EIA For Maize & Wheat Milling Plant DEI PDF

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Environmental Impact

Statement for proposed


maize & wheat milling
facility in Wakiso District

DEI Industries International Limited


P O Box 35854 Kampala(U)
Tel: 0414-660519/0752522754
Email:dei@deigroupinternational.com

Consultants
JULY 2016
CONSULTANTS

This Environment Impact Statement (EIS) is a result of analytical and observational studies of the
various environmental and social aspects of the proposed maize and wheat undertaken by a
team of certified environmental practitioners on behalf of DEI Industries International Ltd. The
consultants include:

Name & Expertise Expertise Signature


Certified Environmental Practitioner/Team
Dr. Denis Byamukama
Leader/ Infrastructure projects, Water
resources, Supply industries, Energy
development, Solid waste& Waste water
Certified Environmental Practitioner/Waste
Phionah Sasira
Management Specialist

Babra Kamatungo Certified Environmental Practitioner/


Environmentalist

Other contributing consultants include;


Sylvia MA in Development Studies (UMU, Nkozi), Bachelor of Arts in
NakalemaNdazima Social Sciences (MUK), Diplomas in Theology and PPM (UMI).

Paul Okiror MSc. Environment & Natural Resources (MUK), Masters in


Management Studies (UMI), PGD M&E, (UMI), PGDs in
EIA/EA/OHS-(JKUAT, Kenya), BSc. Forestry (MUK).
Jane Chono MSc. Environment & Natural Resources (MUK), BA in Environment
Management (MUK), Kampala Uganda.
Junior Nuwahereza Bachelors of Environment Science Technology and Management
(KYU)

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


Executive Summary

Consumption of maize and wheat flour in Uganda has been steadily increasing during the past 20
years as a result of growing population, changing food preferences and a strong urbanization
trend which has led to a growing food gap. For example maize flour is most widely grown staple
food crop in Uganda and consumed by people with varying food preferences and socio -
economic backgrounds, as more than 10 million people depend on it as source of food and
livelihood. During 2010-2013 the average quantity of wheat import in Uganda doubled, and the
government put in place better institution and market arrangements aimed at creating incentives
to wheat producers. Even as significant productivity gain for maize has been realized and imports
for wheat improved, there are serious challenges in processing these grains in Uganda.

The rising consumption pattern, the high post-harvestlosses and current substandard process
technology, all combined pose a seriousinvestment opportunities in a country where maize forms
the highest percentage of calorie intake in the national diet, and wheat imports are now third of
the country’s food imports.It’s against this background that the DEI Industries International
Ltd“the developer” intends to establish a maize and wheat milling facility in Kigogwa Village,
KiryamuliParish,Gombe Sub -County,Kyadondo CountyinWakiso District.

Maize and wheat milling is not associated with significant environmental and social impacts save
for high energy consumption during milling and transportation operations. However, these
operations involve large amounts of produce/ grain and the surface area required for these
operations is to a large extent large. Hence establishment of such a facility will require opening
up large areas of land with consequential in-situ and ex- situ erosion effects, dust and fumes from
the land preparation equipment and vehicular movements to and fro the site. Other major issues
include health and occupational issues during operation involving staking and movement of
packed maize & wheat flour from the production process to the storage and into trucks. The
developer cognisant of the environmental and social implication of establishing the milling facility
has undertaken an Environmental and social impacts assessment of all the project components
and compiled a report for NEMA’s approval. This report therefore contains a thorough
assessment of all the social and environment aspects of the proposed development and the
associated mitigatory measures intended to address the identified social and environmental

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


impacts.The report also makes constructive suggestions on how to improve the environmental
performance of the proposed project, and aims at inspiring public and stakeholder interest in the
project objectives and obligations.

Description of project area


The area is characterised by a rising population surge comprised of inform sector in mixed
settlement pattern comprised of residential houses, banana and cassava plantations, and trading
centres in the west and a PET factory. The area is not planned or properly regulated. It drains
into a nearby wetland system. The project lies at coordinates0.494957˚N and 32.522024˚E. The
access to the site is through Bombo road approximately 1 Km from Mattuga Trading Centre.
The site soils are hydromorphic and predominately red sandy, loamy soils, the area is well
drained. The area is raised with a gentle which provides firm ground for laying the mill
foundation structures and provides the requisite soil strength of the building structures.The
project area and the surroundings similar to most parts of have a diverse mixture of ethnic
groups. Finite exchange opportunities exist for various tradable commodities and this social
interaction and exchange of goods is enhanced by the improvement in livelihoods and incomes
of most households in the area. Labour supply to gardens/farms and small scale businesses for
cash is very common and is practiced among the area poor which facilitates easy interaction
between the labour dependent households and businesses in the area. There are social structures
and development committees that bring community members together for development or social
causes.

Anticipated impacts and mitigation measures


Establishment of the proposed grain milling plant will trigger adverse in-situ and ex-situ
environment and social impacts from the different project activities. However most or all of the
anticipated impacts can be prevented/minimized and avoided if all the proposed mitigation
measures are adopted throughout all the project phases.Project establishment will also trigger
positiveimpacts on a wide socio-economic note henceneed for support and approval from
relevant authorities.

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


Public consultation
Public consultations explored stakeholder’s opinion and perception on project operations. The
chapter section reveals that largely the public welcomed the project idea on a whole and their
fears and expectation were will be factored in the project design. Generally the public expressed
support for the proposed project and welcomed its implementation citing envisaged project
contributions to neighbouring communities like creation of employment opportunities, forward
and backward linkages and easy access to milling services among others.

Environmental and social management plan


An Environmental and Social Management Plan has been suggested for the proposed project. The
aim of the ESMP is to avoid all the possible project adverse impacts and to/or maintain the
existing environment quality. The ESMP communicates all aspects of planning, construction and
operation phases of the project relevant to environment and society as a whole, and proposes a
set of management procedures to regularly monitor the project operations to ensure all
environmental and social commitments suggested for protection of the environment and social
order are implemented
Conclusion
Establishment of maize and wheat mill can trigger significant environmental and social impacts.
However, most of the impacts are manageable with the implementation of management of Dei
Industries International Ltd is advised to properly adopt and implement the suggested mitigation
measures throughout all project activities.To facilitate the above, an Environmental and Social
Monitoring and Management Plan has been proposed to ensure that the proposed mitigation
measures are implemented and adhered to during all operation phases of the grain milling plant.
Various aspects of the ESMP will have to be integrated into the overall operational strategy of
the milling plant, and enforced by DEI Industries International LtdManagement under close
supervision of NEMA and technical staff from WakisoDistrictEnvironment Office. It is important
to underpin that implementation of mitigation measures shall be the sole responsibility of Dei
Industries International Ltdmanagement. For effective operation of the proposed grain milling
plant, it is recommended that the developer undertakes environmental audits, to evaluate its
performance and mechanisms for improvement.

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


Table of contents

CONSULTANTS ........................................................................................................................................................ ii
Executive Summary ................................................................................................................................................... iii
Table of contents .........................................................................................................................................................vi
List of Tables ................................................................................................................................................................ x
List of Figures .............................................................................................................................................................. x
List of Plates .................................................................................................................................................................x
Acronyms.....................................................................................................................................................................xi
CHAPTER ONE ..........................................................................................................................................................1
1.1 Objective of ESIA study .................................................................................................. 1
1.2 Scope of proposed project ................................................................................................ 2
1.4 Environmental and social management plan (ESMP)...................................................... 3
1.5 Report structure ................................................................................................................ 3
CHAPTER TWO .........................................................................................................................................................5
2.0 Project description and related activities .........................................................................................................5
2.1 Facility establishment ....................................................................................................... 5
2.1.1 Construction phase .................................................................................................... 5
2.1.2 Operational phase...................................................................................................... 6
2.2 Production process ........................................................................................................... 6
2.2.1 Maize production process ......................................................................................... 6
2.2.2 Wheat production process ......................................................................................... 7
CHAPTER THREE ................................................................................................................................................... 11
3.0 Legal and administrative framework ............................................................................................................. 11
CHAPTER FOUR ..................................................................................................................................................... 16
4.0 Project area social and environmental baseline conditions .......................................................................... 16
4.1 Socio-economic conditions ............................................................................................ 20
4.1.1 Standard of living population.................................................................................. 21
4.1.2 Basic services .......................................................................................................... 22
4.1.3 Social capital ........................................................................................................... 23
4.2 Physical environment ..................................................................................................... 24
4.2.1 Soil and geological characterization ....................................................................... 24
4.2.2 Area drainage and hydrology .................................................................................. 25

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4.2.3 Climatic conditions ................................................................................................. 26
4.2.4 Noise baseline conditions ....................................................................................... 28
4.3 Biological environment .................................................................................................. 28
4.3.1 Area vegetation ....................................................................................................... 28
4.3.2 Fauna ....................................................................................................................... 29
CHAPTER FIVE ....................................................................................................................................................... 30
5.0 Anticipated environmental/social impacts and proposed mitigation measures .......................................... 30
5.1 Socio-economic impacts ................................................................................................ 30
5.1.1 Loss of income and livelihood by the project affected persons ................................... 31
5.1.2 Impacts on local business, profits and employment .................................................... 32
5.1.3 Impact on employment and economic opportunities .............................................. 33
5.1.4 Demographic impacts ............................................................................................. 34
5.1.5 Health impacts, HIV/AIDS and malaria ................................................................. 35
5.1.6 Impacts on public infrastructure and services ......................................................... 36
5.1.7 Impact on the national economy ............................................................................. 37
5.2 Environmental and occupational impacts during facility establishment........................ 38
5.2.1 Impacts during facility establishment ..................................................................... 38
5.2.2 Solid waste generation during construction phase: ................................................. 40
5.2.3 Waste-water generated during establishment phase of the project ......................... 41
5.2.4 Impacts on human health ........................................................................................ 41
5.2.5 Dust emission during establishment phase ............................................................. 42
5.2.6 Traffic flow impacts:............................................................................................... 42
5.2.7 Impact of site scenic alteration: .............................................................................. 43
5.2.8 Possibility of drainage impairment: ........................................................................ 43
5.2.9 Occupational, health and safety risks during construction: .................................... 44
5.3 Environment, occupational health and safety impacts during operation ....................... 45
5.3.1 Physical hazards ...................................................................................................... 45
5.3.2 Exposure to noise ......................................................................................................... 46
5.3.3 Exposure to dust emission from plant operation ......................................................... 47
5.3.4 Generation of solid wastes at the factory premises ...................................................... 49

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5.3.5 Sewage and Sullage (Wash Water) .............................................................................. 50
5.3.6 Solid waste from the operational activities at the facility ............................................ 50
5.3.7 Contaminated storm water/runoff ................................................................................ 52
5.3.8 Impact from increased traffic in the area ................................................................ 53
5.3.9 Fire and explosion hazards: ......................................................................................... 54
5.4 Operation impacts on natural resources ......................................................................... 56
5.4.1 Impact on water requirement ..................................................................................... 56
5.4.2 Impacts due high energy consumption ................................................................... 58
5.4.3 Natural Disasters .......................................................................................................... 58
5.4.4 Collapse of the warehouses/facility ............................................................................. 59
5.5 Decommissioning of the facility .................................................................................... 59
CHAPTER SIX .......................................................................................................................................................... 61
6.0 DISCUSSION OF ALTERNATIVES ............................................................................................................ 61
6.1 Alternative 1: Local production from proposed project ................................................. 61
6.2 Alternative 2: Establishment of grain milling plant on an alternative site. .................... 62
6.3 Alternative 3: Plant design and raw material alternatives .............................................. 62
6.4 Alternative 4: Maintaining the status quo: ..................................................................... 63
6.5 The no project scenario .................................................................................................. 63
6.6 Comparison of alternatives............................................................................................. 63
6.7 Recommendations .......................................................................................................... 64
CHAPTER SEVEN ................................................................................................................................................... 65
7.0 Public consultation and land-use options at the project site ........................................................................ 65
7.1 Stakeholder/public consultation approach/methodology ............................................... 72
7.2 Stakeholders’ response analysis ..................................................................................... 72
7.3 Analysis of the various land use options ........................................................................ 74
7.4 Distribution of probabilities of acceptance of land use option....................................... 76
CHAPTER EIGHT.................................................................................................................................................... 77
8.0 Environmental and social management plan ................................................................................................. 77
8.1 Strategies for sound environment management ............................................................. 78
8.1.1 Good process management practices ...................................................................... 78
8.1.2 Site selection and management ............................................................................... 78
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8.1.3 Environmental protection........................................................................................ 79
8.1.4 Waste management plan ......................................................................................... 79
9.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................................................. 86
9.1 Recommendation ................................................................................................................ 87
APPENDICES............................................................................................................................................................ 89
Appendix I: Approval letter of TOR ......................................................................................... 89
Appendix II: Copy of land title ................................................................................................. 91
Appendix III: List of stakeholders consulted during the EIA process ...................................... 96
Appendix IV: Soil analysis result ............................................................................................. 97
Appendix V: Water analysis result ........................................................................................... 98
Appendix VI: Site layout plans ................................................................................................. 99

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List of Tables

TABLE 1: REGULATORY AIR QUALITY STANDARDS FOR SELECTED POLLUTANTS ................................................................................15


TABLE 2: ENVIRONMENT BASELINE NOISE LEVELS: ..................................................................................................................28
TABLE 3: EMISSION POINTS – FLOUR MILL ............................................................................................................................48
TABLE 4: SHOWING THE TYPE OF WASTE ALONG THE PRODUCT PROCESS ......................................................................................51
TABLE 5: SUMMARY OF STAKEHOLDER’S COMMENTS ABOUT THE PROJECT ...................................................................................66
TABLE 6: SHOWING STAKEHOLDERS RESPONSE TO PROJECT ESTABLISHMENT ................................................................................74
TABLE 7: LAND USE TYPES CONSIDERED BY THE COMMUNITY/STAKEHOLDERS ...............................................................................75
TABLE 8: OVERALL RANKING OF THE LAND USE OPTIONS SELECTED BY COMMUNITY MEMBERS .........................................................76
TABLE 9: SUMMARY OF POTENTIAL IMPACTS FROM OPERATIONS AND THEIR PROPOSED MITIGATION MEASURES ..................................80

List of Figures

FIGURE 1: WAKISO DISTRICT CLIMATE AND TEMPERATURE GRAPHS ...........................................................................................27


FIGURE 2: WAKISO DISTRICT CLIMATE TABLE.........................................................................................................................27

List of Plates

PLATE 1: GRAIN MILLING PROCESS FLOW CHART .....................................................................................................................10


PLATE 2: PLATE 4.1: BOMBO ROAD .....................................................................................................................................16
PLATE 3: PROPOSED SITE AND NEIGHBOURHOOD. ...................................................................................................................17
PLATE 4: AERIEAL VIEW OF PROPOSED PROJECT SITE ................................................................................................................18
PLATE 5: THE PET FACTORY AND CASSAVA PLANTATIONS IN THE NEIGHBOURHOOD. ......................................................................20
PLATE 6: THE MAJOR SOCIAL AND ECONOMIC ACTIVITIES IN THE AREA .........................................................................................21
PLATE 7: ACCESS TO THE PROPOSED SITE THROUGH BOMBO ROAD ............................................................................................22
PLATE 8: IMMEDIATE SHOPS FROM THE SITE...........................................................................................................................24
PLATE 9: SHOWING SOILS AT THE PROPOSED SITE ....................................................................................................................25
PLATE 10: THE DRAINAGE CHANNEL CLOSE TO THE PROPOSED SITE .............................................................................................26
PLATE 11: NATURAL VEGETATION WITHIN THE PROPOSED AREA.................................................................................................29

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Acronyms

AIDS Acquired Immune Deficiency Syndrome


CO2 Carbon dioxide
CO Carbon monoxide
Cap Chapter
DIIL Del Industries International Ltd
dB Decibels
EA Environmental Audit
ESMP Environment Social Management Plan
ESIA Environment and Social Impact Assessment
EIA Environment Impact Assessment
HIV Human Immune Virus
ILO International Labour Organisation
IUCN International Union for Conservation of Nature and Natural Resources
KCCA Kampala Capital City Authority
NEMA National Environment Management Authority
NWSC National Water and Sewerage Cooperation
NOx Nitrogen oxides
OP Operation Policy
OSH Occupational Health and Safety
PPE Personal Protective Equipment
PBP Pay Back Period
PE Professional Engineer
PM Particulate Matter
ROI Return on Investment
STIs. Sexually Transmitted Infections
SO2 Sulphur dioxide
SO3 Sulphur trioxide
UNRA Uganda National Roads Authority
VOCs Volatile Organic Compounds
VAT Value Added Tax

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


CHAPTER ONE

1.0 Introduction
Consumption of maize and wheat flour in Uganda has been steadily increasing during the past 20
years as a result of growing population, changing food preferences and a strong urbanization
trend which has led to a growing food gap. For example maize flour is mostly consumed by
people with varying food preferences and socio -economic backgrounds, as more than 10 million
people depend on it as source of food and livelihood. During 2010-2013 the average quantity of
wheat import in Uganda doubled, and the government put in place better institution and market
arrangements aimed at creating incentives to wheat producers.

