05th March 2024
Director General
Central Environmental Authority
Parisara Piyasaa 104, Denzil Kobbekaduwa Mw.
Battaramulla
Comments on the Environmental Impact Assessment (EIA) for the proposed 250 MW Mannar Wind Power Project (Phase II)
Centre for Environmental Justice is a public interest Environmental organization based in Sri Lanka established in 2004. We have been involved in monitoring the EIA process in Sri Lanka and also engaged in the training of government and non-government staff on the EIA process in the past two decades. We have been working with the people in Mannar over the past 5 years in relation to environmental conservation as we found the island is a very sensitive habitat that is facing severe impacts due to the various development projects and is also highly vulnerable to climate change.
1. Inadequate Terms of Reference
Mannar already has a 100 MW Wind power project operate by the Ceylon Electricity Board. CEB also has studied for a second project parallel to the existing project. In our understanding, this EIA is for the 3rd project coming to Mannar Island. However, we don't see that TOR has specifically requested a cumulative impact assessment. This is one of the significant weaknesses we found in this TOR.
2. Lack of study on the cumulative impacts
The annex document carried an Avifauna study and page 40 state
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“The key result of the cumulative assessment is that the Mannar II wind park would not make any material change to the cumulative impacts for Mannar I and the transmission line, as it would contribute only a small additional risk. The main avian collision risk comes from the transmission line.”
We disagree with this statement as the existing project located only one line of turbines in the southern coast of the island while the new 250 MW Adani wind power project will lay 52 turbines in the entire island.
Further the EIA page 183 states
“ The project proponent, SLEA, has serious concern on the issue and it is now engaged in negotiations with the relevant agencies to resolve the matter amicably. The land that was declared for mineral sand mining can remain and successful implementation of both projects could be achieved without compromising their individual objectives. However, a safer buffer zone for each affected turbine will be specifically decided after geotechnical investigations.”
To our information an Australian mining company has bought almost 3000 acre land in the Island and the exploration license has been given to an Indian mining company Mars Minerals and Metals in both the southern and northern side of the island. ( see below)
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We have learned that these projects also will go ahead, and the cumulative impact will be very high for the fauna and flora as well as the basic human needs such as water, land etc. Therefore we demand that a proper cumulative impact assessment be carried before considering the approval of this project.
3. Damage to the migratory birds in the Asian Flyway are significant and proposed bird corridor is a greenwash
We have been involved in advocating the Ceylon Electricity Board and the Asian Development Bank in relation to the ADB funded 100 MW wind power plant and this intervention resulted in installing an emergency radar shutdown system with extra cost( 0.8- 1 million USD) due to the project being located in the central Asian Flyway. As we know Mannar is the most important wintering wetlands for migratory birds in Sri Lanka.
Central Asian Flyway covers 30 countries of Asia & Europe and Sri Lanka is the last destination for over 15 million birds to migrate through this flyway. According to the scientists, Mannar alone gets about a million birds representing 150 species. As Sri Lanka is a party to the UN Convention of Migratory Species Sri Lanka should protect them.
Mannar is the most important location for the wintering waterbirds, including 20 globally threatened species that reach up to about one million birds. For this reason, Mannar is recognized as an important location and Vankalai wetland has got the Ramsar status. Mannar
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also provides breeding habitats for eight species of seabirds, many of which are listed as Critically Endangered (CR) in the national Red List of Threatened Species.
The research conducted by the Sri Lanka Waterbird Tracking Project conducted by the University of Colombo has gathered critical information and shows the strategic role of Mannar within this asian flyway. Unfortunately, the EIA does not highlight the real impacts on the birds when it proposes a bird migration Corridor as a mitigation.
We reject the bird study in this EIA report for the following reasons.
● The bird observations were done by observers walking in the forest – on foot – during the daytime from 6 am – 6 pm, while the majority of the movement between protected areas happens during the night between 6 pm – 6 am.
● The EIA did not cover the critical Migratory Period of birds during this study. Therefore, the observers failed to see the movement of large numbers of birds, as resident birds typically do not move in large flocks in Mannar.
● According to the bird researchers the globally accepted technologies for the study of bird movement were not used to map the movement tracks.
