In 2010, it appears a few senior professionals in their individual capacities had done an Initial Technical Pre-Feasibility Study, focusing on a small-scale development of 200 acres (80 hectares), as had been initially planned. Their report was not comprehensive and considered as a ‘concept note’.
In October 2012, the Chinese Developer had submitted a project proposal to the Board of Investment. It focused purely on the developer’s interests, his return on investment, marketing perspective, funding arrangements, etc. The report does not address the project feasibility at all. However, the project was moved to construction phase without knowing its technical, financial or socio-economic viability.
When work started, there was no infrastructure development plan in place. It is understood that a draft master plan was submitted to the Urban Development Authority (UDA) in late January 2015. It was returned to the developer for further improvement, reports Eng. Channa Fernando (The Sunday Times, 05-04-2015).
The purpose of the Port City
The Colombo Port City is to be an alternative to the highly congested and unplanned City of Colombo. It is advertised as an iconic business district having shopping and water sports areas, a mini golf course, hotels, apartments, recreation areas and a luxury yacht marina.
Environmental Impact Assessment (EIA)
The EIA process is laid down under the National Environment Act No 56 7 1988 amended in 2000 as Act No 53. It is further prescribed in the Gazette No 772/22 of June 24, 1993. The process includes steps the project proponent should take in submitting preliminary information to the Central Environmental Authority (CEA).
The CEA would decide whether the project could be carried out with an initial Environmental Examination (EE) or whether there is a need for further consultations requiring the project proponent to respond, before approval is granted. However, it is not clear whether this requirement has been satisfied with regard to the Port City project.
On behalf of the developer, the Sri Lanka Ports Authority (SLPA) made an initial application for the EIA to the Coastal Conservation and Coastal Resources Department (CC & CRMD). The Concession Agreement places responsibility of obtaining all approvals on SLPA.
The initial application was for the development of 300 acres (120ha). At the request of the Central Environmental Authority (CEA), the CC&CRMD issued Terms of Reference (TOR) for the project’s EIA. In doing so it incorporated some environmental concerns associated also with offshore sand extraction as it is logical for sand extraction and dumping on reclaimed areas to be assessed as an integrated activity.
However, the developer prepared the EIA report through his consultants in April 2011 without impact assessment on sand burrow (mining) areas. Still the CC&CRMD granted preliminary clearance, subject to the condition that the developer will carry out a separate EIA study for burrow areas.
The developer then decided to expand the project by nearly 200 percent from 120 hectares (300 acres) to 233 hectares (575 acres). A lesser known fact is that, although the Port City is set to be 233 hectares in size, the extent of its total “footprint” is a massive 485 hectares or 1,200 acres including waterways and canals.
Strangely, the developer (through its EIA consultant) proposed an addendum to the original EIA without receiving fresh TORs from the CC&CRMD. Thus the addendum was drawn up on self-defined TORs by the developer, who is the project proponent. This was perhaps done for the first time in the history of any EIA conducted in Sri Lanka for a mega project of this nature, states Eng. Channa Fernando.
Two-fold expansion
To date, the quantity of natural resources to be consumed by the Port City has not been disclosed accurately. On the basis of accessible information, experts assess the need for 200 million cubic metres of sand allowing 15-20% wastage (common practice when extracting sand from sea bed) and about 3.45 million cubic metres of quarry (granite) material from the hill country. It appears the project’s sudden two-fold expansion has resulted in extracting an unprecedented volume of this country’s natural resources for a poorly conceived (from Sri Lanka’s point of view) development. This was probably done to achieve an increase in financial return on the developer’s investment at the expense of Sri Lanka’s environment and limited natural resources.
Conflict of interest
Public concern regarding the lack of transparency in the Port City project resulted in the Government appointing an independent experts committee headed by Ajith de Costa to decide on the continuation of this project by analysing the project’s EIA report.
It is reported that Mr. de Costa had appointed Prof. Samantha Hettiarachchi from the University of Moratuwa as one of the members of this committee. Prof. Hettiarachchi is a consultant to CCCC, the project proponent of the Port City. He was also their team leader of the EIA, of which the validity is challenged. This gives rise to a conflict of interest. Hence their report should be disqualified, states Ranil Senanayake, the Government’s Megapolis Advisor.
