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Technical Report
Environmental impact assessment (EIA) for establishment of a katsuobushi processing facility in Hithadhoo, Addu City
(2015-12) Adam, M. Shiham; Ahusan, Mohamed
1. The Environmental Impact Assessment (EIA) report carried out for proponent Yours Maldivian Addu Katsuobushi Pvt. Ltd. to develop and operate a katsuobushi plant on a leased plot of land from the RAF area of Hithadhoo Island, Addu City. The EIA is prepared as fulfilment of the requirement by the Ministry of Environment and Energy for granting permission for the Project. Environmental Impact Assessment (EIA) of development projects is a requirement by the Environmental Protection and Preservation Act (EPPA) (law 4/93) of the Government of the Republic of Maldives. 2. This report has been prepared in accordance with the Environmental Impact Assessment Regulations published by the Ministry of Environment and Energy in 2012 and covers environmental and socio-economic impacts arising from the proposed project. Major findings of this report are based on data and information gathered during the field inspection of the existing environment. In addition, expert judgement and published literature were used to predict the possible impacts from the project. 3. The development project is located in the western side of the southern section of Hithadhoo Island, Addu Atoll. The plot is separated from the western beach by about 65m of coastal vegetation. Terrestrial vegetation around the plot area is a mix of salt and salinity tolerant trees and shrubs. The population of the Island is mostly concentrated to the northern end of the island while the southern end is sparsely inhabited resulting in an abundant. 4. Tuna to be processed will be sourced from the local fishermen. While only skipjack tuna will be used to make katsuobushi, other species in the catch (yellowfin tuna and small amounts of bigeye tuna) will also be purchased and processed into other products and marketed to the locals. This is in order to incentivize the fishermen to sell their catch to the proponent and ensure a steady supply of raw materials. 5. Pole-and-line tuna fishery of the Maldives exploits the wider Indian Ocean stocks, the management of which falls on the Indian Ocean Tuna Commission (IOTC). Maldives is a full member of IOTC and takes a lead role in promoting management of the Indian Ocean tuna stocks. Most recent assessments for skipjack tuna (2014) indicate that the skipjack tuna stock is being exploited at safe levels. However, 2015 assessment of yellowfin tuna stocks showed that the stock has been overfished and is being overfished. 6. The development project involves construction of a 100 by 100 feet processing facility, its supporting infrastructure and a staff accommodation block for the employees of the facility. All construction will use general construction materials such as cement, imported river sand and aggregate, deformed steel bars etc. Construction materials and crew will be transferred to, and waste removed from the facility via existing dirt roads. 7. Major waste stream from the factory would consist of organic waste (fish offal) and blood water from gutting and cleaning raw fish, domestic sewage diluted in flushed water and greywater from the staff accommodation block and ash from the smoking process. 8. Organic waste (consisting of viscera, cuttings, skin and bones) will be collected in leak proof containers and routinely removed from the facility before it becomes putrid. This will be disposed of in the sea by an external party during the first year and later used to make agricultural fertilizer. Blood water and water generated from cleaning the facility will be discharged onto the reef flat on the western side of the island. Septic tanks will be used for the treatment of domestic sewage and greywater from the accommodation block. 9. Assessment of the existing terrestrial environment in the vicinity of the site showed that the area consist of typical island vegetation except for a dominance of coconut palms (Cocos nucifera). Site of the project does not contain strong vegetation as it was cleared prior to leasing to the proponent. Small scale farming takes place in plots around the project site. 10. The island being located on the western atoll rim reef and the project site being located on the western side of the island, is in close proximity to the marine environment. The beach is exposed to strong swell waves originating in the Western Indian Ocean. Breaking of waves on the reef creates longshore currents which would allow almost instant mixing and dilution of effluent discharged. Benthic cover on the reef flat/lagoon showed a predominant abundance of seagrass and a lack of live corals and associated benthic fauna. 11. Minimal environmental impacts are predicted for the project. Key negative impacts include a transient deterioration of water quality at the effluent discharge site and likely deterioration of groundwater due to sewage from the accommodation block. Further, a localized reduction in air quality is expected due to gaseous (NOX) and particulate emissions from the smoking process. 12. The project is expected to have a number of positive impacts on the local economy and wellbeing of locals especially fishermen. Firstly, fishermen will be paid a competitive price for their catch in order to ensure a reliable supply of raw materials. The project will also open up employment opportunities for locals. Further, it will contribute to the local economy by outsourcing some aspects of the project such as waste disposal and sea transport of products to Male’ and contribute to government’s policy of value0addition of fishery catch.