Even as significant productivity gain for maize has been realized and imports for wheat
improved, there are serious challenges in processing these grains in Uganda. Commercial milling
and grain processing is one of the stages for postharvest grain lossesmainly due to limited
availability of processing facilities, lack of appropriate processing technologies, inadequate
commercialization of new technologies and lack of basic infrastructure, inadequate facilities and
infrastructure, and insufficient promotion of processed products.

These challenges given the rising consumption pattern and consumer awareness provide a great
investment opportunity in agro processing. In view of requirement for establishing such facilities,
DEI Industries International Limited (DIIL)“herein referred to as the Developer” has undertaken
an ESIA of its proposed development to evaluate the environmental and social appropriateness
of its facility as required by law. This ESIA also provides guidance on how environmental and
social concerns associated with the proposed project developmentcan be incorporated in the
planning, establishment and operational phases of the project in order to preserve environment
and social integrity of the area and trigger project acceptability by society and approval from
relevant institutions.

1.1 Objective of ESIA study

Establishment and operation of maize and wheat milling plant is inescapably associated with in-
situ and ex-situ environmental and social issues. Hence falls in the Third Schedule of the National

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Environmental Act Cap 153, which requires undertaking ESIA for projects likely to cause impacts
on society and environment. Therefore undertaking an ESIA for this proposed project was aimed
at assessing the environment and social aspect of the project activities, and identify all probable
environmental impacts associated with project operation, then recommend appropriate
mitigatory measure to lessen the impacts on society and the environment.

1.2 Scope of proposed project

The scope of the project was limited to the geographical location in Kigogwa-MatugaZone where
the project is proposed, and all environment and social aspects related to the geographical
location in addition to any ex-situ aspects associated withthe project operation.
1.3 Assessment approach/methodology
The assessment involved review of extant literature of the proposed project operation, project
location, area baseline data focusing on topography, geology, soil, climate, drainage and
hydrology, flora, fauna, population, ethnicity, utilities and economic activities, architectural and
archaeological and cultural heritage and legality surrounding the project operation.The literature
review was supplemented with field visits to assess the area land use, location of utilities, local
area hydrogeology and physical identification of receptor systems in the area. Public
Consultations with stakeholders was also undertaken aimed at securing a buy in of the project
development conceptfrom the community and integrate community issues in the planning and
operational phase of the project to secure social order and community harmony during project
operation.

Consultations focused at communities in the neighbourhood, relevant government agencies


(NEMA, local authorities, Ministry of Labour, Gender and Social Development,) among others.
The mode of consultation was formal and informal interviews to ensure public participation as
recommended by the National Environmental Act, Cap. 153 EIA Regulations 1998.

Prediction and analysis of project impacts; project's likely positive and negative impacts were
assessed. Opportunities for environmental and social enhancement were explored and mitigation
measures for negative impacts proposed. Impacts were identified basing on their relation to
biophysical or social environment. Impact were evaluated in relation to; probability of

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


occurrence (low, medium or high) extent (local, national or regional), duration (temporary,
short, medium and long term), magnitude (low, medium or high) and overall assessment
(negligible, minor, moderate, substantial or severe). A Socio- Impact estimation of proposed
project was done ranging from the desirable to adverse.

Finally, analysis of the predicted environmental impacts and mitigation measures proposed were
based on internationally best practices for industrial operation as guided in the National
Environmental Act Cap, 153. An Environment and Social Management and Monitoring Plan
for the project was drawn to address all project apparent and predicted negative environmental
impacts and also attach responsibility for proper implementation as described below.

1.4 Environmental and social management plan (ESMP)

The ESMPspecifies the technical, operational, managerial and institutional measures necessary to
minimize or eliminate any adverse social and environmental impacts to levels acceptable under
the requisite national and international requirements. The ESMP also defines the timeframe
within which mitigation measures will be implemented and the individuals/institutions
responsible for this.

1.5 Report structure

The report is organized in sections; chapter one gives an introduction to the project, ESIA
objectives, purpose and methodology of the study in addition to ESMP, Chapter 2 reviews the
relevant legislation pertaining to various aspects of the project. This chapter reviews national and
international compliance requirements of the project throughout project life span and the legal
framework for routine environment monitoring. Chapter 3 gives a presentation of the baseline
environmental conditions and establishes the basis for discussion of project impacts in Chapter 5.

Description of the proposed project, project features and particulars of the developer are given in
chapter 4. It examines the project cycle more closely from the project preparation phase through
construction and the operations phase. All aspects of the project cycle components are reviewed
here. Particular attention is given to the operational phase to clarify the nature of the project and
the probable sources of impacts on the environment.

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Chapter 5 revisits the project activities already introduced in Chapter 3 on baseline conditions,
analysis of project impacts, their evaluation is undertaken, also suggests appropriate mitigation
measures. Chapter 6 pulls the project alternatives together, at the level of proposed location and
design. The analysis of project alternatives justifies the recommended option. Chapter 7 evaluates
the public perception during consultation with main stakeholders. Chapter 8 sets the
Environmental and Social Management Plan of the project and chapter 9 gives conclusions and
recommendation.

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ESIS – Establishment of DEI Maize and Wheat Processing Facility


CHAPTER TWO

2.0 Project description and related activities

The proposed development will comprise of four warehouses which will be partitioned into
production and process line area, a store for both raw maize and wheat grain and finished
products (maize and wheat flour); and one office block. The milled flour will be supplied to
different wholesalers in and around Kampala. The proposed facility will be enclosed in a
perimeter wall with the intention of minimising dust and noise impacts in the surrounding
neighbourhoods, a well-constructed storm water channel connecting to the area drainage channel
along main route will be constructed. Layout Plans for the structures have been submitted to
Wakiso District for consideration and approval.

Establishment of maize and wheat milling plant is made up of three phases namely preparation,
construction and operation phase. Each of the phases comprises a series of activities likely to
affect the wellbeing of the environment and the people. The activities involved in each phase are
elaborated below;

2.1 Facility establishment

2.1.1 Construction phase

This phase will involve clearing significant area of the proposed site, laying the foundation
structures, building construction, utility connections and finishing. The activities during this phase
are;

• Site preparation and levelling in particular will entail removal of existing structures,
scarifying of topsoil and earthworks to establish the required levels.
• Excavation works will involve digging and excavation of trenches for foundation strips for
the structures, trenches for ground water storage, drainage channels and sewage
reticulation system.
• Construction of the milling plantwill involve preparing of mortar and concrete, structural
steel erection, the laying of concrete block walls, fixing of roofs, erection of roof trusses,
installation of finishes, fixing electrical and plumbing fixtures and fittings and lastly
landscaping.

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• Materials mobilization, handling and storageand storage of materials such as gravel,
laterite, and stone aggregates required for construction works.
• Transportation of construction materials and machinery; transportation of construction
materials to and from the site will involve the movement of heavy vehicles. Construction
activities such as clearing, excavation, earth moving and mixing of concrete will involve
the movement and operation of heavy machinery and equipment around the site. This
will contribute to existing traffic especially during peak hours, create dust in addition to
emission of fumes by vehicles and other construction works.
• Movement of construction workers; although no labour camp is planned in the project
area, social interaction activities will undoubtedly result between project workers
and local communities.

2.1.2 Operational phase

The milling process turns maize and wheat grains into flours used for various purposes. The grains
are grinded into flour through the following processes;

2.2 Production process

2.2.1 Maize production process

Raw material, storage and selection:Maize will be procured from suppliers that have a direct link
with farmers. The maize will be delivered in woven sacs where upon arrival it is weighed, graded
and dried and impurities removed. In order to ensure a continuous supply of maize at the mill
and to take advantage of price fluctuations, maize will be bought in plenty and stored at the
facility. Silos for bulk storage will be constructed at the site.

Cleaning and conditioning process: Cleaning and conditioning of the maize is an important step
in the process of milling maize and refers to the removal of all extraneous material such as husk,
straw, dust, sand, metal and stones.Once the stock has been cleaned, it’s directed into air
conditioner that removes all the moisture to level required for milling. This also allows the bran
to be peeled off in flakes during milling with plate or roller mills, allowing easy separation in a
sifter and, most importantly to add mass to the meal.

Grinding process: In this process, hammers fixed to central shaftoften swinging on steel pins,
rotate at high speed. The impact of the raw material on the hammers and the continual high-

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velocity impact of particle on particle results in material breakdown until it is small enough to
pass through a perforated screen. The smaller the screen size the more the work that will be
required to reduce the particles to the desired size and the larger the grinder motor required. The
grinding operation can generate considerable quantities of heat and dust and temperatures of
raw materials may increase by at least 10-20°C. Cooling normally occurs as air is drawn into the
grinding chamber, and during the pneumatic conveying of ground material from the grinding
screen to its point of discharge, which will be through a cyclone into a miller. The grinders will
have suction fans fitted to the grinder shaft to bring about cooling and conveying of ground
material in one operation. Normally, grinders will operate in a horizontal direction according to
design.

Milling process: Essentially this is the separation of the bran and germ from the endosperm and
the reduction of the endosperm to a uniform particle size (flour). This is done by a sequence of
breaking, grinding and separating operations. The quality of the maize going into the mill, e.g.
protein content, will determine the types of flour to be produced. By blending together the
many different flour streams produced by the mill, a miller can create further variations in
features such as flour colour. For example, very white flours would come from the early streams
only, while brown flours involve using most streams. Wholemeal flour is produced when all the
streams, bran, germ and flours are blended back together with nothing removed.

Packaging: The finished flour will be packaged in the size of twenty five, fifty and one hundred
kilograms, the flour will be kept at the warehouse for a few days from which it will be sent to the
market for consumption. The milling waste will be collected at factory and blended into other
feeds for animal food. Most components of maize grain will be used; waste is kept to an absolute
minimum.

2.2.2 Wheat production process

Delivery and storage: Wheat grains will be imported from wheat growing countries and received
at the warehouses at the new proposed milling plant, where it will be offloaded, weighed,
inspected and graded according to;

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▪ Variety: different varieties produce different flour qualities.
▪ Moisture content because this determines the length of time that a grain can be stored.
▪ Specific weight:the higher the weight the higher the quality of the flour.
▪ Enzyme activity which determines the stickiness of the bread, making slicing difficult.
▪ Protein quality and quantity: important for baking purposes.

Cleaning and conditioning:Powerful magnets, metal detectors and other machines extract metal
objects, stones and other grains such as barley, oats and seeds from the wheat grain. Throughout
the cleaning process, air currents lift off dust and chaff. Conditioning with water softens the outer
pericarp (bran) layer of the wheat and makes it easier to remove the floury endosperm during
milling.

Gristing:The cleaned and conditioned wheat is blended with other types of wheat in a process
called gristing to make different kinds of flour. Occasionally, wheat gluten is added to increase
the protein content of milled flours.

Milling: The miller’s art lies in finely tuning a sequence of breaking, sifting and rolling to achieve
the desired colour and consistency of flour.
▪ Stage 1: The grist is passed through a series of fluted 'break' rolls rotating at different
speeds. These rolls are set so that they do not crush the wheat but shear it open,
separating the white, inner portion from the outer skins.
▪ Stage 2: The fragments of wheat grain are separated by a complex arrangement of sieves.
White endosperm particles are channelled to a series of smooth 'reduction' rolls for final
milling into white flour.

Coarser pieces of bran with endosperm still attached go to a second break roll, and stages 1 and 2
are repeated until the flour, bran and wheat germ are completely separated. The result is a
number of flour streams containing white flour, bran and wheat germ. The whitest flours are
produced from the early reduction rolls, with the flour getting less white on later rolls as the
proportion of bran particles increases. Brown flour is a mixture of white flour and a portion of
the other streams. To produce wholemeal flour, all the streams must be blended back together.

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Packaging:The different flours are packaged and stored in the warehouse. The flour is used for
bread as well as biscuits, pies, cakes and confectionery. Wheat germ and bran may be used for
certain breads and cereals or sold as health foods. The remainder will be collected at the factory
and blended into wheat feed for animal food. As all components of the wheat grain are used,
waste is kept to an absolute minimum.In brief, the proposed project process line will undergo the
following steps;
▪ The grains of wheat will be offloaded from the wagons and trucks and stored in grain
silos/warehouses;
▪ The grains will go for cleaning section to remove impurities, dust, stones and stalks;

▪ The grains will be processed for dampening and tempering in respective bins;

▪ In the next milling process, the grains will undergo for breaking, milling and shifting
operations;

▪ Once the flour is shifted in various fractions, it will be conveyed to its destination depending
up on quality;

▪ Every packing section will send the final product for checking of quality parameters and pack
accordingly and lately

▪ Depending up on loading instructions, product will be loaded in truck

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Grain receiving
Truck

Grain handling

o
Preliminary
o clean

Storageo
o
Cleaning House
o Magnetic
Separators Aspirator
o (screens)
o separator Disc separator
o
Surgeo Bin Scourers Stoner (wet or
o
o Optional dry)
o
Tempering
o Magnetic Impact
o
separator machine

Milling
Break rolls
o Sifter (plan sifter)
o Air aspiration (purifier)

Air aspiration Sifter (plan sifter)


o Reducing rolls
(Purifier)
o

Bulk storage
Packaging

Bulk loading
Trucks
Plate 1: Grain milling process flow chart

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CHAPTER THREE

3.0 Legal and administrative framework

Development of a grain milling has several legal and environmental implications. It is also
regulated by several geographic and social factors in addition to technical and biological setup of
the area. In general, it is useful to think of grain milling development as any other activity that is
reliant on social harmony and environmental integrity for effective operation. It requires legal
and institutional measures to establish this facility in line with various public health, land use right
and planning provisions and fulfilling a number of international legal obligations. Generally
beyond perceived air pollution and other environment consequences, grain milling plant
development causes social disorder especially during establishment. Grain milling is regulated by
relevant national and international agreements and conventions to which Uganda is a party.

