosystem services would be substantially (i.e. to a very large degree) affected. If a negative impact, could lead to irreplaceable loss of biodiversity and/or unacceptable consequences for human wellbeing.

Probability – Described the likelihood of the impact actually occurring indicated as: Improbable, where the possibility of the impact is very low either because of design or historic experience;  Probable, where there is a distinct possibility that the impact will occur;  Highly probable, where it is most likely that the impact will occur; or  Definite, where the impact will occur regardless of any prevention measures.

7.1.3 RESIDUAL IMPACT ASSESSMENT Following description of the potential impacts and assessment of their significance, mitigation measures designed to reduce the impact significance are outlined. The significance is re- assessed, assuming application of the mitigation measures, to derive the ‘residual’ impact significance; i.e. an appraisal of the impact that is predicted to result even after mitigation has been applied.

7.2 POTENTIAL POSITIVE IMPACTS 7.2.1 INCREASED SUGAR PRODUCTION AND REVENUES The project will lead to increased sugar supply within the region and the country in general as the ripening at the required time will lead to juice with high sugar content. The ripeners should increase recoverable sugar per ton of cane, while minimizing decreases in tons of cane per acre. Increased sugar production will directly translate into increased revenues to the Company. Consequently, increased sugar production due to the project will lead to increased revenue generated to Masindi District and the country in general in the form Value Added Tax (VAT) on sugar, license fees, and royalties among others.

7.2.3 REDUCED COST OF SUGAR PRODUCTION The cost of sugar production will be highly reduced because of high quality of cane harvested from the NE. It is cheaper to extract sugar from quality cane that will have high concentration of sucrose, and low concentration of non-sucrose components such as other sugars.

7.2.4 JOB CREATION The project is anticipated to create short-term employment opportunities for both skilled and unskilled labor during the exercise; and long-term employment opportunities at the factory. Skilled personnel that will be employed such as pilot, HSE specialists, spray mixers, supervisors, and in other technical positions whereas unskilled laborers will be required as support staff to perform non-technical tasks such as security.

7.3 PROPERTIES OF FUSILDE FORTE 7.3.1 HARZADOUS COMPONENTS FUSILADE FORTE has UN number: UN 3082 and below are some of the key hazardous ingredients: Table 7.1: Key hazardous ingredients in Fusilade Forte Chemical Name Concentration Fluazifop-P-butyl 15.8 % W/W Alcohols, C16-18 and C18-unsaturated., ethoxylated 20 - 30 % W/W Octan-1-ol 1 - 5 % W/W Calcium dodecyl benzene sulphonate 1 - 5 % W/W

7.3.2 PROPERTIES AND HEALTH AND SAFETY PRECAUTIONS Below is a summary of the toxicological information: Acute oral toxicity: Median lethal dose male and female rat, > 2,000 mg/kg Acute dermal toxicity: Median lethal dose male and female rat, > 2,000 mg/kg Skin corrosion/irritation: rabbit: Moderately irritating Serious eye damage/eye irritation: rabbit: Slightly irritating Respiratory or skin sensitization: guinea pig: A mild skin sensitizer in animal tests.

The ecological properties are summarized below: Toxicity to fish: LC50 Oncorhynchus mykiss (rainbow trout), 20 mg/l, 96 h Based on test results obtained with similar product. Toxicity to aquatic invertebrates: EC50 Daphnia magna (Water flea), 20 mg/l, 48 h Based on test results obtained with similar product. Toxicity to aquatic plants: EbC50 Pseudokirchneriella subcapitata (green algae), 0.23 mg/l, 72 h : ErC50 Pseudokirchneriella subcapitata (green algae), 0.84 mg/l, 72 h Based on test results obtained with similar product.

