Peoples Movement Against the Port City

64 Old Chilaw Road, Negombo

March 22, 2017

Mrs. Kanthi de Silva

Director EIA
Environmental Impact Assessment Unit
Central Environmental Authority
104 Denzil Kobbekaduwa Mawatha
Battaramulla

Subject: Supplementary EIA Report for the Off-shore Sea Sand Extraction
Project at Kerawalapitiya SLLRDC response to our comments

Dear Mrs. de Silva:

Thank you for the opportunity to respond to the SLLRDC answer to our
comments. At this time we find the crucial consideration is the application in
that answer to a rule of thumb about a site-specific extraction.

It would be possible to look at the current rates of erosion along the

coast through GIS mapping of the shoreline, using available satellite data,
say every five years for 25 years and then roll the projection forwards. The
aim to would be come up with a figure of potential land lost due to erosion
without the CPC, then develop estimates of how much the rate of erosion
would speed up with the extraction of half the Sand Bank at the mouth of
Kelani Ganga.

In so far as we are aware at present the CCD estimates the average erosion
rate is about 0.5 m per year and average accretion rate is about 0.2m per
year. At some locations the erosion rate is higher, for example in the
Palliyawatta area the erosion rate is about 2m to 3m per year. Will not heavy
dredging in 15 m depth aggravate this? The SEIA does not establish with any
clarity if other factors such as storm surge conditions, natural variations in
the sand supply to the coast from rivers, seasonal and long-term variations in
wind and climate, and sea level changes not to mention anthropogenic
climate change will aggravate the erosion in the area.

Are the sand reserves "offshore" based on nothing more than an assumption
that the delineation of "offshore" and "nearshore" processes is approximately
2km? We categorically state that given the ramification of getting this wrong
such an assertion is simply not good enough. It is not scientifically based,
nor technically robust given the huge implications. If the transition point
between "offshore" and "nearshore" processes is 5 km from the coast -
because of the topography of Sri Lanka's coastal shelf (average extent 17 km
 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

- which is very narrow global terms - from where the approximations is likely
to come from) then the sand reserves are part of the nearshore processes.

Our reading of the SEIA and the SLLRDC response gives us the impression
that the SLLRDC has deliberately put the sand reserves "offshore" - so that
they can mine them given the sensitive nature of sand extraction. It is then
incumbent on the SLLRDC to demonstrate unequivocally that there will be no
impact from extracting the sand. Reliance on a legal limit or a rule of thumb is
just not sufficient when they need to provided independent, scientific
validation for the point at which the nearshore becomes the offshore. In any
event this is likely to vary right around the coast, so you would expect this
point to be different in say Colombo and Trincomalee. No doubt this
depends on the linear extent and slope of the continental shelf. Which is
another consideration.

In fact it would have been appropriate to study the wave patterns in the West
coast especially during the South West monsoon by modeling. The
Coast Conservation Department have been rehabilitating the coastline at
several points by dumping boulders etc. The situation on the East coast is
different as the waves replenish the coast.

Here are some photographs of an insufficiently researched intervention:

Kepungoda Harbour history:

2010 Construction

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

2012 filling up nicely

2013 Storm Damage outer breakwater

2015 Changed to just parallel breakwater

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

2017 Note good beach to the south and erosion to the north

In the Sunday Times of July 10, 2016, Ms. Carmel Corea exercising her right
of reply to Mr. Nihal Fernando, Project Director of the CPC & DDG of the
UDA, quotes Mr. Fernando as saying, thousands of metric tonnes of raw
sewage annually discharged to the sea presently. This possibly continues
for 5-7 years.

Ms. Corea continues, His statement was confirmed by Capt. O. L

Samaranayake, Master Mariner and Marine Surveyor. Capt. Samaranayake
stated that the raw untreated sewage outfalls are about 1.2Km from the
beach.