Technical Report
Environmental impact assessment fish packing and processing facility Euroglobal Maldives Pvt Ltd Huraa, North Malé Atoll
(2013-03) Adam, M. Shiham; Riyaz, Mahmood
1. The Environmental Protection Agency (EPA) recently noted some fish processing facilities in operation do not have environmental clearance for their projects. EPA informed Ministry of Fisheries and Agriculture that all fisheries projects should have submitted the Decision Note on environmental clearance before issuing the Fish Processing License. 2. Euroglobal Maldives Pvt Ltd established on island of K. Huraa Island falls under this category. Originally built and owned by the erstwhile HMS Pvt Ltd, Euroglobal acquired the facility during November 2009. There were no records of an EIA for Huraa’s fish processing and packing facility by HMS either. When Euroglobal Pvt Ltd appeared to renew its Fish Processing License, the Ministry of Fisheries and Agriculture issued a temporary Fish Processing license and requested to undertake EIA for the project. 3. The work of Euroglobal Maldives Pvt Ltd is essentially packing fresh yellowfin tuna (Thynnus albacares) in variety of forms and exporting to EU-Territories and the USA. Their main products are gill and gutted, head and gutted, loins and fillets. The lowgrade tuna and off-cuttings including belly flaps, trimming are sold in Malé outlets through their agents in Malé. Fresh yellowfin tuna are sourced from Maldivian fishermen fishing from local boats. The catch is exclusively caught from the handline method which used livebait, but has little of no-by catch. The fish are gill and gutted and bled before storing in ice boxes. Trips may last 10-14 days fish normally sold for the highest offer, currently range from MVR 65-160 per kg. 4. The fish processing and packing facility is located on the north western corner of reclaimed area of Huraa, at the northern end of the urbanized area. The landing and access to the facility faces to the north which also happens to be the mouth of the mangrove area – Kulhi, which is a protected site. Tidal currents flow along the seawall in an out of the mangrove area. The area, slightly west, is also where the fishing vessel alongside the sea-wall for landing the catch. Sediment run off from the mangrove area has made the area shallower almost completely exposing during low tide. The area also has a seagrass bed on the western side nourished (and fertilized) by the nutrients run off from the mangrove area. 5. The waste water stream from the factory is released directly to the area, in front of the mouth into the tidal stream. Waste water includes, sewage mixed with water released from the collection septic tank, blood water mixed with drainage from the factory floors and reject (brine) water from RO plants. Because the area is shallow little water mixing takes place causing eutrophication and foul smell. Water quality tests show high nutrient load (sulphate + ammonia). As a result water quality test showed high BOD and excessive counts of coliform colonies and faecal coliforms. It was recommended to make direct connection to Huraa sewerage network or pump the waste stream outside reef into deep water into the channel. 6. The water production and power generation takes place in the compound. Two diesel generators with 500kvA capacity are in operation. A diesel fuel tank on a metal frame outside the power house serves the fuel to the generators. However, signs of oil spill during filling and change of oil filters was evident on the ground. These were identified as impacts and remedial measures were proposed. Water production takes place from two RO plants. Electricity from domestic grid is also present but due to high electricity demand during ice and water production it has not been possible to use effectively the local power supply. 7. Feed water for RO plant and ice production is sourced from the lagoon on the western side of the facility. The intake pipe is placed in a concrete well with the granite aggregate serving as a sand filter. Intake from the sea is difficult to main and prone to contamination given that intake is actually not far from the polluted are on the northern side. It was recommended to install a bore-hole for sourcing water for the plants. Water production is supplemented by rainwater harvest from the roof of the main building. There is about 50,000 Litres of water storage on the site. Both water plant and power generation plant required to be registered in EPA and Maldives Energy Authority respectively. 8. There are three ice plants with a total capacity of 150 MT/day. Again sea-water from the lagoon is used as feed water. Ice is given to fishermen free of charge, but only for fishermen who sell their catch. 9. Raw material (fresh fish) is supplied by the Maldivian fishermen who conduct fishing in local vessel with local crew. During 2012, record show some 150 unique vessel sold fish to Euroglobal Pvt. Ltd. During the initial stages of these processing companies supported fishermen on condition of selling the catch to facilities. Euroglobal Pvt Lrd provided icebox and start-up capital was provided. 10. The economic activity been done don by the Euroglobal is highly profitable. At present some US$ 40million per year is declared at the Customs which represents close to 50% of the total marine export earnings to the country. Although there are no accurate records at MoFA, 50% of the licensed fishing vessel (total ~750) is likely to be exclusively handline yellowfin fishing vessels. This gives the scale of this activity and positive socioeconomic impact from this activity. 11. An indirect impact from the work of Euroglobal Pvt Ltd would be the potential negative impact to the yellowfin tuna stock. Yellowfin tuna is considered to be straddling and highly migratory and the stock is distributed across to the entire Indian Ocean. However, since the current catches from Maldives represent only 7-8% of the total Indian Ocean yellowfin tuna catch (~300,000 MT/year) local harvesting levels may not cause much impact at the current level of fishing mortality. 12. Taking together all the activities of the Euroglobal Pvt Ltd (the main work of the sourcing fish, cutting, cleaning and packing and the support activities of producing electricity, water, ice and waste) the positive environmental impact far outweighs the negative impacts from the waste. These impacts can be made reversible and remedied. If the recommendation and mitigation measures are implemented, the development project of Euroglobal Pvt Ltd should be environmentally sound.
Technical Report
Environmental impact assessment fish packing and processing facility Maldive Marine Products Pvt Ltd Hulhumalé Industrial Zone
(2013-04) Adam, M. Shiham
1. The requirement for an environmental impact assessment (EIA) for Maldive Marine Products Pvt Ltd (MMP) came in late 2012 when the company applied to renew its Fish Processing License for 2013. The Ministry of Fisheries and Agriculture (MoFA) informed that under the EIA Regulation Maldive Marine Products Pvt Ltd should undertake an environmental impact assessment study for the development activity according to a communication from the Environmental Protection Agency (EPA). The report is something that has to be done before the development take place, but in order to comply with the regulation the MoFA requested that a report should be submitted to EPA and the necessary environmental clearance be obtained. 2. During 2006 Maldive Marine Products Pvt Ltd submitted a Project Proposal as per guideline provided by the erstwhile the Ministry of Fisheries, Agriculture and Marine Resources (MoFAMR). The report titled ‘Proposal to establish a Fresh Fish Packing Facility at Hulhumalé Industrial Zone’ was submitted in January 2006. Following approval by the MoFAMR, the factory was constructed and the operation of the facility started in early 2007. Until December 2012, no government department or office has asked MMP that and EIA should be undertaken for the factory to comply with the government regulations. 3. The produce of the MMP packing facility is variety of fresh yellowfin products (loins, gill and gutted, head and gutted, frozen loins, frozen) for export to EU-Territories and to USA. As such the factory is audited and assessed for EU-compliance by the National Competent Authority of EU- The Maldives Food and Drug Authority (MFDA). The factory has an approved HACCP plan endorsed by the MFDA prior to the construction of the factory. Following the completion the factory dry runs of the entire production process was undertaken to ensure the process followed the approved HACCP plan. The factory is inspected twice a year by the MFDA and Compliance Licence is renewed one every six months. 