24559 December 1998 Public Disclosure Authorized
Public Disclosure Authorized Ufbam MiMM Omrf LmMJ Public Disclosure Authorized Public Disclosure Authorized
PILOTING URBAN ENVIRONMENTAL CHANGE IN SRI LANKA:
METROPOLITAN ENVIRONMENTAL IMPROVEMENT PROGRAM 1990-1998
Metropolitan Environmental Improvement Program (MEIP) An initiative of the World Bank, executed in Sri Lanka in partnership with the Ministry of Plan Implementation and Parliamentary Affairs
December 1998
This publication was written by Tanvi Nagpal and Illangovan Patchamuthu, The World Bank and Ravi Pereira and Mookiah Thiruchelvam, MEIP, Colombo.
Contents
Foreword
Acronyms
Acknowledgments
Summary: MEIP in perspective
I. Brief History of MEIP-Colombo
II. Strategies and Investment Planning
III. Investment Program and Pilot Projects
IV. Moving to Secondary Cities
V. Lessons Learned
Foreword
As one of the first environmental initiatives funded by the World Bank in Sri Lanka, the Metropolitan Environmental Improvement Program or MEIP, as it is commonly called, has lived up to high expectations. MEIP played a pioneering role in the evolution of the World Bank's dialogue with Sri Lankan stakeholders on environmental issues. It provided a venue for the government, civil society including nongovernmental organizations, the private sector, and the media to engage in constructive dialogue. Environmental policy, legislation and institutional reform in Sri Lanka have benefited from MEIP programs. MEIP has also assisted in mobilizing resources for environmental investments, including the World Bank-funded Colombo Environmental Improvement Project. Through its pilot and community demonstration projects, MEIP has not only made a difference in the lives of people, it has created structures that will enable communities to improve their own environment in the future.
This publication and a series of issue papers that will emerge from the MEIP workshop in Colombo in December 1998, will highlight MEIP achievements, some of its innovations and the general lessons that were learned. We hope that these documents will be a useful guide for communities, nongovernmental organizations and other policy makers committed to solving the array of environmental problems that face urban areas every day.
MEIP is a true team effort and we would like to extend our thanks to the Government of Sri Lanka and its officials, members of the private sector, representative of nongovernmental organization, community members, and MEIP staff.
Roberto Bentjerodt Richard Ackermann Country Director, Sri Lanka Sector Manager, Environment South Asia Region South Asia Region The World Bank The World Bank
November 20, 1998
iii
Abbreviations and Acronyms
CDC: Community Development Council CEA: Central Environment Authority . CEIP: Colombo Environmental Improvement Program CIEDP: Committee for the Integration of Environment into the Development Process CMC: Colombo Municipal Council CMRSP: Colombo Metropolitan Regional Structural Plan EMS: Environmental Management Strategy GOSL: Government of Sri Lanka IDA: International Development Association IPM: Industrial Pollution Management KfW: Kreditanstalf fur Wiederanfban (Reconstruction Credit Agency, Germany) MEIP: Metropolitan Environmental Improvement Program M/HUD: Ministry of Housing and Urban Development NDB: National Development Bank NESC: National Environmental Steering Committee NGO: Nongovernmental Organization NWSDB: National Water Supply and Drainage Board PACE: Public Awareness Campaign on Environment PCAF: Pollution Control and Abatement Fund SMI-IV: Small and Medium Industries - IV SCOPE: Scheme for the Pollution of Control from Existing Industries UDA: Urban Development Authority UNDP: United Nations Development Programme USAID: United States Agency for International Development Acknowledgments
In addition to the Staff, Consultants, Associates and NPCs - Past and Present of MEIP - Colombo, the staff of the World Bank field office and the NPCs of other regional MEIPs the following persons were closely associated with various phases of MEIP:
Abayawardana, Dr. S. A. K. Kotagaama, Prof. S. Ailapperuma, W. D. Kuruppu, R Algama, R. Kuruppu, Ms. S. Allahakone, Ms. N. Madugalle, Deshabandu T. B. Amarasinghe, Cecil Maliyadde, C. Amarasinghe, Patrick Marikkar, Ms. Neela Amaratunga, G. K. Mathes, Dr. J. A. P. Ambalavanar, Dr. V. McCauley, Dr. D. Amirthalingamn, A. Mendis, Prof W. Anandagoda, A. Mohamed, Akiel Arudpragasam, Prof. K. D. Mohideen, Faiz Baldwin, M. Mohottala, Dr. A. W. Bandarathilake, K. G. D. Mohottala, Ms. N. Basnayake, H. Mubarak, Dr. A. M. Bassnayake, Dr. B. F. A. Nanayakkara, E. A. Batuwitage, Ms. P. Nanayakkara, V. K. Bulankulame, S. W. P. Nesiah, Dr. D. Chandrasekera, D. Nilaweera, Dixon Chanmugam, Ms. Shenuka Obeysekera, Dr. Sarath Chularathna, H. M. U. Paskaralingain, R. de Mel, Sathis Peiris, Tilney de Silva, Dr. N. R. Perera, G. L. de Silva, Lalanath Perera, G. V. S. de Tissera, C. H. Perera, M. A. V. Dias, Ms. Visakha Perera, S. S. Dissanayake, Leonard Perinpanayagam, T. Dissanayake, T. K. Premachandra, D. G. Dixon, N. D. Ramanujam, Dr. P. Ellepola, Ms. Ramnani Ranaweera, K. A. H. Femando, R. M. S. Ratwatte, Charitha Fermando, Austin Samarakody, Priyantha Femando, Tissa Sapukotana, U. Gunapala, R. D. Scott, Ed Gunasekara, K. A. S. Selvanathan, Mano Gunashanhar, G. J. Seneviratne, Asitha Gunawardena, Vas Senevirtne, S. L. Gunawardene, Prasanna Silva, Prof N. Guneratne, A. W. Silva, Prasanna Hewage, Ari Sirivardana, Vasantha Jayamaha, J. H. J. Sivagnansothy, V. Jayamanne, Ms. Manel Siyambalapitiya, Dr. J. T. Jayaratne, K. A. Speldewinde, Ms. K. P. M. Jayasekera, Lakshman Weerasekera, D. Jayasinghe, Roy Weerasinghe, Ms. Sandhya Jayasinghe, Lionel Weragoda, N. V. K. K. Jayasundara, Shantha Wickremaratne, L Jayatilake, K. A. K. Wijewantha, N. W. E Jayawardena, C. D. R. A. Yasaratne, Ms. Shirani Jayawardena, A. R M. Jayawardena, A. S. Jayawardena, H. M. K. S. Jayaweera, D. S. Jinadasa, S. A. Junaid, M. N. Kanagasingam, T. Karunaratne, Ms. Malika Keerthiratne, J. G.