● Even though the EIA report states that a thorough review of information is done, the publicly available and widely circulated information on movement patterns of critical species of the Central Asian Flyway in Mannar mostly done by the University of Colombo was not referred to and seems ignored.
● The proposed narrow ‘movement corridor’ for millions of migratory birds seems highly arbitrary and lacks support from currently available information in the EIA report. No study or Data supports the proposed corridor which is clearly a greenwashing.
Further, it is important to understand why Mananr has become a key entry point for migrant birds. To our understanding, it provides the required habitats for them to rest after a long journey and facilitate their further stay. This is mainly due to the water environment including lagoons, freshwater lakes etc. Therefore moving in between such habitats is necessary. In a condition that the whole Mannar island is accommodated with wind turbines, it makes it very difficult for them to move around.
According to the data reported in Thambapavani solar park, the most affected birds due to turbines were raptors such as Brahminy kites. However, water birds had been impacted due to the transmission lines. It is wise that the proposed solar project has avoided transmission lines.
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The EIA report justifies the feasibility of the wind park as the period with high wind does not coincide with the bird migration period. However, the above data in the table indicates otherwise.
Source - Environment Monitoring Report- Thambapawani WInd Project
“According to the bird collision risk assessment the collision impacts are minor. However, as this project is spread in a large area possible localized conditions may change the predicted bird collision risk. Also, in the case of Thambapawani Wind Power Project, higher bird collision risks than predicted have occurred, as there are reported bird collisions in the transmission lines. (Executive Summary Page XXI)
Based on the results of the post construction monitoring of the existing Thambapavani wind farm, indicates that collision risk for migratory species that arrive at Mannar island in large numbers in a dispersed passage is comparatively low compared to resident birds. Out of the 139 carcasses recorded representing 24 species, migrants accounted for 6 collisions (4%) representing 4 species (16%).”
We are surprised by the fact that fewer migratory birds have been affected by the turbines. Mannar’s role in the waterbird-rich Palk Bay region has been brought to light by the findings of CAF-SL Waterbird Tracking Project conducted in Mannar. The over-wintering & over-summering
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migratory birds were observed to regularly move between Mannar & South India along Rama’s Bridge, through the Jaffna peninsula or directly across the Palk Bay.
The major movement corridors of waterbirds across the Palk Bay and Gulf of Mannar, as revealed by tagged birds under CAF-SL Waterbird Tracking Project are ; (A) along the northwestern coast from Mannar via Iranativu Island, Jaffna peninsula across Palk Strait to Point Calimere and above, (B) along Rama’s Bridge Island chain via Dhanushkodi to Point Calimere and above, (C) direct northward route across Palk Bay and (D) Mannar to Dutch Bay across Gulf of Mannar (Source: CAF-SL Waterbird Tracking Project)
The tagged birds have revealed the heavy connectivity of key wetlands in Mannar Island. The birds fly from west to east and vice versa across the island daily. They connect Rama’s Bridge and Urumalei mudflat, Korakulam tank, Erukkalampiddy lagoon, Vankalei Sanctuary and Vidataltivu Nature Reserve in Mannar. All these are critical wetlands recognized internationally (by CMS) and nationally by the Department of Wildlife Conservation (DWC).
Examples of movement along the northern coast include: nationally Critically Endangered (CR) Crab Plover & globally Threatened Bar-tailed Godwit, The rare & nationally CR Crab Plover’s heavy usage of the northern coast while moving between their two most widely used sites in Mannar: Rama’s Bridge & Erukkalampiddy Lagoon.
As the proposed 250MW wind farm covers the entire northern half of Mannar island that falls between the Adam’ Bridge Marine NP & its buffer zone & Veditaltivu NR & its buffer zone, the
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proposed wind farm can severely affect the aforementioned movements. Installation of a radar based automated early warning system for detection and mitigation of bird collision risk together with several other mitigation measures indicated in the Section 5 is not very effective due to the low estimated plant factor of 41.83 %.
In the alternative analysis, EIA has explored only site alternatives, design and technology alternatives, and logistics alternatives. Considering the high level of socioeconomic and biological impacts, it is needed to explore offshore turbines during alternative analysis. This will address many bird related issues or reduce the number of turbines which will be installed.
