ENVIRONMENTAL IMPACT ASSESSMENT

For the Proposed Resort Development

Kanbalifaru

Shaviyani Atoll,

Proponent: Kanbalifaru Development Pvt Ltd.

Sndcys

August 2014 EIA for the Proposed Resort Development on Sh. Kanbalifaru

Table of Contents

TABLE OF CONTENTS ...... I

TABLE OF FIGURES ...... VI

TABLE OF TABLES ...... VII

CONSULTANTS DECLARATION ...... VIII

PROPONENT’S DECLARATION ...... IX

EXECUTIVE SUMMARY ...... X

1 INTRODUCTION ...... 1

1.1 INTRODUCTION ...... 1

1.2 BACKGROUND TO THE EIA ...... 2

1.3 SCOPE OF THE EIA AND APPROACH ...... 2

1.4 RELEVANT STUDIES ...... 3

1.5 EIA IMPLEMENTATION AND METHODOLOGIES ...... 4

2 LEGISLATIVE AND REGULATORY CONSIDERATIONS...... 5

2.1 POLICY GUIDANCE ...... 5 2.1.1 National Framework for Development 2009-2013 ...... 5 2.1.2 Third National Environment Action Plan...... 6 2.1.3 Maldives National Strategy for Sustainable Development 2009-2013 ...... 7 2.1.4 National Biodiversity Strategy and Action Plan...... 8 2.1.5 Waste Management Policy 2007 ...... 8 2.2 REGULATORY BODIES ...... 9 2.2.1 Ministry of Environment and Energy ...... 9 2.2.2 Environmental Protection Agency (EPA) ...... 10 2.2.3 Ministry of Tourism, Arts and Culture ...... 10 2.2.4 Atoll/City Councils and Island Councils ...... 10 2.3 LAWS AND REGULATIONS ...... 10 2.3.1 Environmental Protection and Preservation Act ...... 10 2.3.2 Environmental Impact Assessment Regulation 2012 ...... 12 2.3.3 Land Act ...... 12 2.3.4 Maldives Tourism Act ...... 13 2.3.5 Regulation on the Protection and Conservation of Environment in the Tourism Industry ...... 15 2.3.6 Maldives Recreational Diving Regulation ...... 17

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2.3.7 Regulation on Uprooting, Cutting and Transportation of Palms and Trees ...... 19 2.3.8 Desalination Regulation ...... 20 2.3.9 Dredging and Reclamation Regulations ...... 20 2.3.10 Regulation on Environmental Damage Liabilities ...... 21 2.3.11 Waste management regulation ...... 22 2.3.12 The Borehole Guidelines ...... 23 2.3.13 Powerhouse Registration Guidelines ...... 24 2.4 INTERNATIONAL AND REGIONAL CONTEXT ...... 24 2.4.1 Environment Sector ...... 24

3 PROJECT DESCRIPTION ...... 26

3.1 INTRODUCTION ...... 26

3.2 THE PROPONENT ...... 26

3.3 PROJECT LOCATION AND BOUNDARIES ...... 27

3.4 THE PROJECT ...... 27 3.4.1 Accommodation ...... 29 3.4.2 Food ...... 29 3.4.3 Recreation ...... 29 3.4.4 Staff Area ...... 30 3.5 ENVIRONMENTALLY SIGNIFICANT ACTIVITIES ...... 30 3.5.1 Land clearance ...... 30 3.5.2 Temporary facilities ...... 31 3.5.3 Desalination Plant ...... 31 3.5.4 Powerhouse and fuel storage ...... 32 3.5.5 Sewerage System ...... 33 3.5.6 Waste Management ...... 34 3.5.7 Landscaping ...... 35 3.5.8 Coastal modifications ...... 35 3.5.9 Emergency Response Plan ...... 36 3.5.10 Equipment, Machinery and Tools ...... 36 3.5.11 Transport ...... 37 3.6 TOURIST ACTIVITIES AND SERVICES ...... 37

3.7 PROJECT DURATION ...... 38

3.8 PROJECT INPUTS AND OUTPUTS ...... 38

3.9 NEED AND JUSTIFICATION ...... 39

4 PROJECT ALTERNATIVES ...... 43

4.1 INTRODUCTION ...... 43

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4.2 NO PROJECT OPTION ...... 43

4.3 ALTERNATIVE LOCATION ...... 45

4.4 ALTERNATIVE USES OF THE ISLAND ...... 46

4.5 ALTERNATIVES FOR ENERGY GENERATION ...... 46

4.6 ALTERNATIVES FOR WATER PRODUCTION ...... 46

4.7 ALTERNATIVES FOR SEWAGE DISPOSAL ...... 48

4.8 SHORE PROTECTION OPTIONS ...... 49 4.8.1 Existing coastal structures ...... 51 4.9 PREFERRED ALTERNATIVES ...... 52

5 EXISTING ENVIRONMENT ...... 54

5.1 INTRODUCTION ...... 54

5.2 METHODOLOGIES ...... 54 5.2.1 Location identification ...... 55 5.2.2 Marine Water Quality...... 55 5.2.3 Coastal processes ...... 55 5.2.4 Bathymetry ...... 56 5.2.5 Marine Ecology ...... 56 5.2.6 Socio-economic conditions ...... 57 5.3 OVERVIEW OF PROJECT SITE ...... 57

5.4 CLIMATE ...... 58 5.4.1 Monsoons ...... 59 5.4.2 Temperature ...... 59 5.4.3 Rainfall ...... 60 5.4.4 Wind ...... 61 5.4.5 Waves ...... 63 5.4.6 Evaporation Rates and Relative Humidity ...... 64 5.5 HYDROGRAPHY ...... 65 5.5.1 Tides ...... 65 5.5.2 Currents ...... 66 5.5.3 Bathymetry ...... 67 5.6 WATER QUALITY ...... 67 5.6.1 Marine water quality ...... 67 5.6.2 Groundwater quality ...... 68 5.7 GEOLOGY AND GEOMORPHOLOGY ...... 68

5.8 ECOLOGY ...... 71 5.8.1 Marine Protected Areas and sensitive sites ...... 71

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5.8.2 Endangered species ...... 71 5.8.3 Housereef of Kanbaalifaru ...... 71 5.8.4 Marine Ecological Survey Results ...... 72 5.8.5 Status of the coral reef ...... 79 5.8.6 Floral Landscape ...... 80 5.8.7 Terrestrial Fauna ...... 82 5.9 SOCIO-ECONOMIC ENVIRONMENT OF ...... 83

5.10 NATURAL HAZARD VULNERABILITY ...... 85

6 STAKEHOLDER CONSULTATIONS ...... 96

6.1 SCOPING MEETING ...... 96

6.2 CONSULTATIONS IN THE FIELD ...... 97

7 ENVIRONMENTAL IMPACTS ...... 99

7.1 INTRODUCTION ...... 99

7.2 METHODS AND LIMITATIONS ...... 99

7.3 IMPACT IDENTIFICATION ...... 100

7.4 OVERALL IMPACTS OF THE PROPOSED PROJECT ...... 101

7.5 PROJECT SPECIFIC IMPACTS – CONSTRUCTION PHASE ...... 103 7.5.1 Temporary facilities, constructional material machinery and workforce ...... 104 7.5.2 Construction of Sewer Outfall ...... 106 7.5.3 Feed water intake ...... 106 7.5.4 Brine discharge ...... 106 7.5.6 Removal of Vegetation ...... 107 7.6 PROJECT SPECIFIC IMPACTS – OPERATIONAL PHASE ...... 108 7.6.1 Pollution ...... 108 7.6.2 Transport Related Impacts ...... 109 7.6.3 Marine-based Activities ...... 109 7.6.4 Air, noise and light pollution ...... 109 7.7 SOCIO-ECONOMIC IMPACTS ...... 110 7.7.1 Significant negative socio-economic impacts ...... 110 7.7.2 Significant positive socio-economic impacts ...... 111 7.8 UNCERTAINTIES IN IMPACT PREDICTION ...... 112

8 MITIGATION MEASURES ...... 115

8.1 INTRODUCTION ...... 115

8.2 MITIGATION MEASURES – CONSTRUCTION PHASE ...... 115 8.2.1 Clearing of vegetation ...... 115

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8.2.2 Waste Management ...... 115 8.2.3 Human Environment ...... 117 8.2.4 Air ...... 117 8.2.5 Marine Environment ...... 118 MITIGATION MEASURES – OPERATIONAL PHASE ...... 118 8.2.6 Waste and wastewater ...... 118 8.2.7 Recreational activities ...... 120 8.2.8 Air and light pollution ...... 120 8.2.9 Shore protection ...... 121 8.2.10 Co-corporate social responsibility (CSR) ...... 122

9 ENVIRONMENTAL MONITORING ...... 125

9.1 INTRODUCTION ...... 125

9.2 RECOMMENDED MONITORING PROGRAMME ...... 125

9.3 MONITORING REPORT ...... 126

10 CONCLUSIONS ...... 128

11 ACKNOWLEDGEMENTS ...... 129

12 REFERENCES ...... 130

13 APPENDICES ...... 133

APPENDIX 1: TERMS OF REFERENCE ...... 133

APPENDIX 2: MOT APPROVED CONCEPT DRAWING ...... 133

APPENDIX 3: COMMITMENT LETTER FROM PROPONENT ...... 133

APPENDIX 4: DOCUMENT RECEIPT FROM ATOLL COUNCIL ...... 133

APPENDIX 5: CVS OF ASSISTING CONSULTANTS ...... 133

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Table of Figures

Figure 3-1: Location of Kanbaalifaru Shaviyani Atoll ...... 27 Figure 2: Proposed development concept ...... 41 Figure 3-3: Proposed shore protection plan ...... 42 Figure 4-1: Alternative location ...... 45 Figure 4-2: Proposed and Alternative disposal locations with beach nourishment option ... 53 Figure 5-1: Beach areas on the west (left) and east (right) ...... 58 Figure 5-2:Some of the existing structures on the island ...... 58 Figure 5-3: Daily average temperature for Central Maldives with percentile bands...... 60 Figure 5-4: Probability of precipitation at some point in the day for Hulhulé, Maldives ..... 61 Figure 5-5: Windrose diagram based on data from Hanimaadhoo Airport ...... 63 Figure 5-6: Average daily relative humidity with percentile bands ...... 65 Figure 5-7: Tidal variations recorded at Hanimaadhoo ...... 66 Figure 5-8: Area covered by different attributes of Kanbaalifaru ...... 70 Figure 5-9: Different and their extent around Kanbaalifaru ...... 72 Figure 5-10 : Photos of Site 1 ...... 73 Figure 5-11: Photos of Site 2 ...... 73 Figure 5-12: Photos of Site 3 ...... 75 Figure 5-13: Benthic cover at Site 4 ...... 75 Figure 5-14: Photos of Site 4 ...... 76 Figure 5-15: Photos of Site 5 ...... 77 Figure 5-16: Fish survey results, Site 6 ...... 78 Figure 5-17: Photos of Site 6 ...... 78 Figure 5-18: Photos of Site 7 ...... 79 Figure 5-19: Tsunami hazard zones ...... 86 Figure 5-20: Tracks of Cyclones affecting Maldives, 1877-2004 ...... 87 Figure 5-21: Tracks of Cyclones passed within the Scan Radius of 500 kilometres ...... 88 Figure 5-22: Regions to capture Cyclones passing through Maldives for Hazard Zoning ... 88 Figure 5-23: Three Dimensional View of Bathymetry of Maldives (depth in meters) ...... 89 Figure 5-24: Storm Surge Hazard Zones with Cyclones Affected ...... 89 Figure 5-25: Maldives Seismic Hazard Zones ...... 90 Figure 5-26: Survey locations ...... 91 Figure 5-27: Bathymetry ...... 92