vi World Bank Staff Colombo Development Council Department of Meteorology Abedin, Ms. E. Department of Motor Traffic Ackerman, R. Development Finance Corporation of Ceylon Bentjerodt, R. Extemal Resources Department Davis, Ms. Gloria Federation of Charnbers of Commerce and Industries of Sri Hafeez, Rohil Lanka Hulugalle, Ms. S. Galle Municipal Council Illangovan, P. Industrial Technology Institute (formally CISIR) Kim, Ms. K. Industrial Association of Sri Lanka Kitamori, Ms. K. Kandy Municipal Council Koch-Wesser, Ms. M. Legal Draftsmen's Department Nagpal, Ms. T. Marine Pollution Prevention Authority Nangia, Rakesh Ministry of Finance Ramankutty, R. Ministry of Forestry and Environment Shah, J. Ministry of Housing and Urban Development Stem, S. Ministry of Industrial Development Vanjani, Ms. S. Ministry of Plan Implementation & Parliamentary Affairs Walton, T. E. Ministry of Provincial Council and Local Government Williams, D. Ministry of Science and Technology Zao, N. Ministry of Transport and Highways National Aquatic Resources and Research and Development MEIP Staff Agency National Building Research Organization de Silva, Shamali National Development Bank Fernando, Bernadette National Housing and Development Authority Hiripitya, Chandana National Planning Department Illangovan, Patchamuthu National Water Supply and Drainage Board Pereira, Ravi Nuwara Eliya Municipal Council Perera, Tamara Sri Lanka Association for Advancement of Science Pakeer, Zuhura Sri Lanka Land Reclamation and Development Corporation Pilapitiya, Sumith Sri Lanka Ports Authority Ramachandran, Easha Sri Lanka Standards Institution Thiruchelvamn, M. Transport Study and Planning Centre Veliah, Mankesh University of Moratuwa Wanniarachchi, Malraki University of Peradeniya Wijeratne, Danny Urban Development Authority Wijeratne,Danny Urban Program Unit Nongovernmental Organizations Westem Provincial Council
Sevanatha Donor Organizations Environmental Foundation Ltd Asia Foundation ArtEacharya Foundation Canadian Intemational Development Agency EMACE Foundation Government of Belgium Evergreen Foundation Nuwara E1liya Tourism and Trade Services Association Government of the Netherlands Norwegian Agency for Development Cooperation (NORAD) United Nations Development Program Companies United States Agency for Intemational Development Andropogan Associates, USA Associated Engineering Intemational Ltd, Canada BKH Consulting Engineers, the Netherlands Engineering Consultants Ltd, Sri Lanka Environmental Engineering Consultants, Sri Lanka Environmental Resources Management, UK Grannt-McCann- Erickson, Sri Lanka Resource Development Consultants, Sri Lanka Roche Intemational, Canada Soil and Water Ltd, Finland
Govermment and Private Institutions
Board of Investment Central Environmental Authority Ceylon National Chamber of Industries Ceylon Petroleum Corporation Coast Conservation Department
vii
MEIP in Perspective
In the eight years of its operation in Colombo, the Metropolitan Environmental Improvement Program (MEIP) has made a lasting impression on policy makers and communities in the way they perceive urban environmental issues. MEIP has brought new ideas and innovative approaches to the table. It has partnered with local governments, the private sector, nongovernmental organizations (NGO) and communities to pilot projects, programs and approaches that have often, but not always, been success stories. Many of the ideas originated by MEIP have been adopted by the Government of Sri Lanka. Private enterprises have embraced good environmental practices; communities have demonstrated their ability to effectively address environmental problems; and NGOs have forged links with local governnents and authorities enabling creative problem solving.
From its inception, MEIP was viewed as a pilot program that would introduce and test concepts and innovative practices in urban environmental management in Sri Lanka. Its establishment coincided with the Government's own foray into environmental protection, and thus the program was able to play a pioneering role in the evolution of interventions for environmental improvement. In the policy arena, MEIP assumed a leadership role in the formulation of strategies for overall environmental management in Colombo, and especially for industrial pollution and air quality management. On the investment front, MEIP facilitated the preparation of the Colombo Environment Improvement Project (CEIP) and establishment of the Pollution Control and Abatement Fund (PCAF). Through its role in community-based pilot projects, MEIP has been able to make a direct impact on the lives of the poor, and has also demonstrated that empowered communities can invest in and improve their living environment. MEIP has been only marginally successful at reforming institutions to make them function more effectively. While in the initial years it played a direct role and often substituted for a government entity, in later years MEIP increasingly took a back seat, allowing state agencies to carry forward the process it had begun. CEIP and PCAF are today independently managed by the Ministry of Housing and Urban Development (MIHUD) and the National Development Bank (NDB), respectively.
MEIP has been successful because of strong govemment comrnitrnent. However, not unlike many donor-fimded projects, the commitment has tended to wane over a period of time, especially after there has been internalization of the concepts and processes. Clearly, some MEIP initiatives will last long, and those elements of the MEIP approach which have been internalized by its partners will continue to effect the way in which environmental issues are handled in metropolitan areas in Sri Lanka.
MEIP performance has been independently assessed by the Program Evaluation and Monitoring Unit of the Ministry of Plan Implementation and Parliamentary Affairs in the Govermment of Sri Lanka (GOSL), and by the Environmental Foundation Limited, an NGO. The Government evaluation team was of the opinion that MEIP interventions had been timely and relevant, and had positive impacts in improving the environment of the metropolitan area. However, given the worsening of the general urban environment, the report also concluded that MEIP should have been expanded and its activities continued. The NGO evaluation was also supportive of overall MEIP contributions but added reasons why the program's goals had not been more fully realized. These included the following:
* Action plans and policies have not been implemented with sufficient speed and efficiency; * Implementing agencies and available mechanisms are not sufficiently developed or geared toward dealing with the program's requirements; * Lack of funds or delays in obtaining funds for project implementation; and * Lack of sustained political will and interest.