4. Maldive Marine Products Pvt Ltd has regularly renewed the ‘Fish Processing License’ introduced by MoFA in 2010 under the new regulation on ‘Fishing for Sale of Fish to Exporters, Fish Processing and Aquaculture Licensing’. Maldive Marine Products Pvt Ltd has also acquired ISO certification 22000:2005 ISO. This standard deals with the requirements for a food safety management system where an organization in the food chain needs to demonstrate its ability to control food safety hazards in order to ensure that food is safe at the time of human consumption. 5. Maldive Marine Products Pvt Ltd is established on a land area of roughly 5,500 m2 in the Hulhumalé Industrial Zone. When the land was leased from HDC during 2006 there was no electricity, water or a sewerage system in the area. The proponent managed them until the STELO and MWSC established those services. However, the proponent continues to produce electricity and water for its use in the facility. To provide the full range of services the facility has 7 buildings including the housing for ice plants (5 of them), power generators and the control room with sync panels and the reverse osmosis (RO) water production plants (2 units). In addition to factory floor, office space, accommodation for expatriate and site staff, kitchen and canteen area all are within the compound forming fully self-contained fish packing plant. 6. When the services of MWSC’s sewerage system were available sewage and greywater from kitchen and staff canteens were connected to the sewerage system. At the time of this writing the proponent has obtained permit from the MWSC for connecting the blood water stream. Once connected the proponent will do away with the series of septic tanks/ soak pits that were used earlier. Source water for the RO plant is extracted from the ground through a borehole well below any fresh water that may have formed since the reclamation of Hulhumalé Island. The reject water from the plants is released to western side into the lagoon. Turbulence by wind and wave energy creates conditions for rapid mixing diluting the brine water almost immediately. 7. The water production plants and power generation systems require registration at EPA and Maldives Energy Authority respectively. To accommodate the process environmental impact of the plants were assessed and audited. Where necessary, mitigation measures were proposed. The proponent declares the buildings that house both these services are temporary. There are plans to relocate the power gen sets and RO plants to a new building constructed on a plot adjacent to Maldive Marine Products Pvt Ltd that belongs to a subsidiary company of the proponent. It was found that one ice plant uses the refrigerant R22, which is not fully compliant with government’s HCFC reduction policies. However, others use 404A, which has zero global warming potential. The proponent has plans to decommission this plant in the coming year. 8. The raw material for the production is yellowfin tuna (Thunnus albacares) purchased entirely from the Maldivian fishermen. Fishing is conducted on local vessel from handline gear using livebait. Over 200 different vessels have sold fish to Maldive Marine Products Pvt Ltd over the last year. Ice is given free of charge as incentive for fishing and to encourage loyalty to the company. In addition the proponent has provided iceboxes and sometimes start-up money for staring the large yellowfin handline line fishing. 9. Fish are landed are gill and gutted and bled and so the amount of fish offal produced is minimal. The company who is assigned for disposing the fish waste harvests any left over after fish cuttings (heads, off-cuts, blood meat, and vertebrae). Only skin, fins and tail are thrown. Lower quality fish including belly flaps and fish eyes are packed for local consumption to be sold in local shops. 10. Maldive Marine Products Pvt Ltd contributes significantly to improving socioeconomic conditions of the fishing community and support secondary activities (fuel, fresh water, food etc). Together with the seven other fish packing companies exporting to EU-Territories and USA makes a significant foreign currency input to the economy. By exporting roughly 10,000 mt of processed fresh yellowfin tuna products the sector contributes about US$ 55 million per year, which is about 50% of the total declared marine export revenue. 11. The overall positive environmental impact from the development project was noted. The job creation in the island communities and the impact that is making in the visible exports is a significant positive environmental impact of this activity. The long-term sustainability of the activity however, will depend on the sustainability of the fish stock. Yellowfin tuna is highly migratory and its stock is spread out to the entire Indian Ocean. The stock is being managed by the Indian Ocean Tuna Commission which Maldives is now a full member. The current status of the stock is healthy and the total catch is below the assessed maximum sustainable level. The Maldives fishery component takes only 7-8% of the total Indian Ocean yellowfin tuna catch which is currently around 300,00 mt.
Technical Report
Environmental impact assessment for beach nourishment and maintenance dredging of access channels and harbour in Thulhaagiri Island
(2014-01) Adam, M. Shiham; Riyaz, Mahmood
1. Thulhaagiri is a small round island in the central North Malé Atoll. Located just north of Bandos Island resort, the island may be considered one of the oldest resorts in the Maldives, now operating for over 25 years. Currently in full operation, the resort has 52 beach bungalows and 34 over-water bungalows equipped with modern facilities and amenities. The current management of the resort is Angiri Resorts and Management Operation Pvt Ltd, which have been operating the resort for close to 15 years. 2. Owing to its somewhat isolated location in the centre of a large atoll basin, the island is exposed to wind driven waves from eastern and western side of the reef. Consequently the operators have been using two sides of the island for entry into the reef. During the SW monsoons season when winds are blowing from west the eastern entry is used and during north NE Monsoon when the winds are blowing from East and northwest the entry on the western side is used. 3. The inner reef flat used as a harbour sheltered by the well-developed reef crest. The area is shallow, but over time the reef flat becomes shallower due to deposition of sand. In order to maintain the depth at safer levels for the speedboats and vessels, a small pump is used to dredge the areas that get shallower. This has been the practice the resort operators. 4. The objective of the proposed project is to undertake maintenance dredging of the channels on the eastern and western side of the island and to deepen the reef flat area that is being used as harbour. And finally it is proposed to make use of the dredged sand to nourish the receding beaches on the north eastern side of the island. 5. The project activity is justified since these regular pumping and deepening of the channels and reef flat is inconvenient and hinders the smooth operation of the resort. During bad weather entry into the Thulhaagiri is dangerous and risky. There is also a need to rebuild the lost beach on the north-eastern side of the island, now felt necessary by the operators to maintain Thulhaagiri’s market position. 6. Following the recently established regulation on dredging and reclamation of the islands and lagoons, a permit was first obtained for the proposed reclamation and dredging followed by the scoping of the environmental impact assessment of these activities. This EIA is follows the Terms of Reference developed and agreed at the scoping meeting. 7. Dredging will be carried out by using a dredger mounted on a flat-top shallow-draft barge. A temporary sand bed may be constructed on the excavations area. Sand required for the construction of the bed will be obtained by excavation from the adjacent shallow areas. 8. Excavated material deposited on the barge will be transported and deposited on the beach identified for extending where it will be sieved. The coarse material will be deposited first for filling and extending the area followed the finer material on top. Temporary measures will be taken to avoid the sediment washing into the lagoon. Nourished beach will then be levelled using excavators, loaders or manually by the labourers. 9. It has been proposed that timing of this activity should be restricted to February and March, which is the transition period from northeast to southwest monsoon. Wind frequency and magnitude during the period is on the lower side. 10. The total time taken for this activity is estimated at 30 days following approval (or issuing of decision note) following successful evaluation of this report. The key mitigation measures other then timing is that limit dredging activity at lower or slack tide as much as possible. 11. The proponent has provided a commitment letter confirming accepting and confirming their responsibility on mitigation measures suggested in the report and environmental compliance during this undertaking of the proposed activities.