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Figure 5-28: Vegetation ...... 93 Figure 5-29: Illustrated summary of conditions of the coastal environment ...... 94 Figure 5-30: Illustrated summary of conditions of the marine environment ...... 95 Figure 31: Impact zones for Kanbaalifaru including beach nourishment ...... 113 Figure 7-32: Summary of socio-economic and environmental impacts ...... 114 Figure 8-1: Summary of mitigation measures ...... 123

Table of Tables

Table 3-1: Matrix of key inputs of the proposed project ...... 38 Table 3-2: Matrix of major outputs ...... 39 Table 4-1: Advantages and disadvantages of the no project option ...... 44 Table 5-1: Key meteorological information (Maldives) ...... 59 Table 5-2: Summary of general wind conditions in Kanbaalifaru. (DHI 1991) ...... 62 Table 5-3: Summary of wave condition in Kanbaalifaru ...... 64 Table 5-4: In-situ water quality results ...... 67 Table 5-5: Groundwater quality ...... 68 Table 6: Fish survey results, Site 1 ...... 73 Table 5-7: Fish survey results, Site 3 ...... 74 Table 5-8: Fish survey results, Site 4 ...... 76 Table 5-9: Fish survey results, Site 5 ...... 77 Table 5-10: Results of vegetation transect 1 ...... 81 Table 5-11: Results of vegetation transect 2 ...... 81 Table 5-12: Results of vegetation transect 3 ...... 82 Table 5-13: Results of vegetation transect 4 ...... 82 Table 5-14: Island level Demographic statistics of Shaviyani Atoll (census 2006) ...... 84 Table 5-15: Employed population of Shaviyani Atoll (Census 2006) ...... 85 Table 7-1: Impact evaluation scale ...... 101 Table 7-2: Impact matrix for the proposed project ...... 102 Table 7-3: Impact potential indices for the proposed project ...... 103 Table 8-1: Waste management plan – construction phase ...... 117 Table 9-1: Proposed annual monitoring programme ...... 127

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Consultants Declaration

This EIA has been prepared according to the EIA Regulations 2012. I certify that the statements in this Environmental Impact Assessment study are true, complete and correct to the best of my knowledge and abilities.

Ahmed Zahid (EIA 08/07) Hussain Fizah (EIA01/14)

Proponent: Kanbalifaru Development Pvt. Ltd. Page | viii Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

Proponent’s Declaration

As the proponent of the proposed development I guarantee that I have read the report thoroughly and that to the best of my knowledge all information provided here is accurate and complete.

Mr. Adam Manik

Company Chairman / Managing Director.

Kanbalifaru Development Pvt. Ltd

Proponent: Kanbalifaru Development Pvt. Ltd. Page | ix Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

Executive Summary

This report addresses the environmental concerns of the proposed development of a resort on Kanbaalifaru; shaviyani Atoll. The island is about 195,709 m2 in its size. Kanbaalifaru is located close to the eastern rim of Shaviyani atoll at 6° 7'26.84"N and 73°15'18.89"E. There are no other islands within the house-reef of the island. The Proponent of the proposed development is Kanbaaalifaru Development Pvt. Ltd.

The Proponent proposes to develop a medium to high end resort on Kanbaalifaru with 201 rooms, having a bed capacity of 402, which comprise of 30 x Beach Villas (2 rooms each); 50 x Ocean view villa; 18 x Family Villas (2 rooms each); 30 x Water villas and 25 x Superior water villas. In addition to these, guest facilities will include an Arrival Jetty; water villa arrival point; Reception and Admin office, a Main Restaurant; Main bar, Specialty restaurant, Spa Complex, Dive Center & Medical Clinic, Shops, Beach Bar/Coffee shops and Sports area.

The proposed development will conform to all current environmental legislation including the Regulation on the Protection and Conservation of the Environment in the Tourism Industry. The main negative impact of the proposed development will be the impact of deforestation due to land clearance for proposed buildings. There may also be some degree of sedimentation due to excavation to place footings of jetties and water villa structures, which is considered minor negative. The other impacts due to environmental infrastructure such as power generation, sewage and wastewater disposal and water production are considered general impacts similar to all such developmental projects. There are no specific concerns or environmental impacts related to these. These impacts are inevitable. Yet, every effort is to be made to minimize the impact and footprint of the impact.

To minimize the impact of deforestation, buildings will be designed around mature trees minimizing their removal. If a mature tree were to be removed, they will be carefully uprooted and transplanted elsewhere. It is noteworthy that there are very few mature trees in Kanbaalifaru with a few mature coconut palms. The other negative impacts of the water villas include impacts on sediment transport around the north-western side and south-western side of kanbaalifaru and some minor degree of sedimentation on the reef nearby. The impact on hydrodynamics would be minimized by placing water villas as far away from live reef areas

Proponent: Kanbalifaru Development Pvt. Ltd. Page | x Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru and dynamic beach areas as possible especially on the southern end where there is a dynamic sand spit. To minimize the impact on longshore sediment transport, the walkways of water villas will stand on piles with their footings buried in the seabed. Care will also be taken to minimize sedimentation on the reef when placing water villa footings and columns. Precast footings and columns will be used and excavator movements shall be minimized. Excavator is preferably moved on barge to minimize sedimentation and if high bed excavators were to be used, they shall move as far from coral reef flat areas as possible. This impact of sedimentation will be short-lived given that tidal and wind-driven currents would normally carry the sediments away from the reef at all tides and monsoons. It is vital, therefore, to monitor the condition of the reef prior to the start of works, during the works and after the works to establish the true nature of the impact. Transplanting live corals in impacted area would be a priority. There are very few live corals in development zones, which may be impacted.

The other environmental impacts of the proposed development include solid waste management, water supply, sewage disposal and energy generation. Solid waste will be generated both during the constructional and operational phase of the resort. Constructional waste will be disposed of by the Contractor to in or Thilafushi in . During the operational phase, a waste management center established on the island will segregate waste and dispose of them in a manner prescribed in tourism regulations. It is during the construction stage that the waste is often not managed properly and waste ends up in the environment. Therefore, it is vital that waste management procedures are in place during construction phase to ensure waste is appropriately dealt with. Supervision and awareness of construction workforce is highly recommended. Desalination, sewage treatment and power generation are fuel-dependent processes and fuel efficient desalination technology, STPs and, especially, generator sets will be installed in the island. Solar water heaters have been proposed and photovoltaic system incorporated, the costs of which have already been taken into consideration. Gravity sewers will deliver the sewage with multiple pumping stations, which will be minimized by appropriate design. Treated effluent with low levels of BOD (less than 20mg/l) will be disposed to the sea at not less than 10m below MSL and 5m away from the reef edge. Therefore, the impact from sewage disposal will be almost negligible. In fact, the daily peak flows is quite small that the proposed sea outfall would provide over 500-fold dilution to the sewage effluent even if it were raw sewage, which would occur only in the unlikely event that the sewage treatment plant fails. Hence, no further

Proponent: Kanbalifaru Development Pvt. Ltd. Page | xi Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru mitigation measures have been considered for sewage disposal and treatment. In order to minimize the energy-intensive nature of wastewater treatment, it has been recommended to avoid wastewater treatment and to consider direct disposal to sea or ground, if possible. Although the island is located within the atoll, the reef on the east is subjected oceanic swells from the channel between and Eriyadhoo, therefore, the southeastern side or the north-northeastern side of the island is considered appropriate for disposal of raw sewage. Furthermore, due to the narrow nature of the island, the groundwater is quite saline and a proper groundwater lens is not formed, therefore, sewage and wastewater (being primarily domestic in nature) may be disposed into the ground through a septic tank system.

The project encompasses clean technology and alternative energy options will be investigated with specific focus on a solar energy system. This will complement the proposed diesel generator sets. In addition, solar water heaters will be installed to provide hot water to all guest units. Also, to minimize fuel and water consumption, it is proposed to install energy and water efficient technology including faucets. The costs of these would be included in the project.

Environmental monitoring has also been incorporated into the project. Arrangements for monitoring during constructional and operational phase will be considered immediately upon EIA approval. Monitoring will be undertaken according to the monitoring programme recommended in this report. Recommended monitoring for the project includes the monitoring of shoreline at predetermined and bench-marked tide levels, beach profiles and drogues at locations given in the EIA report, marine water quality at the location of the intake, brine discharge, sea outfall and a control location, air and groundwater at a location close to the powerhouse and desalination plant and a control location and quality of product water at 3 specified locations including product water tank. Fuel and water production data and clean energy initiatives may also be incorporated. Annual monitoring reports have to be submitted to the Environmental Protection Agency over the monitoring period and shall include fuel and water consumption data and greenhouse gas emission calculations.

The overall environmental impacts of the project have been assessed using appropriate matrices and the results indicated that the proposed project has net positive impact. Given that the project has major socio-economic benefits although there would be some negative environmental impacts, it is recommended to allow the project to proceed as proposed.

Proponent: Kanbalifaru Development Pvt. Ltd. Page | xii Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

ާޞާލުޚ ާދާސ

ްށަޓްށެވާމިތ ްނުބަބަސ ެގުމުރުކ ްތަކްއަސަމ ެގުމުރުކ ީޤްއަރަތ ްއެޓޯސިރ ިއަގ ުރަފިލާބނަކ .ށ ީކަޓޯޕިރ ިމ

ީތަމުރިއ ެގުޅޮތައ ިނަޔިވަށ ީކަރަފިލާބނަކ .ެވެކެޓޯޕިރ ާވިއަފިވެރުކުރާޔްއަތ ްނުތޮގ ެގުމުރުކްނާޔަބ ުރަވްނިމ ެނާރޯފ ުރަސައ

ުރަފިލާބނަކ ީކަރާޔިދެއ ެގުޢޫރްޝަމ ިމ .ެވެކެށަރ ެގުރަޓުކެހ 20 ްށަކަޑަގްތާގ ަންނޮއ ިއަގްއެޅަފ ިކަވ ިއަގުތާރަފ

.ވެ ެޑެޓިމިލ ްޓެވިއަރްޕ ްސްޓްނެމްޓްސެވްނިއ

201 ިއަގުޓޯސިރ ިމ ޭވެރުކ ީޤްއަރަތ ްށަރަވްނެފ ީނާމަޒ ްނެގްށޮކުޒާމައ ްށަންނުޓްސިރޫޓ ެގީތްނަފުދެމ

ކޮޓަރީގެ މައްޗަށް ބެހިފައިވާ ޖުމްލަ 402 އެނދު ހިމެނިގެންވާނެ އެވެ. އޭގެ ެތރޭގައި 2 ކޮޓަރީގެ 30 ބީޗް ވިލާ އާއި،

50 އޯޝަން ވިއު ވިލާ އާއި، 2 ކޮޓަރީގެ 18 ފެމިލީ ވިލާ އާއި، 30 ވޯޓަރ ވިލާ އާއި، 25 ސުޕީރިއަރ ވޯޓަރ ވިލާ

އެވެ. މީގެ އިތުރުން އަރައިވަލް ޖެޓީ އާއި، ވޯޓަރ ވިލާ އަރައިވަލް ޮޕއިންޓް އާއި، ރިސެޕްޝަން އަދި އެޑްމިން އޮފިހާއި،

މެއިން ރެސްޓޯރަންޓް، ސްޕެޝިއަލް ރެސްޓޯ ަރނޓް އަދި މެއިން ބާރ އާއި، ސްޕާ ކޮންޕްލެކްސް އަދި ޑައިވް ސެންޓަރ އާއި،

މެޑިކަލް ކްލިނިކް އާއި، ފިހާރައާއި، ބީޗް ބާރ، ކޮފީ ޝޮޕް އަދި ސްޕޯރޓްސް ސަރަހައްދެއް ގާއިމް ކުރުމަށް ހަމަޖެހިފަ

ިއާއްމާޒިނ ާދްއަފުއ ްޓްނަރަކ ިއާނެފ ެގުށަރ ިއަގޭރެތ ެގާޔިރޭއ ްފާޓްސ ާދަހ ްށތަ ޮގޭވެލުކެއ ްއަތްތަމުދިޚ ްނެހިނެހެއ .ެވެއެވ

