From SEA.unu.edu/wiki

JAMIE MACKEE* CLIVE BRIFFETT**JEFFREY OBBARD***

Abstarct

Sri Lanka is an island Republic situated off the southern tip of the Indian sub-continent. It has a long and continuous recorded history dating back approximately 2500 years, and claims to have one of the oldest nature reserves in the world. Environmental Impact Assessment (EA) in this country has a much shorter history. It can be traced back to the early eighties when there was a dramatic change in economic policies and EA legislation was enacted. Although there were some EAs predating this legislation they were voluntarily prepared for large infrastructure projects such as the Mahaweli Scheme. The final three amendments to the initial legislation making EAs mandatory came into force in 1993. Since then a number of EAs and Initial Environmental Examinations (IEEs) have been prepared for a wide variety of projects with varying degrees of success. Despite this the natural environment is still suffering rapid deterioration in quality and proper implementation of good EA practice is still needed.The research presented in this paper, which is part of a larger study on implementation of EA and Strategic Environmental Assessment (SEA) in Southeast Asia, discusses the current status of environmental assessment in Sri Lanka based on information collected from field visits, and interviews as well as published and unpublished data. EA practices are discussed in the context of investigating the potential for introducing the process of SEA in Sri Lanka. Two case studies are presented that demonstrate consideration of environmental issues in the development of strategic sectoral policies, programmes and plans. These case studies highlight the potential benefits of an effective SEA strategy in Sri Lanka, and identify some of the weaknesses in the current EA system within the country.Findings from the study suggest that rapid industrialisation combined with poor monitoring, a lack of technically skilled personal, inadequate baseline information and the continuing protracted civil war are key factors influencing the failure of the EA process to adequately prevent losses and degradation of the natural environment. It is this context that the paper looks at the possible role that SEA may play in overcoming the failings of EA, presenting a summary of the findings.

KEYWORDS: Environmental Impact Assessment, Strategic Environmental Assessment, Sri Lanka, environmental problems, EA status, environmental legislation, commitment.

1. INTRODUCTION

The effectiveness of EA in Asia has been subjected to a number of research enquiries over the years and most of these identify major implementation problems and consequent natural resource losses and degradation ( Biswas and Agaarwala 1992; Briffett 1996,1999; Lansdown 1991, Werner 1992). Thailand and the Philippines introduced EA legislation in the late 1970's but despite this many of the forest resources are now lost and large scale infrastructure developments have regularly caused major irreversible impacts. The problems of EA as a single project based activity and its use as an adjunct to the main design and project management processes are all too obvious. Due to lateness of preparation, the inadequacies of monitoring control, especially during construction and the lack of enforcement relating to mitigation measures and environmental management plan recommendations EA has been failed to meet up to expectations. EA is still inadequately recognised, respected and conformed to by many of the development stakeholders. Where implemented EA is often regarded simply as a means to the end of obtaining the planning approval and not as a planning tool designed to improve the quality of the development and the environment. Research has also indicated that both in Asia and elsewhere the earlier you apply environmental considerations in the design and planning processes the more effective you can be in influencing big decision makers and committing policies, plans and programmes to produce more environmentally friendly perspectives. Where large infrastructure projects affect extensive regions or diverse sectors and where planning land use policies are prepared then environmental considerations need to be rigorously applied. In practice sectors such as agriculture, mining, forestry, energy generation, waste treatment and disposition and transport all produce significant adverse impacts on the environment. Strategic Environmental Assessment applied in the earlier stages of planning and design can address many alternative options such as site selection, technological choices and scale of developments not available at the project based EA stage. This paper attempts to identify that criteria that can be used to identify the potential that an existing EA system may have for SEA policy application.

2. BACKGROUND

Sri Lanka is a "tear drop" shaped island-nation pinned to the southern tip of India approximately the size of Ireland or Tasmania in Australia; refer Figure 1. Within its 65,000 sq-km area diverse variations in the natural environment can be found ranging from tropical primary rainforests in the highlands with a European-like climate to very dry arid land to extensive Indian Ocean beaches and coastal wetlands. Sri Lanka is a low-income country with a per capita income of about US$810 per annum (World Bank Report 1998). The incidence of poverty has been reduced over the past four decades, yet approximately 35% of the 19 million people living in Sri Lanka still subsist below the poverty line. Economic growth has been fluctuating around 3.8% to 6.5% during much of the nineties, and in 1998 was at 4.5% (CIA Factbook, 1999).However, with its strong human resource base and natural endowments, Sri Lanka could have achieved substantially greater poverty reduction had it not been for a history of ethnic conflict, political unrest, and lack of sound economic policies. Since independence 50 years ago, hostilities between the majority Sinhalese and minority Tamils have restrained nation building. A civil war waged by Tamil separatists in the country's north and east region since 1983 has exacted a heavy toll on human lives, the environment and the economy (Prasad, 2000).In 1977, Sri Lanka made its transition from an inward-looking, socialist system to a market economy based on liberalized trade and exchange arrangements, and a deregulated foreign investment regime. Since then, the gross domestic product (GDP) has grown at a moderate rate of 4-5 percent a year (CIA Factbook, 1999). This performance, however, has been below the country's potential, due in part to low productivity, and slow implementation of fiscal reforms, particularly in the public sector, agriculture, and banking. However, it is also these open economic policies and the associated drive for economic growth that has posed the greatest threat to the natural environment since independence from Britain in 1948 (Marga Institute, undated). The economy, which was primarily agrarian based up-until the late 1970s, is now striving to become industrialised with a strong manufacturing base. Foreign capital and grant-aid form bilateral agencies such as the World Bank and Asian Development Bank has flooded into the country since the early eighties to support a vast number of industrial and infrastructure projects (Marga Institute, undated).To address this situation the Government of the day began the process of introducing environmental legislation, the first National Environmental Act coming into force in 1980 (GOSL, 1988). This act paved the way for the formation of the Central Environmental Authority (CEA) the Government's environmental protection agency. The provisions ushering in the practice for EA were finally made law in 1993, however prior to this there were a number of voluntary EAs for large projects such as the 1980's Mahaweli scheme a large infrastructure project that involved the damming of Sri Lanka's largest river for hydro-electricity upstream and irrigation downstream. This research is based on the data collected through interviews in Sri Lanka and provides a background to the country and the physical environment, environmental issues, legislation and impact assessment. This paper puts together information on the status of Environmental Impact Assessment (EA), and the potential for SEA from case study material.

