IRN Comments on Bujagali Large Hydro Project (Uganda)
Comments on the Project Proposal regarding the Bujagali Hydropower Project Submitted by the AES Corporation to Senter Internationaal
1. Introduction
International Rivers has invited Ugandan NGO representatives to Washington DC so they could present their concerns to World Bank Executive Directors. Several International Rivers representatives have visited Uganda, and the project area, and International Rivers has taken up a series of issues concerning Bujagali with AES, the World Bank and other financial institutions directly.
The Bujagali project has serious social and environmental impacts. The power generated by it will likely not be affordable for Uganda’s consumers, and the dam risks turning into a white elephant project, thereby adding further to Uganda’s unsustainable debt burden. The project will directly contravene the mandate of the CDM to assist developing countries achieve sustainable development. Fundamental project documents have so far been withheld from the public, and important issues, including alleged cases of corruption, remain unresolved. No further funding for the project should be approved while these issues remain outstanding.
In terms of CDM validation requirements, Bujagali is a business–as–usual project, and there is no realistic baseline scenario in Uganda which would make emission reductions by Bujagali appear additional. International Rivers believes that validating the Bujagali project as a potential CDM project, or accepting it as a source of carbon credits, would cast serious doubt on the concept that carbon trading can reduce greenhouse gas emissions and promote sustainable development and clean energy.
2. General comments
2.1. Social impacts:
A group of NGO representatives, including from International Rivers and Uganda’s National Association of Professional Environmentalists, visited the Bujagali resettlement site on July 14, 2002. They found that the resettlers were extremely unhappy about the conditions at the resettlement site. The resettlers felt that the quality and the size of their land plots, the access to water, firewood, markets and social services, and the conditions of housing for the majority of them were much inferior to the conditions at their original homes. In a letter dated July 29, 2002, the NGOs asked AES Nile Power Ltd. to address these problems. AESNP has so far not responded to this letter. (The NGO letter is annexed.)
In July 2001, Ugandan NGOs submitted a complaint to the World Bank’s Inspection Panel claiming that the Bujagali project violated Bank policies. The Panel submitted its report to the Board of Directors in June 2002. The Panel found that the planning for resettlement, compensation, and the development of dam–affected communities under the Bujagali project fell short of the World Bank’s requirements in several key areas. Problem areas include the compensation of affected people, the Community Development Action Plan, and the Resettlement Action Plan.
The Panel found that the Community Development Action Plan (CDAP) is under–funded, short–sighted, and generally lacking in detail. Its report says the CDAP "is weak and sketchy in the extreme; it focuses almost entirely on short–term exercises; its targets are poorly laid out; and it makes no significant or systematic effort at achieving long–term poverty alleviation" (para. 273). The Panel report states that as a result of the inadequacies of the CDAP, Bujagali is not in compliance with IDA’s policy on Involuntary Resettlement.
2.2. Environmental impacts:
The Bujagali dam would be located on the main stem of the Victoria Nile, only 8 km downstream of the Owen Falls and Owen Falls Extension dams. The cumulative impacts of this dam cascade have never been seriously assessed. The dam would also destroy a landscape of great scenic beauty, with a deeply rooted cultural value and a growing importance for Uganda’s tourism industry (see below).
The Bank’s Inspection Panel reported that there is no Sectoral Environmental Impact Assessment (SEA) for the Bujagali project. As the Panel stated, this is in violation of the Bank’s Operational Policy 4.01. The Panel suggests that "to be consistent with IDA policies", such a report may still need to be undertaken (para. 136).
In June 2002, the World Bank Board of Directors approved the Management Response to the Inspection Panel report. This Response proposes to carry out an SEA later, as part of the Nile Equatorial Lakes Subsidiary Action Program, which "would address future regional power options". In violation of World Bank policies and the Panel’s recommendations, the Bank has not assessed, and does not intend to assess, the cumulative environmental impacts of the Owen Falls, Owen Falls Extension, and Bujagali dams.
2.3. Economic impacts:
In several submissions to the World Bank and AES, International Rivers demonstrated that the economic analysis of the Bujagali project was seriously flawed, and that the economic viability of the project is questionable. The World Bank appraisal documents contain major discrepancies and inconsistencies, including on the projected growth of power demand, and on the amount of investment needed in transmission and distribution to connect Bujagali with consumers. The documents neglect important risks, including the potential impact of climate change on the Nile’s hydrology, and the Bank’s projections have already proven to be over–optimistic regarding Uganda’s macroeconomic development, and the pace of privatization in the country’s power sector.