ުކެއ ިއާކަރަދަބ ްށަމުދެހ ިއަވުރައ ިތެކަތ ްށށަ ަރ ިއާށަމުބޭފ ިއަރައ ްށަށަރ ިމ .ެވެއެނާވިއަފިވެރުކްމިއާޤ ްމާޒިނ ާލާތްއަނިނުކ

.ެވެއެނެމިހ ްއެއީޓެޖ

ޭދްނަތ ްއެކަތުދިއާވަޤ ިއާކަތުނޫނާޤ ާހިރުހ ޭޅުގ ިއާމަކ ީނާދ ްނެގިވެރުކ ީޤްއަރަތ ިވެލާވަލުކެއ ުޢޫރްޝަމ ިމ

ަދ ްފޮއ ްނަޝޭވަޒްނޮކ ްޑްނެއ ްނަޝްކެޓޮރްޕ ަދ ްނޮއ ްނަޝޭލުއިގެރ" ިއަގްއެތޮގަޞްއާޙ ިއަގޭރެތ ެގީމ .ެވެންނިތމަ ެގްއެތޮގ

ވޭ ެދޭނ ެމްނެއ ްށަޓްށެވާމިތ ްނުބަބަސ ެގ ުޢޫރްޝަމ .ެވެއެވެރުކަގަހާފ "ީރްޓްސަޑްނިއ ްމަޒިރޫޓ ަދ ްނިއ ްޓްނެމްނަރަޔަވްނެއ

ިއާކަތާލިވ ރަޓޯވ ިދައ .ެވެންނުބަބަސ ެގުމުހެޖ ްނަޑނަކ ްސަގ ްއެއަބ ްނިއެރެތ ުށަރ ިއަކަޓްށަމުރުކްތާރާމިޢ ީނާރޯފ ުރަސައ

ޖެޓީގެ ބުޑުތައް ބަހައްޓަން ކޮނުމުގެ ސަބަބުން ކޮންމެވެސް މިންވަރަކަށް ކިލަނބުގެ އަސަރުކުރާނެއެވެ. ނަމަވެސް،

މިކަންކަމުގެ ސަބަބުން ތިމާވެށްޓަށް ފޯރާ ނޭދެވޭ އަސަރު މި މަޝްރޫޢުގައި ވަރަށް ކުޑަވާނެއެވެ. އެއީ، މި ރަށަކީ ބޮޑެތި

ްށަމުޅެއ ީޓެޖ ިދައ ްސާލިވ ރަޓޯވ ިއަގުރުދ ިއާކަތުބާސިހ ިރުހ ްނުރިދ ެގުރަފ ިއަފެވްށަކަށަރ ުދަމ ްއަތްސަގ

Proponent: Kanbalifaru Development Pvt. Ltd. Page | xiii Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

ެނާފްށޮކ ްނުބަބަސ ެގުމާޒިނ ެގުޓްނަރަކ ިދައ ްމާޒިނ ެގާމަދުރަނ ިއާނެފ ުރިއާލަބ ްށަމަކްނަކ ްނެހިނެހެއ .ެވެއީތާވިއަފިހެޖަމަހ

ިދައ ަންނޮއ ްއެލިވ ުޑޮބ ްނުތޮގ ީތަރުދުޤ ީކަރަފިލާބނަކ .ެވެއަދަފްއެއ ޭކެކަތުޢޫރްޝަމ ްނެހެއ ަދަފިމ ުރަސައ ޭވެދޭނ

ުކައ ުޢޫރްޝަމ ިމ ްއެމަކްނަކ ަދަފ ްނުދެހ ުރަދނަބ ިއާމުރުކްނުފުރެނ ީތާވްށަކަށަރ ްތޮއ ްށަތޮގޭވެދަވ ުކެއާމަކަހޭސަފ ްށަލިވެއ

.ެވެއނެ ެމިހުނ

ނަމަވެސް، މިކަންކަމުގެ ސަބަބުން ތިމާވެށްޓަށް ކޮށްފާނެ ނޭދެވޭ އަސަރުތައް ކުޑަކުރުމަށް ކުރެވެން ހުރި

ިއަކަޓްށަމުރުކުދަމ ުރަވްނިމ ޭހެޖ ްނަޑނަކ ްސަގ ްނތު ޮގިމ .ެވެއެނޭވެރުކަޑުކ ުރަވްނިމ ެނާރޯފުރަސައ ްނެގްށޮކ ްއެމަކ ާހިރުހ

ެގުބނަލިކ ޭދެފުއ ުރިއަންނޮކ ިދައ ްނުދެހ ްނަތްނަތ ިދައ ިއާމުރުކާމުރަފ ްޓޯސިރ ްށަތޮގޭހެޖުނ ްނަޑނަކ ްއަތްސަގ ިތެޑޮބ

ިއަޅައަޑނަކ ްށަޅަގަރ ްއަތުދްއަހަރަސ ާވިއަފިހެޖަމަހ ްށަމުރުކްތާރާމިއ ްނެގިއަލަބ ށް ަރަވަޔިދ ިއާރަވިއޮއ ްށަމުރުކަޑުކުރަސައ

ްނަކިރެތާކްއަރ ްށަކަނަތެއ ަމަނ ްއެބާސިހ ިރުހ ްނުރިދ ިއަގުރަފ ިއާމުށޮކުނ ްސަގ ްނނު ަތްނަތ ްނެހެއ ާވަޔިފ ްނަތްނަތެއ

ްއަތްތާރާމިޢ ްށަކަތޮގ ަދަފ ޭހެޖުނ ްނަޑނަކ ްއަތްސަގ ިތެޑޮބ .ެވެއެނެމިހ ްނަކްނަކ ަދަފ ްނުރުކްތަކްއަސަމ ްނެހެނޭބިލ

ސެޓްކު ުރމަށް ޙާއްޞަ ސަމާލުކަމެއް ދޭނެއެވެ. އަދި ކޮންމެހެން ނަގަން ޖެހިއްޖެ ނަމަ، އެގަސް ހުރިތަނުން ފަރުވާތެރި

ްށަމުޅެއ ްއަތުޑުބ ެގުކަތރި ަޓޮކުދޫމ .ެވެއަފިހެޖަމަހ ީނަވ ްށަމުރުކާލާއ ާދްނިއ ިއަގްއެނަތ ްނެހެއ ްސޮގްނެގ ްނެގިއަގަނ ުކެއާމަކ

ކޮންނަ ކޮނުމުގެ އަސަރު ރަށުގެ ފަރަށް ކުރުމަކީ އެކަށީގެންވާ ކަމެކެވެ. ވީމާ، މޫދުކޮޓަރި ތަކުގެ ބުޑުއެޅުމަށް ކޮންނަ

ްށަމުރުކަޑުކ ަތަވުނ ްށަކަތޮގ ެނާރުކުނ ްށަރފަ ުރަސައ ެގުބނަލިކ ޭދެފުއ ްނެގިއަލަބ ްށަރަވިއޮއ ިއާރަވަޔިދ ްސެވުރިއ

ަމަނާރުކްނުނޭބ ްއެރަޓޭވަކްސްކެއ ްޑެބިއަހ ަތަވުނ ްނުޅުގްނެގ ަގްއެޖާބ ުރަޓޭވަކްސްކެއ ިދއަ .ެވެއެނާވްނަރުކ ްތަކްއަސަމ

.ެވެއެނާވްނަރުކްތަކްއަސަމ ްނުރުދ ިއާރަފ ުކެއާމަކިރެތާވުރަފ

ިއާމުލާތްއަނ ިނުކ ޭދެފުއ ުރިއާދ ްނުމަރުކްޓޭރަޕޮއ ްޓޯސިރ ިދައ ުރިއާދްނުމަގނިހ ްތަކްއަސަމ ެގުޢޫރްޝަމ ިމ

ްށަމުރުކަޑުކ ުރަވްނިމ ާރޯފ ުރަސައ ްށަޓްށެވާމިތ ިއަގުމުނިދްތަމުދިޚ ެގުޓްނަރަކ ިދައ ްތަމުދިޚ ެގާމަދުރަނ ިއާނެފ

ާވިއަފިހެޖަމަހ ްށަޓްށުފަލިތ ަތަވުނ ްށައދޫ ްނަވ .ރ ީނާލާކުއ ިނުކ ޭދެފުއ ިއަގުޖޭޓްސ ާރުކްތާރާމިޢ .ެވެއެހެޖ ްނަރުކްތަކްއަސަމ

ްޓޯސިރ .ެވެއެނާންނުހ ިއަފެވްމިއާޤ ިއަގުށަރ ްއެމާޒިނ ުޅަގަރ ެނާލާތްއަނ ިނުކ ިދައ .ެވެންނުކަލޫޞުއ ުޅަގނަރ ެމްނެއ

ިއާރަޓޭރަނިސްނިއ ްނިތަމ ެގުތޮގ ާވިއަފާޅައަޑނަކ ިއަގުދިއާވަގ ްމަޒިރޫޓ ިއަކަޓްށަމުލާތްއަނ ްށޮކިކަވ ިނުކ ުރިއާދްނުމަގނިހ

ުޓން ަރަކ ިއާނެފ .ެވެށަނަތްނަތ ާވިއަފިވެރުކަޞްއާޙ ްނަލާކުއިނުކ ީނޭވެލާކުއިނުކ ިދައ .ެވެއެނާންނުހ ްއަތްތާލާއ ްނެހިނެހެއ

ްއަތްމާޒިނ ާރުކްނުނޭބ ްނުދަމ ަތަކަހ ްނުތޮގ ެގުމުރުކ ިރެތްތަމުޙަރ ާޓްށެވާމިތ ްއަތްތަކްއަސަމ ިއަހެމްނެއ ޭވެރުކ ްށަމުދްއެފުއ

Proponent: Kanbalifaru Development Pvt. Ltd. Page | xiv Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

ިށެވާމިތ ްނުނެފ ްސިޖަނ ިއާހިޖަނ .ެވެއެނޭވެރުކްމިއާޤ ުރަޓީހ ރަޓޯވ ާލޯސ ާރުކުނޫހ ްނެފ ްނިވައ ިދައ .ެވެއެނޭވެރުކްމިއާޤ

ީނަވ ްއެމާޒިނ ާރުކުފާސ ްނެފްސިޖަނ ިއާހިޖަނ ާވިއަފިވެރުކްމިއާޤ ށް ަތޮގ ޭދނިހުނ ްނެފ ްށަމިބ ްނުތޮގ ެގުމުރުކ ްތަމާލަސ

މަޝްރޫޢުގައި ހިމެނިފައެވެ. އަދި މި ނިޒާމުން ސާފުކުރެވިފައިވާ ފެން ދޫކުރެވޭނީ ފަރުން ބޭރަށް 10މ އަޑިއަށެވެ. ވީމާ،

ްސިޖަނ ޭދެފުއ ިއަގުޓޯސިރ .ެވެއެނާދްނެގިވރެ ުކ ަޑުކްށަޑޮބ ްށަރަވ ުރަވްނިމ ެނާރޯފ ުރަސައ ްށަޓްށެވާމިތ ްނުބަބަސ ެގުހިޖަނ

ްސަޔިވ ިއަގުމަކ ިރުކުނުފާސ ްނެފްސިޖަނ ްނުމަކ ްށަޑނަކ ްށަރޭބ ްނުރަފ ީނަރުކރު ޭބ ްނެފެއ ިއަފެވަޑުކ ުރަވްނިމ ެގުނެފ

ްސެވެމްނޮކ ީނަންނޮއ ުރަފިލާބނަކ ިދައ .ެވެއެނާދ ްނެގެވަޑުކ ްށަޑޮބ ްސެވ ެރުވ ްށައަނުގ 500 ުރަސައ ެގުހިޖަނ

މިންވަރަކަށް އަތޮޅު ތެރޭގައި ކަމަށް ވިޔަސް، އިރު މަތީ ފަރާތަކީ ފުނަދޫއާއި އެރި ަޔދޫ އާއި ދެމެދު އޮންނަ ކަނޑުއޮޅިން

