Environmental Assessment Report

Summary Initial Environmental Examination Project Number: 39419 July 2008

SRI: Clean Energy and Access Improvement Project (formerly Sustainable Power Sector Development Project)

Prepared byby [Author(s)]Lanka Electricity Company (Private) Limited for the Asian Development Bank [(ADB).Firm]

The draft summary initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

ENVIRONMENTAL ASSESMENT REPORT

Summary Initial Environmental Examination Report (Revised) July 2008

SUSTAINABLE POWER SECTOR DEVELOPMENT PROJECT

Prepared by Lanka Electricity Company (Private) Limited Colombo, Sri Lanka Summary Initial Environmental Examination report of New Primary Substation Project (Revised) July 2008

ABBREVATIONS

ADB - Asian Development Bank EIA - Environmental Impact Assessment EMP - Environmental Management Plan IEE - Initial Environmental Examination PIU - Project Implementation Unit EA - Executing Agency

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CONTENTS

ABBREVATIONS 1 CONTENTS 2 INTRODUCTION 3 1. DESCRIPTION OF THE PROJECT 4 1.1. PROJECT LOCATIONS 5 1.2. TYPE OF PROJECT AND THE CATEGORY 6 2. DESCRIPTION OF THE ENVIRONMENT 7 2.1. PHYSICAL RESOURCES 7 2.2. ECOLOGICAL RESOURCES 8 2.3. SOCIAL AND CULTURAL RESOURCES OF THE PROJECT AREA 9 3. POTENTIAL ENVIRONMENTAL IMPACTS AND PROPOSED MITIGATION MEASURES 10 3.1. PROJECT SITING 10 3.2. POTENTIAL ENVIRONMENTAL IMPACTS OF PSS AND MITIGATORY MEASURES 10 3.3. POTENTIAL ENVIRONMENTAL ENHANCEMENT MEASURES 13 4. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MANAGEMENT PLAN 14 4.1. PUBLIC COMPLAINS HANDLING PROCEDURE. 15 4.2. ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN 15 5. PUBLIC CONSULTATION AND INFORMATION DISCLOSURE 24 6. STREET LIGHTING DEMAND SIDE MANAGEMENT SUB PROJECT 25 7. FINDINGS AND RECOMMENDATIONS 26 8. CONCLUSIONS 27

List of Tables Table 2.1 Scope of the proposed PSS 4 Table 3.1 Existing flora on the site 9 Table 4.1 Environmental Monitoring Plan 23

List of Figures Table 2.1 Scope of the proposed PSS 4 Table 3.1 Existing flora on the site 9 Table 4.1 Environmental Monitoring Plan 23

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Introduction

Lanka Electricity Company was set-up in 1983 to take-over badly maintained local authority distribution networks in view of enhancing power quality. ADB funded this mission from the out set funding 4 projects by which the LECO network is developed.

At present LECO is engaged in power distribution mainly in the western coastal areas of Sri Lanka. The franchised area is divided geographically into seven branches which includes the prime economic zone of Sri Lanka

The requirement of enhanced capacity is in need to supply the load growth in these areas. The last substations project in LECO area was implemented 8 years ago. After this project, no capacity expansion has taken place and this has severely affected the LECO distribution capacity.

LECO wishes to propose two new 33/11kV, 2X5MVA substations in Katunayake, Kotikawatta and two 33/11kV, 2X10MVA Primary Substations in Kiribathgoda and Nawala. The project is formulated based on LECO five year load forecast and load flow study. The land area required is approximately 1000 sq.m. The plots of land are identified as close as possible to the load centre and be purchased at commercial rates. During purchase of land it is ensured that those are environmentally suitable for a primary substation.

This is the summery of the initial environmental examination report which was produced in the initial phases of the project preparations envisaging submission for ADB funding.

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1. Description of the Project

Table 2.1 summarise the planned capacity enhancements by the proposed primary substations.

PROPOSED LAND EXTENT GRID SUBSTATION CAPACITY PURCHASED

Katunayaka 2×5 MVA 1000m2

Kiribathgoda 2×10 MVA 1000m2

Nawala 2×10 MVA 1000m2

Kotikawatta 2×5 MVA 1000m2 Table 1.1 Scope of the proposed PSS The proposed substations will relieve the existing over-load substations in the areas of Katunayake, Seeduwa, Dalugama, Dalupitiya, Ethulkotte and Nugegoda.