Persistence and degradability Stability in water Fluazifop-P-butyl: Degradation half-life: 1.5 - 1.7 h Not persistent in water Stability in soil Fluazifop-P-butyl: Degradation half-life: < 2 d Not persistent in soil. Bio-accumulative potential Fluazifop-P-butyl: Does not bioaccumulate. Mobility in soil Fluazifop-P-butyl: Fluazifop-p-butyl is immobile in soil. Contra-indications/Precautions:  Store away from food and feed  Flammable - keep away from open flames  Keep out of reach of children, uninformed persons and animals  In case of poisoning call a doctor and make this label available to him  Re-entry: Do not enter treated area within 1 day after application unless wearing protective clothing  Aerial application: Notify all inhabitants in the immediate vicinity of the area to be sprayed and issue the necessary warnings. Do not spray over or allow drift to contaminate adjacent areas or water.

7.3.3 PROPERTIES OF PROPOSED FERTILIZERS Below are the key characteristics: Fertilizer Key Properties

Diammonium Chemical formula: (NH4)2HPO4 phosphate (DAP) Composition: 18% N 46% P2O5 (20% P) Water solubility (20 ºC): 588 g/L Solution pH: 7.5 to 8 Hazards and safety: Relatively safe.

Triple Chemical formula: Ca(H2PO4)2•H2O superphosphate Fertilizer analysis: 45% P2O5 (0-45-0) 15% Ca (TSP) Water-soluble P: Generally, >90% Solution pH: 1 to 3

TSP is used mainly in blends with DAP and MOP. TSP has excellent physical qualities. It stores, handles and flows through all types of equipment extremely well. Does not take up moisture in storage or in the field. Spreads very evenly.

Restrictions: Do not mix with urea as the fertilisers will react together and become wet. Please check with your local depot on suitability for blending. Do not store in silos.

Urea 46% With more than 46% nitrogen, it has the highest nutrient concentration among the commercially available solid nitrogen fertilizers.

Chemical Name: Carbamide – commonly referred to as Urea Chemical Family: Amides CAS Number: 57-13-6 Molecular formula : CH4N2O

Stability: The product is stable under normal conditions of storage, handling and use.

Materials to avoid: Strong oxidizers, acids, alkalies, nitrates, sodium or calcium hypochlorite.

Hazardous reactions/decomposition products: Urea reacts with sodium or calcium hypochlorite to form explosive nitrogen trichloride.

Transport Information: Urea is not classified, i.e. considered nonhazardous material according to UN Orange Book and International transport codes e.g. RID (rail), ADR (road) and IMDG (sea).

Muriate of Muriate of potash (MOP) is most commonly called potash or potassium Potash (MOP) chloride (KCL). Nutrient composition is approximately: Potassium: 50% Chloride: 46%

Stable under normal conditions of storage and handling. Material is hygroscopic (May absorb moisture from air when relative humidity > 72%).

LD50 (rat, oral) = 2.6 g/kg LD50 (mouse, oral) = 1.5 g/kg LC50: no information available Eye (rabbit): 500 mg/24 H, mild irritant Inadequate carcinogenicity, mutagenicity, or developmental toxicity data located for potassium chloride. No target organ data located for potassium chloride

Dissolution of large quantities of potassium chloride and sodium chloride in water may create an elevated level of salinity that may be

harmful to fresh water aquatic species and to plants that are not salt- tolerant.

7.4 POTENTIAL NEGATIVE IMPACTS 7.4.1 DRIFT SPRAY Spray drift involves the movement of chemicals outside the intended target area, most commonly through small driftable droplets (less than 150μm) being blown off-target through the effects of wind and air movement (known as droplet drift). Spray drift (droplet drift) generally occurs because of crop protection products being applied using inappropriate or poorly set-up spray equipment or under unsuitable application conditions. Drifts can cause serious damage when drifted onto non-target sites such as newly planted cane, other crops or residential landscapes. Spray drifts are usually accidental because of operator's error or unfavourable weather conditions.

Given the risk factors contributing to spray drift are relatively well understood, there are a range of simple steps that applicators can take when planning and implementing a spray program to both optimise product performance and minimise the risk of spray drift.