އަންނަ ބާނިތަކުގެ ސަބަބުން ފުއްޓަރު ފަރާތް ކަމަށް ވާތީ، ިއރުދެކުނު ނުވަތަ އިރުއުތުރު ކަންމައްޗަކީ ޓްރީޓްނުކޮށް

ނަޖިސްފެން ބޭރުކުރަން އެކަށީގެންވާ ދެ ތަނެވެ. ވީމާ، ޓްރީޓްކުރުމަކީ ޚަރަދުބޮޑު އަދި ގިނަ މިންވަރަކަށް ހަކަތަ ބޭނުންކުރާ

ޕްރޮސެސް އަކަށްވާތީ، ކަނބާ ިލފަރުގައި ޓްރީޓްނުކޮށް ކަނޑަށް ނަޖިސްފެން ބޭރުކުރެވިދާނެކަމަށް ފެނެއެވެ. އަދި މީގެ

ިއތުރުން ރަށަކީ ހަނި ރަށަކަށްވާތީ، މި ރަށުގައި ދެމެހެއްޓެނިވި ގޮތަކަށް ބޭނުން ހިފޭނެ މީރުފެން ފަށަލައެއް އޮތުމަކީ

ުކްނޭޓ ްކިޓްޕެސ ީތެނާރުކުންނުނޭބ ްނެފ ެގުމިބ ްސެވްށަކަތޮގްއެއ ިއަގުޓޯސިރ ިމ ިދައ ީތާންނެފުނ ްށަމަކ ްއެމަކ ާވްނެގީށަކެއ

.ެވެއެވެރުކަގަހާފ ިއަގުމަކ ްއެތޮގ ާވްނެގީށަކެއ ެމްނެއ ްސެވީކމަ ުދްނިހ ްށަމިބ ްނެފްސިޖަނ ްށޮކިރެވުދެމ

ްނަބާކ ަމަތަރުފ ެމްނެއ ެގޭޔިނުދ ިދައ ާޔިކ ާބަހުރަމ ްށަކަތްތާލާއ ިރެތްތަމްޙަރ ާޓްށެވާމިތ ީކައެޖްއާރިހެވިދ

ނިއު ްޓރަލް ޤައުމަށް ވުމުގެ އަޒުމުގައި މަސައްކަތް ކުރާ ޤައުމަކަށް ވާތީ، ކަނބާލިފަރު އިންވެސްޓްމަންޓުންވެސް އަވިން ހަކަތަ

ިއަގްޓޯސިރ ްނުރުތިއ ެގީމ .ެވެއަފިވެރުކުދްސަޤ ީނަވ ްށަމުނިދ ްއެމަކުތަޔްއިމްއަހައ ުޑޮބ ްށަރަވ ްށަކަތްމާޒިނ ާދްއަފުއ

.ެވެޗްއެކަތ ާރުކްނުނޭބ ްނުދަމ ްނެފ ިއާކަތްތަލާއ ާރުކްނުނޭބ ްނުދަމ ަތަކަހ ްސެވްނިޅުމ ީނާރުކްނުނޭބ

ިމ .ެވެކެޓޯޕިރ ޭހެޖ ްނަޅަހަށުހ ްނުދިއާވަޤ ީކަޓޯޕިރ ޭހެބ ިއމާ ުތަގެނެދ ްއަތުލަދަބ ާދްނުމަންނައ ްށަޓްށެވ

ަންނައ ްށަށޮދުޑޮގ ިއާކަތުލަދަބ ަންނައ ްށަރަވިއޮއ ާގނިހ ްނެގިއަށަވްށަރ ިއަގުކަތާސާރިދ ަދަފިމ ާރުކ ްނުށަދ ެގުޢޫރްޝަމ

ާވިއަފިކިހ ަގާޔިދިކިހ ިއާއަގިއަޔިދުޑޮބ ިއާލިއަފޮރްޕ ްޗީބ ްނުނަތްނަތ ާވިއަފާލަބ ިއަގާސާރިދ ިމ .ެވެއެނެމިހ ްއތަ ުލަދަބ

ސަރަޙައްދު ނުވަތަ ފެންގަޑު ހުންނަވަރު، އަދި ފެނުގެ ކޮލިޓީވެސް ބަލަމުން ގެންދިއުން ހިމެނެއެވެ. މި ދިރާސާތަކަށް ފަހު

ްނުމަޅަހަށުހ ްށައ ީސްނެޖޭއ ްނަޝްކެޓޮރްޕ ްލަޓްނެމްނަރަޔަވްނެއ ްޓޯޕިރ ޭހެބ ިއާމުތަގެނެދ ްއަތުލަދަބ ާދްނުމަންނައ ްށަޓްށެވ

.ެވެއަފިއަޅައަޑނކަ ީނަވ ްށަމުއިދްނެގ

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ޭވެލެބ ްށަމަކ ެނާރޯފުރަސައ ްށަޓްށެވާމިތ ްނުބަބަސ ެގުމަކްނަކ ާވިއަފާޅަހަށުހ ްނުށަދ ެގުޢޫރްޝަމ ިމ

ްނުބަބަސ ެގުޢޫރްޝަމ ިމ ްނުމުރުކްތަޔާއިރ ްށަމަކްނަކ ާވއި ަފާޅަހަށުހ ްށަމުރުކަޑުކ ުރަސައ ެނާރުކ ްނުމަކްނަކ ެއ ިއާމަކްނަކ

(ްނިއ ްސްކިރްޓެމ) ްނުލަވާތ ާވިއަފާނަމިހ ިއަގުޓޯޕިރ ިމ ްށަމަކުޑޮބ ްއަތުރަސައ ާވްނެގިވެދެއ ެރުވ ްށަރަސައ ޭވެދޭނ ެނާރުކ

ދައްކާތީވެ، މި މަޝްރޫޢު ހުށަހަޅާފައިވާ ގޮތަށް ކުރިއަށް ގެންދިއުން އެންމެ ރަގަޅުކަމަށް ފެނެއެވެ ެ..

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1 Introduction

1.1 Introduction

This EIA report has been prepared in order to meet the requirements of Environmental Protection and Preservation Act of the Maldives (Law No 4/93) to assess environmental impacts due to proposed resort development on Kanbaalifaru; Shaviyani Atoll. Clause 5 of Environmental Protection and Preservation Act (Law No. 4/93) of Maldives states that an Environmental Impact Assessment (EIA) study need to be carried out before implementing any development project which may have potential impacts on the environment. Resort development is an activity prescribed in Schedule D of EIA Regulation among activities that require Environmental Impact Assessment.

This report will look at the justifications for undertaking the proposed project components. Alternatives to proposed components or activities in terms of location, design and environmental considerations would be suggested. A mitigation plan and monitoring program before, during and after the works would also be included. Monitoring would ensure that the proposed activities are undertaken with caution and appropriative care so as to protect and preserve the built environment of the areas in proximity to the site or those areas and environmental aspects affected by the development.

The findings of this report are based on qualitative and quantitative assessments undertaken during site visits from 1 to 3 April 2014 and 24-26 July 2014 as well as professional judgment. Data and information presented in the project concept documents have been relied upon in order to understand and present the project. The impact assessment methodology has been restricted to field data collected, professional judgment and experience of similar settings and projects across the Maldives and elsewhere. Long term data relevant to this report on specific aspects such as meteorology and climate were gathered from secondary sources and published reports on the Maldives. Since several projects of this sort have been undertaken in the past, documents and experiences from these projects by the Consultants such as the resort development project on Lh. Hudhufushi, GA. Maareha and HA. Berinmadhoo have been taken into consideration. Similar works undertaken by other consultants have also been reviewed including previous EIA for Kanbaalifaru undertaken by Water Solutions in 2008.

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1.2 Background to the EIA

This EIA is prepared in accordance with the Terms of Reference (TOR) approved by the Environmental Protection Agency (EPA) on 11 June 2014. It is a legal requirement that new projects having potential for environmental impacts gain environmental clearance or approval prior to construction and operation of such projects.

The principal environmental institution that implements EIA process in the country is Environmental Protection Agency. Additionally, the Ministry of Environment and Energy provides policy guidance and directions while Atoll Councils and Island Councils also provide approvals before projects are implemented.

1.3 Scope of the EIA and Approach

The main scope of this EIA report as per the approved TOR is to broadly assess, identify, predict and document potential environmental impacts from the proposed resort development project. Hence importance is given to document the whole project proposal in detail, identify the main environmental impacts that are associated with the proposed development and address the legal requirements that need to be taken into consideration while implementing this project. This document also addresses the existing environmental condition of the island and foresees the ways in which potential environmental impacts will be managed, mitigated and reduced.

Hence the key aims of the report are to;  Describe in detail the proposed project;  Identify the need and justification for the proposed development;  Describe the biophysical status of the existing environmental condition of the island based on the findings undertaken during the site visits;  Assess, identify and predict potential environmental impacts of the proposed development;  Evaluate the significance and magnitude of impacts that will be generated; and identify and predict ways in which these environmental impacts will be prevented and removed through appropriate environmental management and mitigation measures;

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 Develop a mechanism to closely monitor and understand the long-term effects and changes of the proposed development on the environment with respect to the available baseline information, mostly collected from field assessments and site visits;  Provide legal protection with regards to the proposed development activities; and  Review the predictions and assessments made on environmental impacts that are associated with the proposed development activities.

In general, the EIA report has been based upon the following sources of information:  Review of available Project documentation;  Discussions with involved key personnel;  Site visits to the island;  Baseline environmental assessments;  Maldives Environmental Protection and Preservation Act No. 4/93;  Regulation on Environmental Impact Assessment of 2007  Other Environmental Regulations  Maldives National Development Framework  Sandcays’ previous experience of undertaking EIAs for projects in the Maldives; and  Other EIAs for similar development projects that have been carried out in the Maldives.

1.4 Relevant Studies

In order to prepare this EIA, relevant EIA reports for resort development projects, in which the project consultants have been recently involved as well as those in the vicinity of the project site in which the EIA consultants have been involved have been carefully studied. These include;  Environmental Impact Assessment (EIA) for proposed resort development on HA. Berinmadhoo  EIA for proposed resort development on Lh. Hudhufushi (Sandcays 2013)  EIA for proposed resort development project in G.A. Maareha (Zahid 2012)  EIA for proposed resort development project in G.A. Maareha (Sandcays 2014)  EIA for proposed resort development on Sh. Kanbaalifaru (Water Solutions 2008)  EIA for coastal modifications at HA. Alidhoo (Zahid, et al 2005)

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Some EIAs by other consultants for recent resort projects undertaken in the north have also been studied.  EIA for the proposed resort development on K. Gusfinolhu (CDE 2014)  EIA for the proposed resort development on K. Thanburudhoo (Aleem 2014)  EIA for the redevelopment of HA. Dhonakulhi (Aleem and Jameel 2011)  EIA for Resort Development Project at Fushivelavaru, (Zahir 2011)

1.5 EIA Implementation and Methodologies

This study was based mainly on data collected during field investigation missions from 1-3 April 2014 and late July 2014 by a team from Sandcays Pvt. Ltd. The EIA report was compiled by Ahmed Zahid, who is a registered EIA consultant with over 16 years of experience who has been involved in numerous resort development project projects in the Maldives. He was assisted by Hussain Fizah, a graduate in Environmental Science, who has been involved in all the EIAs carried out by Sandcays since 2012 and Mohamed Ibrahim Jaleel, who is a third year under graduate student in Environmental Management working as a Research assistant for Sandcays. Trained environmental surveyors at Sandcays namely Mohamed Shifaf, Mohamed Riyaz and Mohamed Shafiu were involved in the baseline surveys.

Established and widely accepted methods have been applied in this EIA study. Field studies have been undertaken using methods generally employed for EIA studies in the Maldives. The field assessment methodologies are briefly described in Section 5.2 of this report.