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1.1. Project Locations

Figure 1.1 Map of new PSS locations

Katunayaka

Facing the by road Sarath Mawath, off to the land side between 18th and 19th kilometre post on A3 (Colombo, Negambo) road, 700m along the Sarath Mawatha, Negambo road junction.

Kiribathgoda

Facing the New Hunupitiya road, left turn between 8th and 9th kilometre post on A1 (Colombo, Kandy) road, 400m along the New Hunupitiya Road, Kandy Road junction.

Nawala

Facing the 4th lane (by road of Nawala Road), right turn between Koswatte Junction and Nawala Junction on Nawala road, 100m away from the 4th lane and Nawala Road junction.

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Kotikawatta

Facing the road from IDH junction to Kotikawatta, off to the land right side, 750m along the Kotikkawatta Road.

1.2. Type of Project and the Category

This project consists of building four new Primary Substations in small land extents of 1000m2 approximately. According to the clause 142 of Environmental Assessment Guidelines, Asian Development Bank, 2003, this project can be classified as follows due to minimal environmental impact associated with the project:

Project Type: Power Transmission Category: B

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2. Description of the Environment

2.1. Physical Resources

Geology and soils

The project sites are located in the Colombo (Nawala and Kotikawatta PSS) and Gampaha (Katunayaka and Kiribathgoda PSS) districts. The geology of these sites is described below.

(i). Kiribathgoda

The area is consisted with compressible alluvial depositions. The soil is generally blackish, silty - clayey –fine sand. Part of the land is filled with latrotic soil. The approximate depth of ground water level is at one meter depth from existing ground level.

(ii). Katunayake

The area is consisted with lagoonal depositions of white medium to coarse sand with traces of silt. The approximate depth of ground water level is at three meters depth from existing ground level.

(iii). Kotikawatte

The area is consisted with compressible organic depositions. The soil is generally blackish, silty - clayey –fine sand. Majority of the land is filled with latrotic soil. The approximate depth of ground water level is at two meters depth from existing ground level.

(iv). Nawala

The area is consisted with organic debris of blackish silty fine sand with some clay. The approximate depth of ground water level is at two meters depth from existing ground level.

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Climate

Weather in the project areas stays evenly hot and humid throughout the year, with no distinct seasons apart from two rainy seasons. Heavy monsoon rains occur between May and July (South West Monsoon), and again between October and December, (North East Monsoon) resulting in a mean annual precipitation of 2345 mm approximate. The average annual air temperature in the project area is ranged between 220 Celsius(C) and 310C.The air quality of the project areas tends to deviate from site to site and time. All the air pollutants in the four project areas are well within the range of standards.

Hydrology and water resources

Water resources in the project area are represented by surface water (rivers and lakes) and ground water. The ground water in the project area is classified as shallow aquifers on costal sand as shown on the aquifer diagram below. The water supply system in the project area mainly comprised of surface water distribution.

2.2. Ecological Resources

Flora

The flora existing in the proposed sites are predominantly home garden vegetation common in the area. No endangered flora exists in these sites. The results of the audit carried out of the existing flora of the sites are presented bellow given table.

Site Plant (Scientific name) Kiribathgoda Cocos nucifera ‘king’ Cocos nucifera Mangifera zeylanica Musa st. Alocasia st. Cyterus st. Katunayake Artocarpus zeylanica carica papaya Azadiractus indica caryota urans aegle marmilos Sesdenia grandislora Musa st.

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Kotikawatte Alocasia st. Nawala Artocarpus nobilis Zizitus st. Anacardium st. Psidium st. Cocos nucifera Musa st. Artocarpus zeylanica Table 3.1 Existing flora on the site

Fauna

The protect sites are limited to a land space approximately 1000 square meters. Thus the audit of fauna is not possible to be carried out in this space and such activity is not practical.

2.3. Social and Cultural Resources of the Project Area

The population of the Colombo and Gampaha districts account for about 25% of the national population. The population densities of the districts are 3330 per square kilometre and 1539 per square kilometre respectively.

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3. Potential Environmental Impacts and Proposed Mitigation Measures

The potential environmental impacts discussed in this section are identified by the Rapid Environmental Assessment process.