Mitigations: Drift-control agents may be added to reduce drifting potential. However, ripener should only be applied when wind speeds are between 3 and 10mph and should not be applied when there is a surface temperature inversion. A surface inversion occurs when temperature at the surface is cooler than air above the surface; usually in the evening or early morning. Surface inversions restrict vertical air mixing and cause spray droplets to remain suspended where they can move laterally reducing effectiveness of application and potentially causing damage to non-target sites. The exercise will be carried out only during the sunny hours of the day, to avoid cases of surface inversions. Also, wind direction should be considered when applying to avoid drifting onto sensitive non-target sites. Qualifying fields that are close to each other will be selected and clustered for spraying. Inhabitants of the immediate vicinity of the area to be sprayed will be will notified and necessary warnings will be given.

7.4.2 HEALTH AND SAFETY Fluazifop-P-butyl, the active ingredient (the a.i.), in FUSILADE FORTE is rapidly converted to fluazifop-P, the acid equivalent (a.e.) which is a weak acid (USDA, 2014). Because the a.e. is much more persistent than the a.i., the exposure assessments given in the current risk assessment are based on the a.e. For the human health risk assessment, the toxicity values are the acute RfD of 0.43 mg a.e/kg bw/day, a surrogate intermediate RfD of 0.017 mg a.e/kg bw/day for workers, and a chronic RfD of 0.0063 mg a.e/kg bw/day for longer-term exposures. These toxicity values are taken from the most recent EPA human health risk assessment (U.S. EPA/OPP/HED 2011a) but are adjusted from units of a.i (fluazifop-P-butyl) to units of a.e (fluazifop-P acid) (USDA, 2014). Based on the toxicity values and the central estimates of exposure, workers involved in ground broadcast spray and aerial applications of fluazifop-P-butyl do not appear to be at risk. This conclusion is consistent with the risk characterization for these worker groups expressed in

U.S. EPA/OPP/HED (2011a). The central estimate of the HQ for backpack workers (HQ=2), however, modestly exceeds the level of concern. U.S. EPA/OPP/HED (2011a) does not assess backpack workers. Based on upper bound estimates of exposures, most of the HQs exceed the level of concern by factors of up to 43. These estimates indicate that measures to limit or otherwise mitigate worker exposures are warranted (USDA, 2014). The workers may be exposed during the application process that will include; storage, transportation, mixing, spraying the chemical and cleaning of the equipment after application. Mitigation Adequate training and sanitation of the personnel involved with the chemicals is the best safeguard against injuries and accidents. The developer will:

 Offer health and safety training to all workers involved in the exercise  Provide adequate PPE and enforce its use  Enclose the chemical mixing site and the airstrip to keep off the onlookers  Ensure that there is a standby firefighting equipment to control the potential fires due to aviation fuel.

Urea 46% - Precautions: Harmful if swallowed, inhaled or absorbed through skin. Causes moderate eye irritation. Avoid contact with skin, eyes or clothing. Avoid breathing spray mist. Wash thoroughly with soap and water after handling and before eating, drinking or using tobacco. Remove contaminated clothing and wash before reuse. Keep children or pets away from treated area until dry.

MOP - Health Hazards: Contact may cause mild eye irritation including stinging, watering and redness. Skin contact may cause mild irritation including redness and a burning sensation. No information available on skin absorption. Avoid contact with eyes, skin and clothing. Wash thoroughly after handling. Potassium chloride is generally recognized as safe (GRAS) when used in accordance with good manufacturing practice. Protection for fertilizer application: For open systems where contact is likely, wear safety glasses with side shields, long sleeves and chemical resistant gloves. Where over-exposure by inhalation may occur, and engineering, work practice or other means of exposure reduction are not adequate, approved respirators may be necessary. Wear suitable gloves when handling the product over long periods. Use suitable dust respirator if dust concentration is high.

Specifically, for MOP, the use of cloth or leather work gloves is advised to prevent skin contact, possible irritation and absorption. A source of clean water should be available in the work area for flushing eyes and skin. Air purifying respirator also required.

