Environment impact assessment for the proposed cold storage facility development project at Koo’ddoo Island, Gaafu Alifu Atoll

Abstract

The purpose of this document is to fulfil the requirements to get necessary environmental clearance from the Environmental Protection Agency (EPA) to carry out the proposed cold storage facility in Koo’ddoo Island, Gaafu Alifu Atoll. The proponent of the project is Mr. Mohamed Ali Janah. Koo’ddoo Island houses an airport, Koo’ddoo Fish Processing Plant and a transit hotel. The project is proposed on an uninhabited 6 Ha piece of land on the SE corner of the island. The site has been leased to the proponent for 21 years under an agreement with the Ministry of Fisheries and Agriculture (MoFA). The project proposes to develop and operate a cold storage facility on the site. The objective of this project is to import food perishable food in bulk, store them in cold storage rooms or units and distribute to the region. The primary clients are expected to be the resort islands in GA Atoll where the proponent has an investment stake. The client base will be expanded to local inhabited islands and other resorts based on demand. The project design will include modular storage systems which will be expanded based on demand and a transport system to deliver the goods directly to islands. The infrastructure proposed on the island include buildings to house cold storage room or units, own utility infrastructure, support service facilities, accommodation, recreation and a harbour for loading and unloading. The project also anticipates undertaking small scale farming, medicinal plant farming and supporting local medicine activities. These are all additional services undertaken at a small scale. The project aim of improving food security and availability is in line with the ruling party manifesto and government policies. Project activities will be in conformance to the laws and regulations of the Maldives, and relevant international conventions that Maldives is party to. The key laws and regulations applicable to this project are: Environmental Protection and Preservation Act, Employment Act (2/2008), Immigration Act (1/2007), Land Act, Public Health Act, Civil Aviation Act, Environmental Impact Assessment Regulation 2012, Dredging and Reclamation Regulation, Waste Management Regulation 2013, and the Environmental Liability Regulation. The project parameters cannot adhere to the dredging reclamation regulation as is states that no dredging shall be undertaken within 50 m of the vegetation line or 500 m from the ocean side reef edge. The harbour proposed in this project is located within both these restricted zones. For projects of economic or social importance, the regulations allow for exceptions to be made. Therefore, discussions must be held between the proponent and the EPA before the commencement of the project in order to resolve this issue. The assessment shows that the proposed developments result in significant positive socioeconomic benefits during the operational phase. Most important is the availability of food in the atoll at a lower cost and in higher quantities. However, both the construction phase and the operational phase of the development result in negative impacts on the marine and coastal environment. The main construction impacts results from the harbour project and vegetation clearing. The main impacts from marine works are on sediment movement patterns around the island, marine biodiversity due to sedimentation and turbidity and potential marine and groundwater contamination. Impacts during facility construction, impacts are limited to vegetation clearing, potential ground water contamination, negative effects of improper vegetation disposal and health and safety. Main operation stage impacts include waste management difficulties if a product batch goes bad or expires, potential fuel leakage into groundwater, ground water impacts from pesticide and fertilizer use and marine impacts related to sewage outfall. The proposed channel is unlikely to be useable throughout the year due to rough wave conditions. Safety concerns exist if boats try to access the site during rough conditions. Boat movement across the aircraft approach path close to the Runway End Safety Area is also identified as a concern. Key mitigation measures for the construction stage include finding options to minimise turbidity and sedimentation through the use of sediment control measures especially during the dredging and reclamation works, carrying out project activities only in the allocated areas, and ensuring that activities are a carried out in as short a time period as possible to allow normal conditions to re-establish in the area. The construction staff should also be properly educated on the sensitivity of the reef system and measures which can be taken to minimise impacts on the marine environment. Vegetation removed is to be replanted around the transit hotel area, project site and if require, on other areas of the airport. Given that the proponent at present has stakes in these two investments, it is practical to implement this plan. A good communication system between boats, proposed site office and Air Traffic Control tower has been recommended to minimise safety issues related to air and sea transport near the harbour entrance. A composting machine has been proposed by the developer to manage potential issues resulting from food waste. Alternatives were evaluated for the project. This assessment found that the proposed original master plan had a number of issues including wrong locations for island access, missing land use items and lack of island access options. These issues were recommended to be corrected and were presented as an alternative master plan. The developer is in agreement with these changes and has already submitted a revised plan to MoFA and is pending approval. This EIA has evaluated the recommended alternative Consultations were held with Environment Protection Agency (EPA), Maldives Food and Drug Authority (MFDA), Health Protection Agency (HPA), Ministry of Fisheries and Agriculture and Civil Aviation Authority (CAA). The results revealed a number of aspects which need to be incorporated into the design and construction plan. They include: a. The first task of construction should include construction of fence to delineate the project site before construction personnel can be deployed for general construction. b. Using air-side access to the project site to transport goods on public vehicles is not recommended and the alternative plan of accessing via the new harbour should be enforce. The air-side can still be used for emergency access and if required, personnel access. c. Airport will require developing an access control system and an access road to facilitate the above process. d. Crossing the runway with goods and public vehicles are not recommended from a safety perspective e. A mechanism to communicate between the tower and the project site needs to be established to deal with unforeseen safety issues. The Environmental Management Plan (EMP) for this project is designed to produce a framework for anticipated impacts, including practicable and achievable performance requirements and systems for monitoring, reporting and implementing corrective actions. In addition, it will also provide evidence of compliance to legislation, policies, guidelines and requirements of relevant authorities. Monitoring plan is designed to assess any changes to the physical environment as well as operational aspects of the development. The programme may cost about RF 40,000 per year. Overall the project has significant beneficial socio-economic impacts on Huvadhoo Atoll, and if successful, promises to become an important logistical hub for food distribution in the Atoll.