This report describes MEIP and its lessons in Sri Lanka. The first section of this publication briefly describes the history of MEIP-Colombo; the second section discusses the formulation of different strategies and the preparation of investment plans, as well as the move to secondary cities; the third section discusses the investment program and pilot projects; the fourth section explains the move to secondary cities; and the final section contains the lessons learned.
2 Box 1: Snapshot of MEIP achievements
Environmental Strategy * Clean Air 2000 Action Plan * Industrial Pollution Management Policy, Strategy and Action Plan * Environmental Management Strategy for Colombo * Secondary City Profiles and Action Plans - Galle & Kandy * Hazardous Waste Management
Capacity Building * Training Environmental Agencies, NGOs and Financial Institutions * Laboratory Equipment for CEA, CISIR and NBRO * Hazardous Waste Regulations * Model Environmental Statute for Western Provincial Council * Curriculum Development for Environmental Education * Cleaner Production Audit for over 50 industrial units * Information, Education and Communication with NGOs and Private Sector Investment Planning and Resource Mobilization
* Colombo Environmental Improvement Project: Beira Lake Restoration, Common Industrial Wastewater Treatment Facilities at Ekala and Ratmalana and Sanitary Landfill . Pollution Control and Abatement Fund (PCAF) * Air Quality Monitoring Network * CleaNet - Information Clearing House Community Empowerment
* Clean Settlements Program - Bo-Sevana and Stadiumgama * Integrated Environment Improvement Projects - Galle & Kandy * Sanitation & Water Supply Project - Galle * Solid Waste Management Project - Galle Knowledge Exchange * Envirolanka'92 . MEIP Inter Country Workshops * International & National Workshops * Sector Specific In-country Workshops . Participation in Government Environmental Committees
Pilot Innovation
* Private-Public- University collaborated Composting Plant at Kandy * Community Based Water Supply/Drainage Schemes Galle and Kandy * Community Based Solid Waste Management Projects - Galle and Kandy * Community Based Urban Greening Project - Nuwara Eliya . Coastal Zone Monitoring - Schools Project - Galle
3 I. Brief History of MEIP-Colombo
In 1989, responding to the environmental challenges of urban growth in Asian cities, the World Bank and the United Nations Development Program (UNDP), initiated the Metropolitan Environmental Improvement Program in five Asian cities. The defining feature of this approach is its commitment to improving the institutional basis of environmental management and devising locally anchored and sustainable solutions to the environmental challenges of urban growth. Specific objectives include the following:
* Assist urban metropolitan areas develop environmental management strategies and action plans in the context of urban and industrial development; * Strengthen the institutional and legislative framework for environmental planning, monitoring and enforcement; * Help identify and prepare high priority investment projects and mobilize the resources necessary to implement these; * Promote community-led efforts to improve the living environment; and * Initiate a process of cross country dialogue to share information and lessons.
The World Bank procured funding from European and Australian donors in 1995 to continue and expand MEIP operations. Currently MEIP offices are active in Metro Manila, Jakarta and Colombo. Secondary cities such as Cebu and Davao (the Philippines), Semarang and Surabaya (Indonesia), and Kandy and Galle (Sri Lanka), have also entered the program.' New programs are commencing in Haiphong, Vietnam and Thailand.
MEIP was endorsed by GOSL in 1990, and placed under the Ministry of Policy Planning and Implementation which worked closely with the Ministry of Environment and Parliamentary Affairs.2 An inter-ministerial National Environmental Steering Committee3 (NESC) was constituted to provide policy guidance and direction to MEIP, as well as to review progress periodically. A National Program Coordinator was appointed to coordinate and manage MEIP in Sri Lanka. Technical Working Groups were appointed to examine relevant issues when they emerged. In the eight years since MEIP was first constituted many political changes have taken place in Sri Lanka. From the perspective of MEIP, however, environmental issues have continued to gain increasing recognition. The NESC became defunct in 1994, and its place was taken by the Committee to Integrate Environmental Concerns in Development in 1998. This committee is jointly chaired by the Secretaries to the Ministry of Finance & Planning, and the Ministry of Forestry and Environment.
I Between 1989 and 1993, MEIP also functioned in Beijing (China), Mumbai (India), and Kathmandu (Nepal). 2 These ministries have since been reorganized and MEIP is no longer under their purvey. 3 National Environmental Steering Committee (1990-1994) jointly chaired by Secretaries to the Ministries of Finance and Policy Planning & Implementation, and Environment & Parliamentary Affairs, and including Secretaries of key development Ministries.
4 Environmental protection and natural resources management have been a part of Sri Lanka's constitution for two decades. The Central Environment Authority (CEA), created in 1980, has been granted increasing powers of regulation. In early 1990, a cabinet-level Ministry of Environment was created, giving higher visibility to environmental issues. Although these mechanisms and legislation were in place, they were unable to respond adequately to the environmental challenges that Sri Lanka was facing because of limited financial resources and technical manpower.
The cornerstone of the MEIP approach in Colombo was the preparation of the Environmental Management Strategy (EMS). The objective of the EMS was to provide a city-wide strategic framework within which public and private agencies and community groups could implement planned environmental improvement and investment activities. The EMS not only established environmental priorities but also the actions needed to achieve them. Equally importantly, the priorities and strategies were established through a consultative process involving local governments, nongovernmental organizations, the private sector, environmental experts and World Bank representatives. An environmental survey highlighted the fact that, in Colombo, the greatest challenges lay in domestic wastewater and industrial and air pollution management. The initial MEIP workshops served as a catalyst for the formation of a broader environmental network, and laid the groundwork for the development of an EMS for Greater Colombo.