Figure 1 Plan of Sri Lanka

3. NATURAL ENVIRONMENT IN SRI LANKA

3.1 Physical Environment

Sri Lanka is one of the most scenic physical environments in the world and this has largely been the result of extensive geological faulting and erosion processes. Three zones are distinguishable by elevation: the Central Highlands, the Plains, and the Coastal Belt. The south-central part of Sri Lanka--the rugged Central Highlands--is the heart of the country. The core of this area is a high plateau, running north south for approximately sixty-five kilometres. This area includes some of Sri Lanka's highest mountains rising to a height of 2500 metres. Flanking the high central ridges are two lower plateaus. To the west is the Hatton Plateau, a deeply dissected series of ridges sloping downward toward the north. On the east the second plateau, the Uva Basin consists of rolling hills, traversed by some deep valleys and gorges. The land descends from the Central Highlands to a series of escarpments and ledges at 400 to 500 metres above sea level before sloping down toward the coastal plains. Most of the island's peripheral surface area consists of plains that are between 30 and 200 metres above sea level. In the southwest, ridges and valleys rise gradually to merge with the Central Highlands, giving a dissected appearance to the plain. The transition from the plain to the Central Highlands is sharp in the southeast, and the mountains appear to rise up abruptly. In the east and the north, the plain is flat and dissected by long, narrow ridges of granite running from the Central Highlands. Much of the coast consists of scenic sandy beaches indented by coastal lagoons. In the Jaffna Peninsula, limestone beds are exposed to the waves as low-lying cliffs in a few places. In the northeast and the southwest, where the coast cuts across the stratification of the crystalline rocks, rocky cliffs, bays, and offshore islands can be found; these conditions have created one of the world's most spectacular natural harbours at Trincomalee on the northeast coast, and a smaller rock harbour at Galle on the southwestern coast. Sri Lanka's rivers rise in the Central Highlands and flow in a radial pattern toward the Indian Ocean. There are sixteen principal rivers longer than 100 kilometres in length, with twelve of them carrying about 75 percent of the mean river discharge of the entire country. Once they reach the plain, the rivers slowly meander across flood plains and deltas. Human intervention has altered the flows of some rivers in order to create hydroelectric and irrigation projects. In the north, east, and southeast, the rivers feed numerous artificial lakes or reservoirs (tanks) that store water during the dry season. During the 1970s and 1980s, large-scale projects dammed the Mahaweli Ganga (the longest rivers at 335 kilometres) and neighbouring streams to create artificial large lakes along their courses. Several hundred kilometres of canals, most of which were built by the Dutch in the eighteenth century, link inland waterways in the southwestern part of Sri Lanka (Library of Congress, 1988).

3.2. Biological Resources

The zonation of habitats in Sri Lanka is directly dependant on the availability of rainwater. The mountains and the southwestern part of the country, known as the "wet zone," receive ample rainfall i.e.: approx. 2500 to 5000 mm/year. Most of the southeast, east, and northern parts of the country comprise the "dry zone" with only 900 to 1200 mm/year. Much of the rain in these areas falls from October to January; during the rest of the year there is very little precipitation. The arid northwest and southeast coasts receive the least amount of rain (at around 600 mm/year) concentrated within the short period of the winter monsoon.The natural vegetation of the dry zone is adapted to the annual change from flood to drought conditions. The typical ground cover is scrub forest, interspersed with resilient bushes and cactuses in the driest areas. Plant growth is prolific from November to February when rainfall is heaviest, but stop growing during the hot season from March to August. Various adaptations to the dry conditions have evolved. To conserve water, trees have thick bark; most have tiny leaves, and some drop their leaves during this season. Also, the topmost branches of the tallest trees often interlace, forming a canopy against the hot sun and a barrier to the dry wind. Varieties of flowering acacias are well adapted to the arid conditions and flourish on the Jaffna Peninsula. Among the trees of the dry-land forests are some valuable species, such as satinwood, ebony, ironwood, and mahogany. In the wet zone, the dominant vegetation of the lowlands is a tropical evergreen forest, with tall trees, broad foliage, and dense undergrowth of vines and creepers. Subtropical evergreen forests resembling those of temperate climates flourish in the higher altitudes. Mountain vegetation at the highest altitudes tends to be stunted and windswept. Forests at one time covered nearly the entire island, but by the late twentieth century lands classified as forests and forest reserves covered only one-fifth of the land. The southwestern interior contains the only large remnants of the original forests of the wet zone called Sinharaja covering an area of approximately 8,864hectares (WCMC, 1997). The government has attempted to preserve important ecological habitats for vegetation and animal life. For example Ruhunu National Park and Bundala in the southeast protects herds of elephant, deer, and peacocks, and water birds while Wilpattu National Park in the northwest preserves the habitats of many water birds, such as storks, pelicans, ibis, and spoonbills. During the Mahaweli Ganga Program of the 1970s and 1980s in northern Sri Lanka, the government set aside four areas of land totalling 190,000 hectares as national parks. Currently 13% of the total land area is gazetted as protected areas ranging from strict nature reserves to nature reserves and national parks ( Kotagama, 2000 pers comm..).