He further elaborated on marine environmental conditions affected by this

massive sewage outfall:

The inshore currents are not strong enough to dilute the effects of the
untreated sewage outfall.
The South West Monsoon winds which affect the sea currents are
mostly westerly or southwesterly and this tends to drive the effluents
(sewage) towards the beaches of Sri Lanka.
The gradual accumulation of sewage inshore will damage the beaches
and marine life.
As a result of Colombos sewage outfalls, it is clearly observed that
the coastal waters remain turbid for long periods of time, even after
the monsoon ends. The reduced light penetration will adversely affect
the marine ecosystem destabilising it. This situation will adversely
affect Sri Lankas income generating fishing and tourism industries.
The turbidity caused by metric tonnes of untreated sewage in coastal
waters blocks the effective light reaching the sea bed, essential for
plant growth and marine life. Under normal conditions even at 15
metre depth marine life and soft corals abound in Sri Lankan waters

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

their survival is now under threat due to massive untreated sewage

outfalls. Can this fragile important ecosystem survive another 5-7
years under these clearly adverse environmental conditions?
Aesthetically the outfall is described as a disgusting sight, identified by
scavenging sea birds constantly soaring over it.
It is suggested that if this situation continues, polluted water will even
enter coastal canal systems, a health hazard to the citizens of this
country.

In view of the above disclosures the Government, we believe, should take

immediate action to upgrade the sewage system which is a potential health
and safety hazard to the citizens of this country. We appeal to President
Maithripala Sirisena, who is also our Minister of Environment, to speedily
eradicate the faecal pollution of our coastal waters.

With respect to the important disclosure by Mr. Fernando, will the UDA
publish the faecal coliform levels in our coastal waters to safeguard the
health and safety of residents and tourists? Faecal coliform levels are stated
as MPN/100. We understand the Primary Contact Level (e.g for swimming) is
internationally at 150/100. For Secondary Contact (e.g boating) the
International level is 1000/100. No doubt, residents and the tourism industry
will look forward to this valuable information important for human health and
safety.

Coastal structures such as groynes, detached break waters, ports etc

interfere actively with the littoral transport and aggravate coastal erosion.
This massive reclamation structure coming up will interfere the littoral
transportation and may aggravate the erosion in the other coastal areas if
adequate studies are not conducted.

If the CPC is created artificially by borrowing (pumping) sand from deep

water and fortifying with boulders brought from quarries inland, there will be
environmental consequences both on land and off shore. According to the
SEIA 2015 the requirement of rock material for land reclamation for the CPC
is 3.43m m3. It further sates that the rock mining would come from 11
quarries in the Gampaha, Colombo and Kalutara districts. The report has
omitted consideration of the enormous quantity of explosives necessary for
such quarrying and the consequenct destruction of the flora and fauna of our
small island.

This is quite apart from the noise pollution, propensity for earth slips and
landslides and the reduction in groundwater levels and obtainable water
supply. The prevailing dearth of groundwater reserves in Gampaha district in
Minuwangoda, Katunayake, Kongodamulla, Divulapitiya, Kotadeniyawa,
Udamitta et al and the Colombo District in Padukka, Meepe, Kaduwela et al
can only be exacerbated.

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

Oceanographers from abroad have carried out detailed studies on wave

movements during the South West monsoon and find that these waves move
north along the SW coast. If there is a large artificial obstruction like the CPC
these waves will strike the coastline and coastal erosion will take place
rapidly destroying the coastal railway line roads etc. The worst effected will
be the hotels that have been constructed on the coastline and there is a
danger of such hotels being destroyed by being eaten up by the waves. It is
also believed that storm surges may be experienced due to such increase
wave intensity and the effects could be worse than a tsunami.

We have become aware of a study conducted by the University of Moratuwa

for a Norwegian Intercon project that included mapping of the Sri Lanka
coast some ten to fifteen years ago. We understand that the Marine
Environmental Protection Authority was handed several copies of this
document. Repeated telephone calls to this Authority resulted in no one
answering the calls but perhaps the CEA may be able to obtain a copy to
compare the coast then and now?