This Adani project, which has spread all over Mannar island, has allocated only 253,968 USD for the Emergency Radar Shutdown system. We are not clear how many Radar systems they will install with this little money. We have learned that CEB wind project has one horizontal and 2 vertical radar systems at the cost of 800,000 USD to 1 million USD. Considering the
huge land area, phase II might require more systems to install. Since there is no design available, we consider this proposal is just for greenwashing.
4. Transmission Lines and Proposed Bird Corridor
Transmission lines pose a significant threat to birds and bats and it’s unclear from the EIA where they will be located. The EIA reports on page 22 that the monitoring study of the existing Thambapawani Wind Power Project noted, “higher bird collision risks than predicted have occurred, as there are reported bird collision in the transmission lines.”
Pg 203 of the EIA also notes,
“the number of carcasses recorded during the post construction monitoring of the existing wind farm and transmission line across Vankalai Sanctuary indicate that bird mortality due to the transmission line (235) is much higher than what is recorded at the wind farm (139).”
Conflicting references are made to the use of underground cables and transmission lines, for example:
Page 245 – 5.4.1.1 Reducing death and injury to birds and bats due to collision states, “…the transmission lines connecting the turbines, turbines to the collector station and collector station to the Nadukuda grid substation will be placed underground as much as possible to prevent creation of a barrier effect.”
Figure 2-19 shows the cable route/transmission line layout crossing. However, Figure 3-10 shows cable crossings are planned in areas of high flood hazard, which would indicate underground crossings may not be feasible.
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Figure 3-27 shows the proposed bird corridor with access road crossings that correspond to the cable and transmission lines in the above figures. If cables cannot be installed underground, they will cross the proposed bird corridor.
This likelihood is recognized in the EIA on page 208:
“Nevertheless, there is an impact posed to the proposed bird corridor by overhead power cables, which intersect the designated bird flying path at four specific locations. This causes a potential barrier effect for avian species, impeding their natural flying trajectory and increasing the risk of collision and electrocution.”
Even though the EIA report proposed a narrow ‘Bird Corridor’ at the interior of the island, GPS tagged birds in the Mannar Island show a wide use of the northern coast while moving between the Protected Areas in Mannar (Adam’ Bridge Marine National Park, Veditaltivu Nature Reserve and Vankalei Sanctuary).Therefore,The Environment Impact Assessment (EIA) on the proposed 250MW Wind Power Project (Phase II) grossly devalues the importance of Mannar
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5. The project put the energy Sovereignty of the country at risk
Although the Sustainable Energy Authority has been given the TOR it is only a proxy project proponent. As we know, SEA is taking environmental clearance for the Adani company, an Indian tycoon, to enter Sri Lankan energy generation. They will have 6% of the control in the energy sector, and with Adani's second power plant in Poonariyn, they will have 12% control of the Energy Generation in Sri Lanka. We also know there is ongoing negotiation to connect India and Sri Lanka through a transmission cable. This will seriously compromise the Energy sovereignty in Sri Lanka.
Although Sri Lanka has developed most of its energy projects through loans obtained from various multilateral financing institutes and governments, it has not affected the country's energy sovereignty. Except for a few individual power producers who produce small-scale electricity using diesel, mini hydro, and wind. etc However, this project is different from previous projects as it is planned as a Build Operate and Own type project. This means Adani Private Limited will hold the project ownership and the Indian government is backing the project from the behind. Further, it was circulated in the news that CEA /Government of Sri Lanka has still not finalised the agreement between the Adani group. Therefore financial gains through this project for the people of Sri Lanka is still uncertain.1 Committee appointed by the Cabinet of Sri Lanka on this matter has questioned the higher unit cost.
6. The proposed wind park is not in line with the UDA development plan
As stated in the paragraph 3.6.1.2 of the EIA report the proposed wind park is not matching with the UDA plan which questions the legitimacy of the project.
“In the "Mannar Urban Development Plan 2021 to 2030" (Gazette No. 2236/24 - July 13, 2021), the Urban Development Authority (UDA) recognizes and suggests that the current township of Mannar urban council area serves as the administrative capital of the Mannar district. The urban council region, which will be included in the future growth of the township, is considered as the island's beating heart. It will be designated as the Central Business District and will continue to function as the district's administrative hub, alongside its significant role in business activities.
