A poorly-researched Initial Environmental Examination Report (IEER) poses a serious threat to Vankalai Sanctuary, situated near Mannar, an invaluable refuge for birds and a unique fragment of Sri Lanka’s biodiversity heritage. It may not be generally known that Sri Lanka was terrestrially connected to India by a wide land-bridge until 10,000 years ago, and perhaps until as recently as 6,000 years ago. When the earliest of our ancestors arrived on this land from India on foot. At the peak of the last ice age, sea levels were some 122 metres lower than at present, converting the shallow sea we now know as the Palk Strait into a 120km wide land bridge that allowed not just the migration of early humans, but also countless species of plants and animals between Sri Lanka and mainland India.
Now the seas have risen and the land bridge is for the most part underwater, preventing the migration of plants and animals between the two landmasses. Except for the birds. Millions of migrant birds continue to use the pathway developed through the eons of evolutionary history to cross the Palk Strait via Adam’s Bridge and winter in Sri Lanka. The route is a vital link in what has come to be known among ornithologists as the Central Asian Fly-way. Millions of birds use it each year, flying down the Indian peninsula and then funnelling through the 4km wide Talaimannar panhandle to reach food-rich wetlands such as Vidattaltivu and Vankalai on Sri Lanka’s Northwest coast.
And it is across this 4km wide corridor that the CEB now proposes to erect a wind farm. As great as renewable energy is, however, setting this wind farm in the middle of the island’s busiest bird-migration route is an idea that is at best, moot. Wind farms kill birds. But no doubt an environmental impact assessment will be published in due course and then we can judge the exact merits of the proposal and he measured proposed to mitigate adverse impacts.
For now, however, what we do have is an IEER in respect of the 220 kv transmission lines that will ferry the electricity generated by the wind farm to the national grid. And it is with this piece of shabby pseudo-science that I wish to take issue here, for the plan calls for the transmission lines to go directly through the Vankalai Sanctuary, which is a site recognized by the Ramsar Convention as one that “harbours more than 20,000 water birds in a given year, including the Northern Pintail (Anasacuta), Greater Flamingo (Phoenicopterusroseus) and the Eurasian Wigeon (Anas Penelope), of which Vankalai Sanctuary supports 1% of the population of the latter two species” (www.ramsar.org/vankalai-sanctuary).This area is among the richest (both in terms of species and numbers) three or four water bird habitats in Sri Lanka and a vital gateway for migratory birds travelling between Sri Lanka and India. It is a potential future national park and its landscape should be preserved as a national heritage. So important a site deserves better than a poorly-conceived and shoddily evaluated IEER such as the one that has been presented by the CEB. The IEER authors have overlooked several material facts in arriving at their poorly-considered conclusions that in effect rubber-stamp this project. The object of an IEER is to iterate environmental risks, assess how they may be mitigated and conclude whether those risks are effectively mitigated, the project should be implemented. However, the IEER fails at the very outset by not making a reasoned assessment of the risks, as the text below demonstrates.
The report (page7) concedes that “Transmission line passes through Vankalai Sanctuary which is also declared as a Ramsar wetland as there is no reasonable alternate route between mainland and island could be found. Construction activities within the wetland may cause adverse impacts on habitats which are breeding grounds for aquatic fauna. As the surrounding area is inhabited by a large number of water bird species, including annual migrants travelling on the Central Asian Fly-way, the presence of towers and conductors possibly along the migration path of birds can have negative impacts including disturbance and collisions, which may result in mortalities of birds.”
By way of mitigation, however, the IEER offers only this (p.8): “For the 7km length of line route that has to be routed through Vankalai Sanctuary will be aligned parallel to the railway track and follow the once existed 33kv line route. Tower foundations within the wetland area will be located in the places where old towers existed.”
Astonishingly, nowhere in this 97-page document is a map provided to show the trace of the proposed transmission line. Will it run parallel to the railway on the eastern or western side of the track? No one knows, for these details are supposed to be in various annexes to the IEER, 17 in all, not one of which is included in the body of the IEER, or even mentioned in the Contents page of the report. Vital details have thus been omitted from the IEER, including lists of plant and animal species in the affected area, the various alternatives traces considered for the transmission lines, the heights of the transmission towers (pylons) and associated cables. Why this secrecy?
