Uganda: Oil Methane Control Readiness Lags as Production Nears

• Uganda faces significant gaps in its legal, technical, and institutional readiness to monitor and control methane emissions from its upcoming oil and gas production.
• The government's draft methane action plan is still under development, lacking complete data, coordination, and financing details.
• Current national greenhouse gas inventories do not include actual domestic oil and gas production emissions, leading to reporting challenges.
• Existing petroleum laws lack detailed methane-specific regulations, measurement standards, and enforcement mechanisms for oil and gas operations.
• Uganda's emissions accounting relies on general estimates, hindering accurate assessment and baseline establishment for methane.

The meeting report stresses the imperative of establishing reliable arrangements for collecting, validating, and reporting this information *before* production commences.

Uganda is rapidly approaching the commencement of commercial oil production from its significant Lake Albert development, a venture involving TotalEnergies' Tilenga project, CNOOC's Kingfisher project, and the Uganda National Oil Company. However, this impending milestone is accompanied by growing concerns regarding the nation's preparedness to effectively manage and reduce methane emissions from its nascent oil and gas industry. A recent briefing from the Natural Resource Governance Institute (NRGI) has specifically highlighted deficiencies in Uganda's legal, technical, and institutional capacity to monitor these emissions.

Further underscoring these challenges, a meeting report from the Ministry of Water and Environment indicates that the Ugandan government is still in the process of establishing the necessary data collection and reporting arrangements to accurately account for emissions stemming from domestic oil and gas production. These findings collectively raise questions about whether Uganda will have adequate monitoring systems, clear regulatory frameworks, and enforceable controls firmly in place before commercial operations officially begin. The government's draft National Action Plan for Short-Lived Climate Pollutants and Methane Emissions Roadmap is intended to guide action on methane and other pollutants, yet even this document is still undergoing development.

A significant hurdle for Uganda's oil methane control readiness lies in the absence of a robust system for measuring emissions once production commences. During an October 2 technical engagement with civil society, the Climate Change Department (CCD) acknowledged that the draft roadmap requires further work on critical areas such as data gaps, institutional coordination, financing, and monitoring. Assistant Commissioner Muhammad Semambo, chairing the engagement, clarified that while Uganda's current Nationally Determined Contribution (NDC) includes mitigation measures for the oil and gas sector, it does not yet feature a specific production-related greenhouse gas emissions target.

This omission is primarily attributed to the fact that commercial production has not yet begun, meaning the national greenhouse gas inventory currently lacks actual activity data for domestic oil and gas operations. The existing fuel-related emissions within the national inventory predominantly reflect the consumption of imported fuels within Uganda, rather than emissions generated by local oil and gas production. When civil society representatives questioned why the draft roadmap indicated "zero" production-related emissions, the CCD explained that this figure merely reflected the absence of actual domestic production activity data in the national inventory, not an assertion that planned operations would produce no emissions.

The department emphasized that once production begins, industry operators and responsible institutions will be required to collect activity data using agreed parameters, which will then be incorporated into a sectoral inventory before feeding into the national greenhouse gas inventory. The meeting report stresses the imperative of establishing reliable arrangements for collecting, validating, and reporting this information *before* production commences.

Beyond the immediate data collection issues, the NRGI Uganda methane report also raises concerns about the adequacy of Uganda's existing legal framework for controlling methane emissions from petroleum operations. The institute points out that current petroleum laws, while containing restrictions on gas flaring and venting, are not sufficiently supported by detailed methane-specific regulations, precise measurement standards, or robust enforcement mechanisms. This lack of specificity in Uganda petroleum methane regulations creates potential compliance ambiguities and enforcement challenges.

Furthermore, the briefing identifies weaknesses in Uganda's overall emissions accounting methodology. The national greenhouse gas inventory largely relies on Tier 1 default emission factors. These factors provide generalized estimates rather than measurements specifically tailored to the unique characteristics of individual facilities or operational sites. This reliance on broad estimates significantly limits the accuracy with which emissions can be assessed and complicates the establishment of reliable baselines against which future performance and reductions can be measured. Addressing these legal and methodological gaps is crucial for effective Uganda oil gas emissions monitoring and ensuring accountability as the Lake Albert development methane emissions become a reality.

Lawyers advising oil and gas clients in Uganda must closely monitor the development of methane-specific regulations and reporting requirements. The identified gaps in legal, technical, and institutional readiness indicate significant compliance risks and potential for new, more stringent obligations once commercial production begins, necessitating proactive preparation for robust monitoring, reporting, and verification.

Source: Original reporting via the Natural Resource Governance Institute.