II. Strategies and Investment Planning
Environmental Management Strategy and Action Plan
Stemming from the Government's National Environmental Action Plan, the preparation of an EMS was the first MEIP initiative. Funded by UNDP and Dutch Trust Funds, the World Bank and GOSL jointly developed the terms of reference for consultants and selected them. The Urban Development Authority (UDA) functioned as the key government counterpart agency responsible for overseeing EMS and Action Plan development. At each stage, the UDA took the lead in clarifying policy options, with policy guidance from the NESC and technical consultants' consortium. Completed in 1994, the EMS now serves as the framework for the Colombo Environment Improvement Project (CEIP) which became a major MEIP investment program. The restoration of Beira Lake, central effluent treatment plants at Ekala/Ja-Ela and Ratrnalana/Moratuwa, municipal solid waste collection and disposal, and community environmental management and infrastructure development were all part of CEIP. The EMS has also been integrated into the broader National Environmental Action Plan. The UDA established its own Environmental Management Unit to integrate EMS into land use and infrastructure planning. The recently published Colombo Metropolitan Regional Structure Plan (CMRSP) embraces EMS principles such as landuse and natural resource planning. The UDA will use the CMRSP as a framework to guide Colombo's future growth. EMS development was divided into three phases. The first phase of environmental assessment identified the following priorities for the Colombo urban
5 area: loss of natural resources; deterioration of groundwater and surface water quality; flooding and stagnation of water courses; solid waste pollution; deteriorating ambient air quality; environmental degradation in low income areas; and traffic congestion. In phase two, environmental objectives were defined and strategies to meet these objectives were outlined. Costs and benefits of alternative strategies were estimated in order to make judgments regarding their financial feasibility. Six sectoral strategies were created. They included environmental structure planing, overall water management, storm water management, wastewater management, infrastructure development, and the emergence of new growth patterns that respond to the natural ecological systems of the larger metropolitan area. Phase three included the preparation of a ten-year Action Plan for implementing the EMS and proposing investment plans for specific sectors. The Action Plan covered public, private and NGO activities, including economic, fiscal and legal measures; investment projects, spatial plans, monitoring, institutional strengthening, community awareness and education. Issue-specific plans were created for air, water and land management. Remedial and preventive actions were separated.
The original environmental survey and Box 2 - EMS Outcomes,and Priorities'.-- Outcome X- ' - ' EMS; - development'- ~- '~~' .helped' ' to clarify . Quantified-extent of-environmental -- specific issues. MEIP-Colombo played degradation-- - a pivotal role in policy issues involving -- EstablisbedJ a realistic set of environmental -i industrial pollution management, air -' q.^quality goals and improvement targets "Illt-in pollution,p andn solid waste maniagement. - Form ulated a'least-cost strategy and action - - --plan fior environmental inpro've'en't- ': Equally important, although not sector specific, were water-pollution issues Priorities'. - - and the cross-cutting aims of
Qg-based land use planning . ' -. community. development and upgrading. . ~,Flooding an'd r'eclamation of wetlands ''; '=Pilot projects were identified under each ~ managementSolid~waste of these headings. . Wastewater management (domesitic and' -- industrial sources) * Vehicular air pollution control
Industrial Pollution Management
MEIP-Colombo organized its first workshop on industrial pollution management (IPM) in April 1991. The event drew representatives from national government agencies and local authorities, the private sector, NGOs, financial institutions, and the media. Stakeholders discussed the nature and extent of the problem, and the technical, legal and regulatory issues surrounding IPM. As a direct consequence of the workshop, GOSL obtained technical assistance from the World Bank through MEIP in 1992. The objective was to develop a strategy and action plan for IPM, including regulatory actions and incentives needed to promote compliance with the National Environmental Act and Regulations. The IPM strategy that emerged from this project was consequently endorsed by Ministers of Industry, Science and Technology and Environment, and the private
6 sector, including the Chamber of Commerce and Industry in September 1996. The main principles of the strategy are articulated in Box 3.
Box 3 -Indus trial Pollution Management. Policy and Straitegy- Principles
. Pollution prevention at the.source * Central wastewa6terltreatment :-; Polluter pays for the waste gen'erated.:-, - -';--- .. - ; Clustering industrial units-in estates and parks . Providing incentives and strengthening en'forcement .-. Three-way partnership involving'govenment community and private sector-
Following an endorsement by the governnent, CEA assumed responsibility for the implementation of the IPM Action Plan. The pace of implementation has been slow and the dates no longer coincide with those outlined in the original plan. This is largely due to the weak institutional capabilities of CEA. Some of the fundamental problems identified by the strategy remain unresolved.
Air Quality Management/Clean Air 2000
Projected rates of economic and vehicular growth show that air pollution in Colombo will become critical in the next decade unless preventive measures are adopted now. Firewood used in homes for cooking and high sulfur and leaded fuel used by the expanding vehicle fleet are the main culprits. In August 1991, MEIP organized an Air Quality Management workshop and invited policy makers, government officials, researchers, representatives from NGOs and academics. Participants agreed that in the absence of reliable data it would not be possible to create strategies to control air pollution in Colombo. As a follow up, MEIP organized training on air quality management, drawing on the knowledge of experts from Beijing and Bombay who had created air quality management plans. Important issues such as setting standards, monitoring techniques and instrumentation, air quality modeling, fuel pricing, pollution abatement and control and various regulatory and other measures were discussed at this meeting.
Based on these discussions, participants designed a draft action plan for air pollution management - the Clean Air 2000 Action Plan (see Box 4.). In 1993, the Clean Air Plan was endorsed by GOSL through a decision of the cabinet of ministers.
7 Bbxi4 - Key¢E1ements.of Clean,'Ai 2000 -i-'
Actions - - - '. Vehicle Inspection and Maintenance L .' 'Fuel Formulation,.Pricing ?and Fleet Mix -Emission'-nventory,and M,onitoring -Standard'Setti, *, Instittional Fraiew6rk an'd Regulatory Compliance -EconomicJnstruments * Transportation Planning maiid Traffic Management' -.',' ,r
Key Reduction .Targets for y`ar'2000 (from 1990 levels) PaticuWates;-. .40S, * -Carbon monoxide- . 40%, -i .: Oxides of nitrogen , 30S' *"'Lead- 305' 4' Oxides of sulfur 7-5 - * .,Hydrcarbons 20%.
The implementation of this policy framework has been one of the greatest MEIP successes. The achievements include the following:
* Introduction of unleaded gasoline; * Elimination of engine conversion through financial disincentives; * Establishment of an air quality monitoring network funded through the Bank's Colombo Urban Transport Project; 4 * Setting of ambient air quality standards; * Introduction of smoke meters; * Introduction of diesel tax for non-commercial vehicles; * Proposed amendments to the Motor Traffic Act to incorporate inspection and maintenance; * Freeze on lead addition to petrol; and * Heightened awareness of air quality issues among policy makers and the public.
