Friday, May 06, 2011

Uma Oya EIA decision- A lost opportunity

Hemantha Withanage
1st May, 2011

I heard that the Uma Oya project has been approved by the authorities on 12th April 2011. The project is a river diversion. It is controversial more than the Upper Kotmale. Yet there is no debate similar to Upper Kothmale.

There is no doubt that the Environmental Impacts Assessment (EIA) law is not the holy Bible, but a tool for development. If one does a correct EIA, developer can reduce the costs, negative impacts while maximize social and economical benefits. Unfortunately in Sri Lanka, the EIA has been looked as a legal tool only. It has been used to stop the project but not to improve them except in very few cases. This is a serious drawback of the current EIA process. This has lead the political leaders and the bureaucrats undermine the EIA and see it as a negative development tool. Thus, many development projects in Sri Lanka do not follow the EIA process anymore. But the EIA for the Uma Oya Hydropower project was published in Ceylon Daily News of 27th December 2010, seeking public comments.

Uma Oya is a river flows down from the central hills to join the Mahaweli River. It passes through Welimada in the Uva province providing water to large extent of rice fields and other agricultural lands. Under the Uma Oya Hydropower project water will be diverted to Kirindi Oya basin which will take water to Hambantota through a more than 19 km long underground tunnel across mountains in Bandarawela by creating a dam at Puhulpola (in Welimada) and a reservoir in Diaraba. The project cost of headwork is USD 529,059,197 which is equivalent to SLR 60,841,807,770. In brief, 85% of the project cost is provided by a loan from Export Development Bank of Iran and the rest 15% is supplied by the Government of Sri Lanka.

According to the EIA, the objective of the project is to divert water to Hambantota development. The EIA states that, “……..Under this initiative, an International Airport, a Harbour and an Oil Refinery have been taken up for development. These mega projects and the urban and industrial development activities that are expected to take place as a result would need considerable quantities of water in addition to the irrigation and domestic water demands of the region. This project initiative is focused on these requirements”.

But when analyzed the predicted benefits of the project, increased yield of water is only 2% and cultivation of other crops in new areas is 11% of the total benefits of the project. 84% of the benefits are from energy generation. But that aspect has not well covered by the EIA. If energy has recognized as main benefit, this may achieve without trans-basin diversion and many other structures of the project which would result major negative environmental and social impacts in the Uma Oya basin.


Cost benefit analysis

An environmental cost-benefit analysis of a proposed project is essential for decision-makers to determine whether the potential benefits of a proposed project outweigh the project’s environmental costs. An environmental cost-benefit analysis is even more essential for a project of this nature, where the Government of Sri Lanka is planning to borrow several hundred million dollars from a foreign government, and will be obliged to repay the loan even if the project’s benefits do not outweigh the project’s environment costs.

A poor decision will bind the Government of Sri Lanka, and its taxpayers and citizens, to repayment a loan for a project that is also damaging to the environment.

Unfortunately, the environmental cost-benefit analysis presented in the EIA is too deeply flawed to serve as a basis for decision-makers in Sri Lanka to make this determination.

Chapter 6 of the EIA presents a cost-benefit analysis of the proposed Uma Oya Multipurpose Development Project in which the benefits of the project are presented in the following headings and in the following amounts:

As is readily apparent, the benefit of energy generation is alleged predominant benefit of the project, amounting to more than 84% of the project’s total alleged benefits of $221 million per year.

However, the EIA grossly overstates the value of the project’s energy yield. In arriving at a value of nearly $187 million per year, the EIA determined the “cost saved in construction and operation of the cheapest alternative facility that could provide power supply of equivalent quality and quantity to the intended beneficiaries” (Page 284).


Environmental costs

Unfortunately the EIA states that “Certain costs and benefits have not been included in the analysis due to unavailability of methodologies and lack of data.” This includes Impacts on flora and fauna, geological impacts, soil erosion, noise pollution, etc, during the construction stage, River pollution and its long term cumulative impacts on aquatic flora, fauna and humans, clearing of forest areas and damages to ecosystems and functions performed by such ecosystems, including fragmentation, impacts on humans forced into involuntary resettlement, Impacts on wildlife, including endangered elephants and other rare/endemic species, Impacts on aquatic fauna, including anadromous and migratory fish species, Impacts on sites of historical, cultural and religious significance. It is highly erroneous to say that these methodologies ate not available. By not including values for these impacts of the proposed project, the EIA does not contain a true environmental cost-benefit analysis of the proposed project.