Establishment and operation of a grain milling plant is listed in the third schedule of the
National Environmental Act. Therefore a set of relevant and applicable regulations and
policies were considered during the study as appropriate to safe guard the principle of
sustainable development viewed in the lens of social harmony. This section therefore labours
to ensure that project establishment and operation is regulated in a way that adequately
protects the environment and preserves social order in the long term. The section also
provides guidance on how to integrate legal inclusion in investment process. Below are the
policies and laws relevant to the proposed graining milling facility;

National Environment Management Policy, 1994;


The overall goal of this policy is promotion of intergenerational sustainable economic and social
development. The policy calls for integration of environmental concerns into development
policies, plans and projects at national, district and local levels.

Constitution of the Republic of Uganda, 1995:


The constitution provides for, inter alia protection and preservation of the environment as a
sacred responsibility for all, and this assessment is aimed at minimizing/avoiding anticipated
project impacts in line with this constitutional requirement.

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National Environment Act, Cap 153;
This specific legislation mandates the undertaking of environmental and social impact assessments
(ESIA) in Uganda for projects likely to have significant impacts on the environment prior to
implementation.

Environmental Impact Assessment Regulation, 1998:


Part III of the Regulation, Section 10 provides a framework under which en vironmental
impact studies are conducted.Section 12 of these regulations also requires that the public
participate in the Environmental Impact Assessmentprocess, and during this assessment,
several stakeholders where consulted and informed of the project concept, and their views
are part of the final report and its recommendations.

Physical Planning Act 2010;


The Act in respect to the proposed plantalso provides for approval, physical development plans
and for authorization and control of development. Under this Act. It’smandatory for a person
carrying out a development within a planning area to obtain development permission from a
physical planning committee of Wakiso District Layout plans (Appendix VI)for the proposed
development were submitted to Wakiso District for approval in accordance with this Act.
Local Governments Act, Cap 243:

This Act provides for decentralised governance and devolution of central government functions,
powers and services to local governments that have their own political and administrative set-
ups. Local authorities have powers to oversee implementation of development activities under
direct supervision of their relevant departments. Proposed site lies within WakisoDistrict Local
and the district plays a significant role in ensuring that the development conforms to the legal
provisions by ensuring that no works will begin at the site before securing of approvals related to
site plans among others.

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Public Health Act, Cap 281:
This Act provides local authorities with administrative powers to take all lawful, necessary and
reasonable measures to prevent the occurrence or deal with any outbreak or prevalence of any
infectious communicable or preventable disease and to safeguard and promote the public health.
The Act mandates local authorities (Section 103) to prevent environmental pollution in the
interest of public good. This Act is thus applicable to construction, operation and
decommissioning of the proposed project and management of associated waste and emissions.
Mobile toilets should be provided during construction phase.

Occupational Safety and Health Act, 2006;


Part 3 of this Act outlines duties, obligations and responsibilities of employers. These include
but are not limited to employers providing protective clothing where a worker is to be
exposed to pollutant or chemical that could be hazardous. Section 13 states that it is the
responsibility of an employer to take as far as is reasonably practicable, all measures for the
protection of his or her workers and the general public from the dangerous aspects of the
employer's undertaking.Employers are also held responsible for keeping the working
environment free from any hazard due to pollution by employing technical measures. This
particular regulation will apply during construction and to a less extent during operation
particularly for the sanitation workers. It’s the responsibility of the contractor to ensure that
workers’ rights are protected.

National Environment (Standards for discharge of effluent into water or Land) Regulations, 1999;
The National Environment (Standards for Discharge of Effluent into Water or on
Land) Regulations, 1999 is another relevant piece of legislation considering the likelihood of
grey water discharge carried by run-off water, and the social environment in its
neighbourhood, this regulation should be taken into consideration in the development of
this site. The regulation provides for standards (maximum permissible limits) for effluent
or waste before discharge into water or on land, a general obligation to mitigate pollution,
and a duty to keep records of amount of waste generated.The only effluent at the plant will
be grey water, DIIL is committed to management of the effluent as per the requirements of
this regulation.

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National Environment (Noise Standards and Control) Regulations, 2003;
This regulation clearly indicates that noise from all noise emitting sources at the facility must
conform to the National Environment (Noise Standard and Control) Regulations, 2003)
regulations aimed at ensuring the maintenance of a healthy environment for all people in
Uganda, the tranquillity of their surroundings and their psychological well-being. And in Section
8 (1) of the regulations, it’s the duty of the owner or occupier of a facility or premise or
machinery to use the best practicable means of ensuring that the emission of noise from those
premises does not exceed the standards and limitations set in these regulations. The developer
has been advised that all equipment and noise generating sources are regularly serviced
properly to ensure they are efficient and effective to avoid any malfunctioning that would lead
to noise emission. Secondly, generators to be installed should be silenced and located
awayfrom points of occupancy. Lastly permission should be thought from relevant authorities
in cases where noise above the permissive levels is to be generated.

Part III Section 8 (1) requires machinery operators to use the best practicable means to ensure that
noise emission does not exceed permissible noise levels. The regulations require that persons to
be exposed to occupational noise exceeding 85 dBA for 8 hours should be provided with
requisite ear protection. During operation the process line will comprise of various running
machines which will generate noise in the process.

National Environment (Waste Management) Regulations, 1999;


Section 5 of the National Environment (Waste Management) Regulations 1999 advises on
Cleaner Production Methods of managing and minimizing waste by person who owns or
controls a facility or premises, which generates waste to ensure the waste generated does not
pose significant impact on the environment. Proposed project will not generate any hazardous
waste stream save for cleaning water and probably dry cleaning waste water if among the
tenants will be involved in laundry services. The developer will have to put in place measures to
ensure strict adherence to all provisions of this regulation coupled with a monitoring regime to
ensure compliance with the regulations.

National Air Quality Standards, 2006 (draft); Construction and operation of the proposed
development will generate air emissions, particularly emissions associated with haulage fleet and

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construction dust, and flour milling operations. The draft National Air Quality Standards provide
the following regulatory limits (Table 4). Measures to control air emissions should be
instituted.Indoor air quality should be enhanced by having open spaces inside the facility and
providing enough ventilation to allow air flow.

Table 1: Regulatory air quality standards for selected pollutants


Pollutant Averaging time for ambient air Standard for ambient air
Saw dust 24 hr 1 mgNm-3
Carbon dioxide (CO2) 8 hr 9.0 ppm
Carbon monoxide (CO) 8 hr 9.0 ppm
Hydrocarbons 24 hr 5 mg/m3
Nitrogen oxides (NOx) 24 hr 1 year arithmetic mean 0.10 ppm
Soot 24 hr 500 µg/Nm3
Sulphur dioxide (SO2) 24 hr 0.15 ppm
Sulphur trioxide (SO3) 24 hr 200 µg/Nm3
Note: ppm = parts per million; “N” in µg/Nm-3 connotes normal atmospheric conditions of
pressure and temperature (25oC and 1 atmosphere). Source: The National Environment (Noise
and Vibrations Standards and Control) Regulations, 2013)

Employment Act, 2006;


The Act, 2006 repealed the Employment Act (Cap 219) enacted in 2000. This Act is the principal
legislation that seeks to harmonize relationships between employees and employers, protect
workers interests and welfare and safeguard their occupational health and safety through: (i)
prohibiting discrimination and sexual harassment at workplaces; (ii) providing for labour
inspection by the relevant ministry (iii) stipulating rights and duties in employment (weekly rest,
working hours, annual leave, maternity and paternity leaves, sick pay;(iv)continuity of
employment (continuous service, seasonal employment). All workers at the site should be
reminded of the provisions of this Act.

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CHAPTER FOUR

4.0 Project area social and environmental baseline conditions

The proposed development is a grain (maize and wheat) milling project to be located in
Kigogwa Village, Kiryamuli Parish Gombe Sub -County Kyadondo County Wakiso District, lying
geographically at 0.494957˚N and 32.522024˚E. Access to the proposed site is by Bombo road
approximately 1Km from Mattuga trading centre and 800m from Kigogwa trading centre. The
surrounding to the proposed site is characterized by residential houses, the nearest residential
house being in the eastern franks of the proposed site approximately 200m away, Banana and
cassava plantations in the southern franks, and trading centres in the west, Plastic Manufacturing
factory in the western neighbourhood. Exactly opposite the proposed project site in the northern
neighbourhood are fruits and tomatoes vending stalls operated by women just across the Bombo
access road. The proposed plot for development measures approximately 2.8 acres.

Plate 2: Access to the site (Bombo Road)

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Plate 3:Proposed site and neighbourhood.

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PET Factory Bombo Road
Plate 4: Aerieal view ofproposed project site

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Plate 5: The PET factory and cassava plantations in the neighbourhood.

4.1 Socio-economic conditions

The area where project is proposed is experiencing a surge of new settlement and a
corresponding population influx. Currently, the area population density approximates 400
people per kilo meter. The annual population growth rate is high averaging 4.6% and suggests a
substantial rate of immigration from other parts of the district. Much of the area activities are
dominated by trade in Mattuga and Kigogwa trading centres, brick laying, sand mining, stone
crushing, wielding, labor provision in factories, tomato gardens, banana and cassava plantations,
and residential households. Generally, the area is dominated by informal service and goods sector
so much so that there is no organized delivery of goods and services in the area and regulation of
trade and business is not very structured.The proposed site is connected to most of the national
grids including, road network, electricity, and telecommunication and water networks. The area
land tenure system is predominantly mailo and leasehold. The proposed project land is private
land with a title issued in the names of the proponent.

a) Road side stall b) Wielding shop

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c)Brick laying d)Tomato garden
Plate 6: The major social and economic activities in the area

4.1.1 Standard of living population

The current population increase has been a driver for positive development such as increase in
employment opportunities, housing stock, social services and infrastructure expansion, such
development is however occurring in a haphazard manner largely dominated by the urban
informality in most of the sectors.The area is characterised by growth of unplanned informal
housing, and challenges related to solid waste accumulation, wetland encroachment and
destruction, water pollution and land use/cover change with serious implication on the ecological
functions of the existing ecosystems and the associated sink capacity to absorb carbon and waste
water among others. As a result, the living environment of the area poor is deplorable with poor
sanitation, inadequate housing, poorly managed solid and human wastes, increased water
pollution and reduction in ecological services.

The area is faced with a growing number of unemployed but highly educated youth, sprawling
settlements in addition to congestion characterised by traffic jams and air pollution among
others. Livelihood dynamics is drastically changing as many households, are moving away from
reliance on labour supply to private business. More than 70 percent of the population lives in
houses made of brick and concrete.

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4.1.2 Basic services

Generally, the population has access to average basic services. There is however, overcrowding in
areas where more economic opportunities are believed to exist and service delivery is perceived
to be more consistent and of higher quality. Even areas with fewer people, there is adequate
social services. In many places, service delivery including health services and education has
expanded to keep pace with demand, and the quality is quite fair. Doctors are accessible and
infant and mother mortality has been reduced drastically. The provision of safe water and
sanitation has been addressed and most killer diseases such as malaria has been contained among
the possible causes of mortality and morbidity. The capacity of local government to perform
their functions is fair. Wakisogenerates an estimated 30,000 tonnes of waste per month, most of
which is composed of vegetable matter (73.8%). The per capita solid waste is 0.6 kg/ person/per
day with a high organic content and bulky density hence solid waste is among major concern.
The area is connected to the national utility grid (electricity, road networks telecommunication)
therefore impacts related to extending these services in the area will not arise.

Plate 7: Access to the proposed site through Bombo Road

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4.1.3 Social capital

Largely the area economy is agro-based dominated by a few major sectors with crop farming and
livestock production being the key major sectors. Coffee,and bananas are the main crops grown
all over the district however; there has been a steady increase in production of maize, and other
crops including cassava, groundnuts, beans, sweet potatoes and vegetables as trees such as paw
paw, jackfruit among others. Large scale livestock production is mainly in the cattle, sheep, goats
and pigs for various purposes. Cattle are kept mainly for milk, cash income from animal sales and
manure. The project area and the surroundings similar to most parts of have a diverse mixture of
ethnic groups. Finite exchange opportunities exist for various tradable commodities and this
social interaction and exchange of goods is enhanced by the improvement in livelihoods and
incomes of most households in the area.

Labour supply to gardens/farms and small scale businesses for cash is very common and is
practiced among the area poor which facilitates easy interaction between the labour dependent
households and businesses in the area. There are social structures and development committees
that bring community members together for development or social causes. These include area
development committees, youth and women groups. These groups perform several duties
ranging from law and order enforcement, conflict and dispute resolutions, and community
mobilisation and organization for development purposes. However majority of the population
dominated by women and youth are involved in retail shops, stall, and subsistence farming
around the project area.

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Plate 8: Immediate shops from the site

4.2 Physical environment

4.2.1 Soil and geological characterization

The site soils are hydromorphic and predominately red sandy, loamy soils, the area is well
drained. The area is raised with a gentle slopes which provides firm ground for laying the mill
foundation structures and provides the requisite soil strength of the building structures.The maize
and wheat milling plant is not expected to generate any insidious effluent from the various
activities along the process line and grey water from the factory cleaning operation and
sanitation facilities. However, where chemical fluids are likely to be applied (during machine
maintenance & repair), this therefore invokes a specific interest in the baseline concentration of
any chemical constituents related to the chemicals that will be used at the plant. Therefore
increased concentration of chemicals associated with the operations in the soil or water in the
area or the drainage system would indicate spillage of chemical.

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Plate 9: Showing soils at the proposed site

4.2.2 Area drainage and hydrology

Wakiso District is generally endowed with adequate surface and sub-surface water sources
comprising of numerous streams, rivers and wetlands both permanent and seasonal. Minor
valleys have distinct seasonal swamps and rivers, which contain water especially during the wet
season. The water table along these swamps is quite high. They are suitable for sinking shallow
wells. Sub surface water reserves occur in fissures and aquifers of the rocks. This is indicated by
the number of boreholes, spring wells, tube wells and shallow wells, which have been drilled to
harvest water for domestic supply.
Generally the entire project area just like most parts of district is well drained sitting on an
elevation of 3% slope with soils that have a high water holding capacity and a channel that is
close to the project site plot factors which enhances the kinetic flow of runoff and rains so much
that the area rarely experience flooding or water logging.

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Plate 10: The drainage channel close to the proposed site

4.2.3 Climatic conditions

Wakiso District experiences a tropical climate with a comparatively small seasonal variation in
temperature, humidity and wind throughout the year. It receives an annual well distributed
rainfall of 1200-1400 mm with peaks in March to May, and October to November. There is a
relatively dry season between December to March and another one in June to July.
Temperatures vary from a maximum daily temperature of 29o C in January and a minimum
daily temperature of 27o C in July. Relative humidity is low throughout the year averaging less
than 20% both in the morning and evening therefore playing no significant role in climatic
modifications in the district

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Figure 1: Wakiso District Climate and Temperature graphs
(Source: Climate-data.org)
The driest month is July, with 69 mm of rainfall. Most of the precipitation here falls in April, averaging
204 mm.The warmest month of the year is February, with an average temperature of 22.5 °C. July is the
coldest month, with temperatures averaging 20.8 °C.

Figure 2: Wakiso District Climate Table


(Source: Climate-data.org)

The difference in precipitation between the driest month and the wettest month is 135 mm. throughout the
year, temperatures vary by 1.7 °C. The climatic condition are favourable for establishment of grain
processing facility and the subsequent operation of such a facility with minimal interruption on the quality
of the final product.