The methods used to identify, predict and assess impacts are based on matrices that have been established by the Consultants over a long period. In the matrix, the consultants assign a likert-scale number to represent the magnitude, significance, duration and spatial extent of the potential impact for each project activity against the key environmental and socio-economic components that the specific project activity may have an impact on. The product of the magnitude, significance, duration and spatial extent for each activity and component is summed up to measure the exact nature of the impacts by each activity and the overall impact of the proposed project is the sum of all activities.

The Terms of Reference (TOR) for this EIA has been attached as Appendix 1. This EIA has been prepared based on this term of reference.

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2 Legislative and Regulatory Considerations

This section will identify the pertinent legislation, regulations and standards, and environmental policies that are relevant and applicable to the proposed project, and identify the appropriate authority jurisdictions that will specifically apply to the project. The proposed project is expected to conform to all of the policy and regulatory aspects outlined here. This section outlines and summarizes key policies, applicable laws and regulations and regulatory bodies regarding environmental protection and tourism in the Maldives. Also, it outlines some international and regional obligations that the country has to meet in terms of sustainable development and environmental management.

The proposed project will be subject to the key regulations including Environmental Protection and Preservation Act (No. 4/93) of Maldives. Thus, it must satisfy the EIA process and get approval before the project starts implementation. Resort development on Kanbaalifaru will conform to existing tourism related regulations in Maldives.

2.1 Policy Guidance

The policy guidance on the development of the proposed project is taken from a number of policy documents prepared by the Government of Maldives on sectoral developments. Key documents outlined in this EIA are currently being implemented towards sustainable development of the country.

2.1.1 National Framework for Development 2009‐ 2013

One of the most important environmental policy guidance is given in the Strategic Action Plan (SAP) of the National Development Framework for 2009-2013. Due to the fragile nature of the country’s environment, all the development activities must ensure that appropriate care is taken to protect the environment. Environmental sustainability is the basis for socio- economic development, hence, the SAP outlines the key environmental policies that will be implemented in the country for environmental protection and sustainability, while one of the key environmental goals of the country is to protect and preserve the natural environment to ensure prosperous economic development. The environmental policies outlined in the SAP include;

Policy 1: Strengthen EIA process with an emphasis on EIA monitoring.

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Policy 2: Conserve and sustainably use biological diversity and ensure maximum ecosystem benefits.

Policy 3: Develop resilient communities addressing impacts of climate change, disaster mitigation and coastal protection.

Policy 4: Strengthen adaptation and mitigation responses for beach erosion and develop a system to assist communities where livelihood and property are affected by beach erosion.

Policy 5: Ensure management of solid waste to prevent impact on human health and environment through approaches that are economically viable and locally appropriate.

Policy 6: Ensure protection of people and the environment from hazardous waste and chemicals.

Policy 7: Improve air quality to safeguard human health.

Policy 8: Enable a fully functional decentralized environmental governance system.

Policy 9: Develop a low carbon economy to achieve Carbon Neutrality by 2019.

Policy 10: Inculcate environmental values in the society and enable environmentally friendly lifestyle.

The Ministry of Environment and Environmental Protection Agency takes the lead role in implementing the above national policies through various strategies and regulatory measures.

2.1.2 Third National Environment Action Plan

NEAP 3 sets out the agenda for environmental protection and management in the Maldives for the five year period 2009-2013. This plan is targeted to achieve measurable environmental results that matter to the people of the Maldives.

The aim of developing NEAP 3 is to protect and preserve country’s environment and properly manage natural resources for sustainable development of the country and encompasses ten principles, six strategic results with targeted goals to be achieved under each result.

The key principles of the NEAP 3 are:

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Principle 1: Environmental protection is the responsibility of every individual

Principle 2: Achieve results

Principle 3: Promote and practice sustainable development

Principle 4: Ensure local democracy

Principle 5: Inter-sectoral co-ordination and co-operation

Principle 6: Informed decision making

Principle 7: Precaution first

Principle 8: Continuous learning and improvement

Principle 9: Right to information and participation

Principle 10: Environmental protection complements development

The six strategic results of NEAP3 are: resilient islands; rich ecosystems; healthy communities; safe water; environmental stewardship; and a carbon neutral nation with 30 result oriented environmental goals that will be achieved in the span of the NEAP 3.

2.1.3 Maldives National Strategy for Sustainable Development 2009‐ 2013

The Maldives National Strategy for Sustainable Development (NSSD) outlines the key objectives, principles and goals that the country will embark toward achieving sustainable development. Hence, the overall direction of the NSSD is to build a nation which appreciates the true value of the natural environment, utilizes its natural resources in a sustainable manner for national development, conserves its limited natural resources, has built the capacity to learn about its natural environment and leaves a healthy natural environment for future generations.

The guiding principles outlined in the NSSD are:

Principle 1: Promotion and protection of fundamental human rights

Principle 2: Equity within and between generations

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Principle 3: Democratic and open society

Principle 4: Full participation of businesses and civil society

Principle 5: Policy coherence and coordination

Principle 6: Use best available knowledge

Principle 7: Precaution first

Principle 8: Make polluters pay

While the country will be steered in accordance with the underlying principles of NSSD, the country aims to achieve very important environmental goals, including; adapting to climate change, protecting coral reefs, achieving carbon-neutrality in energy, ensuring food security, establishing a carbon neutral transport system, protecting public health and achieving full employment and ensuring social security.

2.1.4 National Biodiversity Strategy and Action Plan

The goals of the National Biodiversity Strategy and Action Plan are:

 Conserve biological diversity and sustainably utilize biological resources.

 Build capacity for biodiversity conservation through a strong governance framework, and improved knowledge and understanding.

 Foster community participation, ownership and support for biodiversity conservation.

In implementing the proposed project activities due to care has to be given to ensure that the national biodiversity strategies are adhered to.

2.1.5 Waste Management Policy 2007

As waste management has been identified as a key environmental issue in the Maldives, a National Solid Waste Management Policy for the Maldives was developed in 2007 as an important step towards mainstreaming waste management in the country. The key strategic principles outlined in the document include; establishing polluter pay principles, integrated solid waste management, best practice environmental option (BPEO), best available

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 8 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru technology not entailing excessive costs (BATNEEC), proximity principle and private sector participation. It is an important priority of the Government of Maldives as identified in the policy document to setup regional waste management facilities and island waste management centres and decentralizing waste management administration. Hence, the key policies relevant to this project include;

Policy 1: Establish a governance structure for solid waste management which will distribute clearly delineated roles and responsibilities for solid waste management at island, regional and national levels

Policy 2: All waste producers have a duty to manage the waste they generate

Policy 3: Waste will be management and disposed as close as possible to the place of their generation

Policy 8: Private sector participation (PSP) will be facilitated where it is financially for both government and private sector.

Establishing a proper mechanism of waste management and disposal will be vital for the overall operation of the project and the waste management practices both during construction and operation of the project will closely adhere to the policies and principles taken as a priority of the government.

2.2 Regulatory Bodies

2.2.1 Ministry of Environment and Energy

The primary environmental institution in the Maldives is Ministry of Environment and Energy (MEE). It is mandated with formulating policies, strategies, laws and regulations concerning environmental management, protection, conservation and sustainable development. The Minister of Environment or a designate gives the environmental approval or clearance to EIA by an Environmental Decision Statement. Additionally, MEE is responsible for formulating relevant laws and regulations, policies and strategies concerning energy, water and sanitation, waste and infrastructure.

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2.2.2 Environmental Protection Agency (EPA)

EPA is the key regulatory body on environment, which is an autonomous body formed under the umbrella of MHE. It is mandated with implementing the EIA process in the Maldives, implementing the Environment Act and subsequent regulations on behalf of MHE, regulating water and sanitation, biodiversity conservation, waste management and coastal zone management. Also, it is responsible for developing environmental standards and guidelines in the country.

2.2.3 Ministry of Tourism, Arts and Culture

For this project, the Ministry of Tourism is the mediator between the Government and the Proponent. All communications including the EIA report shall be submitted through the Ministry of Tourism. The Ministry also has its own regulations and environmental standards for tourist establishments, which shall be strictly adhered to. Therefore, the Ministry will also monitor the environmental impacts of the development in collaboration with the EPA and the Atoll Council.

2.2.4 Atoll/City Councils and Island Councils

Under the Maldives Decentralization Law, elected Atoll Councils, City Councils and Island Councils have been formed as regulatory bodies dealing directly with atoll, cities and island issues. In this regard, some of the development projects are subject to approval of these councils through a public consultation process. For the proposed project, EPA requires that a copy of the final draft of the EIA Report be submitted to Atoll Council and receipt provided to EPA or attached to the EIA report.

2.3 Laws and Regulations

There are a number of laws and regulations relating to environment in the country. Only relevant laws and regulations have been outlined in this section.

2.3.1 Environmental Protection and Preservation Act

The Environmental Protection and Preservation Act of the Maldives, EPPA (Law No. 4/93) provides the basic framework for environmental management including Environmental

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Impact Assessment (EIA) process in the Maldives, which is currently being implemented by EPA on behalf of MHE.

Clause 2 of the EPPA mandates the Ministry of Environment to formulate policies, rules and regulations regarding the environment.

Clause 5 of this Act specifically provides for environmental impact assessment (EIA), a tool implemented to attempt to integrate environmental issues into development decisions. According to the Clause, environmental impact assessments are a mandatory requirement for all economic development projects.

Clause 6 of the EPPA gives the Ministry of Environment the authority to terminate any project that has an undesirable impact on the environment.

Clause 7 of the EPPA refers to the disposal of oil, wastes and poisonous substances in to the Maldivian territory. According to this clause, any type of waste, oil, toxic gas or any substance that may have harmful effects on the environment should not be disposed within the Maldivian territory. If, however, the disposals of such substances become absolutely necessary, the clause states that they should be disposed only within the areas designated for that purpose and if incinerated, appropriate precautions should be taken to avoid harm to the health of the population.

Furthermore, clause 9 sets a fine between five and five hundred Rufiyaa for minor offenses in breach of this law and a fine of not more than one hundred million Rufiyaa for major offenses. The fine shall be levied by the Ministry of Environment or by other government authorities designated by that Ministry in case of minor offenses.

Finally, Clause 10 of EPPA gives the government of the Maldives the right to claim compensation for all damages caused by activities that are detrimental to the environment.

The Environmental Act or Law 4/93 is the single most important legal instrument with regards to environmental management and it gives very high prominence towards safeguarding the environment with regard to all the development activities. Under this Act, the Ministry of Environment has developed regulations and guidelines concerning environmental protection through the implementation of EIA procedures.

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2.3.2 Environmental Impact Assessment Regulation 2012

The EIA Regulation, which came into force in 2007, has been recently revised and the revised EIA Regulation 2012 is currently in force since May 2012. This EIA is subjected to the EIA Regulations 2012.

The EIA Regulation 2012 is currently only in Dhivehi and an official translation is awaited. The Regulation sets out the criteria to determine whether a development proposal is likely to significantly affect the environment and is therefore subject to an EIA. Schedule D of the EIA Regulations defines the type of projects that would be subject to Environmental Impact Assessment. Resort development is among those.

The main purpose of this Regulation is to provide step-by-step guidance for proponents, consultants, government agencies and general public on how to obtain approval in the form of an Environmental Decision Statement.

2.3.3 Land Act

The Articles of the Maldivian Land Act (Law No. 1/2002) addresses the following aspects of land issuing, receiving, owning, selling, leasing, utilizing and using Maldivian land, which is relevant, understood and adhered to in the proposed project.

Policies concerning Maldivian land shall be decided by the President of the Maldives on the advice of the discussions in the Ministers Cabinet

In compliance with the land policies stated in subsection (a) of this section the President of the Maldives shall for different purposes and uses allocate land and change the allocation from one to another.

In accordance with section 3 of this Act, land shall be allocated for the following purposes and uses:  For residential purposes  For commercial use.  For social use  For environmental protection  For institutional use.

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The Ministry of Home Affairs, Housing and Environment (now the Ministry of Housing and Infrastructure) shall entrust the land allocated for different purposes and uses in accordance with sections 3 and 4 of this Act to the concerned Ministries.