Technical Report
Environmental impact assessment for extension of Kooddoo Domestic Airport and development of a city hotel Kooddoo, GA. Atoll
(2013-12) Adam, M. Shiham; Riyaz, Mahmood
1. The domestic airport of Kooddoo was built during 2011 and was officially opened in 2011. This 1,200 m long airstrip in the north eastern side of the Ga Atoll serving the emerging high-end resorts have become one of the busiest and most important domestic airports in the south. It is normal to have 7-8 flights per day with mostly tourist passengers arriving and departing. Also relatively large volume local passengers make use of the route for transferring to the islands in the south or simply commuting on business trips. It was also noticed that guests with reputable business credentials were requesting to resort operators to allow their own air-craft (jet) to fly Kooddoo direct rather than having inconvenient and long layover times at Hulhule Ibrahim Nasir International Airport. 2. In order to address this need the Ministry of Tourism (previously Ministry of Tourism, Arts and Culture) engaged with the Maldives Civil Aviation Authority and the Ministry of Transport and Communication in a development project to extend the airstrip and also to upgrade and modernize the airport to provide services to international standards. Keong Hong Construction Pte Ltd, a reputable property developer in the region, won the airport development contract through competitive bidding tendered by the Ministry of Tourism. The negotiated contract agreement included development of a 50-room city hotel on Kooddoo and also development of Ga. Maamutaa as an upper-class tourist resort. Under the same agreement the Kooddoo airport will also be managed by Keong Hong Construction Pte Ltd, who now has an Aerodrome Certificate to run the airport under their name 3. Following the new Regulation on Reclamation and Dredging of Islands Lagoon and Reefs a permit for dredging and reclamation work was obtained before the scoping of the project took place. As such all paper works, including the dredging and reclamation permit was submitted for the Scoping Meeting held at EPA and was attended by stakeholders. 4. The scope of this development project is to reclaim about 260 m long and 150 m wide area from both ends of the island to extend the runway to 1,800 m, to dredge and create 500 m long entrance channel from the western corner of the reef connected to a harbour basin with access walkway jetty. The scope also includes the complete development works of the 50-room city hotel including upgrading of airport services and equipment following the expansion airport capacity. The most significant development activity with regards environmental change is the dredging of western side, reclamation of the both ends and development 25 over-water bungalows on the shallow lagoon on the western side. 5. Existing environmental conditions have been revised using the comprehensive set of baseline data gathered for the airport development project in 2011 but supplemented by additional field data gathered during the visit made in late November 2013. These have been used to assess and evaluate the environmental impacts from development activities. For activities with potential to cause significant impacts, appropriate and practical mitigation measures have been proposed. 6. Since management of Kooddoo airport is now under Keong Hong Construction Pte Ltd the plan is to upgrade and expand the utility services (production of water, generation of electrify and overhauling of sewerage system) to meet the additional requirements of the proposed city hotel. As such the developer plans to add on to the existing structures and arrangements as much as possible to cut down development costs and improve efficiency. 7. The developer pans to increase current water production capacity of 150 cubic meters per day to 450 cubic meters per day. This would involve installing and commissioning of 2 x 150 cubic meters day capacity RO plants. Electricity generation will be increased from its current capacity of 250kVA to 3110 kVA by adding 2x800 kVA units and 2x630 kVA units. The current septic sewerage system will be overhauled to modern Membrane Bioreactor (MBR) plant with a capacity to treat 200 cubic meters of sewage water per day The outflow water will have negligible amount of coliforms and so will be used for watering the plants and landscaping work. 8. Installation and commissioning of electricity generation and water production system will be done as per guidelines of the Maldives Energy Authority and Environmental Protection Agency respectively. Similarly, to ensure safety, drilling of boreholes for source water for RO plant and construction of 150,000 liters of fuel storage, and 20,000 liters of petrol will be stored in bunded areas. Environmental issues arising from these developments have been identified and practical mitigation measures have been proposed. It has been recommend that water production system and power generation system should be registered with the authorities before the its full commissioning. 9. Reclamation works and extension of runway will take place whilst the airport is in operation. In order to avoid disruption of flight schedules it is advised the developer/contractor provide method statements, including details on plans and schedule of activities that should be agreed in consultation with the Civil Aviation Authority. Coordination should be maintained at all times between the Air-traffic control tower and developer/contractor. Fortunately since the developer and airport management is the same company it is envisaged that there should not be any problems for this coordination. 10. The estimated volume of material recovered from dredging /excavation works is around 70,000 cubic meters. However, the estimated volume required for reclamation is estimated at 120,000 cubic meters. Alternative borrow areas have been identified to make up for this short fall. The issues were discussed at the Scoping Meeting and it was agreed that area on the south eastern side where the reef-flat is widest may be identified as a potential borrow area. Climate condition and orientation of the Kooddoo reef is such that lagoon often times becomes rough, thus prohibitive safe entry. As such hard structures (breakwaters) have been proposed for the channel and the harbor basin. 11. The proposed reclamation work on either end of the island extends close to the reef edge, creating the possibility of blocking the water exchange from the eastern and western side. It was noted that this may cause disruption of the established longshore drifts flow around the island creating areas of pockets of erosion and accretion. Since it will be difficult to predict such changes, appropriate environmental monitoring have been proposed. The developer/operator is encouraged to follow the monitoring programme and report to the authorities on a regular basis. Environmental monitoring allows detecting environmental change so that appropriate remedial action may be taken or addressed in a timely manner. 12. A Leopold Matrix has been used to classify the magnitude and importance of possible impacts which may arise during the constructional and operational phase of the project. Leopold Matrix is the most widely used methodology for identifying the impact of a project on the environment. It is a two dimensional matrix which cross references between the activities which are foreseen to have potential impacts on the environment and the existing conditions (environmental and social) which could be affected. It was concluded that the short term minor to moderate impacts as identified above outweigh the medium to long term socio-economic benefits to the region, to the tourism sector and to the country in general. 13. Since the Kooddoo Island is going to have three distinct business entities, namely Kooddoo Fisheries Maldives Ltd, Kooddoo Airport, and the Kooddoo City Hotel, the EIA report includes, an officially approved boundary demarcations in Annex 3.