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4.2.4 Noise baseline conditions

The measurements were taken using a digital sound level meter. Comparing measured noise
levels with regulatory limits, it is evident that maximum background noise on site prevalently
does not exceed the daytime regulatory limit of 70 dBA. The baseline noise level in the area
during day and night is 65 and 68 decibel respectively, its anticipated the vehicular and
equipment movement, and other human activities and construction equipment will generate
compounded noise level above the baseline and beyond the permissible noise limits. However,
save for occupational noise which the constructor and management have control over, the area is
surrounded by communities with poorly regulated noise emission. Of interest to the developer is
occupational noise and in addition, all efforts will be made to ensure that activities comply with
the applicable noise requirements, and the contractor will be instructed to use only efficient
equipment at the site besides putting in place measures to slow down the speed of vehicular
movement and raising the awareness of the workers to limit noise emission.

Table 2: Environment Baseline Noise Levels:


Point on site Minimum Level (dBA) Maximum level (dBA) Noise

SN1 59.00 68.80 Within limits


SN2 56.15 70.52 Within limits
SN3 53.72 67.60 Within limits
SN4 67.76 72.70 Within Limits

4.3 Biological environment

4.3.1 Area vegetation

Generally the area -where the project is proposed, is comprised of a mosaic patterned
biodiversity a characteristic of crescent vegetation. However, in some areas with natural
vegetation much of the species therein is not of rare type nor categorized as endangered species
of ecological and conservation value save for scenic impression which can be maintained through
well guided reforestation of the affected area once project is established.
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Plate 11: Natural vegetationwithin the proposed area

4.3.2 Fauna

There are basically no wild mammals or species of conservational value in the area save for the
domesticated animals. However, presence of animal species such edible rats were represent by
marks left or their niches and in other instances the specie themselves especially in vacant plot
colonised by hyperrenearufa species. The dominant bird species in the area are Scolopacidae and
stocks,weaver birds, crested eagle as well as African pied wagtail Papyrus Yellow Warbler
Chloropetagracilirostris, Papyrus GonolekLaniariusmufumbiri, Shoebill, Balaenicepsrex, African
Skimmer, Rhynchopsflavirostris, Pallid Harrier, Circus macrouros, Great Snipe, Gallinago media.
The site is therefore devoid of wildlife of significant conservation value save for those associated
with monocrops hence the planned development will not in any way affect animal welfare. No
large mammals or fauna were recorded in the area during the study. Therefore the
implementation of the project holds no significant threat on the area fauna.

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CHAPTER FIVE

5.0 Anticipated environmental/social impacts and proposed mitigation measures

Environment and social impacts associated with establishment and operation of a grain milling
facility are significant, and can be categorized into natural resource use impacts, climatic change,
occupational, environment capacity and functions of the in-situ ecosystem. These impacts take
on a social dimension and some reflect as environment and natural impacts. In this section detail
of each dimension is discussed and appropriate measure to contain the impacts proposed.

5.1 Socio-economic impacts

Socio-economic impacts are “the consequences to human populations of any public or private
actions that alter the ways in which people live, work, play, relate to one another, organize to
meet their needs, and generally cope as members of society. The term also includes cultural
impacts involving changes to the norms, values, and beliefs that guide and rationalize their
cognition of themselves and their society.” Social Impacts can be both positive and negative.

They affect the following areas: employment, income, production, way of life, culture,
community, political systems, environment, health and well-being, personal and property rights,
and fears and aspirations. In short, a social impact is a significant improvement or deterioration in
people’s well-being. Projects affect different groups differently. Some people tend to benefit
while others may lose. Historically, impacts are particularly severe for vulnerable groups, for
example, aliens’, women-headed households, elderly persons, landless persons, and the poor.

The establishment of grain (wheat and maize) flour milling facility in at the proposed site has a
number of impacts on the community. Positive impacts include;
▪ Increased employment for over 100 people in the area,
▪ Improved livelihoods, and improved healthcare for Employees,
▪ Employment of women and vulnerable groups and increased economic activity for local
businesses on the supply and distribution chain of wheat and maize flour and civil works
workers.

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However, the facility establishment and operation also triggers several impacts on society and
these are discussed in the section below;

5.1.1 Loss of income and livelihood by the project affected persons

The project site is located in a peri-urban set up where vacant pieces of land are used for farming.
The project site for some time has been vacant and regulated used by communities for farming
and grazing of cattle. Therefore establishment of a flour mill in the area will reduce and restrict
community grazing activities besides displacing the communities that for long have known this
area as a place where they can do small scale subsistence gardening. Hence establishment of a
grain milling facility will certainly displacing the farming communities from the piece of land. As
result, families fending from farming on this piece of and will be threatened with hunger and
food insecurity.

Impact evaluation
Occurrence of this impact is high since displacement will certainly occur to create room for facility
construction. The significant of the impacts is also high since it alters the livelihoods of the families
that depend this piece for some time. The impact severity is also high since it may trigger food
insecurity and the associated community insecurity concomitant with food insecure households.

Impacts mitigation
The land within the project site is private belonging to DEI industry International and has been
officially gazetted by Wakiso District for Industrial development. Therefore the Developer will
have to issue notice of vacation to the families that use this land a year prior to establishment.
This will provide ample time to these families to relocate their farming activities elsewhere, and
change to other sources of food.

Mitigation enhancement measures


The developer can retain some especially the very poor and site and provide them with cause
jobs for cash an offset for lost income from food grown on the piece of land.

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Therefore, with adoption of the above impacts and enhancement measures the impact severity
will be tremendously reduced to minimal or manageable levels.

5.1.2 Impacts on local business, profits and employment

Establishment of a grain milling facility has implications on the survival and functionality of the
local business community dealing in the same products especially those based majoring in
maizeflour, and those dealing in wheat supplied by other companies or imported. Local traders
importing these products (Baking flour) distributing them on the local market and hence earn a
living through trade in these products will be affected. The new establishment will also tilt the
trend and price these goods in the area which can potentially eliminate other players. If DEI
chooses to establishment its own trade patterns and dealers within the area.

Impacts evaluation
The possibility of this impact occurring is high considering the production capacity of the
proposed facility and the market availability of the proposed products. The significant of the
impacts is also high considering the possible loss of incomes from such threats and the scale of the
impact which is likely to affect many people within the area. The severity is high since loss in
trade means loss in income and the associated social upheavals.

Impacts mitigation
Given the current trend in business the developer will certainly labour to supply his goods in the
local market before venturing in areas beyond the local boundaries. This will address the supply
and trade dynamics of wheat and maize flour. The developer will also ensure the prices of the
goods are those on the market to ensure that the small scale producers are not edged out of
business. Beyond the boundaries of the project site, DEI milling processes are currently taking
place on their hired premises in Tirupati wares houses in Kyebando. The new facility is aimed at
decongesting the current facility and expands on production to meet their market needs. This
therefore necessitated opening up new areas of more space but close to the consumers.
Therefore, this is not a new operation in the area it’s just a swift of operation from one site to
another.

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5.1.3 Impact on employment and economic opportunities

DEI Industry International Limited will have a large positive impact for employment in Uganda
through direct suppliers to dealer and users and the forward and backward linkages of its supply
chain. The company will employ over 200 individuals from the community and this number will
grow to over 300 upon completion of project implementation. Women will hold an above
average proportion of these jobs, with expectations of over 200 female employees upon
expansion. A large majority of employees will be from vulnerable groups, namely communities
around the facility or District.

This investment will create more local jobs and improved conditions for local businesses. The
opening up of employment opportunities for unskilled persons by the project has a positive
economic impact capable of eroding potential for despondency and dejection within the
community. The employment and business opportunities due to the project exceed available
labour supplies within. The expected benefits go beyond immediate locality of the project area.
The operational plant will utilize water, electricity, fuel and telephone services proving income to
respective utility companies. In addition, the plant will contribute tax revenue to central and
local governments.

This impact is positive and would benefit local, national and regional (skilled and unskilled)
labour, local businesses in Wakiso and the national economy in general. The positive impacts can
further be enhanced through the following measures (i) the project should give preference to
local people wherever job requirements match the local skills (ii) women should be considered
for employment in equal measure as men wherever possible (iii) raw material should be sourced
locally (if available) (iv) the facility should adopt and implement a community responsive social
corporate responsibility programme (v) the project once in operation should undertake regular
evaluation of its operation in relationship with social acceptance and improve where deviation
are highlighted;

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5.1.4 Demographic impacts

The demographic impacts of the project refer to changes to the population numbers and
distribution. At full operation, the company will employ over 300 persons on full time basis.
Within a short period of 3 to 5 years, about 600 new employees are expected. The influx due to
project employment growth of the population could bring in businesses to the project area. This
is therefore positive impact to Wakiso District and residents of Gombe Sub County in particular.
Immigrants are often the most intelligent, hard-working and ambitious people of the
communities they originate. They will bring their talents and skills to the project area. This is
enriching to them and to the recipient community alike. They will add to the consumer base,
thus helping the growth of the local economy.

The increasing attraction of the project as a business destination can also be at a cost, rapid
population growth particularly in the communities at the fringes of the project can also be
negative. Among the most negative effects of overpopulation is lack of land and resources which
result in negative impact on the population. Waste management of such populations is also
difficult to handle effectively and can result in pollution and detriment to the environment. As
the population increases so is the need for improvement in social amenities. More investment in
safe drinking water supplies and sanitation is required. Failure could bring about poor waste
management, contaminated water supplies and high levels of disease, such as typhoid, dysentery
and cholera.

Impact Evaluations
The possibility of this impact occurring is high considering the weakness in enforcing regulations
by the various government bodies. The significant of the impact is low because of the land tenure
system and the current development project in the area where large industries are taking over
large chunks of land the area. The severity of the impact is minimal since each factory has a

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carrying capacity beyond which no assimilation is possible besides land in this area is highly value
hence no squatters and low end communities cannot afford settling here.

Mitigation measures for social impacts of demographic change


The developer will endeavour to strengthen existing institutions through dialogue with local
leadership to assist in the development of new frameworks for addressing long-term
development and regional planning that addresses changes; for handling an increased number of
disputes and social problems and gradually help to improve the capacity of the community
institutions to accommodate a much more diversified population.

5.1.5 Health impacts, HIV/AIDS and malaria

An indirect impact of rising population in the neighbourhood due to immigration is the spread of
HIV/AIDS. Vulnerability to HIV and AIDS stems from complex, interdependent causes that may
include the mobility of many employees, the time workers spend away from home, their access
to daily cash income in an overall context of poverty and vulnerability; their demographic profile
(they are often young and sexually active) and the readily availability of commercial sex in the
area particularly the trading centres.

Exposure to water-borne diseases and malaria, along with poor sanitation and limited access to
medical care, also combine to increase susceptibility to infection. These proximate risk factors are
all related to underlying poverty, insecurity and marginalization affecting both women and men
in poor communities. The proportion of people infected with HIV in a community, and the
impacts of AIDS related morbidity and mortality in that community, will depend on the extent to
which the above factors occur and on how they combine to increase vulnerability.

The operation of the project will result in increased economic activity in the area consequently
more people will be attracted to the area. This will expose the community to outsiders who may
lead to the spread of HIV/AIDS and other STI’s.

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HIV/AIDS mitigation
In order to reduce susceptibility to HIV/AIDS company will have to take the lead in adopting the
ILO Code Practice on HIV/AIDS and Work. DEI industry International recognizes the seriousness
of HIV/AIDS epidemic and its impact on the workplace. The company supports national efforts
to reduce the spread and infection and minimize the impact of the disease. Accordingly, the
company will:
▪ Formulate and implement HIV/AIDS workplace policy;
▪ Sustain sensitization of staff on the dangers of HIV/AIDs and STIs
▪ Support local programs by Ministry of Health regarding HIV/AIDs such as through: an
awareness campaign program for workers and community
▪ Provision of free counselling and testing and preventive measures such as free condoms
▪ Support development of a special comprehensive HIV prevention and care program for
workers.

The company will also, whenever practicable, assist through planning, provision of adequate
health services, drinking water and sanitary facilities to deal with the unexpected rise in the
incidence of disease and provide the necessary social, psychological and counselling services new
workers to enable them to cope with socio-economic changes.

5.1.6 Impacts on public infrastructure and services

The project is located in a relatively settled area. Much of the area developments are industrial
establishments of and increased road traffic from trucks hauling materials to and fro the site might
cause damage to public roads which is not engineered for high bearing loads. Raw material
haulage will also contribute to deterioration of air quality in the area arising out of the fumes
from the traffic in and out of the facility. This will lead to outfalls during rainy season or
accumulation of those gases into the area, hence a possible source of water and ground pollution.
Raw material haulage will also provide jobs and income to contractors involved. These are
cumulative impacts contributing to the already existing impacts by the many road users in the
area creating similar effects.

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Impact evaluation
The Likelihood of negative haulage impacts is low, duration long-term and their extent local or
national. Impact severity is thus considered medium. From the foregoing, significance of the
impact is assessed to be moderate.

Mitigation of impacts on public infrastructure


It is expected that less than five percent traffic on the access road will be logistical and
transportation works for the company, this is because the access road is less subjected to many
vehicular movements, only a few trucks and private cars use the road to access the existing
facilities. It is also important to note that some aspects of raw material and finished products
haulage are positive (jobs, revenue to contractors) while others such as road damage are
potentially negative. In either case, the effects are long-term lasting throughout operation life of
the plant.
Mitigation strategies
These include:
▪ the developers should install a road signpost underpinning the diversion from the main
road to the project/facility road for heavy vehicles and other traffic to and fro the site

▪ adopt a clear vehicle maintenance schedule to ensure proper functioning of all trucks and
vehicles belonging to the facility to eliminate noxious fumes and gaseous emission
associated with malfunction motor vehicles:

▪ Hire services of firms with a renowned record on environmental compliances.

5.1.7 Impact on the national economy

Consumption of maize and wheat flour in Uganda has been steadily increasing during the past 20
years as a result of growing population, changing food preferences and a strong urbanization
trend which has led to a growing food gap. The challenge and disincentive for further wheat
milling factories in Uganda is high tariffs imposed on factories, high costs of inputs/ raw materials
for , and for maize it largely poor processing facilities. This has triggered fluctuations in prices of
wheat and maize flour products. Developing the proposed project will necessitate procurement

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of equipment and installation of machinery and services, providing income to suppliers and
contractors. Considering that labour would be local or national but project equipment procured
internationally, this impact has local, national and international spatial extent and would benefit
local suppliers of cement, blocks/bricks, food vendors and other materials required in
construction and operation phases of the project.

These are positive and would benefit the entire country since its processing wheat and maize
grain into desirable nutritious flour ready for consumption and also a linkage to development
through supply of affordable materials for construction and creating a vast number of
employment opportunities. Increased local production of these products rather than importation
would keep jobs and revenue within the country, new sales outlets, and distribution taking
service and products to the formerly inaccessible rural areas would roll out faster, to the benefit
of national economy. It is also considered high quality wheat and maize flour produced locally
would be affordable to the majority of the population hence contribute towards improved
households standards of living.

5.2 Environmental and occupational impacts during facility establishment

Establishment of the facility involve site clearance, grading and levelling to generate the requisite
terrain for the civil works. The second phase (construction) will mainly constitute infrastructure
development which will encompass erection of building structures followed by the installation off
machinery and the process line. Once the facility equipment has been assembled, then
importation of wheat grains and buying of maize locally will be done. It’s expected that over
300 and 400 metric tonnes wheat and maize respectively will be processed per day. It is
anticipated that each phase will generate impacts on the environment as indicated below;

5.2.1 Impacts during facility establishment

This will involve land excavation, grading and levelling of the site to the requisite terrain essential
in the smooth operations of construction equipment and to the level required for building the
factory and its warehouses. Despite, the relevance of such activities, these activities are prune to
generating consequential impacts as outlined below;

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Considering the terrain of the area, it’s estimated that less than 100 m2 of excavated soils will be
generated from the excavated portion. These loose soils will be used to create a level in the
lower section of the site. This will ensure proper use of the excavated material but also prevent
excavated material being poured into sensitive ecosystems like wetlands. It is also estimated that
more than 500 m2 of loose soils will be generated as a result of foundation digging. Soil from this
activity will also be used for levelling and landscaping of the area. Such activities will also
generate noise emission from construction equipment besides water and soil contamination. The
site receives significant rainfall amount therefore the large volume of heaps of soil if not removed
in time before the rain will induce soil erosion incidences that will erode the entire area.

