III. MECHANISMS FOR INTEGRATING ENVIRONMENTAL CONSIDERATIONS INTO SECTOR POLICIES AND FOR MONITORING 20
F. Strengths and weaknesses and advantages and disadvantages of monitoring mechanisms
In the case of EIAs in general (including the tea sector) an inherent strength in the monitoring mechanism is the necessity for PAA to forward the plan to monitor implementation to CEA within 30 days of project approval. However, the weaknesses appear to be centred in the capacity of PAAs to regularly undertake field-level monitoring of the approved projects. That constraint is evident within the Ministry of Plantation Industries as it does not have the staff resources nor apparently a clear understanding of the monitoring role it is expected to play.
Another complication that may arise in the tea sector lies in producing a meaningful assessment of the effectiveness of any mitigatory measures, as a result of the difficulties faced in measuring major environmental impacts such as soil erosion and soil degradation, as well as their downstream external impacts. On the other hand, an inherent advantage for the sector is the ease with which monitoring can be undertaken of compliance with project implementation conditions laid down in the EIA to minimize soil erosion and soil degradation. As experience is gained from the implementation of EIAs for the tea sector, solutions to the constraints indicated above are expected to emerge.
An inherent strength of the processing activities related to the tea sector is that they are listed as low-polluting activities. Instances related to the discharge of toxic effluents and their adverse impacts on natural resources (water bodies) have been rare so far in he tea sector. In fact, only one instance, which concerned a relatively complex processing activity in the sector, has necessitated any action by CEA.
The tasks of issuing of EPLs and subsequent monitoring for normal processing activities in the tea sector have been delegated to the local authorities by CEA. For that purpose, CEA has laid down effluent disposal standards (maximum permitted levels of certain chemicals etc.) and the effluent treatment methodology that should be followed in order to mitigate any impact on natural resources. That is an important step because, in Sri Lanka, effluents are often discharged into water bodies and sometimes on arable land areas, thus posing a potential health hazard.
CEA has adequate laboratory facilities (with the exception of emission monitoring equipment) for testing effluents related to processing activities. Such services are also provided by other State and private sector agencies on a commercial basis. However, CEA lacks the staff resources needed for undertaking field-level monitoring over large areas. A strength in the monitoring mechanism at the field level is the requirement for the local authorities to send monthly progress reports to CEA concerning EPLs issued by them for processing activities. However, according to CEA, a disadvantage at the local authority level is the turnover that often occurs in monitoring staff, which results in inadequate awareness of the enforcement standards as well as the monitoring procedures.
Another weakness in the system is the ideological conflicts that sometimes occur between the local authorities and Provincial Councils, which adversely affects monitoring. Those differences may also be related to the more stringent standards enforced by some Provincial Councils under the provincial regulations and laws enacted by them.