Technical Report
Environmental impact assessment for fish processing and packing facility at Fish World Maldives Pvt Ltd, Maalhos, Alifu Alifu Atoll
(2013-12) Adam, M. Shiham
The development project of Fish World Maldives Pvt Ltd is a fish processing and packing facility. Located in the west central of Maldives in Maalhos, Alifu Alifu Atoll, the proposal is to process, pack and produce variety fish products targeting local markets, including fresh fish requirements of tourist resorts. Essentially the project is conceived on the observation that the amount of resources allocated by the resorts on sourcing fresh fish to feed their guests and staff is not worthwhile their effort. The quality of the fish is poor and wastage is substantial. Simply because fishing is a different enterprise far from their core tourism business; they would rather have this activity outsourced to professionals. 2. Observations by the proponent have shown that requirements of fresh fish on a resort are substantial. For instance, for a resort with 700 staff (not uncommon in high-end 7+ start resorts in the Maldives) would require about 150 − 200 kg fresh fish per night. This result is not surprising since a survey in 2006 have shown that reef fish consumption in resorts stands around 1.29 kg per tourist night. 3. The proponent’s requests to authorities on recognition of the facility on par with facilities producing for export to EU-territories have met with confusion. The current regulation requirement of Maldives Food and Drug Authority (MFDA) and Ministry of Fisheries and Agriculture requirements on issuing ‘Certificate of (EU) Compliance’ and ‘License for Producing Fish and Fishery Products’ (for export) respectively is only for fish processing facilities targeting only for export. MFDA regulation requires the HACCP plan and factory floor layout is pre-approved before construction begins. Approaching Island Council on the issue decided that outlet falls under the category of facilities selling food and food products and therefore have issued ‘Operating License for Food Establishments’ during August 2013. Fortunately MFDA has now approved the layout for the ice-plant and factory floor layout. 4. The location proponent has chosen to build the facility is the area on the west of the Maalhos harbour. The area was reclaimed of dredged material excavated from the harbour basin some years ago. The Island Council have drawn up a land use plan for commercial leasing. Plots of 1,200 sq feet have been marked and 14 such plots have been identified in the area. Of these 4 plots on the western most sections have been leased to the Fish World Maldives Pvt Ltd. In addition they have acquired a large warehouse just three blocks south of their facility in the same area. 5. The proponent is proposing to produce a variety of products; fresh gill and gutted, fresh head and gutted, fresh loins and fillets targeted for resorts. There are also future plans to produce smoked and dried fish for sale in retail outlets on Malé. In addition the proponent plans to have a fishmeal plant with a capacity of 10-15 MT / day which will essentially leave nothing to throw away from the processing activities. The fish meal is intended for sale as component for producing poultry feed or as making aquaculture feed. 6. The Island Council is not able to provide the utility services and so production of water and electricity will take place on site. Initially the plan it to produce 10 MT of fresh water a day supplemented by rainwater harvests. Source water extraction for RO plant is from a bore-hole drilled on site. The borehole will be done by professional and following the guidelines provided by EPA. The depth of the borehole is around 25-30 m well below the fresh water lens in the area. Water will be stored at site on large plastic tanks. Two sound proof gensets of 125kVA each is installed. Maldives Energy Authority’s Regulation will be followed including registration of the power generation system 7. Ice will be produced at site for sale and distribution to the fishermen along with the ice-boxes. The plan is to educate fishermen on post-harvest handline and improving quality similar to the approach adopted in the successful large yellowfin handline fishery. There are also plans to have reefer vessels with ice to collect fish from atolls away from the central Maldives. For smoked and dried fish processing requirements steaming, smoking and drying chambers are fitted. The former is being ordered off the shelf, but the latter two is being custom-fabricated locally. 8. The purchase of fish will entirely be from local fishermen. Fortunately the area is popular for reef fishing; islands of Maalhos, Himendhoo, Mathiveri, Bodufulahodoo and Ukulhas are all popular reef fishing islands. Maalhos Island is strategically located in the atoll, the channel in the north and south (Maalhohu uthuru Kandu and Himendhoo Kandu) are popular crossing by the fishermen into the ocean and from the ocean side. In this sense the facility is well placed for the fishermen on their route to home ports after fishing. The area used to be popular for shark fishing and many are looking for additional work and so the news of establishing the processing factory is welcomed by the fishermen. 9. Waste from the facility will be minimal. Fish waste (from cutting and cleaning) will be used to produce fish meal. Blood water from the factory floor, grey water from toilets and brine (reject water from RO plant) will be collected in a tank underground and pumped into the western side outside the reef. Release of sewage will be minimal as there are no accommodation facilities on factory block. Lube oil and waste oil will be collected in plastic container and disposed appropriately. Any solid waste other than fish cutting will be disposed at the island waste processing facility. 10. Impact prediction exercise was undertaken in qualitative manner or a pre-defined generic template that included all the possible areas of impact from a related development projects. For the impacts that were positive or negative, scores of impact significance were assigned (negligible, moderate, major, beneficial, none). Only few negative environmental impacts were identified. These include moderate negative impacts from odour, potential over-exploitation of fisheries resources in the event of poor or lack of fisheries management from the authorities, potential damage to vegetation from collecting wood (if the plan for processed products starts), burning of significant amount fossil fuel for production of water and electricity and increased transport traffic and potential oil and other forms of pollution of the Maalhos harbour. All were found to be reversible impacts and appropriate mitigation measures are proposed for each. 11. Significant positive impacts were potential to create additional jobs and sustaining livelihoods of fishermen badly needed following the complete ban of shark fishing, better utilization of fish waste and improved opportunities for resources management by the authorities through monitoring control and surveillance and the large positive socioeconomics impact to Maalhos island creating multiplier effects for improving and expanding economic base of the island community. 12. The unique, innovative and a special aspect of the project is its link with the tourism. The project creates market space (for fishermen) and improved efficiency and health and safety of fishery products. Most importantly it adds value to the catch supporting government’s over-arching objective of sustainable utilization of the fishery resources. 13. The island council members are in agreement with this development project and they are happy to endorse the work of the Fish World Maldives Pvt Ltd. An environmental monitoring programme involving monitoring the water quality of the harbour area is proposed.