The Ministry shall in accordance with the provisions stated in this Act, maintain written records of land in the Maldives.

The following data should be recorded:  The way in which land has been allocated for different purposes and uses in accordance with sections 3 and 4 of this Act  The location and size of the land  In accordance to section 5 of this Act, the Ministry to which land was transferred to and the purposes and date of transfer  Private dwellings, private lands and the owners of the aforesaid lands.

The Ministries entrusted with land in accordance to section 4 of this Act shall allocate the land, lease or transact any business in regard to the land only in accordance with this Act and any other Acts in force regarding the allocation of land for different purposes and uses.

2.3.4 Maldives Tourism Act

The Articles of the Maldives Tourism Act (Law No. 2/99) provides for the determination of zones and islands for the development of tourism in the Maldives: the leasing of islands for development as tourist resorts, the leasing of land for development as tourist hotels and tourist guesthouses, the leasing of places for development as marinas, the management of all such facilities; and the operation of tourist vessels, diving centers and travel agencies, and the regulation of persons providing such services., which are relevant, understood and adhered to in the proposed project.

The leasing of islands and land for development as tourist resorts and tourist hotels, the leasing of places for development as marinas, the management of tourist resorts, tourist hotels, establishments such as tourist guest houses and marinas; and the operation of tourist vessels, shall all be in accordance with this Act and regulations made under it.

Zones for the development of tourism in the Maldives, islands for development as tourist resorts and places for development as marinas shall be determined by the President.

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2.3.4.1 Tourist Resorts

License to operate tourist resort

 Every resort developed on an island or land leased in accordance with section 5 of this Act shall be operated after registering the same at the Ministry of Tourism and after obtaining a license issued by the Ministry of Tourism to operate a tourist resort.

 A license to operate a tourist resort shall be issued in respect of establishments that satisfy the following conditions:

o The construction [of the tourist resort] is completed in accordance with guidelines determined by the Ministry of Tourism; and

o The services determined by the Ministry of Tourism to be necessary at such establishments are made available at the tourist resort.

Felling of coconut palms and trees, dredging of lagoon and carrying out such activities

 Felling of coconut palms and trees on an island or land leased for development as a tourist resort, dredging of the lagoon of such an island, reclamation of land, or any other activity determined by the Ministry of Tourism as may be likely to cause a permanent change to the [natural] environment of such places, may only be carried out after obtaining written permission from that Ministry and in accordance with relevant regulations made by it.

 Any application pursuant to subsection (a) of this section for permission of the Ministry of Tourism to carry out dredging of the lagoon of an island or reclamation of land or any other activity that may cause a permanent change to the [natural] environment of such a place shall contain the following:

o evidence that the proposed change is fundamental for the provision of services from such a place, and

o an environmental impact assessment report submitted to and approved by the Ministry of Home Affairs, Housing and Environment ( Ministry of Environment and Energy)

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2.3.5 Regulation on the Protection and Conservation of Environment in the Tourism Industry

This regulation was made pursuant to the Maldives Tourism Act. The regulation mandates the standards for the protection and conservation of environment in the tourism industry of the Maldives, which are relevant, understood and adhered to in the proposed project. The purpose of this regulation is to protect the environment in the tourism industry and to encourage and facilitate sustainable development of tourism.

In this regulation, unless the context otherwise requires, “tourism industry” means any island leased for the development and operation of a tourist resort, tourist hotel, tourist guest house, yacht marina, and islands leased under the Maldives Uninhabited Islands Act (Law No. 20/98) and all other places and facilities registered under Ministry of Tourism for the provision of service to tourists.

In this regulation, unless the context otherwise requires, “property leased for the purpose of tourism” means islands leased for the development and operation of a tourist resort, tourist hotels, tourist guest houses, yacht marinas, and islands leased under the Maldives Uninhabited Islands Act (Law No. 20/98).

2.3.5.1 Protection of environment during construction

Any of the following activity in an island or place leased for the purpose of tourism shall be carried out after obtaining permission from the Ministry of Tourism:  Dredging of the lagoon and reclamation of land  Construction on the beach and lagoon  Beach enhancement by pumping sand  Construction of breakwater  Construction of sea wall, revetment or groyne  Dredging of lagoon or reef for safe access  Dredging of reef  Felling of trees  Importing and exporting living species  Conducting research of land, sea and lagoon  Demolition of a building or facility  Anything which may adversely affect the vegetation or fresh water lens of the island

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In addition to the provisions of clause 2.1 above, any activity that may cause damage or adversely affect the environment shall be carried out after obtaining permission from the Ministry of Tourism.

Trees shall not be felled in order to construct buildings or for other purpose in an island, resort, or other place leased for the purpose of tourism, except with prior written permission from the Ministry of Tourism.

In the event any tree or coconut palm is felled for construction or any other reason in any resort, Picnic Island, or marina or such other place leased for the purpose of tourism, two trees or coconut palms shall be replanted in the same island.

Ground water shall not be extracted for the purpose of construction in an island or land leased for the development of tourism

Any infrastructure or facility in an island or land leased for the development of tourism shall be built five meters inwards from the vegetation line

In order to preserve and maintain the natural environment of islands or part of it leased for purpose of tourism, at least 80% of the island shall be spared un-built. The area inwards from the vegetation line shall be taken as the area of the island. If the relevant area is a designated part of an island, the area inwards from the vegetation line of that area shall be taken. However this percentage was later amended to 70%.

It is prohibited to extract coral stones from any part of the lagoon or the reef of an island in the Maldives, for any purpose of an island leased for the development of tourism

In an island or land leased for the development of tourism, all jetties built in all resorts, picnic islands, marinas or other islands shall be built in such a way that allows free movement of water current and sand beneath the jetty.

2.3.5.2 Planting of Trees, use of fertilizers and keeping living species

Written permission and instructions shall be obtained from the Ministry of Tourism prior to carrying out any of the following in any island or land leased for tourism purpose:  Felling of tress for various purposes.  Importing and exporting of living species

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2.3.5.3 Waste Management

Waste disposal in tourist resorts, picnic islands, and marinas operating in the Maldives shall be carried out in a manner that would have the least impact on the environment, and in accordance with the laws and regulations and in accordance with the rules prescribed by the Ministry of Tourism.

2.3.5.4 Storage of Water

For the purpose of provision of clean and safe water sufficient for use in the resort, every resort shall have a desalination plant. The plant shall be registered with Maldives Water and Sanitation Authority in accordance with the “Regulation on Desalination Plants”, and shall comply with such regulation in the operation of the desalination plant.

2.3.5.5 Sewage and Wastewater Treatment

Sewage shall be disposed in a manner that would have the least impact on the environment, and in accordance with the laws and regulations and in accordance with the rules prescribed by the Ministry of Tourism.

2.3.5.6 Penalty

If any provision of this regulation is contravened by any tourist resort, picnic island, marina, hotel, guest house, or tourist vessel, shall be guilty of an offence, and shall be liable to a fine, taking into consideration the seriousness of the non-compliance, between MRF 1000.00 and MRF 10,000.00 in the first instance. Parties repeatedly in non-compliance shall be liable to a fine between MRF 50,000.00 and MRF 100,000.00 If non-compliance of a provision occurs more than once, the Ministry reserves the right to revoke the license.

2.3.6 Maldives Recreational Diving Regulation

This Regulation deals with the recreational diving in the Maldives. During the operational phase of the project, what is relevant will be understood and adhered to.

2.3.6.1 Environment Protection

As responsible divers, reasonable care should be taken to protect the marine environment, its associated living organisms and their habitats. Divers should be briefed by the dive instructor

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Activities that are detrimental to marine protected areas and protected species and their habitats are prohibited under the Environment Protection & Preservation Act (Act No. 4/93) of Maldives. Marine Protected Areas are living marine aquariums. “Look but don’t touch” is the message in these areas, and ONLY permitted activities can take place. Protected areas, as their name suggests, are there to protect typical areas of the coral reef system, and its resident fish and other animals, in as near to a pristine condition as possible.

Permit to dive in marine protected areas may be required. Please check before you venture.

2.3.6.2 Damage Due to Anchoring

Dive boats are not allowed to anchor on dive sites. Drift boat diving is the norm in Maldives. Boat anchors destroy fish habitats especially corals and even sea‐grass beds. If anchoring is required for any reason prevents reef damage by anchoring in sandy areas or using mooring buoys.

2.3.6.3 Diving in Bait Areas

Bait is an important activity for the traditional pole and line tuna fishery in the Maldives. Hence, occasionally divers may encounter collecting bait. In order to reduce conflict between local fishermen, diving should be avoided in the same area whilst fishermen are engaged in bait fishing. Any such conflicts should be reported to the Ministry of tourism through the responsible dive center as soon as possible. Dive centers should also keep divers informed of these traditional economic activities in the country.

2.3.6.4 Protection of Underwater cultural Monuments

Nothing should be taken out from the sea, and particularly this prohibition refers to cultural monuments. Please contact the National Centre for Linguistics & Historical Research and the Ministry of Finance & Treasury should you find any.

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Damaging and extracting cultural monuments is prohibited, as well as taking the same abroad. Underwater archaeological researches may be performed only with permits issued by the Maldivian government authorities, and the procedure is NOT covered under these regulations.

2.3.7 Regulation on Uprooting, Cutting and Transportation of Palms and Trees

The Regulation on cutting down, uprooting, digging out and export of trees and palms from one island to another was issued by the Ministry of Environment in 2006. The primary purpose of the Regulation is to control and regulate large-scale uprooting, removal, cutting and transportation of palms and trees from one island to another. According to the regulation, certain types of trees and plants that have unique attributes are prohibited to be removed from its natural environment.

Clause 5 (a) of the Regulation states that prior to the commencement of any project(s) that would require the indiscriminate removal and transplanting of trees/palms from one island to another for the purpose of agriculture, development/redevelopment, construction or any other purpose, it is mandatory under the Regulation to prepare an Environmental Impact Assessment report.

Article 8 (a) requires permission be obtained from Ministry of Environment, if more than 10 coconut palms that are of a six of 15ft (from base of the palm to the tip of the palm frond) are cut, uprooted or relocated to another island. The regulation also ensures the replacement of the vegetation that is lost by imposing the planting of two palms for every palm tree that is cut or uprooted (Article 2 (d)). Logging on inhabited islands must be done under supervision of the islands chief or an official appointed by the island chief (now Island Council) (Article 8 (c)).

This regulation also provides particular protection to the following:  coastal vegetation extending 15 meters into the island;  all trees and palms growing in and within 15m around mangrove and wetland areas;  all trees and palms growing in protected areas; and  trees and palms that are unique in shape, structure or character

The proposed project does not directly involve indiscrete removal of trees, however, would require extensive landscaping, for which reason this regulation is of importance.

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2.3.8 Desalination Regulation

Desalination Regulation (2002) states that all sea water desalination plants installed and intended to supply water to 200 or more people or large scale agricultural needs or tourism related activity need to be registered prior to the operation of the plant. Therefore, it would be necessary to consider the impacts of desalination plant in this EIA so that registration can be done without further environmental scrutiny. Desalination plant registration is required to be renewed every five years. Therefore, regular monitoring shall be ensured in order to carry out an efficient renewal process.

2.3.9 Dredging and Reclamation Regulations

The Dredging and Reclamation Regulations was gazetted on 2 April 2013 as Regulation No. 2013/R-15. This regulation is currently in Dhivehi and an English translation is awaited. Clause 6 of the Regulation requires applying for approval under this Regulation by submitting the project details, land use plan, project justification and scaled maps of existing site plan and site plan with proposed project components. The EIA process can be commenced once EPA approves the application under this Regulation.

Clause 7 provides the conditions for dredging, clause 8 for reclamation and clause 9 for beach nourishment or beach enhancement. Clause 9 is of specific relevance to beach nourishment projects. Clause 9(a) states that beach nourishment shall be done up to 10m from the registered shoreline. Clause 9(b) identifies that sand for beach nourishment shall be taken from an area (borrow area) that is not prohibited under clause 13 of the Dredging and Reclamation Regulation. Clause 13(c) states that borrowing material from the following areas are prohibited.