What is more, the IEER implies that the proposed transmission line is justified on the trace of a former (now non-existent) 33kv line. However, pylons for a 220kv line are much taller than those for a 33kv line, and the tower footings too, are very much larger. Indeed the IEER concedes that “The project activities during the construction phase will involve clearing of trees along the route alignment wherever required, excavation for installation of towers, erection of towers, civil works related to transmission line and line stringing.” Then the report adds: “Considerable amount of trees will be removed from the project area for RoW of the 35m total width.”
It is therefore irrelevant that the proposed line will follow the trace of the former 33kv line. What is more, the 33kv line did not exist at the time the sanctuary was declared (September 8, 2008): hence the 33kv line cannot be invoked to justify the proposed line. Further, the statement “there is no reasonable alternate route between the mainland and island could be found” cannot be justified as no alternate route has been proposed or evaluated in the IEER.
Bird collisions with transmission lines
The IEER gives only the most disdainful consideration to the problem of bird mortality as a result of collisions with the proposed transmission lines and their associated pylons. There is a rich literature on this problem (for example Ferrer & Guyonnes’ 1999 book, ‘Birds and Power Lines: Collision, Electrocution and Breeding’), which is exacerbated by the proximity of the proposed transmission line to the Vankalai Sanctuary, which Ramsar estimates to contain upwards of 20,000 birds at certain times of the year (counts of up to 1 million birds have been made at Vidattaltivu, nearby: see Warakagoda, D. 2012. Birds of Sri Lanka). It is the exceptionally high density of birds in this area that amplifies the threat from high-tension cables running through the area, in which birds congregate in their thousands.
Yet, the IEER states only (p.7): “As the surrounding area is inhabited by a large number of water bird species, including annual migrants travelling on the Central Asian Fly-way, presence of towers and conductors possibly along the migration path of birds can have negative impacts including disturbance and collisions, which may result in mortalities of birds.” No mitigation, however, is proposed. Instead, the authors write: “Laying a submerged cable by the side of the causeway that exists along the A14 route was considered as a second option in order to avoid possible disturbances or collisions of migratory and resident birds that inhabited the Vankalai Bird Sanctuary with the transmission line. However, excavation for cable laying would cause major disturbance to the ecosystems within the sanctuary including critical feeding habitats of aquatic birds, which resulted in abandoning of this option.” This does not explain why an underground cable is not possible along the periphery of the sanctuary, or even assess the relative impacts of underground and overhead cables. It simply panders to the project proponent by arbitrarily selecting the cheaper option.
"The IEER authors have overlooked several material facts in arriving at their poorly-considered conclusions that in effect rubber-stamp this project. The object of an IEER is to iterate environmental risks, assess how they may be mitigated and conclude whether, if those risks are effectively mitigated, the project should be implemented. However, the IEER fails at the very outset by not making a reasoned assessment of the risks"
Regrettably, the IEER glosses over the aesthetic impacts of the transmission lines with little concern for the Vankalai Sanctuary. “Proposed line mostly traverses paddy fields away from places of scenic beauty and Mountains”, it states (p.71), concluding, “Hence not much impairment of environmental aesthetics and/or formation of hill scars are anticipated. But in doing so, the countryside scenery has been affected to some extent.” No one with even a cursory knowledge of Mannar will ever talk about mountains in relation to its landscape, so the authors’ reasons for this statement are a mystery. Nevertheless, the proposed 220kV transmission line will have a very serious aesthetic impact on the Vankalai Sanctuary, and the IEER gives no consideration to this.
The Vankalai Sanctuary is among the most precious natural resources available in the Mannar area, with immediate economic benefits for the local people as a result of the growing tourism industry in that region. The Mannar Fort, Doric House, Thiruketheeswaram Temple and many other important tourist attractions combine with the area’s rich natural history resources to make it one of Sri Lanka’s highest-potential tourism venues. Indeed, the IEER itself (p.59) acknowledges that “Programmes are under way to position the Mannar district as a sustainable tourism destination and the European Union (EU) has already provided Rs. 2.6 million to fund a feasibility study on tourism development in the region.” Yet, no consideration has been given to the project’s negative impacts on tourism, and especially none to the aesthetic impact on Vankalai Sanctuary as a result of high-voltage power lines running within or beside it.