Since economic growth and the expansion of power connections in Uganda will likely not reach the highly optimistic projections of the World Bank, there is a high risk that the electricity produced by Bujagali will become unaffordable for the country’s consumers. A devaluation of Uganda’s currency or a reduction in the Nile’s water flow would compound the negative economic impacts of the project. (The economic problems of Bujagali are elaborated in the report "Pervasive Appraisal Optimism", published by International Rivers in May 2002.
The report of the Inspection Panel also raised crucial issues regarding the economic and financial viability of Bujagali. They include the projections for power demand and how they will be affected by tariff increases, and the relation between system losses and the lagging privatization process. The report disclosed that in important aspects, the Power Purchase Agreement (PPA) is unfavorable to Uganda’s government, and not up to "international best practice". Bujagali would make power tariffs increase to 14 cents per kWh if it were not for debt relief measures. A mild annual depreciation of Uganda’s currency of 10% would render the tariffs "surely unaffordable", as the Panel puts it (para. 194).
The Panel revealed that in its zeal to promote Bujagali, the Bank management simply dropped an important policy condition regarding privatization when it became clear that Uganda could not comply with it. As a result, privatization of power distribution is being delayed, and the large amounts of private investment needed to connect Bujagali with electricity consumers may not materialize.
The Panel report suggested, or implied, a series of measures which needed to be taken to adequately assess the project risk for Uganda (and the Bank Group) before it is too late. These measures include, among others:
- an analysis of the impacts of currency depreciation on the power tariffs (para. 184 and 214);
- an analysis of the impacts which a wider range of demand forecasts would have on key features of the project (para. 213);
- an analysis of the risk which a delayed or under–performing privatization has on the development of the power distribution system (para. 215);
- adding a provision to the PPA to renegotiate the contract for commercial reasons (para. 199); and
- adding a provision to the PPA to treat low demand as a category of force majeure (para. 200).
It would be an effort in futility to carry out analyses on the economics of the project after it has been approved. And the necessary changes to the Power Purchase Agreement cannot be effected once the project has been approved. In its Response to the Panel report, the World Bank Management only commits to "closely monitor[ing] electricity demand growth, billing and collection management, and tariff levels", so that "measures can be taken appropriate to circumstances". This is not sufficient to redress the serious shortcomings in the economic analysis of Bujagali which the Inspection Panel identified.
Due to the economic risks, a series of financial institutions declined to become involved in the Bujagali project. They include Germany’s DEG, Great Britain’s ECGD, and US OPIC.
2.4. Lack of transparency and consultation
Civil society organizations in Uganda and internationally have for many years called for public access to essential project documents. Ugandan NGOs have requested public access to the Power Purchase Agreement and the Economic Review of Bujagali. International Rivers has asked for the release of the load forecast studies, i.e. the power demand projections on which Bujagali is based. These documents are essential for Ugandan and international civil society to judge the overall impacts of the project.
The World Bank, AES and Uganda’s government have all refused to make these documents publicly available. AES has not even responded to International Rivers’s inquiries.
The Inspection Panel found that by refusing to release the Economic Review, the World Bank violated its Policy on Disclosure of Operational Information. The Panel further argued that the release of the PPA, while not mandatory under World Bank policies, would be "vital if the intent is to place the public in a position to analyze, under’stand, and participate in informed discussion about viability of the Project and its impact on the economy and well–being of Ugandans" (para. 91). In spite of these findings, the documents are still being withheld from the public. AESNP has had hundreds of meetings with affected villagers and NGO representatives. Without access to basic project documents, such meetings do not constitute a meaningful form of consultation.
As a result, the Bujagali project is not in compliance with 37 (b) of the CDM, which states that as a condition of validation, Price Waterhouse Coopers must confirm that:
" Comments by local stakeholders have been invited, a summary of the comments received has been provided, and a report to the designated operational entity on how due account was taken of any comments has been received."
Given that key documents needed to assess this project have been withheld, and that the World Bank’s own Inspection Panel has found that this prevents stakeholders from being able to "analyze, under’stand, and participate in informed discussion about viability of the Project", it is clear that this crucial requirements has not been met, and Price Waterhouse Coopers consequently should deny validation to this project.