1. 100m shore-wards from the reef line

2. 500m seawards from the reef line

3. 50m from the vegetation line

4. Protected Area or Environmentally Sensitive Areas (ESA) identified under Law No. 4/93 (Environmental Protection and Preservation Act of the Maldives).

Clause 13(d) restricts to borrow material or dredge or reclaim within 200m of a Protected Area or ESA identified in 4 of Clause 13(c). Clause 13(e) states that those areas or islands where the reef extent (distance from shore to reef edge) is less than 300m, dredging and

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 20 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru reclamation may be done in consultation with the EPA. Clause 13(f) gives the EPA the authority to restrict borrowing sand from those locations from which dredging or borrowing sand has been approved earlier, if the EPA finds that the area is environmentally significant or worthy of protection or preservation. Clause 14 identifies the options for disposal of dredge material which include land reclamation, construction, levelling of land, shore protection and other activities approved under the EIA process or EIA Regulations. Clause 14 also states that land levelling shall be done with minimal disturbance to wetland areas. Clauses 15 and 16 provide the details of area (size) that can be dredged and reclaimed respectively. Clause 17 requires that a scaled as-built drawing indicating the new shape and size of the island upon completion of reclamation shall be submitted to the EPA. Clause 18 gives the EPA the right to terminate a project that has been seen to cause significant environmental damage and to claim compensation under the Regulation on Environmental Liability (2011/R-9). Clause 19 further reinstates the compensation claims under the Regulation on Environmental Liability.

Clause 10 is of relevance to projects approved by the Government. As per Clause 10, all the development projects approved by the government in inhabited islands are exempted from rest of the regulation except for Clause 6 (Clause 6 says proponent should obtain approval from EPA for dredging and reclamation components before EIA process could begin.

This project does not involve dredging and reclamation at the present, however, beach nourishment shall be done with approval under this regulation.

2.3.10 Regulation on Environmental Damage Liabilities

Under the Environmental Protection and Preservation Act (No. 4/93), the Ministry of Environment formulated the Environmental Damage Liabilities Regulation in February 2011, which encompasses the basis to avoid environmental deterioration, extinction of biological resources, environmental degradation and avoid wastage of natural resources. The main purpose of this regulation is to stop unlawful activities on environment and adequately implement a fining procedure for violations as well as implement a compensation mechanism on environmental damages. Its Schedules form the basis for levying fines on various environmental components and activities. Hence, the proposed project will be subject to this Regulation for any activity outside of the EIA scope and Environmental decision Statement.

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2.3.11 Waste management regulation

The Waste Management Regulation (Regulation No. 2013/R-58) came into effect in August 2013. The objective of Waste Management Regulation is to implement the National Waste Management Policy; through which it aims to protect the environment by minimizing the impact of waste on the environment, including the impact of waste on human health, establishing an integrated framework for minimizing and managing waste in a sustainable manner and establishing uniform measures to reduce the amount of waste generated. The regulation also ensures waste is reused, recycled and recovered in an environmentally sound manner before being safely treated and disposed. The regulation covers the management of general, hazardous and special waste. Wastes arising from paints and chemical solvents are considered as special waste.

Clause 7 of the regulation requires the preparation of Waste Management Plans for specific sectors or areas. Clause 7(c) requires that City and Island Councils prepare their own Waste Management Plans for EPA approval. Clause 8 is for hazardous waste management and clause 9 for special waste management. The types of hazardous waste considered under clause 8 are given in Appendix J of the Regulation.

Clause 10 is about extended producer responsibility and Clause 11 requires that waste shall be disposed in approved locations only. Clause 11(b) states the areas where waste should not be disposed at all including roads, parks, beaches, lagoon, reef, and so on. Clause 11 (c) (d) states the situations that exempt the enforcement of the regulation including situations where human life is at risk and natural disasters or national security threats. Clause 11(e) states that waste management at household level would not require any permits under the regulation. Clause 12 states the provisions for managing waste in public places; that appropriate bins be placed in appropriate locations with appropriate labels distinguishing different kinds of waste and that those bins shall be emptied periodically in an appropriate manner to avoid nuisances of any sort.

Clause 13 is for waste management on sea-going vessels. Clause 14 is for waste management at harbors or ports. Clause 15 is for recycling and recovery of waste.

Clause 16 to 23 deals with waste management permits including the standards to be adhered by licensed parties, renewing licenses, types of licenses, renewal and change of licensee,

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Clause 25 to 28 lists the provisions for waste transport. Clause 29 talks about the responsibilities of the licensed parties. Clause 30 requires that administrative records including fines shall be maintained by the EPA. Clause 31 gives the EPA the authority to check/monitor the activities of the licensed parties. Clause 32 and 33 are also about data collection and reporting.

Clause 34 discusses the actions to be taken in case of non-compliance. Clause 35 sets the conditions for cancellation of license. Appendix M of the regulation states the different fines that will be levied upon non-compliance.

This regulation was effective from 6 January 2014 and EPA would be responsible for the implementation this regulation. This regulation would be adhere to in managing waste arising due to the proposed project.

2.3.12 The Borehole Guidelines

Borehole Drilling Technical Specifications and Guidelines were issued by EPA dated 25 September 2011. The Guidelines covers drilling of boreholes and installation of electric pumps for source water extraction for various water supply development projects. The Guidelines state that boreholes shall be drilled at the location(s) designated by the client in consultation with Environmental Consultant and Environmental Protection Agency (EPA). It is also stated that care must be taken in handling and storage of all drilling fluids, oils, greases and fuel on site, to avoid any environmental pollution, damage and degradation. Any toxic materials, drilling fluids and other additives, cuttings and discharged water shall be disposed in a manner that do not cause damage to the environment, public and private property.

According to the Guidelines, the in-land borehole depth shall be more than 30m even if the electrical conductivity of discharge water has reached 50-60mS/cm before reaching 30m depth. If electrical conductivity of discharge water at 30m depth is measured less than 50- 60mS/cm, drilling shall continue until electrical conductivity reaches to 50-60mS/cm. This aspect of the Guidelines has raised concerns especially with reference to boreholes at the periphery of the island where, according to renowned hydro-geologists, the freshwater lens

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The Guidelines also provide guidelines for the different records that ought to be made during the drilling process. For monitoring purpose, boreholes drilled shall provide water sampling tubes at the interval of 5m from top to bottom. Water quality testing that may be necessary to be performed upon completion of the borehole has also been indicated in the Guidelines.

This guideline would be respected since desalination is considered for the project and borehole is the preferred option for feedwater.

2.3.13 Powerhouse Registration Guidelines

Guidelines for the registration of powerhouses have been issued by the Maldives Energy Authority recently. According to these Guidelines, all power plants need to be registered and environmental clearance is required prior to registration. Therefore, this EIA will look at the environmental aspects of power generation proposed for Kanbaalifaru resort in order to assist the powerhouse registration process.

2.4 International and Regional Context

2.4.1 Environment Sector

The major global issue facing the Maldives is climate change, global warming and subsequent sea-level rise. The small size of the islands and their low elevation above MSL makes possible impacts of it very seriously. Consequently, the country plays a prominent role in fore-fronting environmental issues faced by many other small islands developing states including the Maldives in the international arena. The Maldives is therefore, a party and signatory to various international conventions and declarations. These include;  UN Convention on the Law of the Sea – UNCLOS (1982)  International Convention for the Prevention of Pollution of the Sea by Oil (1982)  Vienna Convention for the Protection of the Ozone Layer (1985)  Montreal Protocol on Substances that Deplete the Ozone Layer (1987)  Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal (1989)

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 The London Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer (1990)  Agenda 21 and the Rio Declaration of the United Nations Conference on Environment and Development (1992)  Convention on Biological Diversity (1992)  United Nations Framework Convention on Climate Change (1992)  The Copenhagen Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer (1992)  The Montreal Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer (1997)  The Beijing Amendment to the Montreal Protocol on Substances that Deplete the Ozone Layer (1999)  Washington Declaration on Protection of the Marine Environment from Land-Based Activities  Kyoto Protocol to the United Nations Framework Convention on Climate Change (1998)  Cartagena Protocol on Biosafety (Maldives acceded on 2 September 2002)  United Nation Convention to Combat Desertification (2002)

The Maldives is also a key player in formulating and adopting various regional plans and programs to protect the environment by continuously participating in various activities organized by regional bodies such as SACEP, ESCAP and SAARC. As a result the Maldives is committed to the following;  SAARC Environment Action Plan adopted in 1997 in Malé  SAARC Study on Greenhouse Effect and its Impact on the Region  South Asian Regional Seas Action Plan and Resolutions concerning its implementation (1994)  SAARC Study on Causes and Consequences of Natural Disasters, and  South Asian Seas Program initiated by SACEP  Malé Declaration on Control and Prevention of Air Pollution and its likely Transboundary Effects for South Asia (1998)

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3 Project Description

3.1 Introduction

The purpose of this section is to describe the project in terms of the need and justification of the project, location and boundaries of the project, project schedule, main inputs, project mobilization as well as project construction activities. In addition, this section presents materials and resources that will be used as well as the main output of the project.

3.2 The Proponent

The project to develop the resort is proposed by Kanbaalifaru Development Pvt. Ltd.

The business address of the company is;

Kanbaalifaru Development Pvt. Ltd

1st Floor, M. Fehigiri

Telephone number: (+960) 3008050

Fax number: (+960) 3008051

Email: [email protected]

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3.3 Project Location and Boundaries

Kanbaalifaru is located close to the eastern rim of Shaviyani atoll at 6° 7'26.84"N and 73°15'18.89"E. There are no other islands within the house reef of the island. Closest inhabited island is Firunbaidhoo 3km west of Kanbaalifaru; whereas the atoll capital, Funadhoo sits 4km northeast of the island. Viceroy Maldives on Vagaru island; 6.6km southwest, is the closest operational resort.

Figure 3-1: Location of Kanbaalifaru Shaviyani Atoll

3.4 The Project

The Project involves the development of a modern resort on Kanbaalifaru with the following facilities;  Arrival Jetty & Jetty Head  Water Villa Arrival Point ( 2 units)  Service Jetty  Reception & Admin. Office  Main Restaurant  Main Bar  Disco  Karaoke  Billiard

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 Table Tennis  Gym  Specialty Restaurant  Spa Complex  Dive Center  Medical Clinic  Shops  Beach Bar / Coffee shop 1  Beach Bar / Coffee shop 2  Guest Wash Room  Jungle Grill  Lily Pond  Tennis Court  Basketball Court  Volleyball Court  Football Field  Beach Villas (2 Rooms , 78 units)  Ocean View Villa (1 Rooms, 36 units)  Water Villa (1 Room, 24 units)  Superior Water Villa (1 Room, 18 units)  Amin Building – existing  General Manager Bungalow (2 Rooms)  Junior Staff Accommodations (24 Rooms) -existing  Senior Staff Accommodation A (8 Rooms) - existing  Senior Staff Accommodations B (12 Rooms) – existing  Junior Executive Staff Quarters (12-Rooms)  Senior Executive Staff Quarters (4-Rooms)  Staff Mess And Kitchen, Staff Recreation, Shop –existing  Laundry and Housekeeping –existing  Main Store  Powerhouse and Water Desalination Plant  Mosque

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 Staff Recreation – existing  Water Tower  Fuel Farm  Sewage Treatment Plant

3.4.1 Accommodation

At Kanbaalifaru Resort accommodation would be categorized into four types. There would be a total of 156 villas;  78x2-Room Beach Villas (312 beds)  36x1-Room Ocean View Villas (72 beds)  24x1-Room Water Villas (48 beds)  18x1-Room Superior Water Villas (36 beds)  The facilities and services for each of these types would vary. In addition to these tourist accommodations, there will be two staff quarters that is one for juniors and one for seniors.

