Hemantha Withanage
Executive Director, Centre for Environmental Justice
Centre for Environmnetal Justice is a public interest
environmnetal organisation based in Sri Lanka established in 2004. CEJ fied
legal action against the Colombo port city in 2015 since it has violated the
EIA process in Sri Lanka. This article
was produced based on the comments made by Mr. Hemantha Withanage, CEJ Dr. Mrs. Heidi W.
Weiskel, ELAW, and Mr. Indika Rajapaksha,CEJ to be distributed at the symposium
organized by the Alliance against the Colombo Port city held on 27th
January 2018 in Negombo.
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Colombo
port city is a major infrastructure facility in the BELT ROAD PROJECT of China.
It is considered as the third strategic point since Sri Lanka is located along
the east-west shipping line. It would have been beneficial for the Sri Lanka,
if we could enter into a better deal
understanding our significance in this strategy. However, Sri Lanka entered
into this deal as a highly indebted nation and therefore Sri Lanka does not
have much leverage.
The
dream annexed city called Colombo Port City will have a major administrative
and benefit sharing issues. It is proposed to run under new regulations and as
a financial hub which details are not yet publicly available. Both Rajapasksha
regime and Maithree-
Ranil
regime have so far failed to become accountable to the public on this annexed
city. Despite its legal economic and social impacts, the environmental impacts
have not been addressed under the prevailing laws in the country. Infact it is
a highly greenwashed project by the respective agencies including the CCD, CEA,
UDA, GSMB, and the academic community specially from the university of
Moratuwa. This project was highly politicized during the Rajapaksha regime due to
the China bias foreign policy in related to the historical relationship during
the war period and therefore there was no space for the government agencies or
academics to make an independent opinion.
On
16th December 2014 Prime
Minister, Ranil Wickramasinghe, announced
that “the new government, would scrap
the Colombo Port City Project, because it would end up destroying the coastal
belt from Negombo to Beruwala.” Therefore, he himself aware of the
environmental impacts. However, he twisted the situation due to the circumstances.
The
project under the previous regime planned to fill an area of 235 Ha, however
become 269 under the new proposal. However, the total area of filling will be
more than 300 hectare including the 2 canals in the project area and the total
“footprint” could be approximately 485 hectares or 1200 acre of the sea.
UNSTOPPABALE SAND MINING
According
to the supplementary Environmental Impact Assessment, 65 million m3 of dredged
sea sand will be required. It may be minimum 75 million according to experts.
However, considering the 15-20% wastage during suction dredging [which will
wash away and deposited on the coral reefs in the area destroying the fishing
grounds] the total sand mining requirement will be more than 90 million m3.
Further to this, once the project completes it will still require sea sand to
maintain the proposed beachfront and the marina, which will be amount to
300,000 m3 annually. This is not shown in the above figures including where
this sand will be mined.
BIODIVERSITY AND LIVELIHOOD IMPACTS
This
location currently provides livelihood for 15,000 fishermen. The sand mining
area is approximately 150 sq. km protected by three weathered sandy rocks
protecting beach from Colombo to Negombo. According to the previous studies, the
area has four reefs, whose species are generally of low diversity and
abundance. All are significantly influenced by sediments from the Kelani River,
with high turbidity as well as accumulated sediments on the reef surface. The
density and diversity of colonization by corals is generally very low,
typically 85% uncolonized. Only one species (damselfish) Pomacentrus proteus is
endemic. A total of 53 fish species and 4 shrimp and crab species were identified
in commercial catches landed at Modera Fish Harbour.
EIA report on the building
construction produced in October 2017, states that Palagala, Vatiyagala has
been recently recovered completely.” However, according to the fishermen in the
area this is not true. Further, coral reefs from Colombo to Negombo area has
been severely destroyed by the port city project due to sand mining.
CORAL REEFS
The heavy
reliance on reef balls to replace the habitats that will be lost as a result of
this massive dredge/fill/build project is concerning. There is not a lot of
evidence in the literature that artificial reefs are successful, let alone a
successful substitute for a functioning nearshore reef, which is what will be
destroyed in this project.
It is evident
that no pilot tests were conducted to determine whether and how artificial
reefs would perform in this area. The entire section about the usefulness of
artificial reefs is pure speculation, which seems irresponsible when the
proponents know the high productivity and value of the existing reef.
COASTAL EROSION
Coastal erosion has been experienced during
the dredging in this area. It is assumed that this project will destroy the beaches in the Western province from
Mount Lavinia to Negombo due to the coastal erosion. It will also destroy the coral habitats, nesting grounds
and the fish resources in these areas.
ROCK MATERIAL
3.45 million m3 of rock material will be mined from 11 quarry
sites in Kaduwela, Korathota, Divulapitiya and will be transported damaging the
road and crating nuisance. They
will use 300 tipper lories twice a day. This will add 1200 times of trips up
and down which all will cross at Kaduwela town daily. These projects have
already created many environmental impact and public nuisance.