Technical Report
Environmental impact assessment for the development of a domestic airport on Kooddoo, GA. Atoll
(2011-10) Adam, M. Shiham
1. Kooddoo Island is located on the eastern boarder of Huvadhoo Atoll, Ga. Atoll, just south of Villingili. The island has a fresh tuna collection, freezing and storage facility owned by the state-owned enterprise – Maldives Industrial Fisheries Company Ltd (MIFCO). MIFCO was re-structured early 2011 and the Kooddoo operation was made a separate business entity under the name of Kooddoo Fisheries Maldives Private Ltd. 2. Plans for development of a domestic airport in Gaafu Alifu (GA) Atoll have been a government priority for some time. The initial plan was to have the airport on GA Villingili. A large area of the Villingili on the north eastern side was reclaimed in 2005 to provide land for housing and infrastructure developments. However, the size and shape of the reclaimed area was found to be not sufficient or appropriate for the 1200 x 30 m long aerodrome required for the domestic flights. Additional land has to be reclaimed if the airport is to be constructed on Villingili as planned, costing additional financial resources to be allocated. 3. Two uninhabited islands in region are being developed as tourist resorts and one of them - Falhumaafushi Resort - is now close to completion. Falhumaafushi Resort is expected to be officially open in early 2012. The construction of the second island Dhigurah is expected to the start very soon. These islands were tendered and developed in the hope the domestic airport on Villingili will be operational by the time of their opening. The need for a domestic airport for guest transfer is now essential to make the resorts economically viable as originally expected. 4. In order to fast tract the development of the domestic airport, the National Planning Council (NPC) in consultation with the major stakeholders in the region (i.e., Atoll and Island Councils, Members of Parliament and the Regional Administrative Offices) decided that a best possible and practical option is to have the airport on Kooddoo. 5. The developer of the airport is Bonvavista (Maldives) Private Limited, a property developer and resort owner based in Singapore. The agreement has been that the developer gets the GA. Dhigurah Island (not far from Kooddoo) for long term lease including some concession in rent for some initial period in return for the investment costs of domestic airport on Kooddoo Island. The contractor for the project is Keong Hong Construction Private Limited of Singapore. 6. At the scoping meeting the developer requested that EIA be submitted in two parts; the first one focusing only on the initial deployment of machinery, labourers and the clearance of the area required for the development. It was agreed that the second and complete EIA be submitted within the validity of the ToR (see Annex 1) and before the construction work begins. This first report therefore focused only on the initial mobilization and clearance of vegetation. The report is approved and the Decision Note issued (see Annex 2). 7. The surveys required for the EIA has been undertaken on 4-10 September 2011. Two separate trees surveys were done; one by total enumeration on randomly selected 4 x 100 x 100 m plots and the other by image analysis using a high resolution satellite imagery combined with ground truthed data undertaken as a separated survey at the same period. 8. The satellite image was classified to nine categories; “agricultural crops”, “bush vegetation”, “coastal bush vegetation”, “coconut grove”, “developed area”, “mixed woody vegetation”, “modified woody vegetation” and “open area and strand vegetation”. Highest cover was found to be in Mixed Vegetation type which through ground truth surveys were found to be Midhili, Uni and Kandhu1 and some few palm trees. For each category a range of number of trees were provide. Image analysis estimated that number of coconut trees would be in the range of 3,600 – 5,800. 9. The enumerated survey assumed that density and distribution of trees are same across the entire island. Furthermore it also assumes the random quadtrats (4 in nos.) are also representative of the floral composition of the island and their location does not create additional biases. While sound in theory in practice it may not be. The result of this simple averaging method was found to be quite different from results of the image analysis. While also acknowledging biases in the image analysis the true numbers of major trees type would probably in the range the values estimated. 10. All mature trees and coconut palms will be uprooted under the guidance and supervision to ensure that trees are in good condition for transport and replanting. The developer has identified five main potential islands; Villingili, Falhumaafushi, Vilivaru, and the newly reclaimed island of Gulhifalhu, where trees will be transported. Separate arrangement will be made by the contractor to ensure the safe transport and re-planting of tree in those islands. Experience elsewhere shows that replanted trees survive well provided that watering and enough care is given in the initial stages, particularly in uprooting and transporting. A target survival rate has been estimated at 70% and means to ensure this would be monitoring and reporting. 11. Surveys and assessment show the deployment of heavy equipment and machinery will be problematic. It was found to be almost impossible to use lifting equipment to unload the heavy machinery from barges over the quay wall. Following procedures practiced in similar projects in the Maldives, it was suggested to create a temporary landing site north of the island. An entrance to the reef already exists there but the area requires scrapping ~0.3 - 0.4 m off the substrate close to the beach area to allow flat-topped barges to move close to the beach. 12. Land and soil survey of Kooddoo showed presence of loose humus soil up to the water table at 1.4 - 1.5 m. This result was the same in locations surveyed. Laying out the air-field require two compacted aggregate base layers before the porous asphalt layer can be laid on top. These are 0.35 m thick compacted base-layer and 0.15m thick crushed aggregate course on top of the base-layer. These two layers require about 20,000m3 aggregate materials which will be sourced from local house reef. Exploring of alternatives suggests the most practical and cost-effective way to obtain the material is by dredging the house-reef. An area of about 300m x 70m x 1m on the eastern side of the reef flat will be dredged to source the required material. In all earlier airport construction projects the base layer material has been sourced from the local reef. 13. Overall the significant negative environmental impacts of the development project were found to be three; i) sourcing fill material from local reef, ii) clearance over 40% of Kooddoo area off vegetation and iii) creation of a temporary landing site for unloading/loading of construction equipment. Dredging reef flat may have immediate to medium term impacts that could potentially cause unintended erosion / accretion of the island. But shore-stabilization structures are not proposed at this stage. It was noted that significant areas of north eastern reef of Villingili was also dredged which may have potential long term impacts to the region including Kooddoo reef flat. Post- development monitoring will help to better understand the impacts to Kooddoo and provide reasonable time frame to address any remedial or mitigation measure that wil have to be implemented in a timely manner. 