2.5. Allegations of corruption
Since its inception, the Bujagali project has been marred by a lack of transparency, and by allegations of corruption. The project was awarded to AES without any competitive bidding, but under substantial pressure from the US embassy in Kampala. The EPC Consortium for the project was also created without full competitive bidding.
Since 1999, newspapers and members of parliament in Uganda have accused decision–makers, including former Energy Minister Richard Kaijuka, to have accepted bribes from proponents of the Bujagali project. According to The Monitor, one of Uganda’s two mainstream English–language newspapers, Bujagali is "a complex web of deceit, manipulation, collusion and corruption" (The Monitor, June 23, 2002).
In July 2002, Veidekke, a member of the Bujagali EPC consortium, admitted to having extended a bribe of $10,000 to a Ugandan decision–maker in the context of another project. Richard Kaijuka, now an Alternate Executive Director of the World Bank, admitted to having accepted an amount of $10,000, but denied that this was a bribe. The case is presently being investigated by the World Bank, and by authorities in Uganda, Great Britain, Norway, and the United States. In the meantime, the project has been put on hold by the World Bank. The AES proposal to Senter Internationaal fails to mention this.
3. Lack of additionality
3.1. A "business as usual" project
According to the Modalities and procedures for a clean development mechanism as defined in Article 12 of the Kyoto Protocol, "a CDM project activity is additional if anthropogenic emissions of greenhouse gases by sources are reduced below those that would have occurred in the absence of the registered CDM project activity" (Decision 17/CP.7, paragraph 43). Essentially this means that a project is additional only if the emission reductions achieved by the project will not occur if it is not registered as a CDM project. Otherwise, the granting of carbon credits under the Kyoto Protocol would not result in an actual reduction of emissions in addition to what would have occurred anyway.
AES, in its Project Proposal, makes the following statement in this respect:
"Management board of The AES Corporation approved continued disbursement of their equity investment of USD 108 million in the project. However, AES noted their expected return on investment of 14 percent is far less than what private investors require from a project in Uganda. AES, in approving initial equity disbursement, has requested supplementary funding (including the sale of carbon credits) to bring their equity return up to acceptable levels."
In spite of this claim by AES, carbon credits will not have any impact on whether or not Bujagali will go ahead. A hydroelectric power project at the Bujagali site was first suggested by Acres International in 1991. AES and the Government of Uganda signed a Memorandum of Understanding to develop the Bujagali project in 1994, long before the Kyoto Protocol was established. Since then, AES and the Government have also signed an Implementation Agreement and a Power Purchase Agreement in which they committed themselves to developing the project.
Since December 2001, IDA, IFC and a number of export credit agencies have approved funding for Bujagali. A MIGA guarantee is still pending. On May 22, 2002, MIGA’s Management submitted a Report of the President to the Board of Directors on the proposed guarantee. This document summarizes the recent financial problems of AES, and then states: "AES has informed all members of the World Bank Group that it remains committed to the Bujagali Hydropower project, in which it has already invested more than $40 million." (Paragraph 10)
In the Project Proposal, AES claims it expects a return on investment of 14% from the Bujagali project. According to the World Bank’s Project Appraisal Document (Annex 5), AES Nile Power Ltd. projects an average profit after tax of $42.2 million p.a. for the period, 2005 through 2018. With an equity investment of $115 million (at the time of the Project Appraisal Document), these projections suggest a return that is certainly higher than 14%. Approving carbon credits for Bujagali would not reduce the cost of power produced by Bujagali for Uganda’s consumers, but would simply further increase AESNP’s return on investment.
3.2. The baseline according to AES’ project proposal
As mentioned above, the granting of carbon credits must result in investments by which "emissions of greenhouse gases () are reduced below those that would have occurred in the absence of the registered CDM project".
AES, in the project proposal to Senter/CERUPT, presents a counterfactual baseline scenario to Bujagali. In a rather confusing manner, the proposal defines the criteria for selecting the baseline scenario as follows:
"The criteria for selecting the counterfactual are that the planning sequence should not depend on speculative projects, the projects included should not pose the same kind of analytic issues as the candidate project, and subject to those constraints should be least–cost (without Bujagali) and, of course, should be least–cost." (sic, p. 29)
Presumably based on these criteria, AES presents a counterfactual scenario which includes open–cycle and combined–cycle combustion turbines with a total capacity of 300 MW for the period, 2005–2009, and is otherwise almost identical with the Bujagali scenario (see Table 1, p. 29). In either case, AES assumes that a bagasse plant is built by 2005. In other words, AES claims that Bujagali, if not built, will be replaced by a series of thermal power plants. As will be elaborated, this claim is completely spurious.
