Are Uganda’s environmental impact reports just a box-ticking exercise? What a study of 108 projects reveals

Uganda's environmental impact assessment system is meant to protect the environment from harmful development projects. For nearly 30 years, the law has required developers applying for approval to consider alternatives to their proposed projects, such as different sites, designs, technologies or even whether the project should go ahead at all. This is intended to make sure that the least environmentally damaging option is chosen. Biodiversity and environmental impact assessment researcher Mulumba M. Agaba examined 108 environmental impact statements submitted between 2001 and 2023 to assess whether developers were complying with this requirement.

Why aren't developers allowed to propose only one option?

Environmental impact assessments globally are used to evaluate the environmental consequences of major projects before they are approved. They give decision-makers clear information about the likely impact of the project on the environment, and about whether less damaging options are available. In Uganda, assessors must be certified by the National Environment Management Authority. However, they are usually hired and paid by the project developer.

The main aim in project planning is to first avoid harming the environment. If that's not possible, developers need to reduce the damage they do. The last option – repairing damage and paying compensation – should only happen when there is no better option.

The World Bank Environmental and Social Framework and the Convention on Biological Diversity stress that it's best to avoid environmental damage rather than managing it later.

For this reason, it's international best practice for developers to come up with alternatives to their planned projects. Considering more environmentally friendly alternatives is an important step in constructing new projects and is meant to shape decisions before projects are locked in.

What's wrong with the system?

We examined 108 environmental impact assessment reports to see whether developers had properly considered different project options. We also interviewed 18 environmental assessment practitioners about how alternatives are chosen, whether environmental concerns are taken seriously, and why these assessments so often fail to change the final decision on projects.

Our findings are concerning.

Developers routinely include other project options in environmental impact assessment reports, but the study found these were often given only limited attention. The alternatives were usually described briefly, with little evidence-based comparison. In many cases, the reports did not explain why one option would be better for the environment than another. The researchers concluded that alternatives rarely appear to shape the final decision on which projects are approved.

Second, biodiversity gets very little attention in these assessments. Even where different options are considered, they are usually judged mainly on cost or whether they are technically possible, while environmental impacts are treated as less important or ignored. For example, different options were not compared based on their likely impact on habitats, species, ecosystem services, protected areas and other environmentally sensitive areas.

Sectors vary in how clearly reports set out different options, how carefully they compare them, and whether they consider biodiversity when explaining a choice. Projects in sectors that face strong outside scrutiny, such as oil and gas, tend to do this better. Manufacturing and urban development projects tend to do this poorly.

There has been little improvement over time. Uganda's National Environment Act was passed in 2019, and emphasises that the first priority is to cause no damage to the environment. But in the assessments that followed, there was no clear evidence that biodiversity was being better integrated into decision-making.

Which alternatives get attention, and which are ignored?

Our research found that most environmental impact assessments describe what might happen if the project does not go ahead, but they focus on how the economy will lose out rather than on how the environment will gain.

Technology and design alternatives are sometimes considered, but rarely in depth. Moving a development to a different location is often not explored at all.

The areas where projects could most reduce harm to the environment are the ones that get the least attention. For example, we found that developers rarely compare whether a different way of building or running a project would cause less environmental damage. They rarely consider changing timing or building methods.

Environmental impact statements usually stick to one chosen approach, and then add mitigation measures afterwards, rather than properly testing whether other approaches might be better for nature from the start.

There is a clear pattern. Alternatives that could genuinely reduce environmental harm are the least explored.

What can be done to change this?

Our research developed a Biodiversity Inclusion Index to assess whether 108 environmental impact reports properly considered alternative options and their effects on species, habitats and entire ecosystems.

The index examines whether biodiversity was properly considered when different project options were compared. It looks at whether the assessment explained how different choices could avoid or reduce harm to species, habitats and ecosystems.

The results are stark. The average score was just 0.33. This indicates weak and inconsistent integration of biodiversity across most projects. A good score would be 1 – meaning that biodiversity is clearly included in how alternatives are identified and justified.

Only a small number of projects performed well. These are typically projects with international financing or higher regulatory scrutiny.

Why does this matter?

Once a project's location, design, phasing and technology are fixed, environmental damage can only be fixed later. In other words, the focus shifts to mitigation. At that point, the best ways to protect the environment are already off the table.

This is not the way to protect Uganda's biodiversity. Choosing a different site, adjusting a development's layout, or changing when it is built can prevent irreversible damage. These decisions must happen before the development gets started because they determine whether ecosystems are protected or lost.

Our research found that many Ugandan developments give the appearance of complying with environmental laws. But actually, they are locking in avoidable biodiversity loss.

The Biodiversity Inclusion Index offers a practical way to check whether alternatives analysis is genuinely considering biodiversity. It could be adapted by developers, regulators and reviewers to improve how project options are compared before decisions are locked in.

Environmental impact assessors can use this index to improve the quality of their assessments. Policymakers can use our research to find ways of better enforcing environmental protection.

Mulumba M Agaba does not work for, consult, own shares in or receive funding from any company or organisation that would benefit from this article, and has disclosed no relevant affiliations beyond their academic appointment.

By Mulumba M Agaba, Researcher, University of Liverpool