14. Vegetation clearance will have direct loss of habitats and potential agricultural land. Both are important in the context of the green and carbon neutral concept. However, in the long term, the construction and operation of the airport outweighs any potential of loss of ecological habitat and agricultural land. In summary significant negative impacts include loss of top soil, potential degradation of ground water quality, loss of significant area of vegetation and potential death of the significant number of trees and likely shift of ecological regime of the island in the medium to long term. Positive impacts include opportunities for economic growth and development of the region, the local aviation industry and further increase of tourism potential in GA and neighbouring area. 15. Alternatives have been proposed for project activities only. The decision to have the airport on Kooddoo is an executive high level government decision which may supersedes findings of the assessment on suitability of the site. Areas of potential impacts have been clearly identified and ways of mitigation have been suggested. The developer and contractor are fully aware of these issues and are committed to be responsible for implementing these measures during the construction of the airport and its facilities. 16. The operational arrangement of airport is not yet clear. It is envisaged that some of the services of Kooddoo Fisheries Maldives Pvt Ltd will be used for the management and day-to-day running of the airport. In this case separate arrangements will have to be made by the airport operator and the Kooddoo Fisheries Maldives. 17. Additional land surveys for levelling the air field and specification of the construction are being sought by professionals in the field. +++
Technical Report
Environmental impact assessment for the development of tuna purchasing and storage facility, GA. Raaverrehaa, North Huvadhu Atoll
(2016-01) Riyaz, Mahmood; Adam, M. Shiham
1- This is the Environmental Impact Assessment (EIA) report carried out for proponent ̶ Ensis Fisheries Pvt. Ltd. ̶ to develop and operate fish purchase and storage facility in Raaverrehaa North Huvadhu Atoll. The EIA was prepared as partial fulfilment of the requirement by the Ministry Fisheries and Agriculture (MoFA) for acquiring permission for the Project. Environmental Impact Assessment (EIA) of development projects is a requirement by the Environmental Protection and Preservation Act (EPPA) (law 4/93) of the Government of the Republic of Maldives. 2- This report has been prepared in accordance with the Environmental Impact Assessment Regulations published by the Ministry of Environment and Energy in 2012 and covers both negative and positive environmental and socio-economic impact arising from the proposed project. Major findings of this report are based on information gathered during the field inspection of both the existing environment and possible effects of the project activities, and ongoing similar projects elsewhere in the Maldives and through extensive literature review and experiences gained from similar projects elsewhere. 3- Initially the proposed development was planned in Ga. Kedheraa Island and environmental Decision Statement was obtained to go ahead with the project. Shifting the planned development to Raaverrehaa was decided based on strategic analysis of the development, which found potential operational disadvantages that may impede smooth operation of the facility. Most importantly lack of shallow reef space to develop a harbour, which is an important infrastructure for the facility, remoteness of the island and being far from the airport and major fishing islands are also some of the shortcomings of Kedheraa. 4- The proposed activity will take place on Raaverrehaa Island and surrounding Falhu. Ga. Raaverrehaa Island is an uninhabited found on the North Eastern side of Huvadhu Atoll located at the periphery in an elongated, N-S oriented reef platform measuring a length of 20 km is shared by multiple islands. The reef is shared by three more islands including Villingili Island. The eastern part of the reef extends in the form shallow lagoon into eastern rim of the Atoll. The elongated-oval-shaped island of Raaverrehaa is lying in the western half of the reef. The coral reef system of Raaverrehaa is 20km long and the width is 0.8-1.8km. Reef perimeter is 43km and the area is approximately 25sqkm. The distance from the edge of the beach to the reef edge in both eastern and western sides is fairly consistent measured approximately 1km on the east and 400m on the western side. Raaverrehaa is an elongated-oval shape, N-S oriented island, with a length of 415m and width 100-119m and has an area of 4.7 ha. Average depth of the reef flat is less than -1 to -0.5m m from MSL. 5- Major operation that will be undertaken in Raaverrehaa Island will be loading/unloading storage and transportation of fish to Ensis processing facilities located in Hulhumalé Island. The facility will have 500 tonnes cold storage capacity and will produce ice needed for the fishermen to keep the fish fresh until they reach the storage facility from the fishing grounds. Necessary infrastructure needed to operate the facility will be developed on the island including the accommodation facilities for the staff working on the island. Electricity and water required for operations will be produced in the island. 100x3 KvA generator sets will be will be installed at the powerhouse to provide the electricity needed for the island. Reverse Osmosis (RO) desalination plants with total production capacity of 40MT per day will be installed to provide necessary water requirement for the operations. The proponent will ensure that the powerhouse and desalination plant implies with the relevant regulations. The exhaust chimneys, lightening conductors, sound attenuators, and CO2-based fire fighting equipment will be installed. Ear mufflers will be provided for staff working at louder areas of the facility. EIA Ensis Fisheries – Raaverrehaa Shore-based Facility – M. Riyaz & M.S Adam 15 | 90 6- The raw material, mainly skipjack and yellowfin tuna caught by pole-and-line and handline by Maldivian on local fishing vessels will be purchased entirely from the Maldivian fishermen. With Ensis’s long reputation in the country, it is expected that a large number of vessel will sell fish to the Ensis Fisheries Pvt Ltd. Ice will be provided free of charge from all the Ensis facilities as incentive for fishing and to encourage loyalty to the company. In addition the proponent will provide iceboxes for fishing operation startups in the area. 7- During the preparation of the EIA report an impact matrix, which is a standard tool for identifying the possible impacts of project activities, has been created for proposed development project Raaverrehaa Island. The activities carried out during the construction and operational phases are arrayed against a selection of environmental factors that may be affected directly or indirectly as a result of project activities. The impact outcomes from this analysis are considered and appropriate mitigation measures both in the development and operational phased has been provided. 8- The report has identified the main environmental impacts associated with the proposed activities and found that high water and energy consumption and the discharge of effluent with a high organic content are the major issues. Vegetation clearance and construction waste during the construction phase and noise, odor, solid wastes occupational health and safety issues may also be concerns of the operational phase. The study has found that most significant negative environmental impact identified during the operational phase of this project is release of untreated effluent into the sea. Liquid, solid and other forms of wastes and particularly hazardous waste generated during the operational phase has also been identified as significant impact associated with the project and appropriate mitigation measures are suggested for each and every impact identified in relation to the project. 