If the costs of any of these impacts, either individually or separately, are significant, then the project could be a financial as well as an environmental tragedy. For example, if the project were to lead to the extinction of Sri Lanka’s remaining elephant population, would the production of an additional 231 GW-hr of electricity offset the cost of this tragic result?

Therefore, we consider that the environmental costs of the above are very significant aspects which are totally missed in this proposed EIA and therefore developing an Environmental Impact Assessment fades away.


Fauna

The proposed EIA repeatedly stated the serious impacts to the biodiversity specially the fauna. The project would cause substantial impacts to aquatic life, especially through fragmentation of habitat. The EIA, then, recognize the risk of extinction for migratory species. Among the migratory species who live in the area there are Garra ceylonensis and Garra ceylonensis phillipsi. Both endemic species can run to extinction due to the project . But the impact of the fragmentation of habitats will affect all the species and also the other indigenous species of the area Puntius bimaculatus.

In Section 5.4.7 of Management Actions to Mitigate Impact on Aquatic Inhabitants, it states that “However, these species are available in the other undisturbed tributaries of the country. Therefore, no mitigation is recommended as the fish ladders are very expensive and therefore not practical for this project”.

The EIA categorizes the impact of the project on fauna by stating: “Moderate impact on the animals living associated with Victoria-Randenigala-Rantambe Sanctuary is anticipated. This is due to the diversion of Uma Oya water away from it normal path where this Sanctuary is located. Animals living there can face water scarcity problems especially elephants that are ranging downstream areas of Uma Oya. Similarly other activities that take away wildlife habitats located close proximity to any form of reserve will have an impact on species that are having larger home ranges covering outside areas.”

Especially, the EIA recognize an impact on reaming bears. Sri Lankan Sloth Bear is a subspecies of the Sloth Bear who live in Sri Lanka and who is considered Critically Endangered and its population is considered in decrease by the IUCN. However the EIA states: “Last reaming Bear habitats close proximity to Bogahapttiya area and Slender Loris habitats are also affected.”

The EIA also recognize a strong impact on elephants. Of course there is a current debate whether Sri Lanka has too many elephants that cannot be sustained. The EIA of the Uma Oya project clearly states: “The Uma Oya development project has significant impact on elephants” and “Nearly more than 1500 elephants inhabit the area and majority will be affected covering Hambantota and Moneragala Districts.” According to the recent statistics, this is nearly half of the total elephant population of the country.

Chapter 5.4.4 of the EIA report described the proposed mitigatory measures to minimize human elephant conflict such as extension of Lunugamwehera NP, Yala Block IV, and Manage Elephant Range etc. In the monitoring plan none of the measures have defined for monitoring. Recent incidents clearly revel that relevant authorities fail to translocate the displaced elephants, therefore the mentioned mitigatory measures could not be predicted.


Resettlement

The EIA states the necessity of permanently relocating a total amount of 202 households. Moreover the agricultural lands of 197 families will be acquired for the project and the livelihood of those families will be disrupted. Although in Chapter 5.1.4 states that “Agricultural land holders who lost their lands will be entitled to receive lands in downstream area”, the locations and the distance from households have not mentioned.

Also it states that, around 38% of affected people are farmers, specially vegetable and potatoes which cannot be continued in the proposed resettle areas and they have to shift to a totally different employment of tea. Although 1 acre of land is provided, “it is doubtful” whether they would be able to adapt to the new life.

However, above findings show that the recommendations given in the EIA are not based on the true cost and benefits. It shows that energy benefits have overstated and the environmental cost has underestimated. The recommendations also not based on the adequately considered alternatives and the environmental impacts. I believe the government of Sri Lanka has lost the opportunity to benefit from the EIA process in the case of Uma Oya Diversion.