3.1. Project Siting

The four primary substations are to be built in LECO owned land procured through standard procurement procedure at commercial rates. There are no specific environmental concerns as any relocation of people or significant clearing of vegetation is not involved. The land of concern are already cleared and covered with shrubs and home garden vegetations.

3.2. Potential Environmental Impacts of PSS and Mitigatory Measures

Environmentally sensitive area

None of the proposed primary substation sites will encroach into protected area not environmentally sensitive zones of the country. There is no envisaged environmental impact to the water hydrology or the existing waterways. Kiribathgoda Primary Substation land is adjoining a storm water canal and neither the primary substation construction nor the operation will hinder the water flow of this water way.

Storm Water

The proposed primary substations will have a properly designed storm water collection and drainage system including the gravel seepage surfaces, covered drains with proper gulley system which will output the storm water collection at the primary substation surface to the road side drainage system or existing waterways as permitted by the geography of the site.

Water Quality

There is no spillage of chemicals or other potential pollutant to the water resources during the normal operation of the primary substation. During an emergency there is a possibility of a leakage of transformer oil from the power transformers located at site. Thus the transformer

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foundations are designed to comprise of a containment pit so that the entire volume of transformer oil available in each transformer can be held within the foundation. Thus in a rare event of spillage, transformer oil does not interface with the primary substation ground surface or the water resources of the vicinity.

Air Pollution

There is no activity associated with air pollution such as rock crushing. The GIS equipment is associated with SF6 pressure gauges and protection interlocks with indications so that even minute leakage of SF6 is immediately detected and corrected. Further the PSS commissioning test protocol include SF6 gas leakage testing of each GIS interface of the PSS equipment panel so that SF6 gas used for insulation is ensured to be well sealed within the compartments.

Noise and Vibration

During the civil construction there is a possibility of earth filling in Kiribathgoda and Kotikawatta sites. Since the associated soil volumes are small the equipment employed will be small compactors and lorries commonly used in public building construction sites and road construction sites. Thus the associated noise levels would be within the acceptable limits stipulated in the Sri Lanka’s noise regulations published in the Government Gazette dated 21st May, 1996, under the environment Act No 47 of 1980.

During the operation of the PSS, only source of noise will be the operational 50Hz hum of the transformer which is controlled in compliance with IEC standards and measured during the type test of the transformer as per IEC 60551.

Social conflicts due to the civil roads for construction

The proposed site of Katunayaka is accessed through a provincial road spanning a length of approximately 500m from Colombo-Negombo A class highway. Kiribathdoda, Nawala and Kotikawatta are accessed from the main B class roads with less than 200m provincial roads. The construction activities envisaged in PSS is very small and no heavy transportation involved activities such as piling and major filling is required. The civil contractors will be instructed to use covered lorries for construction material transport which is anyway a legal requirement of Sri

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Lanka and reduce any damages to the public roads. In an event of such damage the road will be repaired by the contractors under the supervision of LECO.

Health Hazards

There is no health hazard envisaged during the construction or operation of these Primary Substations. The exposure to electromagnetic fields is negligible since the electrical designs of the substations are carried out with the proper high voltage clearance as per IEC standards. Further since all the substations are GIS, most of the high voltage surfaces are encapsulated within metal clad enclosures solidly grounded.

Risks of Accidents

The risk of accident to project staff, operational staff or the general public due to fire, electric shock, explosion etc. are minimized by a. selection of GIS switchgear, Transformers and other substation equipment complying to international standards with proper type test certificates and functional test equipment from reputed manufacturers who has experience of providing such equipment for primary substations. b. Implementation of safety awareness protocol during the operations of the primary substations, and c. Provision of proper site safety guidelines with safety equipment such as fire extinguishers, warning tapes and barriers during the construction phase of the project.

Waste disposal and Removal

The generation of waste by a Primary Substation is negligible during construction as well as operational phases. During the construction major waste generation is by the packing material and any scrap material associated with civil works. The packing material will be disposed by the means approved by the local government and scrap material will be sold to re-cycling agents. During the operational phase, the major waste generation is by the waste transformer oil during oil filtration. The waste transformer oil will be transported to CEB central stores and disposed as per the methods approved by the Central Environmental Authority

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3.3. Potential Environmental Enhancement Measures

In all proposed lands, the scope of project includes construction of periphery wall acting as a physical and noise barrier between the primary substation and the adjacent privately owned land to both ensure noise reduction and access control.

