By Hemantha Withanage

Senior Advisor, Centre for Environmental Justice

There is no gainsaying that we have to look for green energy to combat climate change. However, the world now seeks a “just energy transition”, meaning the development of energy sources that do not harm local communities and nature while doing justice for workers. Mannar, the location for the Adani wind power project, is undoubtedly a very sensitive location for different reasons. This island has been identified as highly vulnerable to climate change. Mannar is expected to lose over 8000 ha of land to sea level rise in the next 25 years.

The proposed wind power project in Mannar has become controversial due to its impact on the birds, the cost of its electricity, and the unsolicited bidding process. The project is unusual as it is an agreement with political regimes in India and Sri Lanka and not an ordinary investment project. It is also linked to the proposed transmission line between India and Sri Lanka. This is not included in the approved Long-Term Energy Generation Plan-2023-2042(LTEGP) or the Renewable Energy Development Master Action Plan (REDMAP) developed by the CEB.

This Environmental Impact Assessment (EIA) is highly inadequate due to its weak components, including the identification of alternatives, lack of cumulative impacts assessment and an attempt to greenwash a destructive project.

Why is cumulative impact important?

The Ceylon Electricity Board (CEB) manages a 100 MW “Thambapawani” wind power project in Mannar. A feasibility study for a second project has also been conducted. The Environmental Impact Assessment (EIA) for the Adani project is the third project set to be built on Mannar Island.

On another note, both coasts of the island have been given to Mars Minerals and Metals, an Indian mining company, to explore ilmenite. Furthermore, an Australian mining company is in the process of purchasing land for ilmenite mining. However, we have noticed that the TOR has not specifically requested a cumulative impact assessment, which is a significant weakness.

The Adani wind power project will install 52 turbines on the entire island and construct several kilometres of access roads across sensitive habitats. The EIA states, “The key result of the cumulative assessment is that the Mannar II wind park would not make any material change to the cumulative impacts for Mannar I and the transmission line, as it would contribute only a small additional risk. I disagree with this statement as the existing project located only one line of turbines on the southern coast of the island; in contrast, the new 250 MW Adani wind power project will lay 52 turbines on the entire island.

The Sustainable Energy Authority should be held responsible for declaring this region a renewable energy generation site without first assessing its social and environmental impact. Ideally, they should have conducted a Strategic Environmental Assessment before inviting investors. However, the MANNAR DEVELOPMENT PLAN 2018-2030 prepared by the Urban Development Authority has identified only the southern coast for renewable energy generation and the northern coast for fishery development. Yet, they compromised this plan when it gave a no-objection letter to the Adani wind power project, perhaps due to political pressure.

Effectiveness of emergency radar shutdown system

The Centre for Environmental Justice pushed the CEB and the Asian Development Bank regarding the ADB-funded 100 MW wind power plant due to the project’s location in the central Asian Flyway. This intervention resulted in installing an emergency radar shutdown system at an extra cost of about 1 million USD. As we know, Mannar is the most important wintering wetlands for migratory birds in Sri Lanka. In my opinion, this radar system is somewhat effective due to the size and location of the CEB project. However, we questioned the effectiveness of a radar system when the Adani Wind power project was built across the entire island.

According to The Island newspaper on 1st April 2024, Power and Energy Minister Kanchana Wijesekera has stated, “According to the EIA Report, meticulous planning has been undertaken to mitigate potential risks to migratory birds. Contrary to assertions, the EIA report explicitly states that turbines will not be within the migratory birds’ flight corridor”. Interestingly, he believes that birds tend to fly within a corridor that spans 2 kilometres in width. Unfortunately, in my opinion, the proposal to create a so-called bird migration corridor is just a greenwashing idea. When we already know that elephant corridors in Sri Lanka are not functioning, how can they expect the birds to follow these human rules?

According to the data reported in Thambapawani solar park, the most affected birds due to turbines were raptors such as Brahminy kites. However, water birds have been adversely affected by the transmission lines. The EIA report endorses the feasibility of the wind park, claiming that the period with high wind does not coincide with the bird migration period. However, the Environment Monitoring Report- Thambapawani Wind Project shows 93 birds from 21 species have been killed during a 4-month period due to both transmission lines and the wind turbines. In the case of Thambapawani Wind Power Project, higher bird collision risks than predicted have occurred, as there are reported bird collisions in the transmission lines. I believe bird collisions will highly increase once the whole island is covered with wind turbines installed under the Adani wind power project.

I doubt whether the new wind power proposal has real interest in installing an effective radar system. The reason is that the Adani project, which has spread all over Mannar island, has allocated only 253,968 USD for the Emergency Radar Shutdown system. In comparison, the CEB wind project has spent about 1 million USD to install one horizontal and 2 vertical radar systems. Considering the area spread of the Adani project It might require more systems to install. Since there is no design available, this proposal is just a greenwashing.

Flooding may cause severe social impacts

Besides the impact on birds, the project will increase the flooding in the area. Thambapawani wind power project is responsible for the increase in floods on Mannar Island during the last few years, though it was not identified during the EIA stage.  We believe that this project will further aggravate the flooding in Mannar.  Figure 3-10 on page 109 of the EIA shows high flooding areas encompassing several turbine sites, access roads, and a substantial part of the main road bisecting the island. The risk assessment on page 181 indicates the project is in a flood hazard area, with flood risk for turbine foundations on an annual basis.

Out of 72,000 people living in Mannar island, at least 40,000 people were affected by floods in the past. This project will undoubtedly increase flooding. However, no funds have been allocated for offsetting flood related impacts at the operation stage. The company will not be responsible for future flood mitigation work, and the government of Sri Lanka will have to spend public money on this.