7.4.3 HAZARDOUS CHEMICAL WASTE Wastes will include the empty chemical bottles, unutilised mixed chemicals and fertilizers in case they are not applied. In addition, there could be spills of oils and fuels at the site. In addition, there will be domestic waste generated within the two days of operation. Urea 46% - Sweep up spilled material and place in suitable containers for recycle or disposal. If spilled urea enters a water way, then the appropriate water authority and local authorities should be informed. Any spillage of fertilizer should be cleaned up promptly, swept up and placed in a clean, labelled, open container for safe disposal. Depending on the degree and nature

44 of contamination, dispose of by use as a fertilizer on farm by spreading thinly on open ground or to an authorised waste facility.

Mitigation The developer will ensure that:

 Used chemical bottles should be collected and taken back to the supplier for proper management;  The workers at the site vigilant to control spillage of chemicals and fuels;  No chemicals will be disposed of at site;  Well maintained cars should be used;  Mobile toilet to accommodate the personnel at conducting the aerial spraying exercise.

7.4.4 NOISE POLLUTION The effect of noise pollution from the especially the agricultural plane is negligible since it will be last only two days. However, noise from the plane will cause excitement among the neighbouring communities especially schools such as Kasongoire Primary School and Ebenezer Christian school and might disrupt class sessions.

Mitigation The impact of noise pollution from the project is minimal to both project personnel and the neighbouring community. However, the following steps will be taken to further reduce the effect.

 The developer shall ensure that adequate PPE is provided and their use is enforced at all times.  The aerial spraying exercise will be conducted in such a way not to disrupt school classes, for example over the weekends, and holidays.

7.4.5 CONTAMINATION OF OPEN WATER SOURCES Urea is highly soluble in water. Therefore, it is rapidly diluted in water courses and leached from soils. When dissolved, urea will act as a plant nutrient. It has low intrinsic aquatic toxicity but will exert a substantial oxygen demand when significant quantities as in a spillage reach a watercourse and may cause damage to aquatic life. However, Urea is not classified as a hazardous product. All phosphate fertilizers (MOP, TSP and DAP) should be managed to avoid losses in surface water runoff from fields. Phosphorus loss from agricultural land to adjacent surface water can contribute to undesired stimulation of algae growth. Appropriate nutrient management practices can minimize this risk. Contamination of open water sources may come as a result of the chemical being washed into the open water sources. In general, aerial application of fertilizer, properly done, does not have any adverse impact. Continuous monitoring of surface water and groundwater has shown that nutrient losses are small (Satyoso et al., 1997; Liwang et al., 2000) partly because a smaller amount of nutrient is applied per square meter, and thus nutrient losses due to leaching and surface run-off are reduced (Ochs, 1965).

Mitigation  The spray mixture will be sprayed in very dilute amounts of 1:20 litres per 2 hectares;  Open water sources will be avoided and only target areas will be marked with flag poles;  Monthly water quality tests will be done to ensure that the water in the protected springs is fit for human consumption.

Plate 7.1: One of the protected springs in the Nucleus Estate

7.5 MANUFACTURER’S RECOMMENDATIONS 7.5.1 APPLICATION OF FUSILADE FORTE Based on the MSDS by Syngenta, the manufacturer, FUSILADE FORTE is a selective systemic post-emergence emulsifiable concentrate herbicide for the control of annual and perennial grasses in crops and for the chemical ripening and eradication of sugarcane as well as the suppression of grass growth and seeding on verges. FUSILADE FORTE can be applied by ground rig, aircraft or knapsack sprayer (spot treatment). Recommended dosage for aerial spraying for sugar ripening is 225 - 275 ml/ha. Aerial application of this product may only be done by a registered aerial application operator using a correctly calibrated, registered aircraft according to the instructions of SANS 10118 (Aerial Application of Agricultural Remedies). It is important to ensure that the spray mixture is distributed evenly over the target area and that the loss of spray material during application is restricted to a minimum. Timing when using FUSILADE FORTE as a ripener:  Apply 4 - 10 weeks before harvest. Do not apply during months of June to September.