4. ENVIRONMENTAL IMPACT ASSESSMENT IN SRI LANKA

4.1. Environmental Legislation

Although several laws exist to protect the different aspects of the natural environment such as wildlife, forests, and water bodies in Sri Lanka, specific legislation taking into account the integrity and quality of the environment in its broadest sense only came into being with the enactment of the National Environmental Act No. 47 of 1980 (GOSL, 1980). This act established the main institution, the Central Environmental Authority (CEA) as the lead government agency for environmental protection in Sri Lanka (Weerasinghe 1997, De Silva 1993). The necessity for performing an Environmental Assessment (EA) was first introduced in coastal areas by the Coast Conservation Act No. 57 of 1981(GOSL, 1981, 1988a). EA was introduced as a legal requirement throughout the country by the enactment of an amendment to the National Environmental (amendment) Act No. 56 of 1988 (GOSL, 1988b). This act stipulates that approval of major development projects, whether public or private in origin, requires the preparation and review of one of two types of reports; an Initial Environmental Examination (IEE) and/or an Environmental Impact Assessment (EA) (ISEA, 1998: 1-5). However mandatory EAs were only made effective after regulations and orders required to implement the EA process were introduced in June 1993 (GOSL, 1993a, 1993b). (Refer to table 1)Other government actions arising from the 1988 amendments that strengthened the legal framework for environmental management were: the issuance of regulations published in the government gazette no. 772/72 of 1993 (GOSL, 1993c), which designated specific types of projects likely to cause major impacts on the environment as "prescribed activities" requiring detailed EAs to be submitted for approval from each responsible ministry and agency; and the issuance of regulations in government gazette no. 859/14 of 1993, which specified 14 ministries and 8 agencies a Project Approving Agencies (PAA). (De Silva, 1993, Yasaratne, 1997). (Refer to Table 1)Environmental standards, particularly for water and air quality were published in 1992 and for noise control in 1996 (GOSL, 1992a, 1992b, 1996). The CEA has published general EA guidelines (CEA, 1995a) (CEA, 1995b), (Hennayake S., etal, 1997:142) and sectoral guidelines for the Agricultural (CEA, 1997a) and Transport (CEA, 1997b), Tourism, Irrigation, Energy (Hennayake S., etal, 1997:142) sectors.

Table 1: List of legislation related to EA in Sri Lanka. (Source: The Environmental Acts and Regulations of the Government of Sri Lanka)

DATE	NAME OF ACT	SCOPE
1980	National Environmental Act No. 47	Protection of the environment
1981	Coast Conservation Act No. 57	Includes requirement for an EA on projects within 300 metres of the coast.
1988	National Environmental Act (amendment) No. 56	Legal framework for EA established
1990	National Environmental (Protection and Quality) Regulations.	Legislation for Environmental Protection licence.
1992	National Environmental (Water Quality) Regulations No. 1	Scheduling of quantitative figures for water quality.
1992	National Environmental (Air Quality) Regulations No. 1	Scheduling of quantitative figures for air quality.
1993	National Environmental Act No. 47, 1980 amended by Act No. 56 1988	Amendments to the schedule of Project Approving agencies
1993	National Environmental Act No. 47, 1980 amended by Act No. 56 1988	Amendments to the schedule to projects and undertakings for which approval shall be necessary.
1993	National Environmental (Procedure for approval of projects) Regulations No. 1	Amendments providing regulation and guidelines for the approval procedure of projects.
1996	National Environmental (Noise Control) Regulations No. 1	Scheduling of quantitative figures for noise control.

4.2. Status

It is now seven years since EA became mandatory in Sri Lanka. In that period the Government has gained sufficient institutional experience on the EA process with reference to best international practice, and has established an administrative base upon which to build. This has resulted from intensive training programmes that were developed and supported by several donor organisations such as the World Bank and Asian Development Bank (ADB).There is a high level of awareness of the key issues among environmental officials, including mid-level managers, and an apparent genuine interest in improving the EA procedures and review (ISEA, IRG, 1998). This was evident while conducting the interviews: a strong commitment to protecting and cleaning up the environment. One of the next challenges will be to construct a stronger sense of "ownership among those who generally accept the EA system but still do not fully understand how it can be effectively integrated with economic development (ISEA, IRG, 1998).According to CEA records by the end of 1997 a total of 57 EAs and 93 IEE reports had been initiated by various project proponents since 1992. Of the 57 EAs undertaken, 15 EA reports were approved, 3 were disapproved and the remaining 39 have not been finalised by the submission of an EA statement. Of the 93 IEE reports begun, 38 reports were approved, 11 were disapproved, and 57 have not been finalised. Most of the unfinalised projects were abandoned or suspended by their proponents at some stage in the EA process. In addition, by 1997, the Coast Conservation Department had received a total of seven EA applications and eight IEE applications under the Coast Conservation Act, most of them since 1993(ISEA, IRG, 1998), predominately for hotel and tourist resort projects. Table 2 gives an outline of the practice of EA in Sri Lanka.

Table 2: Outline of EA practice in Sri Lanka

	EA PRACTICE	COMMENTS
1	Sectoral Guidelines	Some, not all sectors
2	Screening List	Not compiled
3	Mandatory Scoping	Adopted practice
4	Prediction	Not regularly practiced
5	Mitigation	Not regularly practiced
6	Compulsory Monitoring	Not regularly practiced
7	Cumulative Impact Assessment	Not recognised or introduced yet
8	Public Participation	Adopted practice
9	Environmental Management Plan	Not for whole country, but for selected sectors

4.3. Problems with the EA process and major issues.

A number of problems have been identified in the EA process in Sri Lanka; these became apparent from the interviews and from the reference material collected (De Silva 1993, Hennayake 1997, Nanayakkara 1997, Withanage 1997, Hewage 1999) and comprise four areas:

1. Lack of staffing and experienceMonitoring and evaluation inadequacies Lack of baseline dataPoor reviewing capacity of Project Approving Agencies (PAAs)