Concessions for the project
• Tax concessions to China for 25 years. (Sri Lanka will be denied this income for 25 years.)
• The Concession Agreement places responsibility for obtaining all approvals on the SLPA.
• The Concession Agreement states that the Government of Sri Lanka is responsible for providing all service utilities including water, power, sewage and solid waste disposal, telecommunication required for the operation of the Colombo Port City with an estimated population exceeding one million people. (This would place a massive tax burden on Sri Lankans for at least 25 years.)
Is an estimate available for the massive financial burden the Government has to bear as a result of the Concession Agreement with the Colombo Port City?
Water requirement
Large amount of water is needed for its construction on a daily basis which amounts to around 1,000 cubic metres of water per day. Where the water will be provided from remains unanswered. (Does the Kelini basin have the capacity to support this?)
Power requirement
Have the massive energy needs of the Port City project during the construction phase and for its maintenance, when finalised, been estimated?
Has an evaluation of the emissions created and how much fossil fuels will be used for this mega project, which will no doubt impact the already serious situation of global warming, been estimated?
Sewage disposal
The Colombo Sewage Disposal system is now over 85 years old, is over loaded and out-dated and needs urgent upgrading. Two 1.2 km long pipes are dumping untreated raw sewage into the sea from Modera and Wellawatta. The levels of Faecal coliform pollution of our coastal waters exceed the stated international levels for Primary Contact (swimming) and Secondary Contact (boating etc). This situation will be exacerbated by the sewage from the Colombo Port City and will adversely impact our income earning Tourist Industry. It will no doubt be a health and safety hazard to residents and tourists. The Sri Lanka Government will have to invest even further funds to cater to the disposal of sewage from the Port City.
Solid waste disposal
A big challenge for the Government is to find ways of processing or disposing urban solid waste and garbage. A solution to The Colombo Port City’s solid waste will add to the problem and also add to Sri Lankan Tax payers bills.
Sand requirements
Environmentalists’ claim that no proper environmental impact assessment was done with regard to the massive 200 million cubic metres of sand extracted offshore and dumped outside Galle Face to construct the Port City. Without proper impact assessment it will adversely affect our western and southern coast line including Panadura, Angulana, Mount Lavinia, Uswetakeiyyawa, and upto Negombo which are important towns and tourist beach resorts.
Sand mining can erode beaches
When sand is mined in quantity offshore, the affected sea area is filled by coastal erosion, altering the marine diversity. It adversely impacts marine sea bed weeds, depletes mangrove coastal areas as well as sea grass habitats and nesting places of endemic and endangered fauna. To re-sand a 1.5 to 2km stretch of beach requires 300,000 cubes of sand from deep sea at a current cost of Rs. 600,000,000. It would last about two years and be washed to another area, stated a coast conservation engineer.
Coral reefs around Sri Lanka are most important for the safety of this island. They protect the coast from storms and erosion. However they are now under threat from the effects of climate change and land-based pollution.
Sand mining and dumping and its resulting environmental disturbance will seriously affects coral reefs and possibly cause their destruction. Coral Reefs are one of the most valuable ecosystems on earth. A unit of coral reef supports more species than any other marine environment; thousands of creatures rely on coral reefs for their survival. They are the habitat for spawning and nursery ground for economically important fish species.
That sand mining causing the destruction of coral reefs and spawning grounds and habitats of fish is already evident in Sri Lanka.
Sand mining is seriously impacting the country’s fishing community. Fish netted in our coastal waters provide two thirds of the protein consumed by our people. (Sinharaja Tammita-Delgoda, Island 18-11-2015). Sri Lanka is classified as a developing country with a population of 21 million. The majority of the people on this island cannot afford to purchase deep sea fish, the much cheaper and daily netted fish from our coastal waters are their staple diet and to many their only thriving livelihood. The destruction of fishing communities and villages are now taking place: their homes washed away, some have no place even to park their boats because of sea erosion caused by sand mining. This environmentally destructive aspect of the Colombo Port City development could lead to serious socio-economic problems and malnutrition. It is estimated that the number of fishermen directly affected is now in excess of 30,000 in Negombo alone. The overall figure including those engaged in associated trades is estimated to be more than 600,000.
The situation of the fishing community is so desperate that the fisher folk have filed a case in the Supreme Court and they are represented by Senior lawyer J.C. Weliamuna. The Center for Environmental Justice has also filed a case through lawyer Ravindranath Dabare.
