Confidential documents written by TotalEnergies’ auditing firms reveal the inadequacy of the Group’s actions to limit the damage caused by its Tilenga oil megaproject, in an area of exceptional biodiversity. Elephants, lions and hippos will be heavily impacted.
In this second article of our GreenFakes series, we look into an ecological aberration. Since the summer of 2023, TotalEnergies has drilled more than 400 oil wells in Uganda, near Lake Albert, a third of which are located in Murchison Falls National Park, the country’s largest protected nature reserve. World-renowned for its exceptional biodiversity, the park is home to over 140 species of wild mammals (antelopes, lions, elephants, hippos, giraffes, etc.), some of which are threatened with extinction.
The French oil and gas giant claims that the construction site, which will support the extraction of 200,000 barrels of oil per day, will not cause any damage to the environment. TotalEnergies even promises that this enormous infrastructure project named Tilenga and discreetly supported by President Emmanuel Macron, will have “a net positive impact on biodiversity”.
However, two confidential reports produced for TotalEnergies by environmental auditing firms – France’s Biotope and The Biodiversity Consultancy in the UK – show, on the contrary, that the measures taken by the French oil company are not sufficient to protect nature in this ecologically ultra-sensitive area. And with good reason: while the two consultancies are supposed to work independently, they are in fact subservient to TotalEnergies, which has the right to “validate” the actions to be taken to conserve biodiversity and does not hesitate to water down the ecological significance of these measures.
These are the findings of our second investigation in the “GreenFakes” series, based on confidential documents obtained by the NGO Climate Whistleblowers.
When contacted by Mediapart, Biotope and The Biodiversity Consultancy did not respond. TotalEnergies refused to answer our questions about the facts, but did point out that the Tilenga infrastructure “covers less than 0.03% of the surface area of Murchison Falls Park” (read the full response in the in this article).
Ecological measures kept secret
The French group and its partners, Uganda’s national oil company UNOC, and China’s CNOOC, have promised to comply with the environmental and social performance standards laid down by the International Finance Corporation, a subsidiary of the World Bank, including the controversial “PS6” standard (see the first part of our “GreenFakes” series). It stipulates that the project must cause no “net loss” of plant and animal biodiversity, and even a “net gain” of “critical habitats” that are home to endangered species.
To demonstrate Tilenga’s compliance with this standard, TotalEnergies commissioned an Environmental and Social Impact Assessment (ESIA) published in early 2019. The aim: to identify negative impacts, then respond to them by following an approach called ERC – “avoid, reduce, compensate”. In short, the aim is to minimize damage to the environment, then compensate elsewhere for damage that cannot be avoided.
The lack of ambition and “serious shortcomings” of this ESIA have been criticized by a report from the NGO E-Tech International, as well as by the Dutch Commission for Environmental Assessment. This independent body described the environmental protection measures as a “list of intentions”. The ESIA states that the concrete measures are detailed in other action plans, which TotalEnergies has decided to keep secret.
Mediapart has obtained two of these confidential documents. The first is a non-final version of the Biodiversity and Ecosystem Services Management Plan (BESMP), dated July 2019. This biodiversity and ecosystem services management plan was produced by the French firm Biotope, and invoiced to TotalEnergies for 130,000 euros.
Several experts we interviewed deemed the measures planned to preserve Tilenga’s wildlife too general and insufficient. The report states that, before work begins, it is necessary to “facilitate the departure of animals” such as hyenas and amphibians. If workers come across burrows of medium-sized mammals such as aardvarks or civets, they should “encourage individuals to leave the area by using a repellent.”
“This type of document is a copy-paste of the typical reduction and support measures recommended for this type of worksite”, comments an ecologist who worked for Biotope. There’s hardly any precise data, and he points out that relocating animals is all smoke and mirrors, as they would be going to another habitat where there are already other individuals of their species, which would have an impacts in terms of competition for resources and space . As for the use of repellents, he asserts that this measure is never prescribed in France.
A dangerous work site for wildlife
Biotope’s Biodiversity Management Plan poses questions but offers no answers when work is undertaken close to hippopotamus-populated territories: “Can we continue with the activities, or should we wait until the hippos leave? What measures should be taken?
Yet TotalEnergies has a duty to manage these vulnerable species, of which Murchison Falls National Park is one of the last refuges in Uganda. “These are dangerous animals, and cohabitation with humans is complicated,” explains hippo specialist Nicolas Mathevon, a researcher at Jean Monnet Saint-Etienne University. “Hippos come out of the water at night to feed in grasslands, sometimes several kilometers away. If human activities encroach on this habitat, they will probably be greatly disturbed”.
The proof that the project is having a deleterious impact on wildlife, can be seen in the multiple fences, ramps and trenches that must be erected around the construction site to prevent animal intrusion. To keep out African elephants – a species classified as “critically endangered” – the biodiversity management plan prescribes the installation of fences of 7,000 volts, around 1.5 m high.