Warehouse structures, ablution facilities and parking yard will be constructed. The extent of
excavations to accommodate the building foundation will be 1.0 meters. This is based on the soil
structure of the area and guidance from the building unit of Wakiso District Authorities. The
foundation wall will be laid using stabilized murram, compacted hard-core, concrete and cement
followed by brick works as recommended by the civil and structural engineers and approved
plans for the structure that have been submitted to Wakiso District Authorities. Therefore soil
erosion is the likely impact from the construction phase of the facilities.

Impact evaluation and mitigation strategy


The construction phases will inevitably yield significant volumes of erosion from the excavation
and grading levels which if not factored in the construction plans of the facilities would trigger
serious social and environment consequences. This impact and some secondary effects on the
surrounding ecosystem (silting of natural water drains are long-term and this impact would likely
affect a wide community water sources. However, the likelihood of the impact occurring during
project development is medium. Duration of the impact will be short-term, occurring only
during the construction period. Impact extent would be local, limited to the immediate
neighbourhood of project site, thus impact severity will be low.

Mitigation strategies

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The significance of this impact is therefore low. However, the following will have to be done to
ensure such impacts do not arise;
▪ Developer has been advised to ensure that no heaps of soil are left at the site and that all
excavation and levelling are done in dry season where the kinetic energy of erosive forces
is very low.
▪ All loose soils will be taken off the site to an area to be identified by the developer in
accordance with National Environment (Waste Management) regulations, 1999.
▪ To contain the in-situ and ex-situ erosion from opened up ground trenches soil traps
should be located at well calculated interval along the gradient towards the natural water
flow to contain any fugitive runoff.

5.2.2 Solid waste generation during construction phase:

It is anticipated that these activities will generate a lot of construction waste ranging from wood,
timber, paper, scrap materials, rabbles, and debris in addition to domestic waste generated by the
workforce in the area.

Impacts evaluation and mitigation strategy:


During construction and installation of equipment, there might be incidental contamination due
to inappropriate construction waste disposal. This could result from stockpiles of earth in storm
water drains or inappropriate disposal of spent oil/grease containers and oily cotton waste. This
impact is negative but short-term and reversible. The likelihood of the impact is low if a
competent and responsible contractor is hired and construction operations regularly monitored
by the District Environment Officer. When this is done, impact severity would be low. The
significance of this impact is therefore negligible. However, the following will have to be done to
ensure such impacts do not arise;
• The contractors should provide waste bins and skips on site for proper construction waste
management and avoiding offsite impacts of improper waste management.
• The generated waste should be segregated on site into organic, reusable and recyclable
streams.

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• Land fillable waste should be land filled while beneficial applications should be found for
types that can be reused or recycled e.g. cardboard, plastic and metal scraps.

However, most of the waste generated at this level is recyclable material which can be re-used at
the site and sold to company’s dealing in recyclable materials. Emphasis here will be placed at
ensuring that all materials are sorted and segregated according to use and those that can be
reused at the site will be sold to licensed waste handlers as required by the law. However, in the
likely event of the communities desiring some materials, this will be systematically distributed to
them.

5.2.3 Waste-water generated during establishment phase of the project

It is highly likely that at this phase, waste water from mixing of building materials will be released
into the environment and spills over into the adjacent wetland system hence increasing alkalinity
of the surrounding the calcium carbonate in the cement materials. To avoid this impact, the
developer has been advised to use the services of construction firm that uses modern building
equipment such as concrete mixers.

5.2.4 Impacts on human health

It is at this stage that human footprint is high hence raising the possibility of health related
impacts arising out of having a high concentration of humans in one place. Such impacts include
contagious diseases and HIV in the area. This impact is negative and some effects such as death
are irreversible, and commonly the affected individual is the household’s main income earner.
Such impacts therefore affect more than just the affected persons to include their immediate and
extended families.

Impact evaluation and mitigation strategy


The likelihood of the impact is high if preventive steps are not taken to avoid disease outbreak.
Since the impact involves human life and disease would lead to irreversible effects, impact
severity is high. To avoid occurrence of such impacts, only services of the contractors with a
renowned record of undertaking medical test for their workers will be hired, and for HIV
awareness desk and counselling facilities will be created with the site. A mobile facility will also
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be instituted at the site to address all medical needs within the facility. No residential camp will
be encouraged at the site since no work will require residential attention.

5.2.5 Dust emission during establishment phase

Dust from the trucks felling material to and fro the site and those activities that generate dust such
as mixing of materials among others. Dust will hence settle in the nearby residences and possibly
cause serious allergic reaction to many receptors in addition to increasing the cost of house
cleaning and threatening the nearby sinks with high elevated phosphorus elevated waste water
from cleaning operation.

Impact evaluation and mitigation strategies


The likelihood of this impact occurring is high although localized in nature. The severity will be
low and expected to be significantly only during establishment phase of the project likely to last
for four month. The impact beyond the construction will only add to the existing compounded
effect from the area activities given the poor law enforcement and earthen road network in the
area. It is the intention of the developer to minimize as much as possible dust generation at the
site and on routes serving the facility. The developer will ensure that all trucks move at a slow
pace, and humps to control speed movement will be installed along the route to the site.
Secondly, sprinkling of the site and route to the site will be done on a daily basis in the morning
and evening during the construction.

5.2.6 Traffic flow impacts:

A number of heavy trucks/graders will be hauled to site prior to project commissioning. Hauling
equipment to the site could cause road damage, traffic obstruction in the area. Other effects
could include traffic noise, road dust and accidents.

Impact Evaluation and mitigation strategies


However, the cumulative impacts are low since the entire area is sparsely habited. This impact
however is negative and some secondary effects of road accidents (e.g. death, disability) are
irreversible and long-term and this impact would likely affect a small community. However, the

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likelihood of the impact occurring during project development is medium. Duration of the
impact will be short-term, occurring only during the construction period. Impact extent would be
local, limited to the immediate neighbourhood of project site, thus impact severity will be low.

5.2.7 Impact of site scenic alteration:

During construction, there will be a drastic change in the scenic impression of the site from a
vacant expanse overlooking a serene nature and intact grass land people are accustomed to, into
a busy construction site.

Impact Evaluation
This aesthetic impact would be negative but short-term. It is believed that upon completion of
site development, the area would be more aesthetic than the current state. Likelihood of “visual
shock” is high but would be of low severity since the proposed development conversion area is
small compared to vast expanse of greenery in the area. The developer will be encouraged to
undertake serious vegetation of all the free spaces within the premises and plant trees around the
facility in addition to using environmentally friendly construction designs and finishing.

5.2.8 Possibility of drainage impairment:

There is a possibility of temporary drainage impairment when soil stripped from site is dumped in
storm water drains in the area during construction. However, this impact is negative but short-
term and reversible. Although this impact would not directly affect any person, it could
deteriorate the natural drains and road infrastructure.

Impact evaluation and mitigation strategies

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The likelihood of the impact occurring during project development is medium if the developer
uses a competent contactor and works under guidance of the engineers. The significance of this
impact is therefore minor-moderate, and this will be maintained by avoiding disposition of soil in
anywhere during site development.

5.2.9 Occupational, health and safety risks during construction:

OHS risks can occur if construction workers do not have adequate protection gear and use
guidelines. Even when requisite guidelines are provided, OHS incidents can occur if crews have
low safety awareness.

Impact evaluation and mitigatory strategies


This impact is negative and some effects such as injuries and death are irreversible. Commonly the
injured person is the household’s main income earner. OHS accidents therefore affect more than
just the injured persons to include their immediate and extended families. The likelihood of the
impact is high if not provided or not used as necessary to avoid injuries. Key risk areas include
working with high voltage, hot works (welding), working at heights above 2 meters and working
on slippery surfaces. Since the impact involves human life and some accidents would lead to
irreversible effects, impact severity is high.

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5.3 Environment, occupational health and safety impacts during operation

The factory workers will face OHS risks if not protected. Possible risks include exposure to dust
inhalation from the various stages of the grain milling processing. The proposed facilities will be
characterized by use of fuels, generators, electricity and other combustive materials such as foam,
plastics, paper which bear some degree of flammability; this impact is ranked as high because it
can lead to loss of life and property if not handled with care. Injuries from electric shock and
ingestion particulate materials are other possible risks that workers are likely to face.

There could also be injuries from operation of the various automatic components of the process
line and bruises or back injuries from repeated lifting inventory. As noted above, the factory
workers will face OHS risks if not protected from exposure to noise from the various stages of
process line, physical injuries can result from machine use, dust inhalation can also damage
workers health so is fire explosion, these impacts can leave workers incapacity or cause death.
The factory workers will face OHS risks if not protected. Possible risks include: (i) Physical hazards
(ii) Exposure to noise (iii) Dust inhalation (iv) Explosion /fire.

5.3.1 Physical hazards

Most of the operation along the process line from cleaning to milling of refined baking flour to a
large extent involves use of machine equipment, such as compound selecting cleaner, gravity
destonermagnetic cleaner, seed treater, PG polishing machine, dehuller and thresher, elevator,
packing machine and grain elevator. Poor handling of these equipment can also result in serious
injuries and death of workers as a result of the following; improper releasing from carriers,
equipment failure, poor and unsafe storage, unsafe work practices, and poor stacking. In
addition, process machinery such as multi-opening presses and drive systems can present risk of
trapping.

Impact evaluation
The impact occurrence and severity is high since injuries from this type of machinery often lead to
loss of limbs, finger/hands resulting to death. These physical impacts are negative and some
effects such as injuries and death are irreversible. Commonly the injured person is the household’s
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ESIS – Establishment of DEI Maize and Wheat Processing Facility


main income earner. OHS accidents therefore affect more than just the injured persons to include
their immediate and extended families. The likelihood of the impact is high if not provided or
not used as necessary to avoid injuries.

Mitigation measures for physical hazards


All workers in places of operating certain machines should be trained in avoiding injury to their
bodies and in safe use of machinery equipment. This should be coupled with fitting of all
equipment with safety guards capable of preventing access to moving sharp blades. Specifically,
rollers should be fitted with safety guards which prevent the insertion of body parts in addition
to adequately containing all sharp edges to prevent the expulsion of sharp fragments in case of
breakage. Moving gears, chains, belts and rollers should be fully enclosed and breakage detection
equipment installed to alert management on this failure early enough. Transport routes within
facility premises should be clearly demarcated and vehicle movement should be closely
monitored. Administrative and education measures should be adopted at the facility including
▪ restricting of operating machines for un authorized personnel
▪ training of workers in safe working procedures and planning of escape routes
▪ provision of workers with protective steel capped boots, hardhats, high visibility jackets,
eye protection and gloves
▪ Direction of steam vents and pressure release valves away from areas where workers have
access.

5.3.2 Exposure to noise

The machinery responsible for most wheat milling plant operations emits levels of noise that are
damaging to hearing. In many cases even relatively short term exposure will lead to permanent
loss of hearing acuity. Workers operating at various points along the process line are the primary
impact receptors and need protection. Noise is expected from the following sources: (i) wheat
cleaning process line uses machines and maize hulling section like compound selecting
cleaner/gravity destonermagnetic cleaner(ii) Stacking of finished products (iii) in the packing
section among others (iv) Delivery trucks (iv) Generators used for backup in case of power
failure.

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Impact evaluation
The likelihood of this impact occurring is high considering the nature of the process and the
severity also high.
Mitigation measures against impacts due to noise exposure to workers
The Uganda laws require provision of hearing protection for workers exposed to 80 dBA for a
duration exceeding 8 hours, which is the normal day’s work shift. Fence line noise levels should
also comply with regulatory limits set in the National Environment (Noise Standards and
Control) Regulations, 2003. This regulation sets a limit of 70 dBA and 60 dBA for daytime and
night time respectively in an industrial area. Noise emitting sources should be sound insulated to
ensure that workplaces do not result in chronic exposure to excessive occupational noise. All
points along the process line where noise is expected, proper measures consisting of abatement
measures will have to be instituted. In the work environment layout design, international noise
reduction methodologies shall be employed, with hearing protection equipment also provided if
such measures fail to reduce noise levels below 85 dB(A). Lastly, ear protection for workers
around the mills and grinding areas and in utility plant rooms will be necessary and enforced at
all times.

5.3.3 Exposure to dust emission from plant operation

Dust produced from the processing line which includes any contaminants or additives within the
dust (eg. bacteria, endotoxin, fungal spores, insects and insect debris, pesticide residues). The
major possible sources of dust during processing include;

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Table 3: Emission Points – Flour Mill
S/N Description Air pollution control Air flow
system (m³/min)
1 Pneumatic fans and filters used to Cyclone and fabric filter 450
transport the milled flour from
the roller mills
2 As above Cyclone and fabric filter 170
3 Aspiration points on each roller Cyclone and fabric filter 150
mill, flour collection conveyors,
and filter flowcollection conveyor
4 Cleaning section for incoming Cyclone and fabric filter 400
wheat
Impact evaluation
The likely hood of this impact occurring is high and the severity is also high this is because flour
dusts can form explosive clouds and because explosions from such clouds have caused some of
the worst industrial accidents, Flour dust inhalation may cause irritation, asthma, allergic reaction,
and nasopharyngeal cancer amongst wheat flour processing workers. The dust produced has
health effects leading to specific occupational diseases, these conditions may lead to permanent
incapacity or death. However, the impact is more likely to be localised since it will impact on
workers within the facility.

Mitigation measures against dust emission


To prevent the factory becoming the next reported or unreported subject of dust explosion, it is
desirable to conduct audit of a grain handling installation which begins with a hazard
identification exercise based on experience of the assessor, A systematic approach to identifying
dust explosion hazards and taking measures to ensure safety involves:
(i) Determining the dust cloud’s ignition sensitivity and explosion severity characteristics
based on published information/ data or through appropriate laboratory tests on
representative dust samples
(ii) Identifying areas of the facility where combustible dust cloud atmospheres could exist
under normal and/or abnormal conditions.
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(iii) Identifying potential ignition sources that could exist under normal and/or abnormal
conditions.
(iv) Preventing the formation of exposable dust clouds in the plant and reducing the
extent and duration of any clouds that may be formed.
(v) Taking measures to eliminate/ control ignition sources.
(vi) Taking measures to protect against consequences of dust explosions.

Dust exposure should be prevented and controlled through the adoption and maintenance of
effective extraction and filtration systems, this can be supplemented by the use of Personal
Protective Equipment (PPE) such as the use of masks and respirators, at all times.

5.3.4 Generation of solid wastes at the factory premises

Generally, grain milling facilities and warehousing operation is associated with generation of solid
wastes. However, it is important to note that most of the primary residual wastes generated in
such facilities are non-hazardous and mainly domestic/municipal waste from the factory and
warehouses maintenance operations. The proposed facilities are mainly for production at the
main facility, storage and packing of refined baking flour will be in the warehouses. No stocking
will be encouraged; this will prevent inventory mismanagement that can lead to storing of
expired material that will have to be managed as waste. Inventory management will be based on
the currently supplies and demand premised on time supplies and delivery to guide management
on stocks to be maintained at the facility.