 When crop growth is rapid, the time between spraying and harvesting will be shorter than when conditions are cooler and growth is slower. (Refer to SASRI Information sheet 12.3)  Crops must be growing actively when sprayed, i.e. not suffering from nutrient, moisture or any other stress factor. 7.5.2 THE APPLICATION OF UREA 46% The following criteria are based upon scientific evidence and agronomic experience of urea fertilizer use. These measures contribute to ensuring efficient use of nitrogen in urea whilst minimising ammonia emissions:  Urea should be incorporated into the soil during a tillage operation, if possible.  On bare, light (sandy) soils, urea should only be used for the first nitrogen application, and only on condition that it is incorporated as soon as possible.  On medium and heavy soils, urea can be used for both the first nitrogen application to the soil and for top dressing.  Urea is well suited for top dressing of winter cereals during early springtime on all soils.  Urea should preferably be spread when rain is forecast, or should be washed into the soil by irrigation.  Urea use on grassland is appropriate during the early growing season, during periods of rainfall or if there is irrigation after application.  On alkaline soils (pH > 7.5), urea should be incorporated into the soil immediately after spreading.  At high temperatures and when the soil is dry, urea should only be applied if it can be incorporated without delay. It should not be applied during the hottest part of the day.  Do not use urea soon after liming.  Do not spread urea on top of slurry, manure toppings, crop residues or anything that will impede the quick absorption of ammonium ions by the soil.  Urea can be applied to both dry land and irrigated land as a top dressing and as a base dressing. Depending on the local conditions, rates of 250 kg/ha urea or more should be spread in two applications.

8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN Environmental and Social Management Plan (ESMP) is important in ensuring that all identified potential impacts are maintained within the acceptable levels. In addition, it helps to ensure that negative impacts are mitigated at an early stage, and the expected project benefits are realized.

8.1 SCOPE The ESMP encapsulates actions to avoid, stop, diminish, mitigate, remedy or compensate any adversative impacts on the environment and social fabric in relation to the operation of the project. The ESMP reflects the exact project activities and both their ecological and social impacts, the proposed mitigation measures, the impacts of the proposed mitigation measures, the institutional arrangements required for effective implementation of the proposed mitigation measures, as well as for effective monitoring of the implementation of the mitigation measures, including time horizons and cost estimates for these activities. It shall also include recommendations pertaining to the strengthening of the institutions responsible for the implementation of the ESMP.

8.2 RESPONSIBILITIES The following setup is proposed: An aerial fertilizer coordinator, responsible for all operational logistics, the work program and coordination with Estate Manager, the control of fertilizer preparation and application, the control of operational security, as well as progress reporting to estate and agronomy department; one senior engineer for aircraft maintenance and spare part inventory management; one experienced pilot per aircraft; loader and driver teams (one per aircraft). Environmental issues will be managed and monitored daily by KSL Environmental Officer. The Health and Safety Manager will continuously assess risks of the aerial spraying exercise including those not covered by this ESIA and will work closely with the Agronomist and Estate Manager to ensure that all workers handling chemicals have adequate protection. Contractors for waste management, public liaison etc. will be outsourced or individual from existing staff will be selected by KSL management.

8.3 SUMMARY OF ESMP

Table 8.1: Environmental Management Plan ACTIVITY ENVIRONME IMPACT MITIGATION RESPONSIBILI IMPLEMENTATIO NTAL TY N SCHEDULE IMPACT Transportation of the Traffic increase  Equipment should be transported during non-busy Agricultural During site chemicals, water and hours of the day Engineer preparation all needed materials  Proper signage’s located on strategic area and safety shall be provided to protect those around Mixing of chemicals Health and Application of safety measures and warning devices. Agronomy Team Operation safety to Safety working gears shall be provided to workers. workers Aerial Spraying Noise due to the  The agricultural plane should be properly serviced Pilot and Operation agricultural before the exercise. Agricultural aircraft  The agricultural aircraft should be operated by a Engineer certified applicator Other activities such Noise  Proper maintenance of equipment Health and Safety Operation as drawing and  Proper use of adequate PPE Manager and Field filling water into Manager bousers, pumping spray mixture into the plane powered by generator Emptying of Solid waste All scraps shall be gathered in one stock area for Agronomy team Operation chemical boxes and generations proper disposal and field manager containers Hygienic activities Workers A mobile toilet will be provided for the workers by the Healthy and Safety Operation sewage developer/contractor Manager