4.3.1. Staffing.

The major constraint in assessing environmental impacts of projects continues to be the lack of suitably qualified and experienced professional staff. An imposing array of specialists covering a wide range of technical, environmental and socio-economic disciplines are required to undertake environmental impact assessments and prepare statements. Professionals with sufficient knowledge and experience in preparing these types of documents are largely lacking in Sri Lanka and, as a consequence, unqualified personnel often complete statements.This manpower constraint can be illustrated by an example from Nanayakkara (1997) who wrote on the experiences of EA in Sri Lanka:

"A BOI (Board of Investment) project conceived for mechanised river bed gem mining in 1993 needed the TOR (Terms of Reference) for an EA. It is reported that many of the experts employed for this EA were not familiar with riverbed mining of this type or scale. It was also reported that there are very few experts in mechanised gem mining anywhere in the world and none in Sri Lanka." (1997: 119)

This example is interesting given the fact that gem mining and production is a large and significant industry in Sri Lanka, and that this type of mining may become more popular as the scale of production increases. This example casts doubts on the integrity of the EA process. From the country visit and interviews conducted, it was apparent the EA "profession" in Sri Lanka is minor in scale, as was evident in the fact that many of the former Director Generals and senior staff of the CEA are now in senior positions in NGOs or in private consultancy.

4.3.2. Monitoring.

The monitoring and evaluation aspects of EA seem to have suffered most in the Sri Lankan experience. The effectiveness of mitigation controls of environmental impacts proposed in approved projects are rarely tested. Although current procedure requires a proponent to send a copy of the monitoring plan to the CEA, the CEA has received only one monitoring plan during the entire four years of implementing EA regulations up to 1997. (Nanayakkara, 1997). This issue is also related to the lack of professional and technical staff, as many of the PAAs do not have sufficient technical staff to be able to control the monitoring aspect. Enforcement is also weak in this aspect as there is no follow-up to ensure that Project Proponents (PPs) submit monitoring plans. This major oversight in the implementation of EA regulations calls into question the integrity of the entire process and relegates the exercise to a mere formality without any real legitimacy.

4.3.3. Baseline evaluation.

The requirement of accurate and current baseline information is crucial for the proper conducting of a.n EA. In Sri Lanka this type of basic information is lacking, or out of date. Another example from Nanayakkara (1997) highlights the dilemma:

" The proponent for the Kalu Ganga river bed gem mining project proposal alleged that the investment was held up by the CEA's delay in granting environmental clearance for the project. The CEA and the project approving authorities on the other hand failed to provide adequate project details to prepare a meaningful TOR. The irrigation Department warned that in riverbed mechanised mining projects predictive analysis would be difficult owing to the lack of basic data on sedimentation, river morphology, and riverbed profile. When information vital for decision-making is lacking in quality or quantity a fair and factual EA cannot be carried out. A poorly prepared EA is worse than none at all, because it can mislead the decision makers.Careful monitoring of key environmental parameters over a period of time is hardly ever carried in Sri Lanka. Consequently environmental trends and changes cannot be identified and predictions cannot be verified"

He continues be offering a possible solution:

" A report series that constantly reviews the state of the environment by identifying the major environmental concerns, trends and emerging issues would present data, information and insights for appraisal and analysis." (1997: 120).

4.3.4. Project Approving Agency.

Another area of significant concern relates to the PAAs. The skill, experience and knowledge base of these agencies is one problem that needs to be addressed. From the interviews with government personal it was apparent that many of the Ministries and Agencies that act as PAAs lack sufficiently qualified staff. The role of full-time and component staff in these bodies will act to strengthen the work of the agency/ministry and the EA process. The capacity of PAAs needs to be developed by introducing guidance on appropriate methodologies, techniques and procedures for environmental assessment, the provision of on-the-job training for PAA officials and the development of Management Information Systems. (Nanayakkara, 1997). From the point of view of the Project Proponent (PP) there is often confusion as to which PAA is responsible for a particular project type or sector. Table 3 details the Project Approving Agencies. This problem is also compounded by the lack of inter-agency co-ordination and the lack of control undertaken by the CEA in creating awareness among potential PPs of the role and functions of PAAs. There are, in some cases, a conflict of interest with respect to development objectives and the role of environmental protection. As can be seen in Table 3, in some cases a PAA may also be the PP, as in the case of the Urban Development Authority, who also undertakes development on behalf of the Government. This dual role clearly places the environment in jeopardy as the economic benefits of development take precedence over measures for environmental protection - this will also have to be addressed.While four problem areas have been separately identified here, they are invariably inter-related, with the common factor among them being a lack of experienced and skilled personal to execute and oversee the EA process. This may in part be related to the short period of time in which EAs have been mandatory, although basic training in EA procedures and techniques is clearly required (for an outline of Environmental Education in Sri Lanka refer Hewage 1997). However there are other external factors that exacerbate the situation; the pressures of economic development, politics, poverty reduction and diversion of resources to the civil war. These issues may have to be addressed concurrently while solving the problems of EA in Sri Lanka placing a huge strain on the bureaucratic duties of the respective government ministries.

Table 3: Ministries and State Agencies as Project Approving Agencies (Source: The National Environmental Act No. 47 1980, order under section 23Y, the act was amended as No. 56 in 1988)

State Agencies as Project Approving Agencies	Ministries as Project Approving Agencies
Urban Development Authority	Ministry of Housing and Urban Development
Ceylon Tourist Board	Ministry of Tourism and Aviation
Board of Investment	Ministry of Finance and Planning
Ceylon Electricity Board	Ministry of Irrigation, Power and Energy
Coast Conservation Department	Ministry of Industrial Development
Central Environmental Authority	Ministry of Fisheries and Aquatic Resources
Department of Wildlife Conservation	Ministry of Forestry and Environment
Mahaweli Authority of Sri Lanka	Ministry of Plantation Industries
Geological Survey and Mines Bureau	Ministry of Transport and Highways
	Ministry of Agriculture and Lands

5. CASE STUDY ONE: A Structural Plan for the Colombo Metropolitan Region

5.1. Background

Colombo is the commercial capital of Sri Lanka with a population in the greater area of approximately one million. The Colombo Metropolitan Region (CMR) consists of three districts; Colombo, Gampaha and Kalutara, with a total area of 369,420 ha, or 5.6% of the entire country. Although the land area covered by the CMR is small, its influence over the rest of the country is disproportionate to this size. It accommodates approximately 25% of the country's population and economic and industrial activities in the region contribute approximately 44% to GDP. The projected population for 2010 is 6.5 million (CMRSP; Volume II, The Plan, 1998: 11).