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4. Institutional Requirements and Environmental Management Plan

The project will be managed by the project implementation unit headed by a project manager, who is a senior engineer of LECO. There will be a project engineer, and project supervisor for each construction site to handle the construction work. Further there will be a social and environmental officer to specifically handle and coordinate problems related to the environmental and social aspects of the project. LECO through their project implementation unit will bear the full responsibility of the environmental monitoring and management activity discussed in this IEE to achieve best environmental practices in compliance and exceeding the requirements of National Environmental Guidelines as well as ADB Environmental Guidelines.

The IEE would be made available to the Project manager, project implementation unit as well as to the contractor. The selected contractor/s is responsible for implementing appropriate mitigation measures. And project implementation unit will conduct monthly reviews and audits to monitor the project during implementation, to examine compliance with the conditions stipulated in the approval issued. Further it will coordinate all environment-related issues and activities, and the LECO will provide the necessary manpower and financial resources for the same.

The Lanka Electricity Company (LECO) has past experience in handling the projects similar to this nature. The last power system expansion project funded by ADB (sector loan (No. 1414 SRI (SF)) was done in 1996 to 2000, consisted with implementation of five primary substations and LECO distribution system development. The LECO as the executing agency had good reputation to carry out the project with proper environmental measures. Further LECO worked with ADB with its Secondary Towns Power Distribution project I and II under Loan No 732-SRI (SF) and 870-SRI (SF). This too included Distribution system expansion, rehabilitation and capacity augmentation.

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4.1. Public Complains Handling Procedure.

LECO attributes highest priority to the public concerns associated with any of their projects both during the construction and operation phases. Any complaints and concerns of public either affected or others will first be dealt by the LECO site staff. If the concerns demand augmentation of the construction related activities, the mitigatory measures will be implemented through the contractors. If otherwise which demands governmental interventions and procedural action then the complaints will be channeled to the respective government divisional secretaries.

4.2. Environmental Management and Monitoring Plan

The direct responsibility of implementing the provisions of this IEE, the conditions stipulated by the CEA in project approval, governmental orders through DS and any local authority regulations is with the LECO project manger. LECO will facilitate and coordinate this activity through their operational division as and when required.

Table 4.1 shows the comprehensive environmental management plan as per the ADB standard format.

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Project activity Potential Proposed Parameter to be Measurement institutional Implementation impact mitigation monitored and frequency responsibility schedule measure Pre – Construction Maintain adequate Disturbance to clearance people between the Before the GS occupying land dwellings and Proximity to During the augmentation adjacent to the retaining houses and other LECO design structural layout GS, owing to structures to be buildings is finalized land filling and built at two GS construction where land filling is Grid substation required augmentation Examine the and the new capacity of SCC existing storm water outlets to carry the Before the GS additional Volume and Additional storm During the augmentation volume, release direction of storm LECO water releases design structural layout storm water only water release is finalized to designated drains or water ways, as instructed by the local authority Polly Chlorinated Exclusion of GS Equipment Release of Biphenyls Transformer design, PCBs in During tendering specifications harmful (PCBs) will not and coolants and transformers and tender and design chemicals and be used in operating media used stated in tender evaluation parameters gases substation in all GS specification transformers or any other

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equipment.

GS location and Displacement/ Select a land House and other During land LECO Before the line design Relocation of with no buildings to be selection and route and GS housing buildings or demolished/relocated route selection locations houses, for each finalized preferably state- transmission owned land Design and location of transformers to Before the GS comply with Sri Expected noise During factory locations and Exposure to GSS location Lanka noise emissions based on tests and after LECO transformer noise regulations, substation design commissioning locations are noise levels finalized specified in bid docs. Transformers designed with oil Equipment During spill specifications with commissioning containment pit, respect to potential tests and During design of LECO and with pollutants, and compliance the GSS emergency oil compliance with checking of civil Escape of release and design specifications works Environmental polluting storage system. pollution materials GSS to include Bid documents storm water to mention