The UDA's Plan also emphasizes the crucial role of fishing and renewable energy in Mannar's sustainable economic growth. A considerable number of fishery-related facilities, such as a port, industrial zone, fishing camps, jetty, and marketplaces, are planned to be developed in the northern region of the island.”
1 https://economynext.com/indian-envoy-hopes-for-timely-progress-in-adanis-wind-power-deal-149664/
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7. The EIA incorrectly states noise impacts and has not studied the cumulative impacts
According to Central Environmental Authority (CEA) regulations, the maximum permissible noise levels are 55dB during daytime and 45dB during nighttime (as shown in Table 3-8 on page 125). The EIA states the noise modeling results at human receptors (residences, and public places) show a marginal exceedance of nighttime noise.
On page 24 and 192, the EIA incorrectly states that 45 dBA limit will only be exceeded under wind scenario 3 (18m/sec), but the noise modeling results on page 192 show predicted noise levels both scenario 2 and 3 have a maximum of 47 dBA:
i Scenario 1 (Variant 1) – Wind Speed 6m/sec 20dB to 41dB.
ii Scenario 2 (Variant 2) – Wind Speed 12m/sec 20dB to 47dB.
iii Scenario 3 (Variant 3) – Wind Speed 18m/sec 20dB to 47dB.
Also on page 192, Table 4-5 shows exceedance of the 45 dBA limit is predicted at 50% of the most sensitive receptors.
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Mannar Wind Power Project - Phase I has built 37 wind turbines near the south coast of Mannar island . Mannar Wind Power Project - Phase I Extension Project has planned 21 wind turbines in the south of Mannar island within 10 Grama Niladhari Divisions within the Mannar Town Divisional Secretariat Division. If newly proposed 52 turbines are also added, Mannar Island accommodates over 110 Wind Turbines. The impact of such a large number of wind turbines will have a cumulative impact on all aspects such as communities and the environment.
In 2010, Nissenbaum et al used validated questionnaires in a controlled study of 2 Maine wind energy projects. They concluded that “the noise emissions of Industrial Wind Turbines disturbed the sleep and caused daytime sleepiness and impaired mental health in residents living within 1.4 km of the two IWT installations studied.”
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Table 3-32 which gives the distance from the nearest house to the tower near the residential areas shows that approximately 151 houses, 53 farm cottages, and four numbers of churches are located within 500 m range. These households could face health risks in future.
The EIA does not consider cumulative noise impacts that could result from the proposed wind farm operating near the existing Thambapavani wind farm on Mannar Island. A recent noise modeling study showed the cumulative noise from two wind farms operating in close proximity
2 Nissenbaum, M. A., Aramini, J. J., & Hanning, C. D. (2012). Effects of industrial wind turbine noise on sleep and health. Noise and Health, 14(60), 237-243.
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can increase the dBA by as much 29% over what would be generated from one wind farm alone.3 Table 3 below shows the results of this study:
8. The project will increase the flood damage and social impacts
According to the local people flooding has drastically increased due to the CEB wind power project especially due to the road construction which was not identified as a major issue then. We believe that this project will further aggravate the flooding in Mannar.
Figure 3-10 on page 109 shows high flooding areas encompassing several turbine sites, access roads, and a substantial part of the main road bi-secting the island. The risk assessment on page 181 indicates the project is in a flood hazard area, with flood risk for turbine foundations on an annual basis. This has the potential to not only impact operations, but could result in further degradation to the environment through erosion and increased sediment runoff from the project site.