FLODDING
According
to the project design the port city could block drainage from Baire lake
outfall and this would cause the accumulation of water on land, increasing the
risk of flooding. We should not forget that Baire remains a polluted water body
within the city.
SEA LEVEL RISE AND CLIMATE PROOFING
It is already evident that climate change has
resulted 0.8 Centigrade temperature rise and as a result experiencing 40 cm sea
level rise. The EIA document has no mention to the sea
level rise due to climate change. The recent ADB report suggested that over
6-degree centigrade temperature rise is unavoidable by the end of this century
due to climate change. This will result significant sea level rise, strong
waves and coastal erosion. Almost one meter sea level rise is evident in some
parts of the world. Therefore, all new EIA reports around the world cover a
significant assessment of climate change. They also have climate proofing in
order to mitigate negative impacts. However, this report has no such study. Therefore,
a serious climate impact assessment is vital for this project.
VALUE OF ROCK AND SAND
The
Port City project will use sea sand worth USD 3.2 billion [Rs.
7000/m3]. Similarly, 3.45 m3 millions of rock material will worth
USD 1 billion [Rs. 4000/m3]. There is no equivalent equity for Sri Lanka in
this project. Therefore, it is not correct to consider USD 1.35 billion Chinese
investment in the Colombo port city as a major investment in Sri Lanka.
The
marina was the only component of this investment, which Sri Lanka Ports
Authority would have operated for making profits. But this has already given to
the Chinese company and no profitable operation is now available for Sri Lanka.
JAYA CONTAINER TERMINAL
The operation of the Sri Lankan own Jaya Container Terminal
which is the only revenue making entity in the Colombo harbor will be given to
the other terminals and the land will be sold to the private corporations.
DIKOVITA HARBOUR
The
EIA is silent on the newly constructed Dikovita fishery harbor. It
is Rs.8580 million (Euro 53 million) project. The impact to this harbor is
necessary to study.
SOVERGNITY OF THE NATION
Sri Lankan sovereignty is under serious risk due to the Chinese
own landmass within the Sri Lankan territories with access to the international
oceans. Whether it is fully own or 99 year lease is irrelevant when the country
loose its control once. Minister Champika Ranawaka was once very concern about
this fact, however ironically, he has to implement the project now.
NO ALTERNATIVES
If
the project is for development of Sri Lanka, there are plenty of other acts
that the government can propose development projects. Rather, the EIA is for a
specific development project is not addressing the issue of local development, but
providing business space for the china’s strategy. The same reason the EIA is
lacking alternatives related to the locations, technologies including
alternative development model for Sri Lanka. The EIA has not identified less
environmentally, socially and economically destructive alternative to the
country. The project Magapolis once considered filling and area of 80 Ha and
keeping it as public beach as there is no public beach in Colombo. We could
assume that the pro Chinese advisors of the current regime defeated this
proposal.
TRANSPORT IMPACTS
EIA
report estimates that daily public transport trips in the Port City will be
increased by about 300,000 which will add more vehicular emissions to the air than the
existing. Even though emission free modes of transportation are promoted within
the port city, still there would be a considerable increase in emission in the
others areas. It further states,
“Study
carried out by CEA projected that level of various air pollutants viz. SO2,
NO2, CO, O3 and VOC have been less than the maximum permissible levels
stipulated by the World Health Organization (WHO). However, a comparative
analysis on PM10 reveals that the pollutant level has relatively been stable
within 70-80 μg/m3. This was found to be much higher compared to WHO guidelines
for which the maximum permissible level is 50 μg/m3.”
According to Ambient Air Quality measurements at Fort
Railway Station in 2014 even
though NO2 and CO maximum concentrations were within local AAQ standard, while
that of SO2 and PM10 were occasionally observed to exceed the respective
standard. (Table 4.1)
The
traffic generated due to the project would make the situation worse, if not properly addressed, this
conditions can create photochemical smog which is hazardous to human health.
Colombo could even become another New Delhi.
NOISE AND VIBRATION
Phase
1 of the project which consists of high rise buildings are close to the land
side. Therefore, within the first few years there will be a considerable noise
and vibration. According to table 5.6 of the EIA report, the noise level around
this area has already exceeded the permissible level (for medium noise area day
time: - 63db night time 50 db) in areas around the project site. Construction
activities, noise of machineries and extra traffic would add more noise.
Vibration
was already a major issue during the last few months. Even the H.E. President
raised this issue during one of the meeting held in the presidential secretariat. The EIA suggest that “Interim standards for
noise and vibration limits have been implemented.
SOLID WASTE GENERATION
The
estimated production of solid waste in Port City is around 375MT/Day at the
year 2040 and at present generation of solid waste in CBD of Colombo is
850MT/Day. Waste separation,3R concept suggested in the EIA are good
approaches. EIA states that the collected solid waste (disposable) during
operational period will be directed to Solid Waste Treatment Plants at Karadiyana,
Muthurajawela, and Aruwakkaru which will be in operation in three years from
now. However, Muthurajawela is an ecologically important wetland and disposing
waste in the area would destroy the ecosystem and associated biodiversity.