4 The Central Environment Authority (CEA) has outsourced the operation and maintenance of this network to a research institution - National Building Research Organization
8 Solid and Hazardous Waste Management
The MEIP role in solid waste management has been twofold: (a) promoting community-based recycling efforts, and (b) designing CEIP solid waste management component. The overall strategy included the development of a solid waste management plan for the Colombo Metropolitan Area. The strategy indicated the need for investing in a new sanitary landfill to replace existing open dumps, assisting in the preparation of a detailed long-term waste management strategy and disposal plan, separating hospital and municipal waste and a program to handle hospital waste with greater care, promoting composting in order to reduce the quantity of waste to be disposed, and providing technical assistance to develop in-country waste management capabilities with particular focus on enabling private sector participation in solid waste management. The CEIP solid waste management component, costing around US$12.5 million, includes the following:
* Construction of a sanitary landfill at Hanwela to meet the disposal needs of the Colombo Municipal Council (CMC) and fourteen of the thirty urban local authorities located north and east of the metropolitan area for the period from 1998 to 2004. This facility will be operated by a private sector turnkey contractor. The landfill site will also have a 100 tons-per-day compost plant. Although the need for a landfill was identified as early as 1990, it was difficult to reach a consensus on the selection of a suitable site because communities could not agree on any of the options presented to them; * Institutional strengthening of CMC and other local bodies to improve their capacity to manage garbage collection and disposal; * Management and operation of facilities, and technical assistance in the disposal of hospital waste, would be provided for implementing safe procedures for collection and storage of clinical waste.
MEIP was also instrumental in drafting the Hazardous Waste Management Regulations now used by the Ministry of Environment. A pre-feasibility study on hazardous waste management and disposal, funded by MEIP and Small and Medium Industries - IV (IDA funded), proposed measures that would enable CEA to implement hazardous waste management regulations. It also included an inventory of hazardous waste generation and current disposal practices, identification and ranking of suitable disposal sites, and a conceptual design for an appropriate treatment facility. The Ministry of Environment and CEA are in.the process of seeking Cabinet approval to secure a suitable site for hazardous waste treatment.
9 III. Investment Program and Pilot Projects
'B,x:'5: Investment Program Initiated by-MEIP-'- The main investment vehicle initiated by Colombo Environmental Improvement ProjectAA. 5$ ,IP is the IDA-
,- Municipal'S,olid WasteManagement :: -1255milli,n- funded CEIP. This ~- Wastewater Collection System' 9 million project IS financing Beira Lake Catcbrnent4Pollution-Control - 10.0 million' some of the priority ' Tec nical Assistane 7.5 millio n- environmental
Pollution - ~~~~~~~~~~interventions in *,' ollution Control and.Abatemen't Fuind/PCAF 7.5-mil1i6n (KfW): itreiosn Control and Abatement u-n-dI f 75 mill-on - Colombo. It is now in its third year of implementation.
Beira Lake Restoration
Pollution in Beira Lake, a distinctive Colombo landmark, has been a source of concern for the Government of Sri Lanka for some time. The lake had been losing recreational and economic value, and pollution had become a nuisance to people who lived near the shore. The lake's stagnant condition, numerous outfalls discharging polluted water, and disposal of sewage and garbage were some of the main reasons for the decline of the lake. Although sporadic efforts had been undertaken to restore the lake, few proposals actually came to fruition.
In 1990, MEIP prompted relevant government authorities to take concrete actions for the sustainable restoration of the lake. The NESC coordinated inputs, functions, and responsibilities of sectoral agencies that had jurisdiction over the lake and its catchment. This culminated in a study which adopted a multisectoral geographic approach to the restoration of the lake. The study reported that sewage and sullage entry into the extensive storm-water network through unauthorized connections from households around the catchment was the main source of pollution in the lake, and identified phosphorus as the main cause of eutrophication of the lake. A ten year, two-phase, restoration strategy was proposed.
Phase one, for which US$ 10 million was earmarked, would focus on reducing pollutant loading, mainly sewage, and on monitoring and enforcement. In phase two, restoration techniques such as dredging of the lake's sediment, filtration of algae, and stocking of algae-eating fish, would be implemented. Specific interventions in the first phase included the following:
Redirecting over seven thousand unauthorized sewer connections to the sewerage network from the storm water network which drains into the lake. This will substantially reduce the organic loading into the lake;
10 * Reducing the frequency of sanitary sewer overflows through the expansion of the sewerage network in the lake catchment area; and
* A comprehensive monitoring program that would quantify the improvement in water quality and establish a time series of the lake's trophic.
The MEIP approach to Beira Lake was distinguished by the fact that it was the first integrated and multisectoral plan for the restoration of the lake. The interventions that were identified targeted not just households but also the private sector. Further, it provided sustainable solutions such as improved waste management so that the actual amount of waste being produced and thus disposed would be reduced. Squatter settlements that previously had no sewage connections would be upgraded, and the larger public made aware of the consequences of continued environmental degradation of the lake.
Central Wastewater Treatment Facilities
MEIP assisted the Government of Sri Lanka in conducting feasibility studies with a view to establishing Central Wastewater Treatment Facilities as against individual treatment plants for the industrial areas of Ekala/Ja-Ela and Moratuwa/Ratmalana, north and south of Colombo, respectively. The two facilities, once established, will treat large volumes of industrial wastewater currently discharged into open drains, channels and waterways.
Industrial pollution, especially in Moratuwa/Ratmalana, has long been recognized as a problem. This situation has resulted in the residents objecting vehemently to the existence or siting of industries in the area. In response to this, a moratorium has been declared on the future siting of industries in the Moratuwa/Ratmalana area. However, existing industries cannot be relocated and an equitable solution needs to be worked out.
The option of a public-private partnership for establishment of the treatment facilities is being pursued by GOSL. IDA is providing approximately US$9.1 million toward the construction of a wastewater collection network in the two areas. While private sector participation is being considered for the construction and operation of the treatment facilities, GOSL is in the process of evaluating the option of having a private sector tumkey or a BOT (build, operate and transfer) contractor manage the system. It is envisioned that the private operator will build, operate and maintain the treatment plant, the collection network, and the ocean outfall. In the event that private investment is not forthcoming, GOSL will finance the treatment facilities.
The treatment technology itself would differ for the two locations. Moratuwa/ Ratmnalana is a mixed residential and industrial suburb, with tremendous population pressure on land availability. Here the recommendation is for preliminary treatment with a
11 final discharge into the ocean by an outfall. The recommended treatment technology for Ekala/Ja-Ela is biological treatment using the activated sludge process.
