This post is based on a letter submitted to Minister of Environment, President Maithripala Sirisena; Chairman; Central Environmental Authority; Conservator General, Forest Conservation Department; Director General, Sustainable Energy Authority; Director General, Irrigation Department; Secretary, Ministry of Environment; dated July 30, 2016.
Anda Dola, a tributary of Gin Ganga in Neluwa Divisional Secretariat in the district of Galle is the latest victim of rapidly spreading mini-hydro projects throughout the wet zone. The weir and 2.5 km section of penstock (concrete channel) has been constructed within Dellawa Rainforest which is ecologically part of the Sinharaja Rainforest Complex. Due to construction happening within the protected forest reserve and negligence in part by the developer, the project is causing massive environmental destruction affecting the stream, rainforest, soil and endemic fish in the region. The mini-hydro project will destroy a total 6.5 km stretch of Anda Dola, as water is being diverted off from the weir to the powerhouse several kilometers away. This will result in local extinction of many endemic and endangered fish species recorded in Anda Dola, such as the Barred Danio (Devario pathirana) and Ornate Paradisefish (Malpulutta kretseri). Herewith, we are submitting some of the Environmental and Social Issues, violations and incorrect details on the Initial Environmental Examination (IEE) report of Eaza Hydro Technologies (Pvt) Ltd., for your urgent attention.
1. Incorrect details on Environmental Impact to Endemic Fauna
The IEE report has failed to include many endemic species whose habitat is the stream and surrounding forest used for the mini-hydro project. A report on this matter prepared by Wildlife Conservation Society of Galle submitted to the Central Environmental Authority points out that environmental and biodiversity information including species of fauna on pages 18, 19, 23, 30, 31, 32, 34, 36, 37, 38, 39, 50, 51, 138-151 are incorrect.
2. Social and Economic Issues
Pages ix, 8, 20, 40, 41, 42, 43, 52, 58, 59, 60, 64, 77, 78 on the IEE report prepared by the developer states that only a few villagers are affected and that the Dellawa stream is not used by any villager for drinking, agriculture or any other purpose. The report does not state the negative effect to Anda Dola village, Dellawa village and Ihala Panangala village which are directly connected to the stream. Further, the report states all relevant stakeholders were informed and that everyone understood the project without any objections.
However, a massive protest against this mini-hydro project was held on March 28, 2016 during a field visit by relevant authorities. When District Commitee Co-President Hon. Wijepala Hettiarachchi asked the relevant Grama Niladhari officers if villagers were educated on the project and if they approve this project, GN officers confirmed in front of District Secretary that no such effort has been made.
3. Violation of Forest Ordinance
The weir (6° 20′ 32.9″N, 80° 26′ 39.7″E) and 2.5 km section of penstock are constructed within Dellawa Forest Reserve. Construction activities within a protected forest reserve is a violation of the Forest Ordinance of 1907 as amended and punishable by law.
4. Issues with Construction
According to page 57 of the IEE report, the maximum height of the weir should be 1.5m. This is one of the conditions (A.5) laid out by Forest Conservation Department on its approval letter. However, the actual height of the constructed weir is 2.8 meters. This is a blatant violation of the conditions laid out by the approving Government officers and the project developer should be held responsible for the violation.
5. Failure to monitor and identify environmental issues by approving authorities during construction
According to approval letter issued by Forest Conservation Department, B.10.5 states “A very close monitoring mechanism has to be implemented by the Forest Department to evaluate and monitor the possible negative impacts occur during the project cycle”. However, the actual ground situation has been quite contrary. Not only has the developer gravely violated the condition A.5 regarding weir height, but also violated several other conditions including B.7.4 “Measures should be taken to prevent the discharge of cement, cement mix, fuel oil, lubricants waste oil and polythene into water bodies during construction and operational periods”. During several field visits conducted by Rainforest Protectors of Sri Lanka, evidence of gross negligence related to discharge of cement directly to the stream was observed.
Submitting false reports and carrying out construction violating conditions set forth are grave concerns, in addition to the fact that the weir and 2.5 km section of penstock are constructed illegally within a protected forest reserve.
Therefore, it is shocking to see certain politicians such as Minister Sarath Amunugama and former Minister Piyasena Gamage trying to force the project approving authorities demanding the project be given approval.
Issues with Initial Environmental Examination (IEE) Process
The Initial Environmental Examination (IEE) process itself is highly controversial, especially when it comes to approving mini-hydro projects. These reports are being prepared by the project proponent. Obviously the project developer cannot be trusted to highlight the environmental issues which may cause issues getting their project approved. Further, the IEE process does not allow for public comments unlike the EIA process. Therefore, an environmental disaster is only evident when the project is started.
Public have lost hope on protecting the environment for future generations due to destructive projects such as Anda Dola mini-hydro project being given approval regardless of their opposition. They are voiceless against the rampant bribery and corruption within project approving authorities. The voice of the environmentalists and citizens have been further subdued using thuggery demonstrated by former Minister Piyasena Gamage during the recently held meeting at Dellawa Temple on July 12 to discuss the issues related to this project, during which a journalist had to be hospitalized and one of our volunteer members suffering injuries.
Therefore, we request you to immediately take action against those responsible for the violations below.
1. Producing incorrect details on IEE report.
2. Violation of forest ordinance.
3. Violation of height of weir constructed.
4. Violation of cement discharge to the stream.
5. Lack of transparency and opportunity for public comments on IEE process of mini-hydro projects.
6. Failure to conduct a proper and unbiased Environmental Impact Assessments through qualified and unbiased scientific and technical committee.
7. Use of violence against Media and Environmentalists during public discussion meeting held in Dellawa.
8. External political pressure to approve projects regardless of environmental and social impact.
The Environmental and Social issues of Anda Dola mini-hydro project far outweigh the paltry 0.7 MW energy produced, which can only be achieved during rain season based on rainfall patterns. The 0.7 MW roughly translates to just 0.02% of the current total power generated by the national grid. Therefore, considering the environmental and social issues as well as violations by the project developer, we request you to immediately halt the project, revoke the approvals based on violations, and restore the affected habitat back to its pristine condition as soon as possible.
Rainforest Protectors of Sri Lanka