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    Technical Report
    Environmental impact assessment : fish purchase, pack and export facility of Addu Fresh, Addu city, Hithadhoo
    (2016-01) Riyaz, Mahmood; Adam, Mohamed Shiham; Naseer, Abdulla
    1- This is the Environmental Impact Assessment (EIA) report carried out for proponent ̶ Addu Fresh Pvt. Ltd. ̶ to operate fish purchase, pack and export facility in Addu City Hithadhoo. Addu Fresh Pvt. Ltd. (or Addu Fresh) is one that does not undertaken an EIA study prior to their establishment on Addu City Hithadhoo five years ago in 2010. The EIA Regulation requires the EIA study be undertaken before the project start. However, in this case the EIA is done only for completing formalities and obtaining the license from the MoFA. While the ToR may not entirely reflect this, the readers and evaluators of this report keep this in mind. The EIA was prepared as partial fulfilment of the requirement by the Ministry Fisheries and Agriculture (MoFA) for acquiring permission to renew the fish purchase pack and export licence from the relevant government authorities. 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 , amended in 2015 and covers both negative and positive environmental and socio-economic impact arising from the operation of fish purchase, pack and export facility. Major findings of this report are based on information gathered during the site visit 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- The proposed activity will take place on Addu Fresh fish purchase, pack and export facility located at Addu City, Hithadhoo harbour area on Bandherimagu. Addu Fresh Pvt Ltd is located on North eastern side of Addu City Hithadhoo harbour. Addu Fresh fish purchase pack and export facility occupies 4800m2 area and the factory and processing facilities are constructed in 1500m2 area of land on the main road at the Hithadhoo harbour Bandherimagu. 4- Major operation that will be undertaken in Addu Fresh is fish purchase, pack (G&G/HG) and export to EU and Asian markets. Water and energy needed for the facility will be purchased, on commercial rates, from the local utility providers. An emergency powerhouse will be established at the back of the facility. The proponent will ensure that the powerhouse implies with the relevant regulations and will be registered at MEA. 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. 5- 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. Addu Fresh has been operating fish purchase, pack and export activities in Hithadhoo for over two years therefore, the company is well known among the fishermen in the southern region. 6- During the preparation of the EIA report an impact matrix, which is a standard tool for identifying the possible impacts of operational phase, has been 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 in the operational phase has been provided. 7- 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. Noise, odour, 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 Hithadhoo harbour area. Liquid, solid and other forms of wastes and particularly hazardous waste generated during the operational phase has also been identified as moderate impact associated with the project and appropriate mitigation measures are suggested for each and every impact identified in relation to the project. 8- The study has evaluated alternative options for some of the activities of the operational phase of the project and has suggested alternatives for wastewater discharge, emergency powerhouse and fish waste. It is suggested to under-take an extensive monitoring programme that will keep on monitoring the environmental changes associated with the commencement of operations to make necessary adjustment to the activities and its operations based on the findings of various measured environmental parameters suggested in the monitoring plan. 9- The overall positive environmental impact from the operation of Addu Fresh is to integrate the existing product lines and the value-addition of fishery products. 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. 10- On the basis 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 operation of Addu Fresh fish purchase, pack and export facility will substantially outweigh its imposition on the environment.
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    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.