Although the treatment facilities are expected to be functional by the year 2000, there are several institutional, technical, financial and regulatory issues that need to be resolved. In addition, as this is the first time a project of this nature is to be implemented in Sri Lanka, many unforeseen and unexpected issues may arise during the course of implementation. This initiative represents an example of a project which has gone through the cycle of identification, preparation, packaging, funding and implementation.
Pollution Control and Abatement Fund (PCAF)
One of the outcomes of the 1991 MEIP workshop on industrial pollution was the formulation of a time-bound program called the Scheme for the Control of Pollution from Existing Industries (SCOPE). This scheme provided the framework for industries to meet national standards for pollutants in a phased manner over five years. A Pollution Control and Abatement Fund (PCAF) was also set up with the aim of helping industries comply with the national standards. Initial funding in the amount of US$5 million was provided by Kreditanstalf fur Wiederanfban (KfW) of Germany. PCAF was extended to financially viable industries, existing as of January 1, 1994, for waste minimization, resource recovery and pollution control and abatement.
The existence of stringent guidelines, and the government's willingness to enforce them, contribute to the success of PCAF. In addition, industries have themselves realized that they must adhere to environmental protection techniques in order to stay competitive in international markets. Almost the entire amount of US$5 million has been committed and KfW has expressed an interest in providing additional funds. The Government of Japan is also interested in supporting this initiative because of its early success.
Pilot Projects
Clean Settlements Program
MEIP-Colombo launched its first community-based environmental project, the Clean Settlements project, in 1992, in partnership with Sevanatha, a local NGO. Gajabapura-Bo-Sevana was the first site. The selection was made in consultation with the Colombo Municipal Authority which had already earmarked this 135-family settlement for upgrading. As a first step, Sevanatha organized a community workshop that brought together selected members, health officials from the municipality, and housing officers from the National Housing Development Authority. The workshop's objective was to allow the community and the local authorities to jointly identify problems and develop an action plan that would contain strategies to solve these problems.
12 The project area was divided into three Community Development Council (CDC) areas, and each CDC had the responsibility for implementation in its area. Sevanatha served as the facilitator in organizing activities and linking local government and other agencies with the CDCs. The Action Plan developed in the workshop contained both long- and short-term solutions. The former would be executed by the community without external assistance. Examples of these activities included repair of damaged common toilets, water taps and drains. Long term solutions included actions taken by the communities in partnership with external actors and using external assistance. These solutions were more permanent remedies to environmental problems. In addition to MEIP support, communities were also able to get small-scale grants from the Dutch and Japanese embassies.
A savings and credit scheme was established for women. A community center equipped with a reading room, and sanitary toilets were built for the community. Many families also improved their homes, a process that was facilitated through the availability of information and frequent contact with representatives of Sevanatha and local and state agencies. MEIP also undertook a public awareness-raising campaign using meetings, simple newsletters and music and drama classes for children. The newsletter (Thorathuru Mal-la "Basket of Information") now reaches about 400 organizations throughout the country.
Both the process and the partnerships that were forged under this first community project have made a substantial impact by changing a government-controlled environmental service delivery process into a community-managed process. The Clean Settlements project provided a platform for a low income settlement to plan and manage its own environment and act on issues that it perceived as priorities. Because of its success, the Clean Settlements Project has evolved into a freestanding project, funded by the World Bank. It has been scaled up and is run by the Ministry of Housing Construction and Public Utilities.
Pilot Composting Project
In 1993, MEIP launched a composting project in Wellampitiya to complement its solid waste management project. The plant was set up with financial assistance from the United States Agency for International Development (USAID). Initial studies had shown that the municipal waste was high in organic and moisture content and composting would be a technically feasible option. In addition, given the high demand for compost from home gardens and from the plantation sector, which alone required approximately 9,000 tons of compost per year, this would also be an economically viable operation. While compost production had started, mechanical failures, inadequate labor and supervision, and interruptions by rainfall hampered the ability of the plant to produce on a regular basis. With the closure of the Wellampitiya landfill which had served as an open dump for the Colombo Municipal Council, the production of compost was also abandoned. Despite this setback, the pilot established that local municipal solid waste
13 was ideal for composting using basic technology. In the future, composting will be included as a component in the proposed sanitary landfill to be developed under CEIP.
Pollution Prevention and Cleaner Production
The 1991 IPM workshop recommended that cleaner production efforts in the private sector should be encouraged. Through assistance provided by USAID, MEIP facilitated a cleaner production assessment in 25 private sector manufacturing units covering four sectors. This assessment/audit was undertaken by the US-based Minnesota Office of Waste Management. For the first time it afforded an opportunity for the private sector to learn and practice cleaner production efforts at the plant level. During these audits, industrial units were instructed on how they could benefit from waste minimization opportunities through improved practices at minimum cost. Similar assessment was also undertaken for forty industrial units in Ratmalana and Ja-Ela.
Results of the IPM workshop and subsequent assessments became a corner-stone of the government-endorsed National IPM policy statement of 1996. The assessment also influenced the design of PCAF, which requires applicants to examine pollution prevention opportunities before embarking on end-of-pipe treatment. This necessitated the creation of a clearing house for information sharing on pollution prevention, and thus CleaNet was born. After early difficulties in finding an institutional home in the private sector, CleaNet is now housed in the Ceylon Chamber of Commerce while the technical expertise is provided by the Industrial Technical Institute (formerly CISIR). The World Bank is assisting CleaNet through the IDA-financed Private Finance and Development Project. CleaNet functions as an on-line clearinghouse, brokering information, networking and training, facilitating pollution prevention audits and, eventually, promoting waste exchange among industrial units on a fee levying basis.
Pilots on Public Awareness
MEIP has always functioned on the premise that sustainable environmental management requires a widespread knowledge of environmental issues, both problems and solutions, within communities. Effective stewardship of the environment is only possible if the community is proactive and accepts its responsibility in controlling pollution and protecting the environment on an individual and collective basis. This is needed not only to ensure the development of an adequate political basis for necessary government leadership and action, but also to facilitate meaningful input by industry, NGOs and individuals to the development and implementation of solutions. MEIP has therefore actively sought to promote public awareness through the media, environmental campaigns, posters, stickers, exhibitions and street dramas.
