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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.
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    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.
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    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.