Ms. De Silva on Sunday March 19, 2017 I attended a fisher leader meeting at
Ethukala and I read to them from the document Fishermen Livelihood
Support & Benefit Program. These fishermen represent roughly 1000 fishers.
Firstly they have never seen any part of this document that purports to have
been formulated in consultation with them. Next they do not speak or read
English in which the program has been submitted to you. Are there extant
versions in Sinhala or Tamil that have been circulated to the fisher folk? Can
the CPC project company or any other institution prove the averments of
consultation in that document? As far as we are aware there is no permanent
office of a Fishermens Livelihood Support Society at 6 Mankuliya Road,
Negombo.

While the technical competency of the CPC project company maybe outside
the scope of this submission, the comparison of the Palm in Dubai which is
in sheltered calm waters with the CPC is misleading as there are no intensive
waves that will strike this artificial island. While the China Construction
Communication Company may believe that they have experience in
construction of artificial islands in the South China Sea on atolls and
submerged coral which are shallow, the situation in those seas is that there
are no monsoonal winds like in the Bay of Bengal. Does the project company
or its foreign principle have experience in constructing artificial islands in
seas that are subject to two monsoons like the Indian Ocean.

The Chinese experience with a Port City next to a busy transshipment port
has been horrendous. Please refer to the Deutsche Welle online report
dateline November 9, 2016 headlined China Convicts Dozens for last years
giant explosions in Tianjin in which 170 people died and at least 800 more
were injured.

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

We address the SLLRDCs response as follows:

1. Even if we accept the SEIA as alleged follows the TOR issued by the CEA,
our concern is that that the description of the deposits and delineation of the
area of extraction of the TOR as Off Shore Sand Extraction for the
Construction Industry Kerawalapitiya are scientifically flawed and
misleading.

2. We request the CEA to request further details pertaining to the claims that
it is undisputed and scientifically proven that accretion and erosion as well
as replenishment from rivers are confined to the near shore dynamic areas,
which are typically 2 km from the shoreline. Further research and
investigations from our side have failed to substantiate this claim.

Our research reveals that the term offshore zone is not very well defined.
The definition for the zone is variable for example some sources suggested
that this zone starts from the littoral zone, while others suggested this point is
marked by the point at which the waves begin or from the point at which the
nearshore zone ends.

The SEIA notes that that accretion and erosion as well as replenishment
from rivers are confined to the near shore dynamic areas, which are typically
2 km from the shoreline.

We find this reliance on a general, typical assertion to be of deep concern,

when applied to a specific location in Sri Lanka. What if this location is
atypical? By its very nature this is an unique location on the West coast and

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

the principal location of marine sand deposits. What if the extent of the
offshore zone off the Western coast of Sri Lanka does not conform to typical
profiles for the offshore zone found in undergraduate text books on coastal
processes? Should we be using a rule of thumb to define an area if it is not
typical and is not offshore but part of near shore coastal processes? The
consequences of extracting sand from this zone are then not effectively
described in the SEIA.

The SEIAs failure to research and investigate the actual delineation of the
nearshore and offshore coastal zones at Kerawalapitiya should be of
considerable concern to the CEA. The rule of thumb approach to delineating
the offshore zone as 2 km from the shore, on the basis that this is typically
the case and proposed by the CCD, would be acceptable were the report
being submitted for an A Level exam. It is not and should not be the basis for
demarcating the distinction between these two key areas of the coastal zone
in the SEIA report for such a serious extraction.

As the SEIA points out, of the two the nearshore zones are the more critical,
as it contains the area influenced by nearshore currents, which run parallel to
the shore. These so-called long shore currants are created by the shoreline
processes that run parallel to the shore, arising from the stresses created
within the coastal zone by the wave breaking process of incoming waves,
also known as radiation stresses and by the surplus surge of water that is
carried across the surf zone by the momentum of the waves break towards
the shore. The nearshore zone is again a general definition, which
depending on which source your refer to either stops before or after the
littoral zone.