Impact evaluation
This impact is negative but short-term and reversible. The likelihood of the impact is low if
proper administrative, education and technical procedures for management of solid waste
generated are instituted throughout at the facilities. This should involve putting in place waste
disposal infrastructure in and around the factory premises and ensure their utilization by the
workers in addition to regularly monitoring all facilities to ensure proper waste disposal. When
this is done, impact severity would be low.

Mitigation measures against generated solid waste


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The following will have to be done to ensure such impacts do not arise; (i)the developer should
provide adequate waste bins and skips at the factory premises for proper waste management
and avoiding off-site impacts of improper waste management (ii) waste should be segregated on
site into organic, reusable and recyclable streams (iii) land fillable waste should be land filled
while beneficial applications should be found for types that can be reused or recycled e.g.
cardboard, plastic and metal scraps (iv) disposal of all waste should at all times comply with the
requirements of waste management regulations. However, most of the waste generated at this
level is recyclable and can be used for other subprime uses, therefore material which can be re-
used at the site, will be sold to licensed company’s dealing in recyclable materials. Emphasis here
will be placed at ensuring that all materials are sorted and segregated according to use and those
that can be reused will be sold to licensed waste handlers as required by the law.

5.3.5 Sewage and Sullage (Wash Water)

Sewage and sullage will be generated from toilets, ablution facilities and kitchen at the factory.
This discharge is not expected to impose any threat to the environment since all the sewerage
will be disposed of in an on-site septic tank which will be regularly emptied. This impact if
allowed to occur will be significant and would cause serious effect on the environment
specifically water. Therefore, the developer is encouraged to ensure proper management
throughout the sewerage system. Considering the number of people at the factory premises the
impact of waste water is minimal.

5.3.6 Solid waste from the operational activities at the facility

Generally, grain milling is not associated with generation of large volumes of waste. The primary
residual wastes generated from the facility are non-hazardous. These mainly include packaging
wastes. There will be no wastes associated with the storage and production of wheat flour,
however emissions of flour dust during processing are likely to be observed. Other wastes
generated can be put to other uses and be sold out to fuel furnaces or fertilizer land. However,
this should be collected and turned into low grade products. General municipal waste from
offices and eating areas is also expected to be generated besides used empty chemical containers

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or other containers that may get tainted with waste from plant cleaning and maintenance
operations.

Secondary, solid waste in the processing line includes wrappings (e.g. boxes, sucks), and ash from
combustion of paper waste. Combustion of waste wrappings gives rise to large volumes of ash.
This ash, if not properly stored immediately after removal from incinerators and furnaces, can be
a serious fire hazard since it is light and the embers can easily be blown by the wind. General
municipal waste from offices and eating areas is also expected to be generated besides used
empty chemical containers or other containers that may get tainted with waste from plant
cleaning and maintenance operations. Residues in the form of waste wrappings (sucks and boxes)
can be recycled, sold and others can be burnt.
Table 4: Showing the type of waste along the product process
PRODUCTION PROCESS WASTE PRODUCTS
1. GrainPreparation Bacteria, endotoxin, fungal spores, insects and
(a) Cleaning of the grain insect debris, pesticide residues, stones, dust/dirt,
and metals
2. Tempering/ Conditioning Impure water
(a) Wheat is soaked in water to make
it easier to remove the outer bran
layer
3. Grinding of grain Flour dust
(a) Grain is blended together to obtain
a batch of wheat with the characteristics
necessary to make the type of flour
processed.
4. Milling of grain Flour dust emissions/clouds
(a) A gentle process of extracting as
much as possible of the endosperm Containers of additives such as (calcium, niacin,
(starch) from the inside of the grain. thiamine, folic acid, iron and B vitamins) are
added at this stage
5. Blending Heat
(a) Different components are blended
back together to form different flour
6. Packing of refined white flour Wrapping of; boxes, sucks, papers
(a)Packing section will send the final
product for checking of quality
parameters and packed accordingly

Impacts evaluation and mitigation strategy


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This impact is negative but short-term and reversible. The likelihood of the impact is low if
proper administrative, education and technical procedures for management of solid waste
generated are instituted throughout the project operation and the supply chain. This should
involve training of staff in efficient production techniques and putting in place a monitoring
system to ensure that waste generation is minimized and material resource optimization is
encouraged. When this is done, impact severity would be low. The significance of this impact is
therefore negligible. However, the following will have to be done to ensure such impacts do not
arise

• Ash generated in the process should be stored in a contained wind resistant area until it
has fully cooled. Ash may be returned to some other site for inclusion in the soil as a
fertilizer and soil improver
• Hire highly technical personnel such as machine operators to ensure all machines and each
component functional well all the time
• Convert all the waste wrapping into other useful materials
• Provide waste bins and skips on site for proper waste management and avoiding offsite
impacts of improper waste management
• Waste should be segregated on site into organic, reusable and recyclable
• Land fillable waste should be land filled while beneficial applications should be found for
types that can be reused or recycled e.g. plastic and metal scraps

However, most of the waste generated at this level is recyclable and can be used for other
subprime uses, therefore material which can be re-used at the site, will be sold to licensed
company’s dealing in recyclable materials. Emphasis here will be placed at ensuring that all
materials are sorted and segregated according to use and those that can be reused at the site will
be sold to licensed waste handlers as required by the law. However, in the likely event of the
communities desiring some materials, this will be systematically distributed to them.

5.3.7 Contaminated storm water/runoff

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Generally by nature various types of waste water will be generated at the facility, among them is
storm water and runoff, and this expected to be the greatest source of liquid waste on site. The
facility by operation will not induce accumulation of pollutants in the air that tend to create
outfall during rainy season hence generating polluted storm that drains in the runoff. The runoff
may be contaminated with particles and any other dust generated along the process line from
spillages and leakages due to poor handling of these substances or regular malfunctioning of
critical parts along the process line. Secondly, in case of use of additives in powder form have a
tendency to disperse in the air during handling which then became a significant pollution source
in the air.
Mitigation strategies
• put in place administrative, educational and technical counter measures to ensure if
chemicals are used at the factory, there should be no spill or leaks on the floor and
drains;
• ensure an effective equipment maintenance and repair throughout the lifecycle of the
industry;
• put in place an effective overfill and spill prevention plans and procedures
• put in place an effective monitoring and inspection regime that can easily detect spills
early enough before its discharged into the environment

5.3.8 Impact from increased traffic in the area

A number of heavy trucks and vehicles hauling materials and personnel to the site will be
accessing the site prior to project commissioning and during operation. Hauling equipment to
the site could cause road damage, traffic obstruction along Industrial Estate road serving the site.
Other effects could include traffic noise, road dust and accidents. Increased traffic poses risk of
public accidents, this impact however is negative and some secondary effects of road accidents
(e.g. death, disability) are irreversible and long-term and this impact would likely affect a small
community.

Impact evaluation

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Likelihood of cumulative increment in traffic volume is high and probably inevitable in such a
location. Duration of the impact will be long-term but would be local and limited to the
immediate neighbourhood of project site, thus impact severity will be low. This is also true
because the entire area is sparsely habituated. From the foregoing, significance of the impact is
assessed to be negligible and minor.

Mitigation strategies
The developer should work with the district management to ensure safe traffic flow on access
road leading to the site and the developer should undertake a traffic flow analysis to determine
the traffic density in the area so as to inform the Authority regarding facility accessibility.

5.3.9 Fire and explosion hazards:

Milling operation are characterized handling of large volume of highly combustive and dry cereal
and the associated chaff. In addition, materials used in packaging of refined baking flour are
highly combustive. These therefore portend a serious fire hazard. In addition, the volumes
involved are so much that once a fire erupts at the factory ex-situ extent are expected. This will
release vast quantities of carbon monoxide and carbon dioxide in addition to NOx and SOx.
Factory operation will be involved in handling and storage of highly flammable products and
substances such as fuels and wrappings.

Impact evaluation and mitigation measures


This impact is major because it can lead to loss of life and property if not handled with care.
Cognisant of the fire risk potential, sector best practices adopted by most industrial players have
to a large extent minimized fire outbreak in milling operations. Mitigation of site fires and
emergency response will include;

▪ Procuring and install adequate firefighting equipment and ensure they are routinely
serviced to ensure their efficiency and functionality at all times

▪ Minimizing explosion risk by application of the measures for prevention and control of
dust accumulation as described in this report

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▪ Undertaking regular housekeeping to ensure that dust is removed from the facility,
including a biannual vacuuming of the entire facility if possible

▪ Installing and regular maintenance of spark detection and deluge dousing systems in dryer
systems and dust control equipment

▪ Developing a fire prevention and institute mechanism that will be exposed to all workers

▪ Regularly train all the workers in fire prevention and containment procedures and install
fire extinguishers in strategic locations at the facility

▪ Ensuring all fire hazards are mapped out in the factory and all workers are informed of
potential fire hazards in the factory

▪ Putting in place large capacity water storages tanks and fill them with water all the time
for use in fire containment in case of a fire outbreak.

In addition the facility management should;


▪ Map out fire safety and assemble points within the factory
▪ Regularly review the fire containment procedures at the facility to determine its efficacy
and reliability

▪ Place signs at the plant such as those displaying hazard warnings and deterring visitors
from smoking and use of electronic gadgets that could trigger explosions.

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5.4 Operation impacts on natural resources

5.4.1 Impact on water requirement

Water will be required at the facility especially for wheat milling for cooling of grinding
machines, wetting wheat prior to graining, in tempering/ conditioning stage in the process line,
for drinking and sanitation. The total water requirement at the plant is 8m³/day. A system of
water collection, cooling and reuse which will be installed for the constant reuse of water so as to
minimize waste water rejections. Possibility to extend water at the site with the installation of
taps will also be looked at so as to use the water drawn from the taps in the production process.
Also a system of rainwater collection will be installed so as to supply the plant’s requirement.
In view of this requirement, water at the plant will be sustainably used evidently by applying
constant water recycling procedures, this will be accompanied by water harvesting in tanks at the
site so as to reduce money spent on water bills.

Measures to ensure sustainable water use


The Developer is encouraged to adopt a number of procedures to ensure sustainable
management and use of water at the plant. The measures proposed include;
1. Educating all staff on efficient water usage and set up a water conservation program within
the facility which will include
▪ Building understanding among employees and co-workers about the importance of
water conservation.
▪ Enlightening staff on water scarcity issues and the impact of water conservation
practices,
▪ Empowering staff to identify problems and innovate solutions to reduce water use
within the factory.
▪ Engage staff s in problem-solving to reduce water usage

2. Assessing current water use: It will very important to appoint a person in charge of
coordinating the water reduction process. Use the information gathered through the assessment
process to develop water reduction goals and;

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▪ Read your water and sewer bills to determine how much water is currently used
and to identify peaks,

▪ Apply sub metering to determine use by location or equipment,

▪ Calculate average water use by department or process. Rank processes/departments


by water use to determine where to focus conservation goals,

▪ Survey plant operations to determine areas where water is wasted or could be


reused, (e) check piping regularly and identify leaks.

3. Inspection programme for piping and hoses; If the average water use (base level) is measured
for all operational activities separately, the identification of leaks is simple: wherever water
consumption rises above the base level, the presence of some form of water loss (e.g. a leak) is
likely.
▪ To locate leaks use sub meters to look for a trend of increased usage that cannot be
associated with increased production activities.

▪ Conduct regular inspection of equipment or areas where leaks could occur, like
pipe-work joints, connections and fittings. Indications include dampness, rust marks
or swelling boards. Significant leaks can often be detected by listening in the absence
of other noises.

▪ Check equipment in addition to pipes and hoses.

4. Minimise water use for cleaning; Water use for cleaning can be further reduced if water from
internal processes is used for cleaning. Depending on the water quality required for cleaning, this
might require grey water treatment. Indoors

▪ Use brooms, squeegees and dry vacuum cleaners to clean surfaces before washing
with water.
▪ Use washing equipment that has aerated spray nozzles with shut-off valves.
▪ Fit hoses with high-pressure, low-volume nozzles with shut-off valves.
▪ Where possible, mop floors instead of hosing.

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▪ Switch from wet carpet cleaning methods (e.g. steam cleaning) to dry power
methods or spot cleaning.

Other procedures to be adopted are outlined below;

▪ Modify Equipment; a small modification in existing equipment can result in


substantial water savings.
▪ Use of water saving equipment
▪ Reuse process water
▪ Finding water saving equipment
▪ Changing user behavior

5.4.2 Impacts due high energy consumption

All operating machines are energy intensive, using mechanical power for cleaning, grinding and
milling, and with a high heat demand. Therefore the whole grain milling process line uses
excessive energy in terms of electricity from the mains and the backup generator. This excessive
energy use is not sustainable and must be avoided.
Mitigation measures against high energy use
The developer has been advised to minimize electricity use at source by adjusting fan output
through variable speed inverter drives rather than damper control when air flow rates need to be
adjusted (e.g. in rollers, particle transfer and combustion air fans); and the company has been
advised to minimize energy used by opting to purchase power saving machines that will be used
during the production process. Lastly, factory power can be source for the sunrays by installation
of solar panels at the plant for mainly backup in-case of power (electricity) blackouts because the
sun's energy is free, maximizing use of passive solar techniques before adding active technologies
can significantly reduce your energy bills.

5.4.3 Natural Disasters

The warehouses/facility buildings are subject to being struck by lightning or be affected by


earthquakes. To avoid this, the warehouses should be equipped with modern lightening
conductors to handle any would be lightning strikes. The buildings’ foundation should also be
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strong enough to withstand magnificent earthquakes and will be constructed putting into
consideration the slope stability analysis.

5.4.4 Collapse of the warehouses/facility

Use of substandard materials is likely to cause collapsing of the buildings. When such takes place,
it is likely to lead to an extensive damage both to property and human life.

Impact evaluation
The Likelihood of this impact occurring is low considering that the developer intends to use high
quality building material from UNBS certified dealers. The developer will also hire qualified and
building engineers from registered engineering firms in the country.

Mitigation
Use of standard and ISO certified quality materials would be ensured. The services of credible
building contractors will be hired in addition to periodic testing of the concrete mixture through
certified and qualified consultants and inspectors.

5.5 Decommissioning of the facility

Within 12 months before facility closure, the operator should develop a decommissioning plan,
detailing the following:

▪ Requirements and procedures to restore the site to a useful condition;

▪ Site investigation to determine contaminated areas and extent of contamination

▪ Description of options for remediation of contaminated areas on site, post-decommissioning


land use, information on how possible socio-environmental impacts will be minimized
during decommissioning and measures to protect the public against risk or danger resulting
from site conditions prevailing after decommissioning:

▪ Plan on how decommissioning will be funded.

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The operator should submit the decommissioning plan to NEMA for approval. Decommissioning
should also have a restoration plan to adequately remediate any onsite contamination and
restore site to the maximum extent consistent with anticipated post-decommissioning use.

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CHAPTER SIX

6.0 DISCUSSION OF ALTERNATIVES

The alternatives to grain milling from the proposed site is (i) importation of already made
products and direct distribution to the customers in the country and (ii) local production from
the proposed site (iii) construction of the facility away from the proposed site to another location
(iv) Technology and design alternatives and (v)the No project scenario.

6.1 Alternative 1: Local production from proposed project

At the moment given the already existing business and supplies and distribution network, the
demand and production of both and maize flour locallyis the most suitable alternative.
Developer has 2.8hectares of land in the proposed area which is not encumbered nor settled in
by communities save un permitted small scale farming. Secondly, company already has a milling
plant under operation in Kampala. Therefore the developer is considered to have wide
knowledge and will be able to use environmentally friendly processing techniques during
production due its wide experience in the manufacturing and processing sector.