Community consultation & informed consent
The IEER’s estimation of the local community’s response to the proposed transmission line project is superficial to the point of shame. It states (p. 54) that the local community had “No objection to the project if it did not affect them adversely and particularly the health of the people.” However, the questions that arise from this are, for example, was the local community told that (1) they would have no direct economic benefits from this project, which is in fact intended to convey wind power generated on Talaimannar to southern Sri Lanka? (2) That the aesthetic environment of the area of the transmission line, especially Vankalai Sanctuary (an important local environmental and tourism asset), would be negatively affected by the project? The IEER makes no mention of informed consent by the local community, and as such it must be assumed that no such consent was obtained.
Areas such as Mannar have been long neglected as a result of LTTE’s terrorist activities in the island’s north. As a result, ancient sites such as Maantai, the fort-city that connected Sri Lanka to the world from pre-Roman times, have already been desecrated, most notably by the construction of a housing scheme on top of what is an archaeological site of global relevance. Tourism is unarguably among the greatest resources left to the local people in this otherwise resource-poor area. And the destruction one after the other of its tourist attractions, including the planned defacing of Vankalai by the proposed transmission line, is a national disgrace. What tourism potential will be left of this site with high-tension lines running through it, strewn with dead birds under it?
Legality under FFPO
Finally, the Fauna and Flora Protection Ordinance (FFPO) is very clear on what is and what is not permitted on a sanctuary declared on state land. Section 7(1)(c) states: “No person shall, except in accordance with regulations, in any State land within any Sanctuary— (i) fell, girdle, lop, tap, burn or in any way damage or destroy any plant, or take, collect, or remove any plant there from; or (ii) clear or break up any land for cultivation, mining or for any other purpose”. The IEER states (p. 8) that “In order to reduce the loss of Palmyra trees along the exit corridor, line route has been carefully aligned after identifying sparsely vegetated areas, with the aid of satellite images.” These satellite images have, however, not been reproduced in the IEER. Neither is there a detailed map of the line route. Why? What is there to hide?
Further, the IEER repeatedly concedes that trees will be felled along the trace, which directly contravenes the above sections of the FFPO. No regulations exist with regard to the felling of trees on state land within any sanctuary. In the absence of such regulations, there is no provision for the Department of Wildlife Conservation to permit this project to proceed within the sanctuary. Also, given that the exact transmission line route has not been illustrated through a map or GPS coordinates, it leaves the project proponent free to select a line route of his choice after environmental clearance. This negates the purpose of the IEE.
In conclusion, I maintain that the proposed trace of the transmission line through or near Vankalai Sanctuary should not be allowed. As shown above, it is illegal under the FFPO and there is no provision for the Wildlife Conservation Department to sanction it. Further, it negatively impacts the tourism (especially nature-tourism) potential of this region, which is urgently in need of economic development and the full utilization of all its natural resources for the benefit of the local people. Finally, the IEER provides almost no evidence that the unique natural heritage offered by the Vankalai Sanctuary will be preserved as a result of the project, especially with regard to bird strikes with the proposed transmission line.
This is a matter of urgent national importance and there needs to be a public debate on this plan. I hereby volunteer to defend the proposal that “There should be no overhead transmission line through Vankalai Sanctuary”. Now there’s a challenge. I hope the project proponent and the authors of the IEER will take it up.
Author Rohan Pethiyagoda is an electrical engineer and biologist and a managing trustee of the Wildlife Heritage Trust of Sri Lanka as well as a Research Associate of the Australian Museum, Sydney. He is a former Deputy Chairperson of the IUCN Species Survival Commission whose conservation work has been recognized also by the Rolex Awards for Enterprise. He has published several books on Sri Lanka fauna and flora in addition to more than 50 biodiversity-research papers in international journals.