Colombo was the capital in a prominent British colony and has benefited from the skill base and knowledge that has accompanied colonialism. Today a number of areas within the city are a testament to the town planning and architectural thinking exported to the colonies. Sir Patrick Geddes one of the earliest proponents of Town Planning, prepared the first town plan for Colombo in 1921 (CMRSP; Volume II, The Plan, 1998: 7), and today there are remnants of this in a number of large tree lined boulevards in Colombo. The fact that Colombo was once referred to as the 'Garden City' of east can only allude to the full glory of his plan.

As one of the final acts of the colonial administration, Sir Patrick Abercrombie was engaged to provide a Master plan for the Greater Colombo region in 1948. This plan was prepared to account for the growth that was occurring at the time. The results of this plan can be see in a number of "satellite" suburbs on the fringes of the greater Colombo region, such as Ratmalana, Homagama and Ragama (CMRSP; Volume II, The Plan, 1998: 7). The concept of decentralisation was one of the main strategies of the Abercrombie Plan. This document guided planning in Colombo until the gazetting of the United Nations Development programme Colombo Master Plan of 1978. The direct outcomes of this undertaking was the establishment of the Urban Development Authority (UDA) to oversee the development of Colombo and the City of Colombo Development Plan which was completed and made law in 1985. This document, prepared by the UDA detailed the zoning, development guidelines and planning guidelines for the City and influenced similar documents prepared by many of the local authorities across the island.

In early 1996 the Government directed the Urban Development Authority to revise the Colombo Master Plan that had been prepared in 1978. However while undertaking this work it became evident that the socio-economic characteristics and physical fabric of Colombo region had changed dramatically, thus it was decided not to pursue with the revision but to move the work upstream and focus on the Structure Plan for the whole region. Based on this decision the current CMR structure plan was proposed with the following objectives:

Major Objective:

The overall objective of the Colombo Metropolitan Regional Structure Plan is to design a Strategic Physical Plan and prepare an Action Programme for the development of the region with a view to meeting the aspirations and improve the quality of life of the people of the Western Province and the people of Sri Lanka.

Specific objectives:

Provide opportunities for the increased economic development, employment generation, and improved living standards and quality of life for all inhabitants of the CMR.
Improve accessibility and mobility
Promote environmentally sustainable urban growth
Reinforce the core functions of the metropolitan area
Increase housing supply.
Formulate an investment programme for funding.

(Source: Colombo Metropolitan Region Structure Plan CMRSP; Volume II, The Plan, 1998: 8)

5.2. Environmental problems identified in the Structural Plan.

Uncontrolled urbanisation in the Colombo metropolitan region, particularly the urban sprawl around the city of Colombo and ribbon development along major arterial roads such as the Galle Road, Kandy Road and High Level Road, has taken place without any consideration for the region's natural ecological resources. The pace of growth and economic development has had priority over environmental considerations. An area of approximately 20% of the CMR is flood plain and the most crucial urban environmental issue is that of storm water management. Other significant issues include:

   * micro level drainage problems
   * poor or non-existent solid waste management and hazardous waste disposal arrangements
   * growing industrial pollution
   * coastal erosion,
   * other forms of coastal degradation including beach encroachment, mangrove destruction, and visual degradation,
   * threats to wetlands from garbage dumping, land reclamation and excessive and careless sand and clay mining.

Other Problems of increasing concern are:

   * encroachment into river and canal reservations,
   * conversion of high quality agricultural lands for urban uses
   * poor physical/urban planning causing congestion and chaos,
   * unhygienic squatter settlements,
   * inadequate sewerage,
   * salt water intrusion in the coastal belt,
   * stretches/pockets of severe vehicular pollution,
   * continued destruction of remaining lowland rain forests,
   * indiscriminate rock quarrying and related activities,
   * under-use of the regions mineral potential, and
   * landslide prone areas in the Kalutara district.

(CMRSP; Volume II, The Plan, 1998: 75)

5.3.The Environmental component and proposed solutions in the Structure Plan

In the Structure Plan there is one chapter that deals directly with the environment, ecology and environmental problems of the Colombo Region. The environmental component is by their own admission:

".a sketch plan that identifies major critical elements, it needs more research refinement and on-site verification. An environmental database should be established as a matter of urgency to gather detailed and accurate information on a continuing basis." (CMRSP; Volume II, The Plan, 1998: 71).

Thus the plan only offers broad guidelines while defining very specifically problem areas and the areas that require protection.

It does however make reference to a number of other programmes that are ongoing or proposed that are related to environmental management. Examples of the major projects directly related to the environment include the Metropolitan Environmental Improvement Programme (MEIP) funded by the United Nations Development Programme (UNDP) and implemented by the World Bank, The Action Plan of the National Conservation Strategy prepared by the Central Environmental Authority, and the National Environmental Action Plan (NEAP) prepared by the Government together with the World Bank.

The Structure Plan does make a series of recommendations that include a number of areas such as Regional Resource management Strategies, Ecological Recommended Areas for Urbanisation and Transport strategies. In addition to this recommendations are made for a number of action projects and programmes. These include basic projects such as compiling essential baseline ecological data, the establishment of various bodies for the management and control of infrastructure development and monitor the impacts and the mitigation of problems. There is also one token section on the Use of Adaptive Design Strategies and Emerging Technologies.