9- The study has evaluated alternative options for the project and found that the proposed development is the right development for the right place. To enhance the water circulation in the reef and to limit the access to Raaverrehaa it is recommended to cut a channel through the walkway or remove it as an alternative for keeping the solid walkway which blocks cross reef water motion, increase nutrient enrichment and subsequent growth of seagrass on the eastern side of the reef and provides unlimited land access to the island. It is suggested to under-take post-development extensive monitoring programme that will keep on monitoring the environmental changes associated with the development and its operation and make necessary adjustment to the activities and its operation of the project based on the findings of various measured environmental parameters suggested in the monitoring plan. 10- The overall positive environmental impact from the development project is to integrate the existing product lines and the value-addition of fishery products rather than exporting the whole fish for processing. Job creation and stimulation of local economy, and exports is the most significant positive environmental impact of this activity. The long-term sustainability of the activity however, will depend on the sustainability of the fish stock. Skipjack and yellowfin tuna are highly migratory and their stocks straddle across the countries’ exclusive economic zones into the high seas spreading out into the entire Indian Ocean. The stocks are being managed by the Indian Ocean Tuna Commission which among its 32 coastal and distant water fishing nations. Maldives is a full member and now heavily engaged, partly due to its existing Marine Stewardship Council (MSC) Certification of its pole and line skipjack and yellowfin tuna fishery. The current assessed status of the skipjack and yellowfin tuna stock is considered ‘not overfishing’. The total average Indian Ocean catches are below the assessed maximum sustainable levels and the spawning biomass is healthy well above the point of recruitment impairment. The Maldives fishery component takes 17% of Indian Ocean skipjack and some 15% of the yellowfin. The most recent MSY is around at 680,000 Mt per year for skipjack and 350,000 Mt for yellowfin tuna. 11- Raaverrehaa is occasionally used for local picnic and it is the only remaining island for picnickers in the vicinity Villingili. Proposed fish purchase and storage facility development in Raaverehaa will limit the public accessibility for local picnickers. To overcome potential social problems that may rise in association with this development, the proponent has proposed to develop a picnic facility in any location identified by the public and Villingili Council. At present council is consulting with the people to identify the most suitable area to develop for local picnickers. 12- On the basis of the findings of this environmental impact assessment study and the impact mitigation measures proposed in the report will be duly implemented and recommendations are given due consideration, it is concluded that the benefits of the planned Ensis fish purchasing and storage facility development in Raaverrehaa Island will substantially outweigh an unwelcomed demand of burden on the environment.
Technical Report
Environmental impact assessment for the proposed agriculture project on Dhandhoo, Baa. Atoll
(2013-03) Adam, M. Shiham; Riyaz, Mahmood
Baa Atoll Hanifaru was leased in 2008 to Mr. Mohamed Shareef of Maafannu Sunny Coast to develop agricultural activities. Following Environmental Regulation, an EIA Screening Form was submitted to EPA during early 2009. However, after elapse of some considerable period, the erstwhile Ministry of Housing and Environment declared Hanifaru Bay (lagoon) as a protected site under environmental law. Later Hanifaru was also declared as a protected site. In order compensate for this unexpected ‘taking away’ of Hanifaru, the Ministry of Fisheries and Agriculture, in consultation with Mr. Mohamed Shareef, arranged an alternative island – Baa Dhandhoo. The proposal under consideration is to develop Baa Atoll Dhandhoo as an agricultural island along with three other minor functions. The primary business model is based on production of high quality agricultural products. The island would also be a facility providing complementary and alternative medicine (CAM) services. To complement this function a small nursery of about 4,000 sq feet is proposed to grow indigenous medicinal plants that are becoming rare/extinct. Finally a small visitor centre is proposed which would allow visitors to learn about the activities on the island. Two main approaches − the AutoPot and hydroponics systems − are proposed for the production of rock-melon, cucumber, capsicum, chillies, lettuce, tomatoes etc. The growth system is completely contained either in the grow pots or in water medium. The main development feature of the island is 6 x 4,000 sq feet green houses to set up the AutoPot and hydroponics system. The green houses will be imported and assembled at site. Similarly the AutoPot system will be imported and assembled at site. The hydroponics system will be constructed locally from the imported material. Construction of the buildings will be kept to a minimum; staff accommodation, kitchen / dining facilities will be constructed to accommodate no more than 15 people for the agricultural works. Treatment rooms for CAM treatments will be built on the northern side of the island. A small stilt-jetty is constructed on the western side of the island. A complete list of the buildings is given in the layout plan. The island would be self-contained, and so water production and power generation will take place on the island. An RO plant of 10 cubic meters / day capacity is proposed with intake from the lagoon. To supplement the water production rainwater will be harvested from every possible roof on the island. A 25kW diesel power generator will installed for producing electricity. Storage of diesel on the island will be minimal transporting the required amounts from the nearby islands. The baseline environmental conditions were assessed using standard methods. Significant erosion was observed on the north-western and northern side of the island while accretion was evident on the western side. There appears to be a directional shift of the island to west. However, observation of such magnitude of movement has entirely due to seasonal erosion and accretions have been observed in some islands of Baa Atoll. No interventions for mitigating erosion were proposed at this stage. Biannual monitoring of shoreline was proposed to determine the seasonal dynamics of the island beach. No hard structures are proposed at this stage. A Leopold Matrix was used to determine the scale and extent of the impacts. The short-term environmental impact from this development project would to the island ecosystem from clearance of vegetation. About 60-80 palms may have to remove and/or relocated for the development work that will be replaced accordingly. Loss of top-soil, and shade and the clearance may affect the vegetation around the periphery. It is recommended that clearance take place only where necessary. Septic tanks systems have been proposed for disposing human waste and pose no long-term negative environmental impact considering the small number of people expected to be based on the island. It is recommended that non-biodegradables should be regularly removed from the island for disposal in to another island with arrangement made with the Council. Biodegradable waste from the plant material will be left to appropriately degrade on the island, thereby contributing nutrients pool of the island ecosystem. The Atoll Council and the resorts were consulted regarding the project and their views were considered. There was full support of the Council and no issues were highlighted. There were also no issues raised from the resorts except they wished see only minimal landscape Impacts during the operation phase are considered to be negligible. Overall the impact from the Project will be positive – demonstration of effective economic and sustainable use of uninhabited small islands inducing encouragement for climatesmart type agriculture.
Technical Report
Environmental impact assessment for the proposed channel and harbor development at Full Moon Tourist Resort
(2008-07) Adam, M. Shiham