First addendum to the environmental impact assessment of oceanside channel dredging project in Meedhoo Island, Addu City

Abstract

The purpose of this document is to fulfil the requirements to get necessary environmental clearance from the Environmental Protection Agency to carry out the remaining works of the proposed Oceanside channel dredging project in Meedhoo, Addu City. A part of the channel has already been dredged and completed but the outer rim of the channel could not be dredged or dislodged using conventional methods. It is proposed to undertake controlled reef blasting to dislodge the hard substrate. The proponent of this project is Ministry of Housing and Infrastructure. The rationale for the proposal to blast the reef entrance is based on the fact that all other options available in the Maldives have failed to dislodge the hard substrate. The project already has had two contractors, both of whom had failed to cut through the outer reef rim. The present contractor was handed the task of finishing the project by Ministry of Housing based on a special request by the Meedhoo locals. The contractor has tried a number methods, including drop hammer, but has not been successful in dislodging the substrate. The only remaining financially feasible option is to use controlled blasting. The project has been dragging on for six years and the longer marine works continue, the higher the impacts on marine and coastal environment. Failure to complete the channel will also be a waste of public money as 90% of the project has already been completed. The site already has about a 905 m x 35 m channel dredged to a depth of -3.5 m. The originally planned channel was 920 m x 35 m. The area in question is the last 15 m of hard substrate before it reaches the ocean. The project proposes to dislodge the 15 m x 27 m section of the reef using about 50 bags of 25 kg Ammonia Nitrate placed 1 m apart along two rows. All proposed project activities are 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, Environmental Impact Assessment Regulation 2012 and Dredging and Reclamation Regulation. Significant impacts of this project during construction phase of the project are the potential impact of underwater noise and vibration on marine life, potential damage to property due to vibration, potential formation of reef slope cracks and sedimentation and turbidity associated with dredging. The project is being carried out in proximity to a listed sensitive area. All these impacts apart from potential geological impacts are reversible. Any damage to the reef substrate could be irreversible. Thus, the potential geological impacts will be a risk for this project. The main mitigation measures include carrying out construction activities during low tide hours and calm weather, carrying out the work during daylight hours, informing the public about blasting activities and, schedule and proper supervision of all activities by qualified personnel. A precautionary approach is required for this project due to the unknowns associated with the geological impacts. It is recommended to minimised the charges to the lowest required levels and reduce the critical ground vibration distance (i.e. 10 mm/s) from the blast site. The site should be monitored for reef cracks. If any cracks are observed and depending on the severity of the cracks, all reef blasting activity must be ceased until geological assessments determine it is safe to proceed. Windy days should be avoided especially if the wind is blowing from the west. There are safety risks associated with this project. It has been recommended not to allow any snorkelling or diving within a 1.5 km radius of the blast site. This should include sand miners, fishermen and tourists, among others. The “No Project” option was explored. The project involves significant risks to physical environment. Given the community’s desire to complete this channel, the benefits it bring to the fishing community, and potential loss of public money if this project is not completed, the No Project option has a higher opportunity cost. However, in the absence of a viable alternative, it was recommended that EPA consider approving this project based on conditions. Alternative methods to dislodge the hard substrate were considered, but these options have already been tried and failed. The monitoring plan is designed to assess damages to reef structure, infrastructure and housing, and loss of marine life. Physical environment damage will be checked using marine surveys and damage to nearby buildings will be undertaken in specific sites and based on complaint. Damage to biological environment will focus on larger fish and protected species. The management plan for this project has been updated to include the key management requirements before and during blasting activity. The support for this project is mixed. In the consultations undertaken for the original EIAs and this Addendum, there is overwhelming support by the locals from Meedhoo and Hulhudhoo for this project. The City Council supports this project but is apprehensive about reef blasting as they believe it is detrimental to the future of Addu City. EPA and MRC do not encourage reef blasting. This report has highlighted the risks and impacts associated with reef blasting on the site. It has also provided actions that can avoid or minimize the known risks. This report should now be used as a decision making tool by the implementing agency and regulatory authority to determine how to proceed with the project. There is no legal hindrance for this project to go ahead. If the proponent and EPA decides to move forward with the project, the following course of action is essential to align the project with sustainable development principles. 1. Use the minimum charge possible to effectively dislodge the substrate and minimise the radius of critical ground vibration (i.e. 10 mm/s) 2. Continuous monitoring of the site for reef cracks. If any cracks are observed and depending on the severity of the cracks, all reef blasting activity must be ceased until geological assessments determine it is safe to proceed. 3. Given the potential impact of this project on the public and the future generations, it is recommended that EPA take all possible measures to solicit views from the public for this EIA 4. Safety precautions are essential. Divers, sand miner, fishermen and swimmers need to be properly informed in a timely manner and monitored during work days.