To recap we are concerned with the application of general definitions to a

site specific, technical report related to sand extraction from the coastal zone.
The SEIA report provides no evidence to support its claim that the sand to be
extracted is located offshore and therefore isolated from crucial coastal
zone processes associated with erosion and accretion of the Western and
North Western coastal line as opposed to being located in the nearshore
zone, other than saying this is typically so. We are concerned that the
typography of the coastal zone off the western coast is not typical and of
the consequences for the Western and North Western coastal line if this is
the case.

Furthermore we feel it is incumbent on the CEA to clarify these technical

definitions with the SLLRDC as the entire report is dependent on defining
these two key areas of the coastal zone one outside the sphere of critical
coastal processes and the other imbedded within it as if the SLLRDC has
inadvertently located the deposits in the offshore zone, whereas in fact they
lie within the nearshore zone and the impacts on coastal processed could
be catastrophic.

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

In view of these concerns regarding general definition for coastal processes

used in the SEIA and as a means of resolving this issue fairly and
scientifically, we request the CEA to seek clarification on this issue by
scientifically defining the depth beyond which no significant longshore or
crossshore processes / sediment transport takes place along the Western
coast from the Kelani Ganga to Negombo, due to littoral transport processes.
This is the crux of the matter in terms of coastal vulnerability to the impact of
further mining of sea sand from the area proposed.

This depth is known in coastal zone terminology as the Closure Depth. The
closure depth is the scientifically delineated seaward boundary of the coastal
zone. Beyond this point coastal processes cease to operate, and oceanic
truly offshore systems take over. The CEA would need to ascertain that the
beach profiles for the coast are consistent with the necessary assumption,
but if so, the closure depth can be calculated using the simple expression:

d1 = 2.28HS,12h/y - 68.5 (H2s,12h/y) / (gT2s)

where dl is the closure depth relative to mean low water-level

HS,12h/y is the nearshore significant wave height exceeded 12 hours per

year,

and

Ts is the corresponding significant wave period.

We would caution that given the overriding impact of the South West
monsoon, that the calculation of the Critical Depth be made based on
parameters available during this period and the boundary of the offshore
zone set in accordance with the coastal geomorphological and hydrological
processes associated with the actual location to be dredged, rather than
general definitions of zones found in text books on the coastal zone.

3. Again we have an approximation of the dynamic coastal zone, rather than

a delineation for the zone based on research conducted at the site proposed
for extraction.

The response assumes the sand reserve is offshore but the SEIA proves no
scientific evidence for this based on site specific studies of the Critical Depth
for coastal processes at Kerawalapitiya

Of what relevance is it that the SEIA proposes to extract less than half of the
sand reserve at the site? Why not extract it all if it plays no role in supply or
storing sediment fed into the processes of erosion and accretion along the
western coast? It is not at all clear what role this sand reserve serves from
the report. It is noted that the sand is a reserve, but a reserve for what?

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

4. We are in the process of obtaining expert review of the studies reproduced

in the SEIAs of 2015 and 2016, the current one under consideration. We urge
the CEA to commission their own independent review of these studies and to
include a Sediment Transport model in their deliberations.

5. Our concerns remains that if the delineation of the location of the sand
deposit based on a general rule of thumb as in the offshore zone is not
applicable for Kerawalapitiya site, for what reason the argument that a
sediment transport model linked to coastal stability is invalid? The proposed
project is to extract sand from the coastal zone. A sediment transport model
linked to coastal stability would surely be prudent if for no other reason than
that the results of the study if negative would effectively silence all
arguments against the extraction of sand (including ours), based on the
scientific findings of a sediment transport model for Kerawalapitiya. The
hydrodynamic modeling that has been completed, would make sense if the
SLLRDC was proposing to extract water. A sediment transport model would
be instrumental in resolving all arguments for and against sediment
extraction from the Kerawalapitiya site. Such a model would prove beyond
doubt the isolation / integration of the sand deposits in Kerawalapitiya from
coastal processes.

The response states that removing 70m m3 of sand from the identified sites
will have no impact on sand for coastal processes of the Western coast, but
provides no actual evidence in the form of data or a sediment transport
model for the Western coast to substantiate this claim.