Impacts on freshwater

According to the UDA Mannar Development Plan, water scarcity has been identified as a prominent element. The report states, “Historically, Mannar town has been facing many problems in accessing drinking water. Because Mannar is an only Island, people depend on groundwater for their day-to-day needs, but that is too salty and not suitable for drinking”. Due to ill development in the island including proposed mining, piling work for windmills, the proposed road network and the drainage and flooding will have serious negative impacts on the freshwater availability for human consumption. Who is going to pay for the future water projects?

Energy sovereignty at stake

Energy sovereignty is a prerequisite for the independence of a country. This project will have impacts beyond the environment and society. Although the Sustainable Energy Authority has been the project developer, it is only a proxy proponent. It is taking environmental clearance on behalf of the Adani company, owned by an Indian tycoon, to enter the Sri Lankan energy generation sector. They will have 6% of the control in the energy sector, and with Adani’s second power plant in Poonaryn, they will have 12% control of the energy generation in Sri Lanka. We also know there is ongoing negotiation to connect India and Sri Lanka through a transmission cable. This will seriously compromise the energy sovereignty of Sri Lanka.

Lack of alternative identification

The EIA’s alternative analysis is crucial. It should have also explored the possibility of having offshore turbines, alternative sites, and downscaling the project. High wind energy potential sites in mainland Sri Lanka could also generate 250 MW wind farms without significant ecological damage. Solar power is also a viable alternative. However, these technology alternatives have not been adequately considered in the EIA.

Although we agree that the LTGEP plan 2022-2041 includes multiple renewable energy sources and low-carbon technologies to provide green energy to the country for the next two decades, we have pointed out that this plan has not undergone a Strategic Environmental Assessment. As a result, it fails to identify the negative impacts of wind energy compared to solar power in other locations. Therefore, we would like to reiterate that the alternative site and technology analysis is highly inadequate in this EIA.

Destroying palmyra trees and reforestation

The EIA states that the proposed project will not have major adverse impacts on species of flora in the overall landscape. However, according to the EIA, a total of 4,256 Palmyra palms could be affected due to the installation of the wind turbines in the Hard-Standing Area (95mx90m). Additionally, 4,981 Palmyra palms will be cleared to establish the access roads and internal power cables. The number of palmyra palms in the soft standing area is 8822. We consider this as a major change in the tree cover on the island and will have a severe impact on the bird population as many birds use them for roosting and nesting. This aspect has not been studied adequately in the EIA.

The Mannar residents think that the number of palmyra palms to be removed is much higher as there are many saplings under each mature tree. EIA also states It is difficult to predict the exact number of palmyra palms to be felled site-specifically as action will be taken to minimize the palmyra palms to be cut in the Hard and Soft Standing Areas during the construction stage. Furthermore, a total of 260 coconut palms will be affected by turbine construction.

EIA has proposed an allocation of USD 707,491 for 62 ha of reforestation. However, it has not identified the areas where reforestation will happen. This is very important to negate the impacts of loss of habitats for species. However, such tree plantation will not immediately benefit the birds and other animals which use those trees as habitats and for nesting. The EIA does not provide which species will have significant negative impacts due to the loss of over 8000 trees.

Do not mix-up CSR and benefits to local communities

We have learned that the project proponent has already reached out to fishermen groups to convince them on the project. However, except the improved road network, the community will receive no benefits from the project. Mannar is a tourist destination popular among the bird watchers. The EIA report expects tourism potential will develop further as they might be attractive for tourists to watch those turbines. We believe this is not really the case. In fact, tourism potential may be reduced due to a lack of incoming birds. A steep drop in bird visits, a reduction in wildlife and the depletion of the tree cover in Mannare will severely impact Mannar’s economy and the potential for wildlife-based tourism planned by the Tourism Development Authority and Northern Development framework.

Meanwhile, the EIA has included CSR activities as part of the benefits. They cannot be considered the benefit sharing of the project. Adani as an Indian company and mandatory for companies to spend at least 2% of average net profits made during the three immediately preceding fiscal years (the “Minimum CSR Amount”) on CSR initiatives in accordance with the company’s CSR Policy.

We have learnt that non-title holders of lands will not get compensation for their losses. They will only get land development costs and a one-time payment of 100,000 rupees. Information on the land entitlement in the project area is not available. Around 4500 people live in the GN divisions where these wind turbines are planned.

Does the project conform to just energy transition principles?

The climate solution may harm the people and nature who are not even responsible for climate change. While the contribution of people in Mannar is negligible to climate change, the migratory birds are not responsible for the climate crisis. This is where just energy transition principles are important.

‘Just Energy’ transition is about defunding fossil fuels in a way that reduces inequality, shifting the costs of climate action onto wealthy polluters while prioritizing economic, racial, and gender justice. It requires stopping the use of fossil fuels and utilising renewable energy sources, while ensuring that efforts to scale up renewable energy production do not replicate the harms of fossil fuel, like taking land from people without consent and unjust compensation. It also requires working with indigenous community leaders to seek their free, prior, and informed consent when rolling out renewable projects on their land. The Adani project must respect the Just Energy Transition principles. However, this project neglects the community’s voices and participation.

The project could cause more negative impacts than positive ones on the country, posing significant threats to the environment and communities. The EIA has not considered the combined effects of this and future projects. The area has unique natural resources and ecosystems that could be adversely affected. The extended cost-benefit analysis has not considered the loss of fishery, long-term impacts on birds, bird migration, and other ecological impacts. If the project is to continue, it should explore better alternatives. The project-approving agency should advise the proponent to produce an addendum to study such alternatives for this wind power project. Greenwashing, such as the so-called bird migration route, cannot save Mannar Island or the bird life.