drainage and Substation storm detailed During design sewage disposal water discharge specifications, LECO and construction systems to avoid sewage design and compliance of GSS. surface water checking after pollution. construction. Explosions/ Fire Hazards to life Substation design Bid documents LECO compliance to mention During design Design of GSS with fire prevention detailed and construction to include fire and control specifications, of GSS. detection and control systems Page 17 Summary Initial Environmental Examination report of New Primary Substation Project (Revised) July 2008

and firewalls. Provision of fire and fighting codes Compliance

equipment to be in Sri Lanka checking after located close to construction. transformers. Construction Equipment Noise and Construction Construction Construction LECO Throughout the layout and vibrations techniques and techniques and techniques and construction installation caused during machinery machinery used by machinery period construction selection seeking contractors creating minimal actives to minimize ground ground disturbance, disturbance. before commencement of site work Construction Observations Noise, vibration Construction Throughout the Mechanized equipment status, during site visits, and operator equipment to be LECO construction construction hours of operation, as frequently as safety well maintained. period maintenance required Loss of power supply to local Minimize the Temporary areas, when duration of line Regularly during Throughout the blockage, loss distribution lines shutdown by Total hours of power the period of LECO and construction of service of crossing the new careful shutdown stringing the Contractor period utilities transmission programming of conductors. lines are work switched off Debris to be disposed of in No impact to the When the site is Throughout the Site clearance at accordance with Method and location LECO and external cleared by the construction GSS local authority disposal of debris Contractor environment contractor period regulations and advise Storage of Contamination Transformer oil Location of Examined by LECO and Construction chemicals and of receptors will be securely transformer; spill the project Contractor period

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materials (land, water, air) stored above reports (type of engineer at each high flood level, material spilled, site visit until the amount in m3) and transformer(s) action taken to are filled-up. control and clean up spill Construction workforce temporary sanitation, water Provision of Contamination facilities to supply and waste facilities for Amenities for LECO and Construction of receptors include proper disposal construction workforce facilities Contractor period (land, water, air) sanitation, water facilities once workers supply and waste each new facility disposal facilities. Land area of active Avoid period of Loss of agriculture lost at Encroachment cultivation in Monthly report LECO and Construction agricultural each tower footings in to farmland paddy fields and of the status Contractor period productivity and along the chena land transmission corridor Staged compaction Visual observation Uncontrolled Soil loss, of filling at two of run off and Monthly report LECO and erosion/ silt downstream GSS, covered Construction siltation of storm of the status Contractor runoff siltation at sites gravel stockpile period water drains adjoining GSS and loose material Incorporating Contract good Nuisance to Losses to specifying construction LECO and Construction nearby neighbouring careful Contract management Contractor period properties land uses/ values construction practices, practices. regularly during construction Health and Injury and Contract clauses Contract clauses LECO and Construction safety sickness of Contract (number of incidents compliance- Contractor period provisions

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specifying minimum requirements for construction camps Contractor to and total lost-work workers and prepare and days caused by once every members of the implement a injuries and quarter public health and safety sickness) plan. Contractor to arrange for health and safety training sessions environmental Number and monitoring coverage of personnel and Training schedules programs project and training coverage attended by each engineers/ other person staff Implementation of effective environmental Submission of Inadequate Likely to monitoring and duly completed construction increase reporting system checklists of all LECO and Construction stage damages, lost using checklist Respective contract contracts for Contractor period monitoring time of all contractual checklists and each site, once environmental remedial actions prepared to be requirements taken thereof. used thereafter Appropriate contact clauses Compliance report Submission of to ensure related to duly completed satisfactory environmental compliance implementation aspects for the report for each of contractual contract contract- once mitigation

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measures. Operation and Maintenance Substation transformers located within secure and impervious Transformer oil Oil sump sump areas with sump checked Contamination volume and Transformer Oil a storage through physical During of land/ nearby permeability LECO spillage capacity of at measurement of operations water bodies once after least 100% of volume and visual completion, the capacity of inspection oil in transformers and associated reserve tanks. Careful design Preparedness using Usage of appropriate level for using appropriate technologies (lost these technologies to work days due to technologies in minimize illness and injuries) crisis - once a hazards year Safety Inadequate awareness rising Included in provision of for staff. Injury and Number of design and staff/ workers Preparation of sickness of staff/ programs and LECO monitored health and fire emergency workers Training/awareness percent of staff/ throughout safety during action plan and s programs workers covered operation operations training given to in safety once a staff on year implementing emergency action plan Provide Complaints adequate Provision of facilities received from sanitation and staff, regularly