SOCIO ECONOMIC ISSUES
Fort
is considered as one of the major economic center in Colombo. With the creation
of port city these economic activities could be diverted into port city area
resulting socio economic issues. Small scale Vendors can be affected. This has
not been addressed in the EIA report.
WASTE
WATER DISCHARGE AND STORM WATER MANAGEMENT
The responsibility of
maintaining the sewerage infrastructure within the Port City will fall on the
CMC, once the internal sewer network of the Port City will be laid by the
developer. The
Estate Management
Company of the Port City needs to discuss on this regard and agree with the
GOSL and the CMC in the future. Mixing of waste water with storm water should
be avoided.
WATER QUALITY
During
the construction period, there is a high potential to generate sediments and
other pollutants which can destroy the nearby reefs and aquatic life. Proposed
Marina is a non-point source of pollution. It is important that measures
suggested in the EIA (table 5.7) to prevent water pollution are implemented.
During
construction activities; dredging, mining, piling, as well as during
construction period; storm water, land runoff and waste disposal can
collectively contribute to general degradation of marine area both within and surrounding
areas of Port City through a number of impact vectors (e.g. salinity changes,
turbid plumes, sedimentation, resuspension, release of contaminants, and
bathymetric changes).
Storm water
runoff which contains suspended solids, petroleum hydrocarbons and other
pollutants can contaminate the lagoon area within Port City and in adjacent
waters would resultant salinity change, increase turbidity, sedimentation and
in long run bathymetric change. Reefs in adjacent sea area get smothered and
burial of macro-benthos as they silted caused by enhanced sedimentation.
Sedimentation also results in the formation of sand bars across the sea outlets
of Port City (lagoon and canals), reducing water exchange with the sea and
leading to an accumulation of pollutants.
Shrimp and fish
recruitment and ecosystem productivity may also affect due to reduce light
penetration, increase turbidity and siltation as fish eggs, larvae, and early
juveniles are more sensitive to pollution than adult fish.” The measures are
presented in enough detail that they can be successfully followed.
MARINE WATER
QUALITY
For marine water quality impacts, however, the
mitigation measures are considerably less detailed (Ch. 5, p. 39): Site runoff
during construction stage might affect the salinity, turbidity and
sedimentation of the adjacent seawater. Poor water quality impacts on benthos
and other sessile or mobile organisms would be short-termed and localized, and
would be self-correcting after rectifying the ill. Mobile organisms affected
could return to the area while the nearby benthos and sessile organisms could
disperse their offspring through water currents and recolonize the area after
water quality gets improved. The following mitigation and compensation measures
are recommended in the EIA.
Ø
Erection
of silt curtains around the point of impact;
Ø
Timing
restrictions/phase of construction;
Ø
Designate
specific enclosed area for maintenance activities;
Ø
Introduce
conservation measures like rainwater harvesting, use of tap with sensors;
Ø
Restricted
corridors of working;
Ø
Proper
management of waste water;
Ø
Flood
control, clogging of waterways and pollution of beaches;
Ø
Construction
of revetments and seawalls;
Ø
Design
storm water management plan;
Ø
Optimizing
construction methods to minimize the overall construction period.”
These briefly
listed measures are unlikely to be effective in reducing impacts for at least
two reasons. First, unlike the freshwater recommendations, there is
insufficient detail included for practitioners to be able to take the necessary
steps to carry out the measures. Simply stating “timing restrictions/phase of
construction” and “restricted corridors of working” does not provide
instructions for anyone hoping to prevent impacts. Second, in some cases the
reasoning is not biologically sound.
Sessile
organisms like corals and sponges that are harmed by construction activities
are unlikely to reproduce, and more unlikely still to time that spawning and
dispersal to precisely coincide with the moment when their offspring might be
able to drift back into the area to find conditions improved.
EIA state that “Mobile
organisms affected could return to the area while the nearby benthos and
sessile organisms could disperse their offspring through water currents and
recolonize the area after water quality gets improved.” However, this kind of
reasoning shows either ignorance or disregard for the biological considerations
of these systems by the consultants. The authors have not adequately addressed
the potential impacts on nearshore habitats, which is all the more concerning
because the area is known to be a lobster reserve.
CONCLUSION
This Colombo Port City project has multiple negative
impacts. The Port City project not even consider the negative impacts ate the
construction stage and the operation stage which could include, water supply,
waste management, energy supply etc. The so-called Supplementary EIA is not
adequate and it has failed to address all those issues correctly and in
unbiased manner. Coast Conservation and Coastal Resource Management Department
is already bias towards this decision. They have a conflict of interest on this
project, which is also violation of the law of the natural justice. According
to our analysis and information the Colombo port city project has too many
negative, social, environmental, economic and political impacts. The project is
burdening the country by committing natural resource beyond the level of
replenishment. Use of the main materials i.e. sand and metal will create
unnecessary demand for the local construction industry beyond the economic and
social benefits of the proposed Port city.
