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Item Environmental impact assessment for the development of tuna purchasing and storage facility, GA. Raaverrehaa, North Huvadhu Atoll(2016-01) Riyaz, Mahmood; Adam, M. Shiham1- 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.Item Environmental impact assessment for fish processing and packing facility at Fish World Maldives Pvt Ltd, Maalhos, Alifu Alifu Atoll(2013-12) Adam, M. ShihamThe 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.Item Environmental impact assessment for the proposed agriculture project on Dhandhoo, Baa. Atoll(2013-03) Adam, M. Shiham; Riyaz, MahmoodBaa 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.Item Environmental impact assessment for the development of a domestic airport on Kooddoo, GA. Atoll(2011-10) Adam, M. Shiham1. 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. +++