The main source of raw material supply to the proposed project for wheat will be importation of
from major wheat growing countries via Mombasa straight to the milling facility, and for maize
will be locally sourced from local supplies. The proposed facility is also in character with
surrounding setup in the area hence will not significantly trigger environment and social concerns
that are out of range. Any environmental and social upset will just contribute to the
compounded effect of such concerns that already existing in the area. Other sites outside the
proposed area will imply introduction of a new supply chain and logistical route in addition to
introducing several environment and social concerns. Other sites could be fine but with limitation
on opening up fresh environment and social issues in such area whose mitigation might be costly.
It is therefore recommended to establish the proposed facility in this place.

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6.2 Alternative 2: Establishment of grain milling plant on an alternative site.

The other alternative would be establishment of the facility in any location outside the proposed
site. If this option is adopted, then new land will be acquired in and around Uganda. This besides
being a costly venture for the company would require aligning the proposed development in
terms of environment social and planning provisions, and yet the proposed option would only
require aligning proposed development to the already existing plans. Besides being costly, new
areas come with adverse environmental consequences and costs for operations and
decommissioning.

Seeking for another site could be justified if the proposed graining milling facility and storage
warehouses were out of character with the surrounding, and if the environment and social cost
far out-weight the benefit. At the proposed site, still the predicted impacts from the proposed
facility are manageable and can be avoided altogether. The planned development will be modest
and most of the impacts will be managed within the facility.

6.3 Alternative 3: Plant design and raw material alternatives

The proposed milling plant will use wheat and maize for production of refined flour, however
with recycling and environmental issues becoming the norm, waste paper, boxes and sucks are
being used. The plant can look into the possibility of recycling the above mentioned waste
products to minimise accumulation of wastes at the plant and if these waste products exist in
plenty, they can be sold to recycling industries as required by the law. The facility would invest in
industrial processing technology such as use of panel processing machinery that has minimal
impacts on the environment. Adoption of such technology can lead to more output and high
profitability with the aim of satisfying the producers, consumers and the environment in one way
or the other. The other alternative sources of raw material are in existence in the area. They are
heavenly competed for as source of energy in facilities with boilers fuelled by diesel. Secondly all
of them are located within the proximity of the proposed site without any transports cost
automatically making this a good alternative.

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6.4 Alternative 4: Maintaining the status quo:

Wheat grain is mainly imported into Uganda from outside countries. The tremendous demand of
wheat flour has resulted in the development of significant wheat milling sectors and supplies of
refined baking flour in Uganda by the eight major companies linked to wheat milling in Uganda.
Most producers from Uganda use imported wheat grain for processing refined baking flour to be
sold at the markets and some also export this baking flour in the nearby countries like South
Sudan. This option besides the transportation cost, routine movement of such bulk wheat for
long hours on the road is associated with several environmental issues ranging from vehicular
emissions, oil spills, motor accidents, which triggers environment pollution and social disruptions.
This option from a social, economic and environment point of view is not tenable. Secondly,
maintain the current maize processing chain with many scattered and unregulated facilities,
increase the environment and social footprint and cannot be regulated and mobilized to improve
quality through adoption of appropriate technologies.

6.5 The no project scenario

A positive aspect of not developing the project as planned is avoiding health and ecological risks
associated with the operation of the facility or leave the land barely vacant and undeveloped
which is not economically viable and offering no significant and meaningful opportunity for
growth. The downside of “No project scenario” is foregoing operation and all the associated
positive impacts.

In terms of social cost benefit analysis, the no project scenario still does not represent any social
interest at all, since there are no squatters or community that are meaningfully deriving survival
from the proposed piece of land.
Inference: Therefore “No project scenario” does not offer comparative benefit to society and
environment hence should be rejected out rightly.

6.6 Comparison of alternatives

Under the proposed project alternative, the project would increase production of relatively
affordable unproductive areas, trigger job creation in the forward and backward linkages, in

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addition to stimulating social and economic development of the area, at the same time
conserving the environment and its resources. A cost benefit analysis indicate a ratio far above
one implying the project benefit outstrip the environment cost of the project. And given the
evaluation of the impacts above, most of the probable impacts are within managed range that
low and severity minor.

6.7 Recommendations

The proposed milling plant offers the best option for the Developer in addition to the option
being affordable, it offers no serious threat to environment and any environment and social
concerns triggered by this option are within the manageable range. In addition, the proposed site
is compatible with surrounding environment. Other alternative option to this site is not superior
to those selected by developer with respect to social, environment and economic considerations.

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CHAPTER SEVEN

7.0 Public consultation and land-use options at the project site

Consultation of the public focusing on key informants was undertaken during the assessment. The
aim of the consultation was to introduce the project to the public, identify the likely
environmental and social concerns and views of the stakeholders and to sift out appropriate
\mitigations measures to address the identified impacts and ensure that public concerns are
incorporated into the final implementation plan of the project as required by the law. The
consultation also served to address any fear likely to face the public regarding the construction
and operation of the proposed project. Below are some of the views expressed by the consulted
people about the proposed project.

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Table 5: Summary of stakeholder’s comments about the project

NAME/Contact Designation COMMENT


Nkonge Douglas ▪ The company should have approval of building plans/workplace registration, developer
Principal Safety Inspector should be advised on this legal requirement for construction sites and other operational
0704301651 workplaces/factories.
▪ There should be welfare provision i.e. adequate number of toilets, changing rooms, wash
rooms, dining area and safe drinking water and there should be separate according to gender.
▪ Medical Provision should be provided i.e. first aid facilities and trained first aiders or systems
for referral to nearby clinic/hospital in case the condition can't be handled with a first aid.
▪ Emergency preparedness i.e. awareness of workers on what to do in case of any emergency
(display of emergency contacts).
▪ Ensure fire, and electronic safety by placing fire fighting mechanism (alarms), through proper
wiring.
▪ Ensure general workplace safety through proper housekeeping, waste management, material
handling and environmental protection among other guidelines.
▪ Proprietor should ensure that there is proper signage within the work place including traffic
signage so that there is proper management of traffic at the facility.
▪ Developer should make sure the OSH and health system equipment are put in place.
▪ The developer should make sure that machines to be used during construction are inspected
so that they don’t cause any accidents.
▪ Appropriate PPEs should be provided to the staffs and visitors e.g. gloves, safety boots etc.
▪ They should make sure all records are kept well i.e. records of accidents at the facility.
▪ There should be no child labour
▪ The developer should ensure that the facility is friendly accessed by people with disabilities
▪ The developer should make sure that workers are trained on proper usage of PPE’s.
▪ The workers should undergo per-medical employment checkups before being employed and

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NAME/Contact Designation COMMENT
also regular medical examinations should be undertaken.
▪ Del should consider gender sensitivity when giving out jobs i.e. ladies should also be
employed.
▪ The developer should also consider the employment Act that is the working schedule for the
workers like how many hours, shifts and what will be done in case of any compensation.
▪ If Del is going to employ over 20 workers, they should appoint a safety committee that
oversees health and safety issues at the facility and this should be done by workers not
managers.
▪ Proponent is required to have HIV Policy at the site in order to raise awareness of HIV to
workers.

Mpoza Esau ▪ The developer should seek approval of construction plans from Nansana Municipality
Senior Environment Officer physical planning unit before commencing with the construction.
Wakiso District ▪ The developer should employ appropriate mitigation measures to curb noise pollution from
0782 688709 neighbouring communities.
▪ The developer should work hand in hand with neighbouring communities throughout the
project implementation.
▪ The company should ensure proper sanitation and general hygiene in and around the project
site.
▪ The company should take note of the employees’ safety and health by purchasing all the
necessary personal protective gears and emphasizing their usage by all workers on duty
throughout the project activities.
▪ The developer should ensure that proper soil and water management practices are adhered to
in order to do away with soil erosion and flooding scenarios at and neighbouring the site

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NAME/Contact Designation COMMENT
Banaddawa Fred ▪ The developer should give the first priority to locals of the area when sourcing employees
Chairman LC1-Kigogwa ▪ The developer should ensure proper solid waste management and disposal
Village ▪ We welcome the project as it will create a number of employment opportunities for the
locals of the area.
▪ The project activities are likely to cause air pollution in the area.
▪ The project activities are also contribute to noise pollution around the area
▪ The project will promote economic activity in the area through backward and forward
linkages thus National economic development
▪ The project if established will make a remarkable contribution to government revenue in
form of Taxes
▪ The development of the project will promote agriculture modernisation in the area
▪ The establishment of the project will enhance the development of the area.
▪ The project development will ease food access to the locals of the area.
▪ The developer should ensure proper treatment of the hired workers

Lwanga Charles ▪ Before any construction, the developer should have approved plans for planned structures at
Physical Planner Nansana the site
Municipality ▪ All structures should be located outside the road reserve.
▪ NEMA approval should be acquired before submitting plans to the municipality for approval.

Sammanya Moses ▪ The developer should adopt affirmative employment policy in favour of the local residents in
0753 182595 the project area.
Builder
▪ The developer should participate in corporate social responsibility in order for the
communities to realise benefits of the project establishment

▪ The project establishment will ensure maximum utilisation of land that has been for long been
dormant and under utilised
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NAME/Contact Designation COMMENT
▪ The project will promote economic activity in the area through backward and forward
linkages thus area economic development
▪ The milling plant project will create a good number of employment opportunities for the
local population neighbouring the site.
Isabirye Steven ▪ The project is welcome in the area as it will provide employment opportunities to the people
0774 122212 both semi and skilled labour.
Resident ▪ Project establishment in the proposed area will enhance easy access to good and services
▪ Project development will boost the development in the area.

KalenziAggrey ▪ The project will enhance the area agricultural productivity since its raw materials are
0753818356 agricultural products
Resident ▪ The establishment of the project will create market for the agricultural produce in the area
▪ The developer should adopt all possible pollution prevention measures.
Mukber Robert ▪ The project will be a huge contribution to our area since it will create employment
0783 967090 opportunities for the communities around it
Neighbour ▪ The developer should ensure that the project activities do not negatively affect the health and
wellbeing of the neighbouring communities through air and noise pollution.
Mummaza Racheal ▪ The project is good since it is going to occupy land that has not been under production for
0755 458816 quite some time
Resident ▪ The developer should give the first priority to residents of the area when employing workers
for the project
KabuyeMahad ▪ The project establishment will distort the area scenic value and drastic change the scenic
0774 944311 impression of the sites
Neighbour ▪ The developer should engage directly in corporate social responsibility to benefit the area
locals

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NAME/Contact Designation COMMENT
KalembeMiria Jackie ▪ I personally welcome the project in our area because it will lead to development of our
0788 245272 village as more developments will come up to support the proposed project
Neighbour ▪ The project will as well create employment opportunities for the youth in the area

NamugaboLyindah ▪ As a result of employing different people from different walks of life, the community will be
Vendor exposed to dangers of STDs, defilements, school dropouts, early marriages and domestic
violence among others.
▪ Project establishment will increase the market base and demand for our merchandise
▪ Our children and area residents will easily access employment opportunities.

NalongoKakinda ▪ I think the proposed project will be of great importance to us especially economically and the
0782 102074 social wellbeing of communities neighbouring it provided the environment and social impacts
Vendor are kept at check.
▪ The developer should take all necessary measures to curb pollution of the environment.
Juuko Alice ▪ The project development will ease food access to the locals of the area.
0784 087631
Vendor ▪ The project will as well create employment opportunities for the youth in the area

WaswaGoloba ▪ The developers normally come with their own employees and thus the community will not
0757 669892 be able to benefit from the project
Resident
▪ The project establishment will enhance accessibility to social services like trade,
accommodation, health centres and goods as there will be demand for these services.
Seninde Moses ▪ The land has been vacant so establishing the proposed project would be putting land into
Resident production
▪ The project is welcome in the area as it will provide employment opportunities to the people
both semi and skilled labour.

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NAME/Contact Designation COMMENT
Matovu Rose ▪ The developer should engage in community outreach activities like provision of social services
Shopkeeper including hospitals, schools among others.
0776 115381 ▪ The project will create employment opportunities for area residents thus boost their standards
of living.
Kalule Kenneth ▪ Clearing the land to remove overburden vegetation will result into soil erosion that will lead
0701 826886 to environment degradation.
Welding workshop ▪ The project will promote economic activity in the area through backward and forward
linkages thus National economic development

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7.1 Stakeholder/public consultation approach/methodology

The proposed development will be erected in an area slowing turning into commercial with
industries coming up. Therefore, the focus of the consultation was laid on the neighbouring
industries, local leaders with relevant mandate regulating the area and the surroundings. Issues of
community resettlement not pivotal in the consultation process, this being private land and the
particular land has been approved for industrial development by the District.

Capturing the stakeholder’s opinion and perception on the environment aspect of a facility
largely encompassed variables such as acceptability, expectation of the public associated with the
establishment and operation of the facility in the area. Using a research tool based on a five
point scale anchored on; (1) strongly agree and (2) strongly disagree on social acceptability of the
facility in the area and possibility of archaeological and culture relevancy of the project site were
used to measure the projects suitability at the project site and the area at large. The results from
the consultation were compared with available information in extant literature on the state of
the different environment subsystems in Uganda to obtain the reliability of the information.

Each measure of social acceptability was assessed by a three-item statement giving twelve
statements together. The stakeholders were asked to express their agreements or disagreements
using the likert scale: Strongly disagree = 1, disagree = 2, neither agree nor disagree = 3, agree =
4, strongly agree = 5.

7.2 Stakeholders’ response analysis

Overall, the consultation had a positive response of 90 percent. This was mainly because of the
limited scope of the consultation process owing to the land-use and planning zonation of the area.
Generally, respondents agreed that the proposed establishment of a milling facility at the
proposed site fits within the existing environment and will have minimal visual impacts (Mean=
4.98) and is also consistent with the current and project planning provision of the area (Mean=
4.70).

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The leaders were also (Mean=4.80) sure that the facility will not induce irreversible stress on the
surrounding environment. Similar response were obtained on whether the project was likely to
generate emissions that are not consistent with the environment (Mean= 4.60), whether the
project will alter community activities (Mean= 4.50). Such response on the environment
appropriateness of the facility in the area is not surprising considering the fact that this piece of
land is virtually vacant and entire area has been planned to house Industrial developments.

The stakeholders were optimistic that the project establishment in the area would induce forward
and backward economic benefits (mean= 4.65) to the society as a whole through various
activities, and that once established, the facility would increase development in the area (Mean=
4.54). They also believed that the project will induce direct employment to the community since
the project will need many semi-skilled and unskilled labour forces. It is also important to note
that within the project development area there is no biological species or setup that is of rare
conservation value nor is the proposed site bearing any archeologically/ culture value.

The site is also in character with the surrounding and therefore construction and operation of a
well-planned wheat milling plant in the area premised on sound environment principles as
indicated in the section of environment impact analysis can be done with minimal or no harm on
the environment.

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Table 6: Showing Stakeholders response to project establishment
Project Suitability
Mean Std. Dev 1 2 3
The project is in character with the 4.98 0.96
surrounding environment 1.00
The project is consistent with the 4.70 0.80
planning provision of the area. 0.712 1.00
Raw materials locally available 4.50 0.65 0.45 1.00 1.00
People’s concerns
Project is likely to employ foreign 2.67 0.78
people and ignoring the skills of our
local people 1.00 1.00 1.00
Project will not induce land use 4.50 0.75 0.70 0.95
changes in the area
1.00
Project will not alter community 4.50 0.80
activities 1.00
**. Correlation is significant at the
0.01 level (2-tailed).
Community Expectations
Provisions of employment 4.65 1.00
1.00
Provision of forward and backward 4.53 0.90
economic benefits in the area
0.65 1.00
Induce area development and the 4.80 0.77 0.073 0.98
associated benefits
1.00
*. Correlation is significant at the
0.05 level (2-tailed).