5.4. Conclusions

The success of the plan will only be realised through committed implementation, as explained in the documents this is not the first structure plan. The success of the City of Colombo Development Plan of 1985 can be seen in the extant conditions of the Colombo region that the new Structural Plan seeks to correct. The problems of rapid growth after the liberalising of the economy have overshadowed any concern of the environment that may have been built into the previous plans. As for the environmental component in this particular plan it can be criticised for not doing enough to ensure the sustainable protection of the environment and planning of urban development based on the contents of the structure plan.

However if what is presently contained in the document is implemented it would be a beginning, the problem is the implementation, as has been highlighted in the interviews conducted. In most cases economic imperatives and poverty has been the guiding principles for environmental protection though numerous plans and action plans have been prepared. These priorities and problems have hampered successful implementation of many of the plans proposed to date.

Thus the major problem of this document and the section on the environment in particular is that is doesn't adequately address the problem of implementation. While it is a structural plan with no legislative powers there could have been some framework for ensuring implementation.

This document is an example of a regional master plan and demonstrates the Government's efforts in planning for the future growth of he Colombo area.

6. CASE STUDY TWO: A Tourism Master Plan for Sri Lanka

6.1. Background

World tourism is expected to continuing growing into the new century and Sri Lanka has considerable scope to develop its tourism industry further. It has major tourism resources that can be developed into a richer and more varied tourism product

The Sri Lankan government acknowledges that the tourist industry as a significant sector contributing substantially towards the growth and diversification of the country's economy. Within this context there is the recognition of the need for an orderly and structured growth of the tourist industry and invites foreign and Sri Lankan private sector investment for the industry's development (WTO, 1993).

6.2. The Master Plan

The first tourism plan (ten years in duration) was launched in 1967. The resultant organised development saw an impressive growth rate of over 20% with arrivals reaching 407,000 in 1982. However with the disturbances in the country between the years 1983 through to 1989 witnessed a drop of 50% in tourist arrivals. From 1990 onwards there has been a remarkable recovery with 381,063 arrivals in 1998, an increase of 4.1% over 1997 arrivals, however still short of the pre-conflict period.

The ten-year Sri Lanka Tourism Master Plan (1992-2001) is a result of a study undertaken as part of the UNDP Country programme with the World Tourism Organisation as the executing agency. The first major objective of the master plan was to formulate a long-term comprehensive, strategic master plan for tourism development in Sri Lanka for both international and domestic tourism, that will be well integrated into the country's society, economy and environment (WTO, 1993).

The plan emphasises sustainable development with integrated resort complexes, a high quality network of secondary attractions and safeguards for the social, cultural and physical environments. It further acknowledges that environmental aspects are increasingly influencing tourist's choice of destinations and also realises that environmental protection and enhancement is increasingly important for the local population (WTO, 1993).

6.3. Master plan for tourism.

The Master Plan addresses environmental issues in regard to tourist development in two ways; firstly as part of long-term strategies and potential and secondly as part of a five-year development programme.

Twelve long-term strategies are identified to support sustainable tourist development. Table 5 details these with their objectives.

Table 5: Environmental Strategies of the Tourism Master Plan for Sri Lanka. (Source: Tourism Master Plan; Shri Lanka. 1993.)

No.	Environmental Strategy	Objective
1	Development Control	Land use planning should designate areas for development of tourism in the coming ten years. It is important that plans are adhered to and that priority is given to protection and conservation of areas of scenic and natural beauty.
2	Unsustainable Economic Activities	The objective is to discourage and where appropriate phase out and prevent unsustainable economic activities that impact on the scenic and environmental attractions of Shri Lanka.
3	Sewerage and Waste Water Pollution	The objective is to upgrade the environment of existing resorts and tourist areas. Existing tourist establishments and attractions should be required to have their sewerage and wastewater treatment and disposal facilities reviewed to ensure that minimum standards are met. Regular visits should be made by the CEA and reports given to the CTB.
4	Environmentally Sustainable Tourism	The objective is to ensure that all new tourism development, including small-scale development that does not require an EA procedure is environmentally sustainable.
5	Streamline EA Procedure	The objective is to streamline the EA procedure for all tourism development.
6	Water Management and Conservation	The objective is to ensure that all tourism development is within sustainable limits of the water supply.
7	Erosion	The objective is to protect tourism areas from erosion.
8	Management Policies for Tourist Attractions	The objective is the promotion and enforcement of sustainable management policies.
9	Implementing CITES Resolutions	The objective is to phase out the use of materials from endangered species while protecting the livelihoods of craftsmen, and unskilled labourers using these materials.
10	Monitoring and Management Systems	The objective is to improve and enhance the monitoring and management of environmental and development control policies in local government.
11	Development Control	The objective is to extend development control to areas where there are clusters of small developments that are too small to justify EA approval.
12	Public Support	The objective is to enlist public support, including commercial enterprises, for environmental conservation and sustainable development.

These same twelve areas are developed as part of the five-year development programme, however with the added strategy of Landscaping and beautification schemes as a priority to restore the landscape in gem mining areas.

While the environment is still only considered for its aesthetic attraction for tourism and does not become the driver of sustainable tourist development several of the strategies are of interest in the context of this study. Strategies 1, 5, 8 and 10 are discussed further because of their relationship to strategic thinking to support tourist development, and as they reflect the general areas that have been identified as the problem areas in the EA process in Sri Lanka.

The first strategy looks at the issue of land use with the idea of designating land suitable for tourism, unfortunately the qualifying statement '"of scenic and natural beauty" only relegates the environment to an object of visual pleasure. However the objective should have been to avoid areas of environmental sensitivity or significance in designating areas for tourism development.

Strategy five deals with the issue of streamlining the EA process. Many of the recommendations made for streamlining have been instigated since the publishing of the master plan, such the publishing of sectoral guidelines. Unfortunately none have been written for the Tourist sector. Thus the problem of how to approach an EA for tourist development is still a problem. One important recommendation to the EA process for tourist development is the suggestion that EA requirements are extended to cover:

  o developments which are likely to generate significant pedestrian or vehicle activity or noise;

  o developments of any type or size that are proposed in environmentally sensitive areas.