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water supply facilities Preparedness level or using Careful design these using Usage of appropriate technologies in appropriate technologies (number crisis - once a technologies to of injury incidents, year minimize lost work days) technologies in hazards crisis - once a Included in month Injury/ design and Electric shock Security fences mortality y to Maintenance of LECO monitored hazards around staff and public fences Report on throughout substations maintenance - operation Appropriate Maintenance of every 2 weeks warning signs on warning signs facilities Number of Electricity safety Training/awareness s programs and awareness programs for all Percent of total raising in Project Concerned parties persons covered areas - once a year Adequate training in O&M to all relevant staff of Number of Operations and Unnecessary substations Training/ awareness programs and maintenance environmental Maintenance Throughout programs for all percent of staff LECO staff skills less losses of various crews. operation relevant staff covered-once a than acceptable types Preparation and year training in the use of O&M manuals and standard operating

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Staff to receive Inadequate training in Number of periodic environmental Diminished Training/ awareness programs and environmental monitoring of Throughout ecological and s programs for all percent of staff LECO monitoring. project operation social values. relevant staff covered-once a Environmental operations and year monitoring. maintenance activities. Noise levels at Substations boundary nearest sited and Nuisance to to properties and designed to Throughout Noise related neighboring Noise levels (dB(a)) consultation with LECO ensure noise will operation properties affected parties not be a if any - once a nuisance. year Table 4.1 Environmental Monitoring Plan

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5. Public Consultation and Information Disclosure

All proposed sites for the primary substations are owned to LECO and has no public impacts. But all the substation sites are located in residential areas. Thus if public needs any information regarding the construction and operation of the primary substations, then such clarification requests are directed to LECO, specially if those are related to the land associated matters by adjacent neighbors. IF further clarifications are required then such would be provided though the DS upon written request from the public concerned. LECO will provide all necessary information as directed by the DS limited to the contractual and information disclosure requirements.

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6. Street Lighting Sub Project

At present LECO distribution area consists of 24.5 MWh of annual street light consumption out of which 5.4 MWh is from unauthorized street lamps. These unauthorized lamps are highly inefficient and altogether the street lights are controlled in irregular manner causing further energy loss. With the above in focus, LECO as part of their demand side management plan implemented a street lighting project in municipalities of its distribution areas. The aim of this project is to take strict control over the administration of street lamps, by introducing following technical changes 1. Installation of automatic group street lamp control panels with metering for each distribution substation. 2. Installation of street lamp conductors on LV lines where it is not already available. 3. Rearrange or reinstall street lamps as per Ministry Guide lines. 4. Replace inefficient lamps with energy efficient lamps. The only environmental concern with this sub project is the handing of replaced inefficient bulbs and burnout bulbs. The lamps which are identified to replaced are mercury, sodium vapor and halogen bulbs with high wattages.

Disposing Method of Replaced Lamps The replaced mercury lamps are to be stored safely at LECO warehouse in Waskaduwa with the recommendation and inspection of Central Environmental Authority (CEA). Presently Sri Lanka does not have a recycling plant to recycle the replaced bulbs. It will be stored safely until a recycling project which is schedule to be commission in two years time. CEA will carry out inspection at the facility.

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7. Findings and Recommendations

No major environmental impacts are identified in this IEE associated with the construction of the proposed four primary substations. The small quantities of earth filling associated will not create environmental impact provided that managed carefully. The accesses to all lands are though the public roads which do not need any augmentations or new constructions. No relocation of assists owned to members of public is required.

The standard practice of PSS design will be adopted in ensuring the transformer oil spillage control and provision of proper electromagnetic clearances. Further international standards associated with transformer noise limits will be ensured in procurement through the type and factory testing of the power transformers. LECO will implement the safety practices during construction and CEB will implement their health and safety standards during the operation of these PSS.

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8. Conclusions

The proposed project is a Power Transmission Project classified under ADB environmental classification to Category B. There will be no involuntary relocation of private or public property. There are no major environmental impacts associated with the constructional and operational phases of this project. The careful management of the project construction activity and thereafter the implemented asset this project will environmentally acceptable and compatible with any other similar primary substation construction project.

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