3.3. The baseline according to IFC
When preparing the Bujagali project, AES and IFC commissioned Acres International to assess the different options for the expansion of power generation in Uganda. The respective study has not been released to the public, but has been summarized in an IFC document (IFC, Bujagali Project, Summary of Economic Due Diligence, October 12, 2001, www.ifc.org ). This document indicates the following net–present value costs for "non–Bujagali options" (see Table 4.1., p. 18):
- Geothermal $510.0 million
- Kalagala hydro & thermal $558.1 million
- Kalagala hydro & Karuma hydro $562.0 million
- Mini/medium hydro & Muzizi hydro $577.4 million
- Karuma hydro & thermal $600.0 million
- Kakira bagasse & large thermal $619.1 million
- Mini/medium hydro $632.3 million
- Large thermal $651.0 million
This list indicates the present value of options according to the Acres International model of the Victoria Nile’s hydrology. According to this hydrological model, the proposed Bujagali project has a net present value cost of $499.3 million. A cost of $19.6 million for the foregone value–added of whitewater rafting at the Bujagali Falls must be added to this cost. Under the hydrological assumptions of the United Kingdom’s Institute of Hydrology, the geothermal and hydropower options are even more favorable compared with the thermal options (see also Table 4.1., p. 29).
By presenting the Kakira bagasse & large thermal option as the counterfactual scenario, AES stipulates a baseline scenario to Senter/CERUPT which ranks only as the sixth option in the non–Bujagali baseline scenario that Acres International prepared for AES and IFC. Presumably, the reason for this choice is that AES excluded projects that "pose the same kind of analytic issues as the candidate project", i.e. other hydropower projects, from its project proposal. There is no evident reason for doing so, except if the purpose is to inflate claims for carbon credits. Price Waterhouse Coopers must insist on a more rigorous justification for this baseline to avoid the clear impression that it was chosen solely on the basis of being the baseline that would provide the maximum possible credits.
3.4. The potential of geothermal energy in Uganda
Uganda is generally acknowledged to have a geothermal potential of about 450 MW. Preliminary geological and geochemical investigations of three promising fields have been conducted, but so far, no site drillings have been carried out. The African Development Bank recently approved a project to assess alternative energy resources in Uganda, which will include pre–feasibility studies of promising geothermal sites.
The options assessment carried out by Acres International for IFC and AES demonstrates that if the economic value of rafting at the Bujagali Falls is included (which is foregone if Bujagali is built), geothermal energy is the least–cost option for the expansion of power generation in Uganda, and cheaper than Bujagali. The Economic Review of Bujagali estimates the cost for geothermal power to be $2,000/kW. The World Bank’s website on geothermal indicates this cost to be $1,150–2200/kW (www.worldbank.org). In comparison, the cost of Bujagali, with a budget of $582 million and a capacity of 200 MW, will amount to $2,910/kW.
AES project proposal argues that "the geothermal resource in Uganda remains speculative" (p. 27), and that according to the Economic Review of Bujagali, the earliest that geothermal might be available in commercial quantity is 2010.
International experience, including in a World Bank project in Kenya, shows that geological sites are usually explored in two to three years, and that geothermal power plants typically take another two to three years to be built. The Inspection Panel in its report found that the estimate for the construction time of geothermal plants used in the Bujagali Economic Review was "pessimistic" (para. 238). At this point in time, geothermal power plants in Uganda are no more speculative than the Bujagali project.
AES’ attempt to claim undeserved carbon credits results in a baseline scenario which in Uganda’s power sector is unrealistic both on economic and political terms. In economic terms, it would make most sense for Uganda to rapidly explore the geothermal sites which have been identified as having a promising potential, and to develop respective geothermal power plants. This option is being pursued by the Government of Kenya, which intends to increase the share of geothermal power in the country’s overall power supply from 5% to 37% by 2015.