Targeted campaigns were focused on air pollution and declining environmental quality in Colombo. They began with the Vehicular Emission Control Campaign (VECC) in June 1992 to promote awareness of the impacts of vehicular air pollution. With the installation of the Air Quality Monitoring Stations, MEIP has printed and distributed air
14 quality data in the three national languages to schools, through the Ministry of Education. Another initiative was the vehicular smoke testing program in collaboration with the private sector and the Sri Lanka Traffic Police Division. Colombo's environmental problems were highlighted in the first national environmental exhibition - Envirolanka 92 - initiated by MEIP. This brought together approximately 70 local and international organizations with the theme of initiating public-private partnership for environmental protection in Sri Lanka.
In the preparation of CEIP, a comprehensive Public Awareness Campaign on Environment (PACE) was undertaken to inform the population living in Colombo on the environmental neglect that has taken place and the consequences of inaction. This campaign was coordinated by an advertising agency through the press, television and radio.
The experience of MEIP has demonstrated that public awareness is not a one-time event but a continuing process. Information, education and communication efforts should be an integral part of all environmentally-oriented initiatives.
IV. Moving to Secondary Cities
Since 1996, MEIP-Colombo has turned its attention to secondary cities, mainly concentrating on demonstration projects based on community participation. The cities that were chosen for this exercise were Galle, an important southern city (110 km from Colombo), Kandy, the hill capital (115 km from Colombo), and Nuwara Eliya, a popular holiday resort, 2000 m above sea level in the central hills (180 km from Colombo).
Demonstration projects in Galle included integrated environmental improvement projects aimed at developing micro-enterprises, composting, improvement of sanitation, environmental education and savings schemes. During the execution of the programs, and responding to the communities needs, a water supply scheme was developed for the semi- urban community of Danduwana and a sewer network developed for the urban low income settlement of Mohideenwatta. Another positive outcome of these projects was that the Galle Municipal Council recognized the value of the role played by NGOs, and requested that similar initiatives be replicated in other wards. A collection unit for recyclable material was also set up by the Galle Municipal Council in association with the NGO as an income- generating enterprise, and is the first of its kind in Sri Lanka.
In Kandy, demonstration projects included a community-based project to increase environmental awareness and encourage solid waste management. This was done through the production of compost in home gardens, recycling plastic, and improving sanitation. In addition, the public (UDA) and private sectors were involved in developing a pilot all- weather composting system, utilizing expertise from the University of Peradeniya. This is the first time that the private and public sectors have come together and used in-country expertise for an environmental investment.
15 In Nuwara Eliya, MEIP undertook an urban greening project to demonstrate the need to conserve urban wetlands that act as water purifiers through bio-filtration. The project also includes the setting up of an environmental visitors center and a nursery that will be maintained by the community, under UDA administration.
One of the heartening outcomes of the secondary cities program is the fact that MEIP has been able to raise environmental consciousness among local authorities, and stimulated the willingness for the public sector to partner with NGOs in addressing environmental problems of the ultimate beneficiaries at the grassroots level.
Despite these successes it was observed that, in many cases, local authorities in secondary cities are not geared to implement environmental infrastructure projects. One example of this is the lack of success MEIP encountered in trying to construct a septage treatment facility for the Galle Municipality.
V. Lessons Learned
Home to nearly two million Sri Lankans, Colombo district is the country's largest and most important urban area. While the environment has not been under attack here in the same way that it has in larger Asian metropolitan areas, there is clear evidence that growth and economic development are creating new and larger stresses. Increased vehicular traffic, flooding, unplanned urban sprawl, the growth of low-income settlements, industrial and water pollution are some of Colombo's critical problems. MEIP environmental management activities in Colombo may be useful examples for cities that are steadily growing and beginning to encounter the environmental problems that megacities face each day.
The MEIP record in Colombo can be judged not only by a review of its piloting activities but also by the extent to which ideas and actions championed by it have become mainstreamed in Sri Lanka. MEIP also expanded its work and partnered with two secondary cities, Galle and Kandy, to replicate the lessons learned in Colombo. Four major lessons that emerge from a consideration of MEIP experiences in Sri Lanka are the importance of building partnerships, strengthening local governments, empowering communities, and creating and fostering networks.
Building Partnerships
MEIP Program Coordinators unanimously agree that one of the program's most important lessons is that all stakeholders should be involved and consulted in a problem- solving process as early on as possible. Whether in the policy realm or in community engagement, involvement of stakeholders has contributed to the success of many MEIP activities. The IPM policy statement and Clean Air 2000 exercises are good examples of active stakeholder participation in formulating policies that are generally acceptable to all parties.
16 * Policy Making
Given the existence of a multitude of institutions in Sri Lanka it is not always easy to arrive at a consensus in a short period of time. Each agency has its own development priorities and often wants to accelerate its pace of achievement. In many cases officials from both the energy and industry sectors in the governnent and in the private sector saw environment as a delaying factor. Many months of often painstaking consultation were required in order to develop strategies that could be embraced by the majority of the stakeholders. Endorsements from cabinet ministers, industry chambers and leading environmental activists, and a quick pace of implementation, are partly the result of this coalition building.
However, despite the consensus building efforts in early years, MEIP has needed to continuously seek the active support of the government in the implementation phase. Absence of this support has sometimes lowered enthusiasm and created a situation in which other stakeholders have withdrawn their own support. In order to sustain the earlier consensus building efforts, in the future, the MEIP facilitator role will have to be taken on by the Ministry of Environment and Central Environmental Authority.
Community-Based Activities
In the case of community-based efforts it was observed that beneficiaries had to be involved at all stages in the design and execution of the initiation project in order for it to be sustainable. Consultations are crucial for many reasons. The community's perception of an issue, and whether it is seen as a problem, is critical in designing solutions. If an environmental problem is not perceived as being critical there may be need for some education and awareness raising before a solution is designed. In the end a blueprint solution that does not involve those who will be impacted is not likely to be sustainable. Further, consultations not only provide knowledge but also build trust. When programs are designed requiring local authorities to work with communities, both sides must be aware of the other's priorities and limitations. Consultations and consensus- building were critical to the success of MEIP in Sri Lanka. No activity, whether a pilot project or a policy reform, however large or small, went through without consultations with all parties that would be affected by the project.
Strengthening Local Governments
In the program's experience, successful environmental management requires a two-pronged approach that combines top-down and bottom-up approaches. Thus, communities must be empowered but at the same time the abilities of local governments to engage communities and provide solutions should also be strengthened.