ACTIVITY ENVIRONME IMPACT MITIGATION RESPONSIBILI IMPLEMENTATIO NTAL TY N SCHEDULE IMPACT Security Temporary  A temporary perimeter fence or any appropriate Health and Safety Operation fence structure will be set up to prevent public access to Manager, Field the site manager and  Only authorized personnel shall be allowed access security to the production unit.  A proper signage must be placed at strategic locations at the site

9.0 ENVIRONMENTAL MONITORING PLAN 9.1 ENVIRONMENTAL MONITORING 9.1.1 OVERVIEW Environmental monitoring is essential for ensuring that identified impacts are maintained within the permissible levels, negative impacts are mitigated at an early stage before they become a problem, and the expected project benefits are realized. Therefore, the aim of an environmental monitoring plan is to assist in the systematic and prompt recognition of problems and the effective actions to correct them, and ultimately good environmental performance is achieved. As a result, it is important to provide a plan to facilitate the monitoring and improvement of environmental performance.

9.1.2 MONITORING OBJECTIVES The Environmental Monitoring Plan provides guidelines for the day-to-day management of environmental issues to enable effective monitoring and compliance. The primary objectives of the monitoring plan are to:

 Define a monitoring mechanism and identify monitoring parameters to ensure that all mitigation measures are completely and effectively implemented; and  Define the responsibilities of project developer and other role players, and effectively communicate environmental issues among them.

9.1.3 DURATION OF MONITORING The monitoring will commence two weeks before and end two weeks after the exercise. This will include regular reviews of the impacts that were difficult to be assessed before the beginning of the project, or which arise unexpectedly. In such cases, appropriate new actions to mitigate any adverse effects and monitoring programme will be identified. The developer will maintain inspection and auditing records, while ensuring that incident reporting and emergency response procedures are established and enforced.

9.1.4 THE MONITORING TEAM It is recommended that a monitoring team be designated following the approval of the environmental aspects of the project. The team will be headed by the Masindi District Agricultural Officer (DAO) and will include the District Environment Officer, neighbouring Sub County administration and KSL Public Relations Officer. The Team will take appropriate steps to ensure that the monitoring plan is followed. KSL will also have an internal Environmental Monitoring Team responsible for detecting signs of drift sprays and pollution control. This will be achieved by first establishing an Environment Monitoring Schedule and then an Environment Management Team.

Table 9.1: Environmental Monitoring Plan Negative Impact Indicators Mitigation Frequency of Responsibility monitoring Human sanitary Human waste littering the site  Provide a mobile toilet for use Daily checks by KSL waste and immediate neighbourhood during the exercise relevant stakeholders Absence or presence of toilet Solid wastes Litter at the site and immediate  Put in place coded waste Daily checks during KSL neighbourhood collection bins; the exercise Masindi DEO  Collect all the waste from the site and dispose it off at the approved solid waste disposal site Occupational Records of accidents  Implement the company safety Regular checks by KSL Health and Safety guidelines; KSL District Health including; allergy,  Using the health clinic near the Inspector suffocation, factory; electrocution,  Ensure that all personnel injuries involved are certified to perform the required tasks  Ensure appropriate PPE is provided to workers and is used Noise generation Record of complaints from  Limit noise generating by using a Daily checks during KSL Community near by the Nucleus certified applicator to operate the exercise Masindi DEO Estate well serviced agricultural plane; Complaints from staff  Notify the neighbouring community about the exercise;  Install muffler on the generator Risk of fire Records of fire outbreaks at the  Provide firefighting equipment at Regular checks by KSL; Masindi site site KSL DEO, District  Train staff in fire fighting Health Inspector