Strategy eight is significant for its proposal of a number of recommendations that look at the protection of the natural assets such as beaches, wildlife, coral reefs and cultural heritage sites. This is to be achieved through the monitoring of carrying capacity, identifying sensitive areas, and controlling damaging practices and uses. The plan calls for the preparation of visitor management plans to allow for the orderly circulation of people and vehicles.

The last strategy is concerned with monitoring and management systems. The authors have identified that:

".implementation and enforcement has been inconsistent and inadequate. In other cases there are loopholes in existing laws, lack of data and inadequate data collection systems for monitoring development and it's impact on the environment." (WTO, 1993:167).

Thus recommendations are based on strengthening these areas, however not at a strategic level but more at the local government level:

".with particular reference to environmental and development control issues." (WTO, 1993:167).

Significantly one of the areas believed to be important for policy development is the area of habitat conservation.

6.4. Conclusions

Firstly it must be noted that this plan was prepared prior to the implementing legislation for EA in 1993, so many of the recommendations and issues discussed in the document have been addressed by the legislation, however as recorded in the interviews monitoring, and enforcement remain problem areas.

This case study has been selected as an example of a master plan at the sectoral level. The plan addressed environmental issues as part of the process of developing guiding principles for tourism development over a ten-year period, which has now concluded. While in the context of this study it shows the government's efforts at building-in environmental protection as part of sectoral development at a strategic level, in reality much of what has been recommended in the document to guide tourism development in terms of environmental protection has not been implemented.

The problems of enforcement, implementation and monitoring identified with the EA process in the plan still exist, hotel development has continued unabated with the requirement for an EA only applying to hotels of more than 100 rooms or if in a sensitive area (perscomm; Kalaiselvam, 1999). In respect of SEA enforcement, monitoring and political commitment to the process maybe the barriers to successfully implementing environmental protection from the strategic level.

7. THE POTENTIAL FOR STRATEGIC ENVIRONMENTAL ASSESSMENT IN SRI LANKA

7.1. Introduction

Much has been written on the subject of SEA; from this literature the common definition of SEA is the assessment of environmental impacts of policies, programmes and plans. In this context SEA is a process that is similar in intent to EA, but is upstream of the EA process, which is project specific rather than generic. The advantages of SEA are that of streamlining the EA process whereby a range of general environmental impacts are determined through the implementation of a particular policy or programme that has been thoroughly evaluated with respect to their environmental implications. The projects resulting from these policies may broadly be environmentally friendly.

While Sri Lanka is technically classified as a developing country deficient in certain resources and technical skill, the interviews conducted within the country revealed a certain degree of awareness in the concept of Strategic Environmental Assessment (SEA). To Sri Lanka's benefit this is particularly the case among people in a position of policy making. However one problem that exists is that some people tend to consider SEA as a substitute for EA thereby removing the necessity for project specific EA. If applied, this would be a disturbing event as it could potentially give a 'carte blanche' to develop without consideration of the local environment consequences of their actions.

The interviews and collection of data did demonstrate that several government ministries were taking some consideration of the environment in their development of policies and master plans. These include the Tourist Board in the development of the Tourism Master Plan as discussed above; the Forestry Department in developing the Forestry Master Plan (Forestry Planning Unit, 1995a, 1995b); and the Urban Development Authority in preparing the Colombo Metropolitan Regional Structural Plan, discussed above. The Asian Development Bank (ADB) also funded a project looking at the specific question of introduction of SEA to strengthen the EA process in Sri Lanka (ISEA Project Report Vol. 1 1998) and titled Institutional Strengthening for Environmental Assessment.

7.2. The potential for SEA in Sri Lanka.

It is clear from the interviews conducted and documents reviewed that policy makers in Sri Lanka are increasingly aware that existing policies and programmes lack strategic planning and implementation with regard to environmental protection of both natural and urban environments. It is broadly recognised by government ministries that the current system of project level EA has considerable constraints with regard to scientific integrity and administration. Currently, the EA legislation is particularly onerous and this, coupled with a general lack of technical skill in undertaking and evaluating the EA process and its results remains one of the major constraints in implementation of an effective EA process. Additional factors are the difference between the actual and predicted environmental impacts, the integrity and effectiveness of any mitigation measures proposed and the general lack of monitoring.

These factors affect the environmental assessment process at the project level by creating the expectation for an unreasonable amount of analysis at this level. For example, the alternatives expected to be analysed at the project level are those that ought to have been analysed at sectoral level (e.g. railway as the alternative to a highway project). Similarly, evaluating alternative locations for a thermal power plant is beyond the usual scope of a project-level EA (ISEA Project Report Vol. 1 1998).

SEA is often viewed as a means to improve the approach and comprehensiveness of environmental planning at both the sectoral and regional level. Some types of strategic planning have been applied to several sectors and regions. The introduction of SEA can serve several functions; first it can incorporate environmental assessment as mainstream to all other aspects of land use and urban planning; second, it can provide the framework for the scale and detail of project specific EA required for individual development projects - having already established the environmental features and characteristics of a sector or region and evaluated baseline; third, it can facilitate more effective implementation of these plans taking into account the inter-related requirements of human needs and the integrity of the natural environment; and finally, it can serve as a platform for the monitoring of environmental quality and the enforcement development related mitigation measures. In short, the introduction of SEA can enhance the existing strategic and regional plans and integrate environmental protection into all aspects of the planning process at national, regional and local level.

However, an assessment of the potential for the introduction of SEA can only be determined by analysing the existing foundations to support the effective implementation and enforcement of SEA. One method is to examine what strategic considerations are already in place what legislation exists and what conventions Sri Lanka is a party to. Table 6 shows the strategic aspects of Sri Lankan Policy making, and international conventions that Sri Lanka is a signatory.

Table 6: Strategic aspects of Sri Lankan policy making.