Even if geothermal energy appears to be more economic, large, centralized hydropower projects offer bigger political, bureaucratic and financial spoils than alternative energy sources. So if corruption or the social and environmental concerns of Uganda’s civil society stop Bujagali, the most likely alternatives appear to be the Karuma dam or other hydropower projects. In the discussions which the World Bank held with Uganda’s Government, the next project in Uganda’s power sector was always seen to be a hydropower dam, even before the Bank identified Bujagali as a project. (See Bank Management Response to the Request for Inspection Panel Review, 13 September 2001, p. 6f.) Thermal power plants play no role in the debate about the future of Uganda’s power sector, and the baseline scenario presented by AES’ Project Proposal is totally unrealistic.
4. Conclusion
The cumulative impacts of the Owen Falls, Owen Falls Extension and Bujagali dam projects have not been assessed. The problems of resettlement and rehabilitation have not been resolved. The economic analysis of the Bujagali project is flawed, and if built, the dam risks turning into a white elephant project. Essential project documents have never been released, and so a meaningful public debate and consultation have so far not been possible. The corruption allegations are still being investigated.
The Bujagali project has been in the pipeline since 1994. AES has contractually committed itself to developing the project. If the project is stopped because of concerns about the social, environmental and economic impacts or about corruption, the most economic alternative appears to be geothermal power plants, and the politically most realistic alternative, other hydropower dams on the Nile. The baseline scenario presented by AES’ Project Proposal is totally unrealistic.
If Price Waterhouse Coopers approves carbon credits for the Bujagali dam, it will open the door for Dutch government resources to help fund a dam which has negative environmental , social and economic impacts and undermines Holland’s commitment to good governance principles. Furthermore, the Dutch Government, previously seen as a progressive player in the Climate Change debate, would undermine the Kyoto Protocol as a whole by meeting its emissions reduction commitments through an unsustainable and non–additional project.
Peter Bosshard
International Rivers
August 19, 2002
Annex:
NGO letter to AES on Bujagali resettlement problems
Mr. Henry Kikoyo
Project Manager & Company Secretary
AES Nile Power Ltd.
P.O. Box 24401
Kampala, Uganda
July 29, 2002
Resettlement problems of the Bujagali project
Dear Mr. Kikoyo,
On July 14, 2002, we had the chance to visit the Bujagali project resettlement site at Naminya, and to discuss the resettlement situation with a group of resettlers, including village elders. The issues which emerged strongly contradict the claims that "when it comes to resettlement, Bujagali is a model project", as you had asserted in a meeting with us on July 11. On the contrary, it appears that many of the well–known problems of dam–induced involuntary resettlement – including a lack of adequate compensation, poor quality and insufficient replacement cropland, lack of adequate common land, fuelwood and water, culturally inappropriate housing – are being replicated by AESNP at Bujagali. The resettlers told us that they now had to "sleep with empty stomachs". Their condition will likely deteriorate once their compensation funds have been spent.
We tried to contact you after we returned to Kampala from the Jinja area. We were told that you were on leave but would respond to our concerns in writing. Below are the main issues which arose from our visit to Naminya.
Compensation:
- All resettlers we spoke to stated that their crops and trees had been under–compensated by AESNP.
- One village elder complained that of the USh 700,000 which he received in compensation for lost assets, USh 200,000 were immediately deducted for transporting his family’s belongings over a distance of a few kilometers to the resettlement site.
- The resettlers stated that AESNP had contracted them to clear the land at the resettlement site but that six weeks later they had still not been paid.
Land and common resources:
- The land at the hilltop resettlement site is stony and much less fertile than the resettlers’ expropriated riverside plots. The elders also maintained that the resettlement site received less rain than their original lands on the banks of the Nile. Some resettlers complained that the one acre of replacement land they had received was less than they had previously farmed. We also heard from many men who had previously tilled two plots of land but had received replacement land for only one plot. Women complained to us that they had previously had their own plots but these had not been recognized by AESNP. This meant that a family comprising of two wives and a husband which previously had access to three different parcels of land now has to share a single one–acre plot.
- In spite of promises made by AESNP, the resettlers said that they have not received legal titles to their new land.
- In a shocking letter dated May 14, 2002, AESNP warned the oustees not to cultivate their plots since they are still in the possession of AESNP. The resettlers we spoke to understood the letter to refer to the new plots for which they have not received titles. The annex contains a full transcript of the AESNP letter. Not surprisingly the resettlers were very worried about the potentially disastrous implications for their livelihoods of AESNP preventing them from growing crops.