Sites have been selected based on micro-siting criteria. However, without site-specific information, it is difficult to approve the environmental feasibility of a site. Site-specific information is not available in the EIA report. Further Satellite images can also be used for decision making. This information is vital in assessing impacts on biodiversity, eco systems etc
3 Josimović B, Bezbradica L, Manić B, Srnić D, Srebrić N. Cumulative Impact of Wind Farm Noise. Applied Sciences. 2023; 13(15):8792. https://doi.org/10.3390/app13158792 https://www.mdpi.com/2076-3417/13/15/8792
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The baseline flood situation could be aggravated by the construction of the proposed access roads, especially in the flood prone areas. This flood impact could be seen in the two dimensional (2D) model simulations. (Executive Summary Page XXIV)
As we have learned there 72,000 people are living in the Mannar island and we believe at least 40,000 people were affected by floods in the past. This project will have negative impacts on these families. However, no funds have been allocated for offsetting flood related impacts at the operation stage. It is clear the company will not be responsible for future flood mitigation work, and the government of Sri Lanka will have to spend public money for this.
8)
Project will destroy the freshwater availability in the Island
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Cumulative impacts due to mining, piling work for windmills, the proposed road network and the drainage and the flooding together will have serious negative impacts on the water table in the area. However, lack of cumulative impacts assessment is a major issue in this EIA.
9. No benefit to the local community
The project proponent has already reached out to fishermen groups to convince them on the project. Except for the improved road network, the community will receive no benefits from the project. However, when Mannar becomes unlivable, there will be no use of roads.
The EIA report expects tourism potential will develop further as they might be attractive for tourists. (Paragraph 4.5.5) This is not really the case. In fact tourism potential may be reduced due to lack of birds incoming. Removal of birds, forests and other wildlife from Mannar will severely impact Mannar’s economy and the potential for wildlife-based tourism that is planned by the Tourism Development Authority and Northern Development framework.
Further non-title holders of lands will not get compensation for their losses. They will only get land development costs and a one-time payment of 100000 rupees. Information on the land entitlement in the project area is not available. Around 4500 people live in the GN divisions where these wind turbines are planned.
Proposed CSR activities cannot be considered as the benefit sharing of the project. Adani as an Indian company and mandatory for companies to spend at least 2% of average net profits made during the three immediately preceding fiscal years (the “Minimum CSR Amount”) on CSR initiatives in accordance with the company’s CSR Policy.
10. Violation of Just Energy Transition principles
The project should respect the Just energy transition concept and destructive green energy projects cannot be considered as a suitable project. A just transition, broadly defined as ensuring that no one is left behind or pushed behind in the transition to low-carbon and environmentally sustainable economies and societies, can enable more ambitious climate action and provide an impetus to attaining the Sustainable Development Goals. From its origins in the defense of the interests of workers faced with job losses it has expanded to include the broader interests of affected communities and other stakeholders, different concepts of justice, and elements of procedural justice such as inclusive and participatory decision-making.
This project clearly does not respect the communities' voices, and meaningful participation is not allowed. It is not a correct project or process.
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11. The Visual pollution due to Wind turbines
The visual appearance of wind turbines makes them very unattractive neighbors. Studies show that property prices are reduced by between 8.8 % and 14.87 % at a distance of 0.5 miles to the nearest turbine.4 EIA does not have adequate information about the land value once the Adani wind power project builds 52 turbines in this haphazard manner.
12. Will Reforestation benefit Mannar community and migratory birds?
The proposed wind farm is located in the best forest areas in central Mannar Island, which serve as vital stopover and refueling sites for birds approaching Sri Lanka. Some of these forest birds continue their migration and fly to key wildlife tourism destinations such as Nuwara-Eliya, Hakgala, Ella and Sinharaja forests. Therefore, disturbance to Mannar can affect bird tourism across the country. These forests are also home to resident species of birds, mammals and reptiles of Mannar and act as the green buffer for the critical wetlands on either side.
The EIA states that the proposed project will not have major adverse impacts on species of flora in the overall landscape. However, according to the EIA , total of 4256 Palmyra trees could be affected to facilitate the installation of the wind turbines in the Hard Standing Area (95mx90m). Additionally, 4981 Palmyra trees will also be cleared to establish the access roads and internal power cables. The number of palmyra trees in the soft standing area is 8822. We consider this as a major change in the tree cover in the island and also have severe impacts to the bird population as many birds use them for roosting and nesting. This aspect has not been properly studied in the EIA.
The residents think that the number of palmyra trees to be removed are much higher as there are many saplings under each mature tree. EIA also states It is difficult to predict the exact number of palmyra trees to be cut site specifically as action will be taken to minimize the palmyra trees to be cut in the Hard and Soft Standing Areas during the construction stage. Furthermore, a total of 260 coconut trees will be affected by turbine construction.