STRATEGIC ASPECT/ISSUES	YES	NO	COMMENTS
National Master Plans (such as five year plans)		X	The have been none since independence in 1948.
Regional Master Plans	X		There is the Colombo Metropolitan Region Structural Plan. There is also the Southern Development Authority that has drawn up plans for the southern province, including the development of a new town called Ruhunupura.
District Master Plans		X	There were some local plans prepared for the Gampaha district, but nothing was convincingly implemented.
Local Master Plans		X	Local authorities are under funded and under staffed to be able to consider such plans at this stage.
Sectoral Master Plans	X		There are master plans for Forestry, Tourism, coastal zone management, and one under consideration for Energy. There is also a master plan being developed for water resources and national land use.
Environmental legislation	X		EA legislation implemented in 1993, however National Environmental Act since 1980.
National environmental action plans	X		One that was first prepared in 1994 and revised in 1998.
State of the environment reports	X		One was prepared in 1991; there have been no updates, as part of the NAREP project..
Biodiversity conservation/ action plans	X		Prepared in 1997-98 by IUCN.
Signatory to conventions	X		Montreal Protocol, Biodiversity Convention, Kyoto Convention, Basal Convention, Agenda 21, Rio convention.

Regular monitoring of the state of the environment.		X	Nothing has been done to date.
Courses and training programmes.	X		A number of specific environmental courses at postgraduate level, with modules/subjects in various undergraduate and postgraduate courses.
Inter-ministerial coordination facilities.		X	Very poor as there is no clear boundaries for responsibilities particularly in relation to the environment.
Awareness amongst policy makers.	X		There have been a number of programmes; the most recent being the ADB funded Institutional Strengthening for Environmental Assessment (ISEA).
Stable political environment.		X	There is a civil war, infighting amongst the political parties, institutionalised corruption and poverty.

The table shows that there are a number of strategic elements in place such as sector master plans, regional plans and environmental legislation, however there is no national plan or strategy for development. Due to the ethnic unrest and civil war the government does, maybe not surprisingly, tend to be responsive to social and environmental crises rather than pro-actively safeguarding natural resources and implementing a more sustainable planning policy.

Although there is a ministry that deals directly with national planning policy development i.e. The National Planning Department, as well as the Central Environmental Authority whose duty is to implement and co-ordinate the EA legislation, effective SEA planning requires top-level endorsement and support and an effective inter-ministerial level of management. It is readily apparent from the interviews conducted that there is no clear direction for SEA within the country and a low level of inter-ministerial co-operation on specific issues related to SEA implementation and enforcement. Without an inherent sense of 'common purpose' between government ministries, it is apparent that SEA initiatives will languish and be inappropriately affected. The worse potential outcome in Sri Lanka is for SEA to be hailed as a method for potentially denigrating the existing site-specific EA system. By using an ill thought out and weakly implemented SEA strategy as a means for avoiding the adequate assessment of environmental impacts at a local level, there is a danger of environmental standards falling still further within the country.

While it seems that there is potential for SEA to be introduced in Sri Lanka as the table indicates and the ISEA Project showed, there are several intrinsic problems that may hamper the success of SEA. It was apparent that much of the enthusiasm for SEA is based on the perception that SEA is a way of removing the process of EA and thus avoiding delays in economic development. This has many dangers as SEA only looks at the environmental impacts of policies, programmes and plans at a very broad macro-level and provides no way of determining the specific impacts of a project at the micro site level.

The other aspect relates to the problems of EA that could be transferred to SEA. For example, it seems that the desire for economic development over-rides all other considerations particularly the environment as is evident in the power sector where there is a huge shortage of electricity and the need to generate more power to meet the escalating demand. This has to the Ceylon Electricity Board (CEB) considering the construction of environmentally harmful options for power generation, including the use of diesel generating equipment in close proximity to urban areas. Such an approach has severe negative implications with respect to urban air quality, but these considerations are being neglected against the perceived need of additional generating capacity.

The final aspect that could be the most important is the need for a stable political environment, where sound policies, programmes and plans are generated and implemented in a systematic manner free of corruption and disturbance. Unfortunately this is not the case in Sri Lanka. Many programmes and plans are determined by political whim often without the backup of research, planning feasibility studies.

Sri Lanka is a developing country with a 17 year long continuing civil war; Corruption is endemic and one out of every five families live below the poverty line (CIA Factbook, 1999). In these circumstances, it is not surprising that the seeds of SEA that have been largely sown by the funding influences of international donor agencies are floundering. It is also clear that the EA system has failed for a variety of technical, political and social reasons, a case-in-point would be the Kandalama Hotel project that produced the greatest public outcry of any development project during the nineties but still went ahead because it was a government sponsored project, even though the company who developed it were against the idea (Interviews 1991-1998). As these types of problems are endemic and institutionalised the same fate may await the implementation of SEA

8. Conclusions

From the interviews and the data collected it is apparent that the EA process in Sri Lanka has so far proved less than effective. This has been attributed to a number of problems identified in research undertaken for the E.A.R.T.H project: lack of staffing and experience; monitoring and evaluation inadequacies; lack of baseline data and the project approving agencies. The need to strengthen the EA process has been identified by many people within Government, funding Agencies and NGOs. SEA has been suggested as one avenue for strengthening the EA in Sri Lanka. This is based on the potential of bringing the environment assessment process upstream so that polices, programmes, and plans generated as part of national planning would incorporate environmental protection measures in there consideration. Two case studies have been presented that highlight the extent to which the environment is considered in current strategic planning exercises at a sectoral and regional level in Sri Lanka.

Footnote

This study on Sri Lanka is part of a larger E.A.R.T.H project to assess the potential for Strategic Environmental Assessment (SEA) in six Asian countries including Sri Lanka, the others being Singapore, Malaysia, Hong Kong, Vietnam and the Philippines. During the visit to Sri Lanka 24 interviews were conducted with government and non-government agency representatives, and over 75 strategic documents obtained as well as material on a number of potential case studies.

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