| Abstract: | This is the first Addendum to the EIA for the harbour project being undertaken in Nilandhoo,
Faafu Atoll. The project is proposed by Ministry of Housing and Infrastructure.
The project constitutes dredging of a large harbour for the people of Nilandhoo while at the
same time creating land using dredged sand including additional dredging for proposed
reclamation of 10hectares of land for housing and infrastructure development including semiindustrial
activities. An environmental assessment was undertaken for this project in Nov
2015, which has been subsequently approved. According to the EIA report, the objective of
the harbour project is to provide a sizeable harbour to accommodate the increasing number of
vessels in the island and to restore the usability of the harbour that has been filled over time
with the breakwater being damaged, especially following the tsunami of 2004. The harbour on
the northeast side is too small given that Nilandhoo has a lot of large fishing vessels and has
been serving as the regional hub with fuelling services established on the old (tsunamidamaged)
harbour on the northwest.
This addendum addresses the modification to the location of the borrow area. One of the main
concerns is that the performance of the dredger is affected due to having to pump up to 1km
from the borrow to the fill area. Therefore, it has been considered important to move the
dredge (borrow) area closer to the fill area in order to enhance dredging performance and
achieve cost-effectiveness.
During the first Scoping Meeting, which was cancelled by EPA stating that the project
justifications were not clear, EPA identified that the borrow area needs to be moved as far as
possible from the proposed quaywall as there may be stability issues. Taking this concern into
consideration, further alternatives to the borrow area were also considered by the Proponent in
consultation with the Contractor and the representatives of Nilandhoo people.
During discussions with the Council and people of Nilandhoo, they have raised concern
regarding the need to protect the proposed harbour, which would involve huge costs if the
proposed option were adopted although it had been mentioned in the original EIA that harbour
protection will be considered in the future. Therefore, in order to reduce the overall cost of the
proposed project and to increase the usability of the proposed harbour even during rough
southwest monsoon, appropriate alternatives were considered to the harbour design as well
although it is beyond the scope of this EIA. A number of alternatives to the proposed harbour
design was considered in the original EIA report. Of these, the option of upgrading the
existing harbour on the northwest has been given due consideration in the light of improving
on social concerns related to limitations in land reclamation. An alternative analysis that have
been done in the original EIA and during the current Addendum indicated that the preferred
alternative to redesign the existing harbour would have several advantages over the proposed
especially the ease of use during rough southwest monsoon while leaving the possibility of an
external quaywall if it becomes necessary at a later stage. However, some stakeholders believe
that the proposed option has advantages over the preferred alternative as it has better
opportunities for future expansion and growth of the economic potential of the island. Some
of the other alternatives considered in the original EIA report including the expansion of
existing harbour on the northeast to the northwest has cost advantages while it has restrictions
over future expansion that the recommended alternative in this Addendum provides.
Environmental impacts were assessed for both the construction and operational phases of the
project. Most of the direct, negative environmental impacts identified for the construction
phase of the project were minor negative; the main impact being the impact on sedimentation
from the proposed borrow area to the coral colonies in the vicinity and more importantly
sedimentation during the filling of the proposed fill areas, which have already been covered in
the original EIA report. Therefore, the impact of dredging has been considered in this
Addendum. The main impact arising from the proposed new dredge area is the damage to the
inner reef as a result of the dredging. There was a concern relating to the closeness of the
dredge area to the proposed quaywall and the potential failure of the structure due to a
collapse of the sides of the dredged basin. However, since the dredged basin would need to be
dredged to less than 4m from the existing seabed, which is less than 6m in depth at present,
there should not be such a problem. Only a few berths or quaywalls just adjacent to the reef
edge dropping to 30m suddenly have failed whereas the proposed structure is over 110m from
the dredge area, which will be dredged to only about 10m and not more than 13m under the
current proposal. Furthermore, most of the naturally deep lagoon areas in similar islands
would be about 10m in the middle areas with some areas having 15m depths. Therefore, the
direct removal of some of the corals due to proposed option can be avoided by not dredging
from the inner reef flat areas but the deep lagoon only, as in the proposed alternative.
Reclamation of land considering current and future potential use is a favoured development
activity in many islands today. However, based on the experience of most of the land
reclaimed in many islands, the cost recovery of the project is low and taxpayers have reason to
question the outcome of the project. Yet, if the project objectives were achieved by renting the
reclaimed land for semi-industrial activities and housing developments, it may be a justifiable
cost. It is sad to note that the proposed reclaimed land has yet to find itself a landuse plan and
development scenario after several months of EIA approval that had passed by. This is a cause
for concern in terms of the afore-mentioned socio-economic impact of the project, although it
is beyond the scope of the EIA. If the land is appropriately managed, the project is considered
to have several socio-economic benefits that will certainly outweigh the negative
environmental impacts, which are of low significance.
Although the impacts are not significant due to the absence of sensitive ecological elements
that would be directly impacted, some project-specific mitigation measures have been
discussed. These include consideration of the preferred alternative (which is also the or one of
the alternatives discussed in the original EIA report) to mitigate the impacts of wave activity
at the proposed quaywall, to consider shore protection as the reclamation progresses to
minimize erosion and to move any live corals that may be directly affected into safer
locations. General mitigation measures, involving appropriate construction management such
as working during low-tide as much as possible and rigorous supervision during project
implementation are also recommended.
It is recommended to carry out regular monitoring as proposed in this Addendum, which
replaces the monitoring programme given and approved in the original EIA report. It would
be important to assess the movement of the sediment plume regularly and to ensure that
sediment plume does not severely affect the reef areas. Turbidity levels are expected to be
measured within the sedimentation zone on a regular basis up to 6 months after the project.
In conclusion, it appears justified, from a technical and environmental point of view, to carry
out the proposed project. Since alternatives have not been considered or discussed with the
relevant stakeholders including the Council, it is recommended to consider all potential
alternatives, including those identified by the EIA Consultants, before proceeding with the
project. The preferred alternative borrow areas including the existing harbour on the northwest
is recommended. |