Further, the number of palmyra trees affected by the Thambapavani project was much lower than this.
EIA has proposed an allocation of USD 707,491 for 62 ha of reforestation. However, it has not identified the areas where reforestation will happen. This is very important to negate the impacts of loss of habitats for species. However, such tree plantation will not immediately benefit the
4 Heintzelman, Martin D., Carrie M. Tuttle. 2012. "Values in the Wind: A Hedonic Analysis of Wind Power Facilities" Land Economics 88, 547-588.
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birds and other animals which use those trees as habitats and for nesting. The EIA does not provide which species will have significant negative impacts due to the loss of over 8000 trees.
13. Inadequate study on Alternatives
It’s unclear why Mannar is selected as the only option based on the site evaluation shown on page 91. Given the significance of the site as a critical stopover location for many migratory bird species, a breeding area for birds, and home to 13 critically endangered bird species, clearer justification should be provided for the ranking of the site as a “2” for “site environmental issues,” and as a “5” for “cultural or environmental concerns,” which is identical to the other sites compared.
There are alternative sites in Mainland Sri Lanka with High wind energy potential and less ecological damage. 250 MW wind farms can go there to provide vital energy demand while not compromising the ecological and economic benefits in Mannar Island. Further, Solar power is a highly potential alternative to wind energy. They can be constructed on canal tops, Roadside or rooftops etc. But such technology alternatives have not been considered properly in the EIA.
While we agree that the LTGEP plan 2022-2041 considers multiple renewable energy sources along with other low-carbon technologies to provide green energy to the country for the next 20
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years, this plan has no being subjected to a Strategic Environmental Assessment. Therefore, it does not identify the negative impacts of wind energy in comparison to solar power in other locations. Therefore, we reiterate that the alternative site and technology analysis is highly inadequate in this EIA.
14. Coastal Protection is compromised
Figure 3-2 on page 101 shows a 300 m proposed setback band of green encircling the island and page 115 notes eight wind turbines (T33, T34, T42, T43, T52, T53, T54 and T55) and relevant transmission lines are located within that area. Page 210 further notes that, “Turbines T 33, T 34, T 42, and T 43 are located close to drainage paths towards the sea …”, which could increase sediment runoff from these developed areas. To protect coastal features, it would be recommended to not build turbines in this coastal zone.
15. Unresolved Methods for Transportation of Turbine Parts
The EIA includes conflicting and inconsistent descriptions of how the turbine parts will be transported. Descriptions range from a sea route relying on construction of a temporary jetty (page 23, 72, 79) or a land route with modifications to existing roads to allow passage of the turbines. Given that transportation of the turbine parts is an essential element of the project, the methods should be included and assessed in the EIA for the project. Currently, the Evaluation of Impacts only considers the option of transportation by existing road (pages 174 and 175):
“Long wind tower parts (Tower parts and blades), unloading, storage and transport Option-1-By road Option-2-By sea plus internal transportation- Transportation by road: Social Inconveniences and traffic during construction period from transportation of large wind tower parts including, blades, towers, cranes, and heavy construction machinery or transportation. (Temporary impact during construction)”
In Conclusion,
We strongly oppose the proposed wind project due to its potential for more negative impacts than positive ones on the country. The project poses significant threats to the environment and the communities residing on the island. The Environmental Impact Assessment (EIA) has not adequately considered the combined effects of this project along with anticipated future projects. Additionally, the area hosts unique natural resources and ecosystems, such as sand dunes and mudflats, which could be adversely affected.
We also state that the Extended cost benefit analysis has not considered the cost of the loss of fishery, long term impacts to birds and bird migration and many other ecological impacts.
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Given these considerations, we urge the CEA to conduct oral public hearing/s in Mannar and Colombo according to the provision of the EIA process before making a final decision on this matter.
Thanking you!
Yours’s Truly
Centre for Environmental Justice
Hemantha Withanage ( B.Sc, BioScience)
Senior Advisor
Indika Rajapaksha (B.Sc, Applied Science, M.Sc, Environmental Management) Environmental Officer
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