17 Initial MEIP activities focused largely on national-level agencies, as the government was highly centralized and local governments had very little autonomy. While this approach was beneficial in the formative years of developing strategies, local governments had to be involved in implementation. Communities often turn to the immediate political authority, local government, for direction and solutions in environmental management. In Colombo, national agencies continue to have a large impact on the manner in which environmental issues are handled, but the same cannot be said for secondary cities such as Kandy and Galle. In the second phase of MEIP, it shifted its focus to work with the two local governments.
Strengthening local governments is crucial, since they play a central role in managing the urban environment, from provision of city services and land use planning to local economic development and pollution control. When services break down or environmental conditions, deteriorate, they are often the first to be blamed. If local governments are to be effective environmental managers, strong institutional capacity - adequate funding, efficient organization, clear lines of authority, and qualified personnel - are necessary. However, local governments are under pressure from rapid urban changes, budgetary shortfalls, growing demands for services, and increasing pollution. In most cases, local governments cannot provide basic urban services, let alone regulate and enforce environmnental legislation. This lesson relates to a criticism leveled against MEIP, and especially the Action Plan, that it concentrated on capital investments while organizational and operational investments were not given significant attention. In the absence of such changes, capital investments are often unsustainable.
The disconnect between the formal role of local authorities, and their ability to perform this role satisfactorily, stems partly from the fact that even where local governments have been burdened with additional responsibilities for environmental management in the name of decentralization, these often come without necessary autonomy. Decentralization has not always resulted in a real devolution of power to local municipalities, nor has it necessarily increased the electoral accountability or fiscal autonomy of local authorities. In many cities, local capacity to generate revenues is limited. This inability to raise funds contributes to the failure of local authorities to properly operate and maintain environmental infrastructure, such as wastewater treatment plants and land fills.
Capacity building for urban planning and governance at the local level must include enhancing local revenue resources, such as property taxes, business or motor vehicle registration taxes, and user fees and service charges for water, sewerage and solid waste collection. It is also important that local bodies have the authority to determine the rates of these taxes and fees according to local conditions, without interference from central governments. Attention to urban finance is crucial if cities are to adequately function as urban environmental managers with less reliance on fiscal transfers from central governments. This aspect of capacity building was not specifically addressed by MEIP.
18 Another important aspect of building local government capacity is enhancing the technical and professional competence of officials. Commitment to training and technical assistance programs is necessary in order to foster capacities of environmental professionals in local and central governments, and to build appropriate managerial, financial and technical skills in general. Several environmental training programs were initiated by MEIP for professionals from environmental authorities as well as local governments, but general managerial and financial skills were not addressed.
With the increasing responsibilities and needs for investment, it has also become important for local authorities to forge partnerships with other actors, including the private sector, communities, NGOs and other counterparts. MEIP has successfully demonstrated that limited government coffers and manpower can be supplemented by financial and other resources contributed by businesses and community members for local environmental initiatives, once they understand that they benefit directly from these activities. Governments must work with them not as beneficiaries, but as partners in achieving common environmental goals in order to ensure sustainability of local environmental initiatives.
Empowering Communities
Community mobilization can greatly enhance judicious government intervention. Selected MEIP initiatives have shown how communities themselves can be agents of change, once their potential to help themselves is recognized and cultivated. The ability of communities, especially low-income settlements, to contribute to the solution of their particular environmental problems is often underestimated. The common misconception is that they lack the organizational capacity or financial resources to either construct community infrastructure or manage environmental services such as water pumps or public toilets. Experience has demonstrated the contrary: neighborhoods and communities can organize to manage drainage and waste collection systems, under supportive conditions.
Some key points to guide the efforts of NGOs and the donor community to best augment grassroots environmental management efforts are summarized below.
* The community must understand the problem and be willing to act on it. This usually begins with an awareness of a specific problem that directly impacts their lives, not a problem perceived by an outsider; * There is a "champion" behind every successful community-based program. A strong leader can serve as a focal point for discussion and decision-making, for mediating conflicts among community members, and for pooling and reallocating resources within the community. Where strong community leadership is lacking, NGOs can help mobilize residents or strengthen existing leadership functions;
19 * It is possible to build on community networks as a means of mobilizing labor, and as a mechanism to improve the efficiency of service delivery; * Community organizations can link up with local governments to manage the micro-end of urban services (e.g. the former manages neighborhood garbage collection while the latter handles subsequent collection and disposal); * One of the best ways to improve household environmental management lies in combining it with income-generating activities. This can be done through activities based directly on environmental management such as recycling, or through programs that create community-based enterprises that enable household members simultaneously to earn income and to obtain essentials such as food, clean water and building materials; * Combining neighborhood environmental improvement programs with community credit schemes serves as an added incentive and also addresses the lack of financial resources faced by residents; * Relationships between environmental pollution and human health are often poorly understood by low-income community residents. Thus environmental education and awareness campaigns are important elements to be incorporated into local environmental improvement programs; * If residents do not feel a sense of security and stability in their households or as members of a community, they are not likely to devote their time and energy to improving environmental conditions, and thus land and housing tenure are critical issues; * Partnering with NGOs in community development is key where local governments have failed to represent their constituencies or deliver basic services; and * Local govemments and communities should work as partners.
Creating and Fostering Networking
Networking among all the relevant government agencies and general govenmmental support of MEIP have also been key to the success of programs in Sri Lanka. GOSL demonstrated a high level of commitment by including enviromnental concems in its national agenda. Environmental management is now seen as much more than pollution control, and enforcement agencies are correctly viewed as only a part of the picture. Strategic location of MEIP within the government hierarchy has also been critical, as it allowed access to senior decision-makers. On the negative side, it has been hard to sustain government interest at the same level over the years. Although MEIP was instrumental in the formulation of CEIP, its involvement in the implementation of CEIP was very limited.
20 MEIP has also served as a focal point for groups and individuals in search of sustainable and affordable solutions to environmental problems. Interaction between government agencies, private businesses and nongovernmental organizations has been critical to forging partnerships for environment. Although such partnerships have emerged between the government and private sector, much remains to be done in engendering greater financial support from the business community.
Because many environmental initiatives are long term processes, it is premature to judge their effectiveness in two to five years. This is especially true of education and training where it is difficult to assess immediate impact. Research and information dissemination have always been a strong point of the Colombo MEIP. It should be pointed out that while continual assessment is central to refining and updating projects, many MEIP achievements may only become visible in the next five to ten years.
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Metropolitan Environmental Improvement Program (MEIP) Environment Sector Unit - East Asia and Pacific Region The World Bank 1818 H Street, NW Washington, DC 20433
Contact: P Illangovan