 Prohibit smoking at the site  Restrict access to the site Pollution of Deteriorated water quality  Ensure that incidents of spray Daily checks by the KSL community water drifting are eliminated through Project Team Leader, Masindi DEO sources and ground monitoring the speed of wind, air Masindi DEO, and water temperature and allowing for a District Health buffer zone of 50m from the Inspector natural ecosystems and neighbouring communities

10.0 CONCLUSION AND RECOMMENDATIONS 10.1 CONCLUSION It is factual, aerial fertilizer application has been used for years in the U.S., Australia, New Zealand, Malaysia, and in Uganda including at Kinyara Sugar Limited. KSL will utilize the services of a specialised aviation (air spray) company of impeccable reputation and duly licenced by a competent authority in Uganda and or East Africa region. The Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) can permit KSL to procure adequate volumes of Fusilade Forte for use on the 5000 ha of sugarcane at Kinyara for ripening of sugarcane. Additionally, the Civil Aviation Authority can clear the aerial spraying project.

Aerial application of the target agro-inputs will be more efficient than ground application equipment because it (air craft) can’t be hindered by too much soil moisture and too thick/tall sugarcane canopy. Aside, the aerial application exercise of the vast nucleus estate can be accomplished in just one day yet ground application may take days. Shamba workers can be spared for specialized and highly paid tasks (e.g., harvesting) that have not yet been mechanized. The potential environmental impacts of the proposed project have been assessed and are found to be minor to negligible and can be effectively mitigated. With successful implementation of the Environmental Management Plan presented in this ESIA, the proposed project will not have any environmental issues of concern. The developer (KSL) is committed to adhering to the necessary laws and regulations to ensure smooth implementation of the project.

10.2 RECOMMENDATIONS

 The Public Relations Officer of the Developer (KSWL) should actively engage both the local and district authorities. This will be help in monitoring and enforcing the relevant legislations and, and to address public concerns;  The developer ought to provide a hotline (telephone contact) to the public, to enable them to channel their concerns regarding the project with ease;  Because numerous factors are critical for efficacious aerial application; we recommend the whole ripener and fertilizer procurement process must be coordinated with the field application program. The physical quality (specifications) of fertilizer materials must be optimized to ensure uniform distribution over the field; granular fertilizers (urea, diammonium phosphate, potassium chloride) should be used and blending must be monitored closely when two or more fertilizers are applied at the same time. It is highly recommended that aadministrative requirements for the pilot, aircraft, and airstrip, as well as flight authorization must be arranged.

11.0 REFERENCES

 The Uganda Sugar Cane Technologists' Association (USCAT), 2012. Fourteenth Annual Report for Calendar Year 2011.  Loong, S.G., M. Nazeeb, and A. Letchumanan. 1990. A Commercial Trial Showing the Promise of Aerial Application of Fertilizers to Oil Palms. The Planter, 66, p. 125132.  Castro, P.R.C. (1999). Maturadores químicos em cana-de-açúcar, Proceedings of SECAPI 19994th Semana da Cana-de-açúcar de Piracicaba, pp.12-16, Piracicaba, São Paulo, Brazil, 1999.  Dalley, C.D., Richard Junior, E.P. (2010). Herbicides as ripeners for sugarcane. Weed Science. Vol.58, No.3, (July 2010), pp. 329-333, ISSN 1550-2759.  Fernandes, A.C. (1982). Refratômetro de campo. Boletim Técnico Coopersucar, Vol.19, (July 1982), pp.5-12.  Glover, J. (1972). Practical and theoretical assessments of sugarcane yield potential in Natal, Proceedings of 46th South African Sugarcane Technologists Association, 1972, pp.138-141, Natal, South Africa.  United States Department of Agriculture (2014): Scoping/Screening Level Risk Assessment on Fluazifop-P-butyl. SERA TR-056-07-02a  The New Vision, January 11, 2014. Sugarcane growing causing food insecurity.