7.3 Analysis of the various land use options

Analyses of the possible land use options for the project site by the stakeholder emphasized the
planning provision of the area and underscore the need to align the proposed development with
the planning requirement and the sensitivity of the neighbourhood. The major characteristics
identified by the stakeholder as the basis for the suitability of the project in the site and the
surrounding is the fact that the entire area is planned for industrial developments which favours
the characteristics of the proposed grain milling industry considering the nature of the facility, and
the conducive surrounding environment.

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Table 7: Land use types considered by the community/stakeholders
Landuse option Rank Respondents (%)
Position
Increase Decreased/ same
a) Grain mill development 1 100 0
b) Residential 2 95 0
c) Conservation 0 100 0
d) Crop growing 0 100 0

1= First 2 = Second, 3 = Third, 4 = Fourth, 5 = Fifth in Preference

Based on the stakeholders’ preferred land-use option, a ranking analysis tool was used to explain
decisions on acceptance or rejection of one option (land-use type) rather than another. Generally
the rank order from the most to least preferred land use at the site was grain mill industrial
development. The stakeholders owing to the planning and proposed provision of the area and
the fact that the area is vacant only two possible land uses of the areas were floated for
comparison. Others such as crop growing and conservation are inconsistent with planning
provision and hence illegal not therefore not subject for this discussion.From the ranking of the
land-use options for the proposed site by the stakeholders, and rank order gave an insight into
the suitability of the proposed project on the project site and the potentially for social
acceptability.

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Table 8: Overall ranking of the land use options selected by communitymembers
Score Factory Residential Farming Conservation
1 2 0 0
1 2 0 0
1 2 0 0
1 2 0 0
2 1 0 0
1 2 0 0
1 2 0 0
1 2 0 0
1 2 0 0
1 2 0 0
1 2 0 0
2 1 0 0
1 2 0 0
1 2 0 0
1 2 0 0
Total 17 28 00 00
Rank Order
1 2 3 3

7.4 Distribution of probabilities of acceptance of land use option

The preference ranking assigned to each land use option and the number of times a particular
land-use option was ranked in a certain position (acceptance frequencies) is shown in Table 7.4.
Grain mill facility establishment was ranked thirteen times in position one, two times in position
2 the selected stakeholders. Therefore, from the rank order, the high probabilities of being
ranked highly by the stakeholders also indicated community preference of the land use options.

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CHAPTER EIGHT

8.0 Environmental and social management plan

The aim of an Environmental and Social Management Plan (ESMP) is to avoid the possible
adverse impacts of a project and to maintain the existing environmental quality. The ESMP
communicates all aspects of planning, construction and operation of the project, which are
relevant to environment. It is essential to implement the ESMP from the planning stage and then
continuing it throughout the construction and operation stage. Therefore the main objective of
the ESMP is to identify the project specific activities that should be considered as having
significant adverse impacts and the mitigation measures required.

The environmental and social management plan involves documentation of land use and water
quality issues during construction and operations. An Environmental and Social Management Plan
(ESMP) can be defined as “an environmental management tool used to ensure that undue or
reasonably avoidable adverse impacts of the construction, operation and decommissioning of a
project are prevented; and that the positive benefits of the projects are enhanced”.

An ESMP is therefore an important tool for ensuring that the management actions arising from
Environmental and Social Impact Assessment (ESIA) processes are clearly defined and
implemented through all phases of the project life-cycle. It is proposed to set the environment
management plan for the proposed wheat mill facility alongside the Best Management Practice
Guide which spells out recommended good practice at all stages of the project cycle to mitigate
adverse environmental impacts of the facility on the environment and vice versa. The objectives
of the ESMP should be understood in terms of the following approaches (strategies) to
environmental management:
▪ Good process management practices
▪ Site Selection and Management
▪ Environmental Protection
▪ Nature and Biodiversity
▪ Waste Management and Reduction

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▪ Water Quality Management and Conservation

8.1 Strategies for sound environment management

8.1.1 Good process management practices

Good grain milling facility practice ensures that appropriate equipment and machinery and
human capital is sourced coupled with adherence to planning and relevant provision and
requirements during establishment. This triggers proper resource use efficiency, waste
minimization and increase the process efficiency at the same time conserving the environment
and maintains social order. The most discussed issue of grain milling plant impact on the
environment is the effect on dust emissions, effect on energy use, and climate change and
atmospheric emissions from the process line. However, this is probably ineffective without a
prior baseline assessment. In addition, the ESMP should be regularly reviewed and management
objectives should be examined and continuously improved. For an ESMP to work properly, good
record management is compulsory.

Similarly effective ESMP begins with appropriate site management as one of the key issues for
success in the production process. Poor site management from the onset makes production
difficult to manage and may also lead to the destruction of critical natural habitats, spread of
diseases and contamination of water sources in the vicinity. When selecting areas for
infrastructure development with the proposed site the following points should be considered:
▪ Documentation of all the regulatory requirements for the site and consider alternatives
for compliance with the regulations.
▪ Survey local communities to determine demography, resource use patterns, availability
of labour and compatibility with project goals.
▪ Survey existing fauna and flora, with particular attention to effects of the project on
animal migration routes and nesting grounds or protected areas.

8.1.2 Site selection and management

Site management begins with high quality construction, regular maintenance, detailed site plans,
and equipment inventories. Facilities should blend with surrounding area to ensure low visibility
and scenic beauty. Planning of clearing and earth movement during construction can prevent

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ecological damage during construction and assist proper management during operations. It is
therefore recommended to:
▪ Use design features and good construction methods to overcome site limitations
and mitigate potential negative environmental problems.
▪ Adopt successfully tested and proven designs and construction procedures.
▪ Construct proper drainage channels to enhance proper flow of runoff and water within
the facility into the natural water ways;
▪ Raw material warehouse should be kept neat and properly arranged to allow easy
movement of materials and guarantee the safety of workers

8.1.3 Environmental protection


Environmental protection is achieved by sound facility management. In this regard, this involves
good construction and process management. Good facility management should aim at operating
towards achieving environmental sustainability and profitability at the same time. In order to
maintain good environment, waste minimization, proper training of workers, and investment in
environment compliance should be maintained all the time. In addition, the facility should have
well-constructed septic tanks where all the waste water at the plant specifically from ablution
area should discharge.Good facility management will require that facility should not interfere
with the environment particularly water flow in the area. General prevention of spills taints
should be controlled and contingency and mitigation plans for leaks and spills should be part
and parcel of overall facility management.

8.1.4 Waste management plan


The management objective of waste management plan is environment conservation. Without
conservation of the environment in the current location, the project sustainability becomes
impossible because the facility production is reliant on the capacity of the natural environment to
accommodate the waste which it generates, and the continued existence of the sink functions of
the natural environment. Towards this goal, the Developer will pursue a three pronged strategy:
waste minimization, maximizing waste recycling and reuse and promoting environmentally
sound waste disposal. In this regard, the waste management plan is based on the principles of
prevention, reduction, reuse and recycling.

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Table 9: Summary of potential impacts from operations and their proposed mitigation measures
ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
Pollutant ▪ Exceeding the critical ▪ Monitor the quality (composition of the DEI During & post
Enrichment level or load (L) would raw material) to avoid inclusion of highly project
lead to environment polluting substances in the process line. impleme
pollution of the ▪ Install settling ponds to capture ntation
receiving ecosystem sediment, organic matter and other
and reduce light pollutants by deposition, infiltration,
penetration into the absorption, decomposition and
waters volatilization
Waste water ▪ Contamination of the ▪ Uncontaminated wastewater should, DEI Throughout the
environment where practicable, be stored for reuse on DEO project cycle
▪ Injure wildlife
site for landscape irrigation or flushing
▪ Emission of odours (air
Pollution) waters.
▪ reduce wastewater quantity
▪ recycle the wastewater for flushing
(where practical)
▪ All wastewater and chemical spills should
be responded to and contained
immediately and fluids recovered or
disposed of. This is for occupational
health and safety reasons and to prevent
contamination of the local environment.

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ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
▪ Adopt and use eco- friendly alternatives
in the various stages of production.
▪ Adopt cleaner production techniques
throughout the process line
▪ Carry out regular monitoring and annual
Environmental Audits

Health Issues and ▪ Accidents and injuries ▪ All workers in places where there are DEI During operation
Occupational ▪ Hearing impairment cutting/sharp edges should be trained in phase
Safety avoiding injury to their bodies and in safe
use of machinery equipment.
▪ Provide workers with protective steel
capped boots, hardhats, high visibility
jackets, eye protection and gloves
▪ Insulate and carry out regular inspections
of all steam and thermal pipelines
▪ Direct steam vents and pressure release
valves away from areas where workers
have access

Noise ▪ Complaints from ▪ Noise emitting sources should be sound DEI During operation
workers and the insulated to ensure that workplaces do phase
community living in the not result in chronic exposure to excessive
neighbourhood occupational noise.
▪ Too much noise being ▪ All proper measures consisting of
generated from the abatement measures should be instituted.
factory. ▪ Place finished products and raw materials

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ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
in key noise making areas for attenuation
of noise from machinery and vehicular
movements.
▪ All operations at the facility should
submit to standard sound attenuation
devices (e.g. mufflers and baffles).
▪ International noise reduction
methodologies adopted for processing
industry shall be employed

Dust emission ▪ Accumulation of dust in ▪ Separate dust from exhaust air before DEI During operation
the environment discharging it into the environment by phase
▪ Complaints from use of centrifugal separators or fabric
neighbours filters.
▪ Use of Personal Protective Equipment
(PPE) such as the use of masks and
respirators
▪ Provide dust control equipment for areas
identified with high potential for dust
generation such as cleaning, grinding, and
the packing sections
▪ Regularly inspect chimneys to identify
and eliminate blockages preventing
effective removal of dust.

Atmospheric ▪ Polluted environment ▪ Air collected from around the presses DEI During operation
emissions and should be routed to the utility plant for phase

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ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
discharges use as combustion air

Solid waste ▪ accumulation of wastes ▪ Ash generated while burning wastes DEI During operation
at the factory should be stored in a contained wind phase
▪ presence of unsorted resistant area until it has fully cooled.
and littered waste at ▪ Ash may be returned to some other site
the plant premises for inclusion in the soil as a fertilizer and
soil improver.
▪ Solid wastes should be disposed of by
licensed waste handlers in Wakiso
▪ Convert all the waste boxes, papers and
sucks( wrappings) into other useful
materials
▪ Provide waste bins and skips on site for
proper waste management and avoiding
offsite impacts of improper waste
management
▪ Waste should be segregated on site into
reusable and recyclable materials
▪ Disposal of wastes and any by-products
should at all times comply with the
requirements of waste management
regulations.

Fire and explosion ▪ ▪ Procure and install adequate fire-fighting DEI During operation
hazards: equipment and ensure they are routinely phase
serviced to ensure their efficiency and
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ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
functionality at all times
▪ Explosion risk should be minimized by
application of measures for prevention
and control of dust accumulation
▪ Undertake regular housekeeping to
ensure that dust is removed from the
facility, including a biannual vacuuming
of the entire facility if possible
▪ Install and carry out regular maintenance
of spark detection and deluge dousing
systems in dryer systems and dust control
equipment
▪ Regularly train all the workers in fire
prevention and containment procedures
and install fire extinguishers in strategic
locations at the facility.
▪ Ensure all fire hazards are mapped out in
the factory and all workers are informed
of their potential.
▪ Put in place large capacity water storages
tanks and fill them with water all the
time for use in fire containment in case of
a fire outbreak.
▪ Map out fire safety and assemble points
within the
▪ Place signs at the plant such as those

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ISSUE IMPACT MITIGATION/ MANAGEMENT RESPONSIBILITY TIME FRAME
displaying hazard warnings and deterring
visitors from smoking and use of
electronic gadgets that could trigger
explosions.

Road access ▪ Road deterioration ▪ Assist in road maintenance DEI Annually


congestion
Aesthetic Value ▪ Construction of ▪ Enhance are beauty through planting of DEI Throughout
Building structures flowers in areas where permanent project
change the natural construction is not allowed and also implementation
scenery of the area blend the building structures with
environment in the area.

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9.0 CONCLUSIONS AND RECOMMENDATIONS

In this report, an assessment of all activities of the factory on the human and natural
environments is made. Both beneficial and negative impacts have been identified, evaluated and
presented in this ESIA. The assessment also underpinned the fact that much as the proposed
development will induce negative impacts some of which are within the severity category, these
impacts are not out of range in terms of mitigation and minimization. Most of the impacts
highlighted in the report can be addressed through adoption and implementation of the
following technical, education and administrative measures such as;
▪ Procuring high efficient production equipment that assure production accuracy and
reduce waste and hiring competent and qualified engineers to ensure that the all
equipment are positioned and functioning according to specifications.
• Provision of safety measures and protective wear to workers in addition to equipping
them with appropriate skills manage occupational and health risks associated with their
work environment.
• Institution of proper in- situ waste management procedures in accordance with all
applicable regulations.
• Putting in place a standard fire-fighting and prevention measures and equipping the
workers will relevant skills to contain and prevent any fire out break at the site.
• Ensure strict adherence to the technical and legal guidance provided all relevant
institution including, NEMA and Wakiso District Authorities.
• Adoption of cleaner production process and techniques at the facility to ensure increased
resource use efficiency.

It is important to note that, appropriate mitigation measures to all predictable negative impacts
due to the proposed development have been adequately provided and proposed. An
Environmental and Social Management Plan has been designed for use by DEI in implementing
the proposed mitigations. An evaluation of alternatives in Chapter 6 also concludes that the
project as described in the ESIA is far more beneficial and environmentally sound.

However, in order to strengthen environment compliance once in operation, the developer has
been advised to undertake regular environmental audits of the project at to assess/ evaluate the

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performance of the facility in regard to all applicable environment regulations, and address any
issues as they arise in the course of the project implementation.

9.1 Recommendation

This project is economically, environmentally and socially justified. Economic justification rests on
its contribution to processing industry to the extent of producing affordable and nitrous baking
flour. It is socially acceptable because it will provide employment to a number of persons that are
currently unemployed; provide alternative livelihood to workers and booster investment in the
wheat growing sector and trigger growth through its backward and forward linkages in addition
to being in character with the current social activities. The project will employ best management
practices and in order to minimise negative impacts on the environment. Because of this, the
project is not only socially acceptable; it is economically viable and therefore environmentally
sound and sustainable.

The report also considers a number of options with regard to location. The conclusion is that the
proposed site location is the best option. The proposed site is referred as suitable for the project
because the area does not have conflicts with land use pattern and the developers have full
ownership over the land proposed for development. Therefore, the development of the project
in this area is appropriate in all aspects and therefore deserves support.

The study also reviewed alternatives to the proposed option and concluded that the proposed
site is suitable to the environment because the proposed facility is not out of character with the
surrounding. The project will not introduce a new environment and social concerns. Other
alternative options are economically risky and should not be tried.

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REFERENCES
1. NEMA April 2004, Environmental Legislation of Uganda Vol 1, National Environment
Management Authority, Uganda.
2. National Environment Management Authority- Uganda. State of the environment report

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APPENDICES

Appendix I: Approval letter of TOR

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Appendix II: Copy of land title

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Appendix III: List of stakeholders consulted during the EIA process

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Appendix IV: Soil analysis result

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Appendix V: Water analysis result

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Appendix VI: Site layout plans

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