Quarry material
The Supplementary Environmental Impact Assessment (SEIA) of the Colombo Port City project states that 3.45 million cubic metres of large granite blocks will be needed for the construction. Experts believe that taking into consideration the magnitude of this project, this amount has been vastly down played. The granite required is equivalent to about two Giza Pyramids and this to be mined from the hill country of Sri Lanka, using explosives.
Brace for landsides
Dr. Gamini Jayatissa (Senior Research Scientist) of the National Building Research Organization (NBRO) states 20 percent of Sri Lanka is mountainous or rocky and one third of our population lives in these areas. He states, “We are already experiencing intensified rain fall in concentrated periods of time and this is believed to be linked to climate change, so we are heading for a period where there will be more landslides.”(The Sunday Times 02-11-2014)
Despite the above warnings, those who produced the SEIA have not considered the impact of quarrying for granite in the hill district using explosives. They have not considered the effect on those living near the quarries and the resulting destruction to the environment including flora and fauna, states Prof. J Katupotha (Emeritus Professor) of Dept. of Geography, University of Sri Jayawardenapura. He states that there is no mention of explosion times, vibrations, possible landslides, and its impact on immediate neighbouring communities, public and private properties.
In view of Sri Lanka’s limited land mass and distribution of its dense population in the hill country, is it reasonable to use explosives and mine such a large volume of granite? Can Sri Lanka afford to risk landslides and endanger the lives of its people by dumping this volume of its granite in the sea to construct a Port City? The destructive effects of landslides, currently experienced are a clear warning that we should safeguard our environment which supports our existence. The Chinese funding of US$ 1.43 billion for the project is provided by the China Communications Construction Company Ltd (CCCC) and the construction work is done by the Chinese Harbour Engineering Colombo Port City (Pvt) Ltd. (CHECPC).
Eng. Channa Fernando states both sea sand and quarry material have “opportunity cost” – an economic term meaning “value of the best opportunity foregone” and the environmental cost of the consequences. The developer has assigned scant importance to the value of these natural resources or its associated environmental consequences.
To assist the developer, the Government has even offered offshore sand free-of-charge. Even the “royalty fee” incurred in using this country’s limited resources has been waived. Eng. Channa Fernando estimates US$ 1.7 billion for even less than half the volume of sand estimated for this construction. Sri Lanka’s investment is thus well in excess of China’s investment for the Colombo Port City project.
Environmental hazard
The construction of the 233ha or 575 acres Colombo Port City adjacent to the Colombo South Terminal will reduce the strength and alter the current flow between the Sri Lanka’s coast and its distal coral reefs resulting in a relatively still body of water. This would cause:
An increase in pollution due to reduced dilution of pollutants.
An increase in the rate of sedimentation, in the now relatively still water.
This would affect our tourism industry. Tourists would desist from entering polluted, faecal contaminated water (1.2 Km sewage pipes open into the sea). It is a health and safety hazard to residents and tourists residing in and around Colombo.
The increased sedimentation of toxic heavy metals (from unprocessed industrial waste) may result in their getting into the food chain via detritus feeders fauna found in coastal waters. Nearly two thirds of the protein consumed by Sri Lankan people comes from the sea. Hence there is a risk that people may consume heavy metals via the food chain.
The above are views expressed by people, environmentalists and experts, as a response to the EIA and SEIA reports on the Colombo Port City project.
It appears that no comprehensive project feasibility study encompassing technical, socio-economic, environmental and financial aspects has been made for this project. Such a study would have identified alternative development concepts and implementations, such as whether it should be full-scale development or one that is phased out. It would have considered the project’s socio-economic benefits and impacts on the country at large, as well as financial returns. It would have also looked into the required upgrading of existing utility services.
The world speaks of sustainable development goals which satisfy the three pillars of social, economic and environmental development. The CPC project seems to violate this concept.
To ignore the views of people whose lives and livelihoods are affected by the Colombo Port City Project is, irresponsible and not in keeping with good governance. We strongly believe that the views of people cannot be ignored by a democratic government.
We urge the President, the Prime Minister and Cabinet to give a hearing to the appeal of the people of our country and to halt the Colombo Port City project or alter the destructive aspects elaborated above, and thereby ensure the safety of our people and our country.