- No grazing land was made available to the resettlers who own cattle, and they are denied access to nearby common land which has signs posted declaring any use of the land to be illegal.
- People used to catch fish in the Nile, but they have been moved away from the river and the place where they used to fish is fenced off. One ex–fisherman stated that "if we went there now we would come back with whip marks on our backs". They do not seem to have been compensated for the loss of this source of food or income. They claimed that AESNP had promised them a fishpond but had not provided this.
- The resettlers also complained of a serious lack of firewood at the resettlement site and said that they now had to walk several kilometers to collect wood.
Water:
- Only one borehole exists for drinking water, which is several kilometers from some of the houses. Again the resettlers claimed that AESNP had promised to drill several boreholes, but had failed to do so. They complained that the water was orange. A rainwater tank has been erected for each house but resettlers told us that these were too small and that after only four months, some were already leaking.
Housing:
- The new houses have been built without kitchens or any other place for cooking. The women of the resettlement site were extremely angry about having to cook in the open without any protection from the rain.
- The toilets overflow when it rains, and the resettlers fear an outbreak of cholera.
- Polygamous families received the standard one–bedroom house, yet traditionally they would have a separate house (and kitchen) for each wife and her children. Forcing these families to live in a single small house was clearly causing distress.
Amenities:
- Unlike where people used to live, there are no markets, stores or main roads in the vicinity of the resettlement site.
Graves:
- The elders say that they were promised financial support by AESNP to relocate the graves of their ancestors, but have so far not received this, and so have not been able to move the graves.
As a consequence of all these problems, the mood at the resettlement site was extremely grim. It turned into open hostility when the resettlers for a moment thought that we represented AESNP. People told us they would "return running" if they could go back to their previous homes, and some women told us they were considering divorcing their husbands so that they could return to their original villages. The resettlers were unanimous in claiming that they were better off before moving.
The conditions we found at the Naminya site contrast markedly with the claims in AESNP’s publicity materials. They are all the more incomprehensible since so far, only about 30 families have been resettled.
We appreciated your interest to discuss the Bujagali project with us in Kampala on July 11. We regret that no member of AESNP’s management was available to register the above concerns, and discuss them in person, on July 15 or 16.
We urge you to address these serious problems of compensation, livelihood, land security, housing, amenities, and compensation for the relocation of graves at the earliest, and to the full satisfaction of the affected people. We look forward to your response.
We are sending copies of this letter to the Ugandan Government officials and Members of Parliament we met in Kampala, to representatives of the World Bank Group, and to the Panel of Experts.
Sincerely yours,
Alfred Belinda
National Association of Professional Environmentalists, Uganda
Peter Bosshard
International Rivers, USA
Christine Eberlein
Berne Declaration, Switzerland
Liane Greeff
Environmental Monitoring Group, South Africa
Patrick McCully
International Rivers, USA
Frank Muramuzi
National Association of Professional Environmentalists, Uganda
Hon. Dr. Ruhakana Rugunda, Minister of Water, Lands, and Environment
Hon. Daudi Migereko, Minister of State for Energy
Mr. Haran Sivam, Mr. Ronald Anderson and Mr. Eric Brusberg, International Finance Corporation
Ms. Karen Rasmussen, International Development Association
Ms. Meg Taylor, Compliance Advisor/Ombudsman
Mr. Edward S. Ayensu, World Bank Inspection Panel
Dr. Lee Talbot, Panel of Experts
Annex:
Letter of AESNP of May 14, 2002
AES Nile Power
Date: 14/5/2002
Name: Khauka Florence, Khauka Goerge [sic], Ella Yakobo, Wenene Margaret, Waiswa Ezephan, Madekere Paul, Anyorit Benaleta Akong, Masiga Francis, Gabeya Miria Muzira, Omudu Sunday, Kizza Lawrence, Kirya Yoronimu
The Chairperson LC1,
Village: Namilyango
Dear Sir/Madam,
RE: TRESSPASS ON THE LAND
We have learnt that the mentioned above are in the process of cultivating our land at Namilyango village without our permission. This is to inform you that cultivating our land without our written permission is criminal and should therefore be stopped immediately failing which we shall have no alternative but to refer the matter to police and cause your arrest.
STAND DULY WARNED!
By a copy of this letter the area LC1 authorities are notified of this warning.
Yours sincerely,
Terry Nantongo
Manager – Legal Services
CC Concerned Trespassers
