REVIEWING ENVIRONMENT AND SOCIAL MANAGEMENT PLAN FOR TILENGA PROJECT

Bugungu Community Association had 3 days retreat at Lweza Training and Conference Centre to review Environment and Social Management Plan (ESMP) for Tilange project. ESMP operationalizes plans of mitigating the serious environmental and social impacts of the Tilenga Project. Over 24 Bugungu community members who are affected by Tilange project participated in this retreat. The retreat funded by BIRUDO with support from KIOS Foundation. However, the participants send out letter to Total E&P demanding for more days to enable them effectively review ESMP document that is over 1500 pages. The following are the community reasons for demand for the additional days for the ESMP review.
1. Since the ESMP operationalizes plans of mitigating the serious environmental and social impacts of the Tilenga Project, it requires meaningful consultation of the project affected communities to get their comments into the ESMP.
2. We have several concerns about the process behind the development and review of the ESMP as detailed below:
a. The 30 days’ timeframe you gave to review ESMP of over 1,500 pages of technical documents and provide written comments is unrealistic. This will not be a reasonable timeframe to enable communities and other stakeholders to meaningfully review ESMP in detail.
b. The documents are not in local languages and thus needs more time to internalize and explain to local communities. Majority do not understand English.
c. There are no non-technical summaries, videos, and infographics presenting information in more accessible formats and languages for easy communication to the local communities and stakeholders.
d. There seems to be no plan to consult with communities who do not have internet access or equipment to engage in virtual meetings.
e. We were not consulted during the development of this document and this is the first time we are seeing it.
f. Nobody has communicated any plans for funded and compensated community-led review of the ESMP and monitoring systems of the impacts of the project.
g. Only part of the ESMP has been shared with us. We believe that all parts of the ESMP document are interlinked, therefore we need to review the full ESMP documents together.
3. For these reasons, the process you outline will not fulfill Total’s human rights and environmental requirements under the OECD Guidelines for Multinational Enterprises or United National Guiding Principles on Business and Human Rights. We are also urging National Environmental Management Authority to withhold any required approvals for the Tilenga project until the above steps have been taken. While we recognize these are meant to be living documents, it is important to recognize that the process you have outlined cannot not be considered consultation.

4. We cannot engage effectively in this process until a genuine effort is made by Total to develop a meaningful consultation process, including the dissemination of the information in an accessible form followed by a minimum of 90 days for public comment. In this regard, we are requesting an extension of the review timeframe and meaningful engagement on the ESMP review process. Please provide documents in local languages (Lugungu and Alur), non-technical summaries, and key ideas and concepts pulled out in accessible formats like infographics and videos for us. Please also provide us support and funding to hire our own independent experts of choice to review information. We also want an explanation as to why we were not consulted as this document was being developed. We also want to better understand what plans if any you have for (compensated) community-led monitoring systems for environmental and social impacts.
Finally, we want to highlight that the Covid-19 pandemic and lockdowns are not an excuse to push forward projects without meaningful consultations. If anything, Total should be stepping up and engaging in innovative forms of consultation with communities. We look forward to working with you in this regard.

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