According to Graham Kerley, Director of Research at Nelson Mandela University in South Africa, these are standard electrified infrastructures to control elephants, but he points out that these fences may exclude them from essential resources and habitats, increasing pressure and stress on the elephant population. And the NGO E-Tech International pointed out in its report that the ten drilling rigs located in Murchison Falls National Park could provide an impassable barrier for elephants seeking to avoid noise and activity at the rig sites.
Biotope also advocates putting in place crossing structures for the animals, such as bridges, culverts, larger underpasses and overpasses where necessary. However, the report acknowledges that this is not enough, since workers must inspect trenches and excavations every morning to rescue trapped wildlife. “In the end, these measures always have little impact; they’re just superficial efforts to make people forget that this type of project is synonymous with the destruction of biodiversity”, the former Biotope ecologist to confirmed to Mediapart.
When questioned on this subject, TotalEnergies asserted that the measures put in place were validated by the competent authorities and are subject to independent monitoring to ensure their effectiveness.
In the event of any impact on biodiversity during construction, the report rarely mentions suspending work. This is hardly a coincidence. Biotope, which is supposed to work independently, has in fact pledged its allegiance to TotalEnergies. In its business proposal, obtained by Mediapart, the firm promised to “work closely with Total”. At the end of each stage of the report’s preparation, the integration of the Total’s comments and validation are expected. Under the heading “Ethics in our reporting”, there is an obligation of “confidentiality” to the client.
Audit firm under influence
TotalEnergies’ influence over the consultants it employs is confirmed by a second confidential document: the working version of the Tilenga project’s “Best Environmental Management Practice” report, produced in November 2019 by the British firm The Biodiversity Consultancy (TBC).
The document is studded with comments from David Ochanda, in charge of biodiversity issues for TotalEnergies’ Ugandan subsidiary, who is working to water down the report.
TBC’s consultants write, for example, that the environmental data collected during the ESIA, the impact study made public, contains “gaps” and needs to be “more focused and updated”. Biodiversity data is “sufficient”, comments David Ochanda dryly. He also insists three times that monitoring the ecosystems impacted by the project must be “realistic.”
On the subject of lion protection, TotalEnergies Uganda’s biodiversity expert goes so far as to delete the fact that a species specialist must be consulted from the text currently being drafted. This is despite the fact that a TBC consultant said, “The fact that a specialist with an international or regional reputation has approved the monitoring approach would considerably reduce the risks for Total”.
The firm had also suggested that an aerial survey of elephant, giraffe and two antelope populations be carried out every two years. David Ochanda, the man from TotalEnergies, suggested that this should only be every three years. TBC immediately agreed to amend its copy.
In short, the firm seems more concerned with satisfying its client than with protecting nature. This is particularly apparent in the section devoted to compensation for the damage caused by Tilenga. TBC stresses the need to define the “number of hectares” of wetlands or forests that TotalEnergies must protect outside the project area, but there are no concrete details.
Measures to compensate for the negative impact on chimpanzees seem particularly unambitious. The PS6 standard that TotalEnergies has promised to meet requires a “net gain” for this protected species. Yet TBC’s report calls for the conservation of “more than 400 chimpanzees” in the Budongo reserve, even though it is currently estimated to be home to between 400 and 800 individuals. This looks like dishonesty,” comments the former Biotope consultant interviewed by Mediapart. To achieve a ‘net gain’, the target should correspond to the middle of the statistical range, i.e. 600 individuals.”
TotalEnergies did not respond to our specific questions about this document, but says it has set up “a conservation program that actively monitors lion, elephant and chimpanzee populations, with the aim of increasing populations by 25% by 2045.”
A field survey carried out by Ugandan NGO Afiego, with support from “Amis de la Terre France”, has in any case diagnosed the first negative environmental impacts of TotalEnergies’ oil activities in Murchison Falls Park. The report, published in September 2024, states that elephants, disturbed by the vibrations and noise of the construction site, are “destroying cultivated land” and are said to have killed five people between June 2023 and April 2024. Light pollution from the drilling platform, visible up to 14 km away, is said to have a negative impact on nocturnal predators such as leopards, lions and hyenas.
Despite these significant warnings, TotalEnergies does not appear to be worried. When the project began in July 2023, the impressive drilling platform siphoning oil from Murchison Falls Park was painted beige to “blend in with the surrounding savannah grasslands”, a paint job that does little to disguise the oil company’s whitewashing of ecological damage thanks to unscrupulous consultancies.
Black Box
In March 2024, Mediapart asked TotalEnergies, unsuccessfully, to consult the final Biodiversity and Ecosystem Services Management Plan for the Tilenga project.
When contacted by Mediapart on January 21, 2025, Biotope and The Biodiversity Consultancy did not respond. TotalEnergies sent us a written response, which can be read in full in the appendices to this article.
“GreenFakes” is a series of investigations conducted by Mediapart, published in partnership with Mongabay and Africa Uncensored. They are based on internal documents from Biotope, leading French ecological auditing firm, obtained by Climate Whistleblowers, an organization specializing in the protection of climate and environmental whistleblowers.
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