9 th December 2019
Department of Coast Conservation and Coastal resource management
4th Floor, Ministry of Fisheries Building,
New Secretariat, Maligawatta, Colombo 10
Subject: Comments on EIA of The Proposed Rehabilitation of Port of Kankesanturai (KKS) in Jaffna District
Centre for Environmental Justice is a public interest environmental organization based in Sri Lanka established in 2004. We herewith send our comments to the above EIA under the request for public comments as per the section16 of the Coast Conservation Act (No. 57 of 1981).
The EIA report does not provide any economic analysis to prove the fact that this project would be economically feasible. For example information such as number of expected trade ships, expected saving in terms of money by developing this port are missing in the report. Therefore, Cost benefit analysis must be done. Terms of reference (TOR) given by Coast Conservation Department also request an Environmental Cost Benefit Analysis.
Is this the development ,the people living in the area expect from the government. Or something else. Report mention that the total fishing population in the KKS west FI Division in 2018 was 1934 and of them 439 were active fishermen. May be a fishing harbor might bring more economic benefits. Therefore a feasibility study should be conducted before the Environment impact assessment.
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