6. We understand that the SEIA allegedly follows the TOR. Our concerns
remains that the coordinates for the identified site have not been scientifically
proven to lay outside the dynamic zone for coastal processes off the Western
coast of Sri Lanka. As we know this is affected by two monsoons every year,
with the South West monsoon generating large waves and effecting shoreline
morphology dramatically throughout the year. According to reports it is not
uncommon during such periods of non-extreme waves and storm surge as
characterized by the South West monsoon that the sediments near the
shoreline may be transported offshore. During the inter monsoonal periods
when smaller waves predominate and ocean swell and in normal water-level
conditions, then these deposits from offshore may very well travel very
slowly towards the coastline again, practically rebuilding the original coastal
profile.

This is a pattern of seasonal erosion and accretion that is common along the
Western coast line. Mount Lavinia Beach and Hikkaduwa Beach in particular
as popular bathing sites undergo dramatic annual changes in shoreline
profile, as a consequence of this process of sediment transport from the near
shore, to offshore and the reverse. Here again we find it is imperative that the
SEIA scientifically understands the boundaries between nearshore and
offshore processes, rather than relying on general assumptions about the

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64 Old Chilaw Road, Negombo

nature and extent of nearshore and offshore sites, in respect of

Kerawalapitiya.

A sediment transport model for the Western coast independently conducted

would be the easiest non-controversial resolution of this argument, for and
against the role played by the Kerawalapitiya sand reserves in the coastal
processes along the Western and North Western coast line.

7. The SLLRDC has not responded to our concerns about the magnitude of
the proposed extraction and the sudden ten fold increase in extraction over a
shorter period of time. The 1013.34m m3 per annum proposed over three
years is as we stated more than was permitted over a period of 10 years for
domestic sand construction needs. We note with appreciation that the
SLLRDC is encouraging the use of sea sand as a substitute for rive sand for
construction.

Our concerns are now raised in respect of SLLRDCs declaration of using

sea sand to meet future domestic construction needs, in again resulting a
request to the CEA to allow another large scale extraction of sand from the
reserves at Kerawalapitiya. In effect a piecemeal extraction of the entire sand
reserve over an unspecified period. In view of which rather than a piecemeal
approach to sea sand extraction, a ten or fifteen year plan would seem
advisable, given the extreme restriction on the availability of sand for
construction purposes facing Sri Lanka on the one hand the ever growing
demand as evidence by the recent spate of luxury apartment constructions
in Colombo on the other. We question whether the use of valuable sea
sand for filling the sea is the most judicious use of a finite resource, for the
SLLRDC?

Again we must stress that the SLLRDC asking for this request to be read in
keeping with GoSL policy established in 2006 for sea sand to be considered
a renewable resource is faulty and even disingenuous given that this policy
was established on an annual requirement of sand for construction purposes
of 7m m3 and their own claim in the SEIA 2016 that the area for extraction is
less dynamic, whatever that means.

8. In conclusion, the SLLRDC has reverted to justifiying the demarcation of

the location of sand reserves in Kerawalapitiya based on the demarcation of
the coastal zone by the CCD this is simply the legal definition for the
department, based on its jurisdication, which is essentially land based. This
is not a meaningful or scientific definition within the scope of coastal
processes linked to sediment transportion and the impacts on shoreline
accretion and erosion which are our main concerns.

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 Peoples Movement Against the Port City
64 Old Chilaw Road, Negombo

We close by reiterating the need to scientifically demarcate the boundaries of

the nearshore and offshore zones at the specific location and seasonality of
tropical monsoon weather patterns observed in Kerawalapitiya incorporating
a site specific estimate of the Critical Depth and the validation of the isolation
of the sand / sediment reserves targeted for extraction based on a peer
reviewed model for sediment flows off the Western coast.

Yours sincerely
Peoples Movement Against the Port City.

F. Mansoor
+94 71 431 5124 Fr. Sarath Iddamalgoda,
+94 77 34 66 760 Feisal Mansoor,
+94 77 789 5109 Aruna Roshantha

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