9 th May 2018 

Director General, 

Central Environmental Authority, 

104, Denzil Kobbekaduwa Mawatha, 

Jayawardnepura, Kotte 

Dear Sir, 

Comments on EIA report of Proposed Ruwanpura Expressway 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. 

Damage due to clearance of vegetation 

An area around 1200 km2 will be cleared for the project area which will directly affect the environment due to loss of habitats for fauna. There will be no re growth of vegetation in the road trace.(4.44 km2) This damage will be permanent. EIA report has calculated the cost for the loss of carbon sequestration value is SLR 99.04 million per year in 2015. Therefore a well- managed forest should be planted in compensation for this loss. I suggest catchment areas of the streams flowing in the area for this purpose. 

Raw material requirement 

Table no 2.6 of the EIA report predicts the material requirement for the project. Most of the filling will be done at stage 1 from Kahathuduwa interchange to Ingiriya. Soil requirement for stage 1 alone is 2,914,438 cubic meters. This requirement should be fulfilled from nearby areas. New quarry sites and soil borrowing sites will be established. A significant environmental damage will happen. Hilly areas will be excavated. Unstable cut slopes will collapse and nearby houses will be in risk. Water resources will be depleted. The same has been experienced during Colombo –Kandy Highway construction. 

In addition to that, preliminary design information reveals an approximate quantity of around 1.1 million meter cubes of unsuitable soil generation due to soft ground treatment and other activities. According to the EIA report, this soil will be transported by the 

contractor to sites identified by Divisional Secretariats of the area under the supervision of RDA. Steps should be taken to dispose all the amount of soil according to that procedure and no soil shall be dumped at lowlands. 

Increase in Flooding 

The extra flood lifts and delayed flood recession that would be created (if unmitigated) by the expressway will have impacts on social and ecological environments.Hydrodynamic model studies have been carried out near Kalu river and Kalu Ganga Athu Oya (Near Kahathuduwa) floods. But solely relying on flood levels predicted by the model is not acceptable. Historical data is available only at Ratnapura and Ellagawa of Kalu river. Flood levels should be studied extensively along the trace. 9.52 km length of the highway runs on viaducts to minimize the increase in flooding. It is a positive step towards minimizing floods. 

Cut slope failure, landslides and collapsing of tunnel inner lining 

The corridor of the road trace is having the potential of receiving high rainfall throughout the year which act as a triggering factor for landslides and slope failures. Section 2 and Section 3 is the most vulnerable sections.(Ingiriya to Pelmadulla). Number of mitigation measures has been suggested in the EIA report. But the actual implementation of all these measures is questionable. 

Agricultural value of Land 

A significant amount of arable land will be lost.( Paddy, Tea, Rubber) In addition to the direct loss of paddy lands, some lands will not be able to cultivate due to the unavailability of water with the changes in irrigation schemes. This has not been accounted in the cost benefit analysis. 

Impacts on flora and fauna 

Fauna will be significantly affected by habitats fragmentation. Four ecologically important sites have been identified close to the highway trace. Kodigahakanda sanctuary, Bodhinagala forest reserve, Pompa Kele forest reserve, Kiribathgala forest reserve. These forest areas should be strictly protected from project activities. Streams flowing from Pompa Kele forest reserve are the sources used by National Water supply and Drainage Board to provide water to Ratnapura town area. 

79 endemic flora species had been found which is 12.6 % of the total plant species. Canopy trees were also among them such as Canarium zeylanicum, Vateria copallifera and Dipterocarpus zeylanicus. Two possibly extinct species had been found during the survey Rinorea bengalensis, Flemingia macrophylla. These species should be conserved. 

80 endemic fauna species had been found during the survey out of 392 total species identified. Among them, there were 4 mammals, 7 birds, 13 reptiles, 15 amphibians, 22 fish , 8 butterflies and 11 dragonflies. Building animal underpass at required locations with appropriate distance is essential as mammals, Reptiles and amphibians cannot move across the highway. But it seems that the conducted biodiversity survey is not detailed enough to take such decisions. 

In conclusion, I must say that this highway is not something the country needs the most. It has been proposed across an area where there is a railway line functioning which has the potential to develop and modify. 

I hope that you will consider these comments before granting the approvals for the constructions proposed under this EIA. 

Sincerely yours, 

Signed 

Indika Rajapaksha, 

B.Sc.(sp) Environmental Science 

Centre for Environmental Justice 

.