1st May 2020
Central Environmental Authority,
104, Denzil Kobbekaduwa Mawatha,
Re: Comments on Environmental impact assessment of the PROPOSED KIVUL OYA RESERVOIR PROJECT
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 National Environment Act, No 47 of 1980.
This comment was slightly delayed due to the current CVID 19 pandemic situation and lockdown. We hope you will still consider this comment valid.
NO EIA in Sinhala and Tamil:
It’s the best practice that you have maintained to have the EIA document in all three language. It’s a legal requirement too. We have checked the CEA website for the Sinhala and Tamil copies of the EIA however we found none other than the Archeological impact assessment in Sinhala language. We don’t know whether Sinhala and Tamil EIA copies are available in the said government officers mentioned in the Notice appeared in the CEA website. This notice also misses the usual language stating the availability of the EIA copies in all three language.
There are number of affected rural communities in this area speaks Sinhala or Tamil language only and they are not able to read and comment this EIA without the EIA available in their preferred language.
Therefore, please make sure that they will be given such copies and provide adequate time for the public comments.
No Public consultations:
The EIA only annex a copy of the public opinion taken from the Government officers. It seems no public is consulted during the EIA making process.
Government Policy and wrong feasibilities
The section 1.5 in page 11 gives ample evidence that the feasibility studies and water resource planning for the irrigation projects are not doing right in the past decade or more.
It says that “ The MASL has taken action to settle families in this area since 1983. A total of 3,100 families were settled in the left bank of Ma Oya in Weli Oya area. Some of these families left their lands during the north east conflict, but now they have returned to their lands. Land problem of 2nd and 3rd generation families is also a considerable issue to the government. As such, now the government is faced with the problem of developing livelihoods for those who have come back and also the population who remained during the period of war. There is good potential for an agriculture based livelihood development project in the area, when land and water resources are concerned.
“The government has already recognized the need to develop this area under System L of Mahaweli Ganga Development Plan. It was proposed to supply water through NCP canal under the original plan. However, according to recent water balance studies, it has been realized that water availability from Moragahakanda reservoir complex is not be sufficient to meet water demand required for the development of the anticipated area. Therefore, the water resources planners have to depend on in-basin water resources development rather than trans-basin water transfers. The government has agreed to this policy of in-basin water resources development.”
In our past engagements with the GOSL we have mentioned that Moragahakanda water is not adequate to bring water to the North as they forecasted based on false statements made by the water resources planners both national and international. GOSL has spent millions of unnecessary expenditures and gives false promises to the people and now spend more public money based on the opinion of the same experts.
Both Malwathu Oya and kivul oya seems too new additions based on false information and data. In our opinion there is no much potential for this kind of large project in Sri Lanka anymore considering the forest destruction, climate vulnerability etc. Best solution is to rebuild the ancient tank system to replenish the ground water system. It will reduce the expenditure on concrete canals and large dams and will build small village tank based economies which is more sustainable in future.
Inadequate Social Impact Assessment:
It is interesting to see the statement in para 3.3.6 “There are no major environmental and social issues in the area, except for human-elephant conflict and occasional floods”.( Page 77) CKDU is the only area specific health issue.
Read the full Comment here.