3.4.2 Food

Kanbaalifaru Resort would have five main food outlets – The Main Restaurant, Specialty Restaurant, Beach Bar / Coffee shop 1, Beach Bar / Coffee shop 2 & Main Bar

The Main Restaurant would be able to cater for 402 guests and would cater mainly to the guests opting for the All-Inclusive Stay Plan. The Kitchen would serve a variety of set meals arranged in buffet style.

3.4.3 Recreation

Kanbaalifaru Resort will have the following sports and recreational facilities:  01 Billiard  01 Table Tennis  01 Karaoke  01 Disco  01 Dive center  02 Volleyball Court  01 Basketball court

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 02 Tennis court  01 Spa complex  01 Gym  01 Jungle Grill  01 Lily Pond

3.4.4 Staff Area

As with any other resort, a dedicated staff area will be present on the resort to serve needs of resort staff. These would include their accommodation blocks, Mosque, recreational facilities and food court.

3.5 Environmentally Significant Activities

The main activities of the resort development that may have impacts on the environment are:  Land clearance (up to 30% of island vegetation);  Jetty construction;  Sand pumping for beach nourishment and construction activities;  Infrastructure construction including power house, water desalination plant, sewerage plant, oil storage tanks, waste management facility and hardware workshop;  Construction and operation of accommodation, restaurants, spa and sports facilities;  Temporary facilities  Utilities including power, water, wastewater, waste and fuel

The following subsections looks at the details of these environmentally sensitive elements of the proposed project.

3.5.1 Land clearance

Clearing of land will occur within about 20% of the total registered land area of the island. However, recently, the cabinet had decided to increase the allowable limit of development on resort islands to 30%. Although this is the case, it is noteworthy that the design of this resort had considered the previously allowed limit, with the total built-up area percentage to be 13.12 (25,670.17 sqm).

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The vegetation clearance will be undertaken with care to minimize removal of mature trees to the greatest possible extent. As has been in the past, areas will not be cleared during stakeout of the buildings and pathways to get the line of sight for stakeout. Instead, state of the art real- time GPS technology will be used to stakeout footprint areas of buildings and pathways. Furthermore, mature trees within the development footprint will be carefully replanted elsewhere. However it should be noted that there are few mature tress on Kanbaalifaru, especially coconut palms and transplantation would be required.

3.5.2 Temporary facilities

Temporary housing of labour will be considered at the onset of the project. In order to minimize the impacts of inter-cultural mixing, priority will be given to employ local labour to the greatest possible extent. Yet, labour camps will be developed in the proposed staff areas. Temporary labour camps will be developed only on actual development footprint areas and other areas would not be cleared for temporary facilities. Temporary facilities will be developed on areas where similar permanent structures such as powerhouse will be located. Therefore, utilities such as powerhouse, fuel tanks, desalination plant and waste management center will be developed at the early stages of the construction of the resort. All constructional waste will be taken to specified area, segregated and sent to landfill upon demobilisation from site. Constructional waste management procedures will be in place.

3.5.3 Desalination Plant

Water supply demand of the proposed resort will be met through seawater desalination using Reverse Osmosis desalination plants of capacity 150m3/day with a backup plant of the same capacity. Rainwater will be collected to supplement desalinated water, especially during the rainy season. Rainwater tapped from staff area roofs would also be treated using UV technology. However, rainwater would be an undependable source and rainwater collection and use would be limited. Groundwater would not be used as per the requirements of the Regulation on the Protection and Conservation of Environment in the Tourism Industry. Also, as per the requirements under the same Regulation, water storage sufficient for 5 days for an estimated total population of 750 persons including staff at an average minimum of 250 litres per person per day would be installed. Feed water will be drawn from a borehole at the location of the desalination plant and brine discharge will be on the eastern side of the island

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 31 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru at about 5m from the low tide line. This location would provide the shortest distance to the lagoon from RO plant facility and live coral would not be affected by high salinities.

Guests would be provided with bottled water for drinking while desalinated water produced on the island is supplied for other basic needs such as bathing, laundry, washing, gardening etc. Desalinated water would also be provided for staff consumption; therefore, the quality of the water will be maintained within drinking water standards acceptable to the EPA and the Ministry of Tourism. Water quality will be tested using onsite water test meters for pH, conductivity, free and residual chlorine regularly and samples sent to laboratory for analysis as required by EPA.

Desalination plants will be installed according to the requirements of the Maldives Desalination Regulation and all plants will be registered with the EPA once the EIA Decision Statement is received. Personnel working inside the RO plant premise will only be subjected to noise levels exceeding 85dB(A) at intermittent periods not exceeding half of an hour. This is acceptable by all international standards, yet ear muffs would be provided on site for personnel to use.

Groundwater will be strictly conserved according to the requirements of the Tourism Regulations and Regulation on the Protection and Conservation of the Environment in the Tourism Industry. Groundwater monitoring will be undertaken to ensure that groundwater pollution is controlled and negative impacts are immediately mitigated.

Water network design and details are currently in progress and will be made available to EPA as and when required.

3.5.4 Powerhouse and fuel storage

Diesel generator sets of capacity 650kVA will be installed in the resort’s powerhouse for electricity generation with backup facility. The electrical supply will be of 3 phase and high voltage cable. Powerhouse and all related facilities will be installed according to the requirements of Maldives Energy Authority. The details of the proposed power grid will be made available to the Energy Authority during the application for the registration of powerhouse. The primary requirement in terms of environmental protection at powerhouses is that the noise level outside the powerhouse building at the facade shall not exceed 55dB(A). Therefore, adequate noise insulation will be done inside the powerhouse to ensure this

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 32 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru standard is met. Generator sets will be placed on anti-vibration mounts and noise insulation baffle walls will be used. Ear muffs will be provided to staff working in the powerhouse and staff will not work inside the powerhouse except for intermittent periods. Control room would be sound proofed.

Diesel fuel will be stored in two tanks outside the powerhouse. As is the normal practice, the fuel tank would have an appropriately sized bundwall outside the tank to contain accidental spills and leakages. Day tanks will be utilized to provide fuel to the generator sets. Exhaust stacks will be connected to each generator set. Each exhaust stack will be above 6m from the ground level. There will be no buildings in the critical path of the concentrated flume.

Electricity will be distributed through low voltage underground cables. Underground distribution system also consists of distribution substations, distribution feeder boxes, and service cables. Glass reinforced polyethylene (GRP) distribution boxes will be used and the distribution cables will be made of four core copper conductors insulated on the outside with polyvinyl chloride (PVC) and steel armored mechanical protection for physical protection.

Fuel will be transported to site by registered or approved fuel suppliers. A fuelling system will be installed at the jetty head, which will deliver fuel to fuel tanks in the island. At least five- day supply of fuel would be stored. Cooling water system will be from the same setup as the desalination plant.

In addition to fuel-efficient engines, energy conservation will be a high priority. Energy saving devices will be used in all operations of the resort. Energy saving lights will be used along with solar and LED lights.

3.5.5 Sewerage System

During the operational phase, wastewater will be treated using a wastewater (sewage) treatment plant (STP). The capacity of the treatment plant and pumping stations will be based on an estimated average of 150litres per person per day of wastewater. Treated effluent will be discharged into the sea at a depth of about 10m below MSL and at 5m from the reef edge. An activated sludge type packaged treatment plant will be installed and the smell will be contained. The details of the proposed system will be made available to EPA before commencing installation of this facility. Treated effluent will be used for gardening and toilet flushing and excess effluent will be discharged into the ocean beyond the house reef. Sludge

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 33 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru will be treated using sludge drying beds at the facility and treated sludge will be used as a fertilizer for gardening and landscaping of the resort.

According to the EPA, currently there is no requirement for the approval of sewerage system designs from the EPA. There have not been any sewerage system design approvals or registration requirements for sewerage systems similar to desalination plants so far. In fact, there are no regulations for sewage and wastewater disposal in the country at present. Design Criteria for Sewerage Systems issued in January 2007 has been widely used in the past few years and has been recently published on EPA website. The sewerage system in the proposed resort on Kanbaalifaru will meet the Criteria.

Where dewatering is required for pump stations, dewatering will be undertaken and water that is pumped will be put back into the nearby areas, although it may not help to replenish the aquifer. In fact, since the aquifer will not be used for any purpose, it will get back to normal within a short period of time and the impact of dewatering would be minor. Only some freshwater dependent plants would be affected, which is not found on the island.

Wastewater reticulation system drawings have not been developed so far and will be submitted to EPA if and when required. Since wastewater is treated and the outfall is at quite a considerable distance from the island in all appropriate locations, it may be disposed in any location. The recommended location based on currents is the eastern side, especially the northeastern or southeastern corner where there will be good mixing and dilution due to ever present currents in the channel. The likeliness of materials moving towards the shore from these locations would be minimal given that the current is generally into the atoll lagoon. Although treatment is considered, an emergency overflow will be considered in the design. The outfall pipe will be placed and anchored to the seabed using anchor blocks carefully placed on the seabed by experienced divers. Corals will be protected during the installation.

3.5.6 Waste Management

All solid waste infrastructure required for resorts as per the Tourism Regulations will be installed on the island. These include incinerator, recycling bins, bottle crusher, compactor and general waste bins. Solid waste generated on the island will be transported to R. Vandhoo or K. Thilafushi. During the construction phase, the main waste stream including kitchen waste, waste from temporary accommodation blocks, hazardous waste (e.g. spent oil) and waste from office blocks will be collected in designated bins for different groups of wastes

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(e.g. plastic, packaging, paper, glass, waste food etc.). Green waste collected during site clearance will be mulched and used as fertilizer for landscaping. In addition to these daily wastes, spillages during unloading of material would be of concern. Therefore, unloading processes will be properly supervised.

Furthermore, hazardous wastes such as grease, waste oil from gensets and machinery, empty paint and varnish cans, batteries, water proofing and other finishing chemicals will be generated during the construction phase. They will be collected in separate areas and send for appropriate disposal at Thilafushi or other designated landfill in separate and appropriate packaging.

During the operational phase, similar sorts of wastes will be generated. Solid waste generated on the island will be segregated on site and transported to Thilafushi or similar landfill site for proper disposal on contract basis. Recycling and reducing waste would be encouraged, especially among staff. Sludge from the sewage treatment process may be UV-treated on site and used as fertilizer and excess sent to landfill or disposed in a safe manner acceptable to EPA and the Ministry of Tourism.

3.5.7 Landscaping

Narrow walkways will be incorporated and existing walkways will be utilized as much as possible. Local species will be used for landscaping; these will mostly include coconut palms. These palms will be transplanted from available sites for which an environmental impact assessment has been undertaken or a separate EIA will be undertaken, if necessary. Coral transplantation and regeneration exercises will be undertaken for those corals in dredge areas and would need protection and preservation.

3.5.8 Coastal modifications

3.5.8.1 Shore protection measures

The problem of erosion is one of the major issues faced by the island communities of the Maldives and the resorts are no exception. Therefore, the following shore protection plan has been proposed for the resort in order to minimize the impacts of erosion.

A groyne field on the east with two terminal groynes at each end (south and north) has been proposed for Kanbaalifaru as shore protection plan (Figure 2). Excluding the terminal

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 35 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru groynes, the groynes on the eastern side starts from the proposed Spa complex and ends at the last unit of the Beach villa on the south of the island. Groynes are considered to be cheap, less intrusive and quite effective option compared to other options such as offshore breakwaters. However, the groynes should be properly designed to minimize aesthetic impact as well as to ensure appropriate functionality. Furthermore, shore protection shall be considered with caution based on at least one year of data on hydrodynamics. Therefore the proposed plan is seen as adequate at a conceptual level but is expected to change at the design stage.

3.5.8.2 Arrival Jetty and Service Jetty

The arrival jetty is located at the west while the service jetty is on the east of the island. The advantage of having one jetty on either side of the island is that even if one isn’t accessible due to weather conditions, there would be no interruption in the operations of the resort as the other could be used without difficulty. The capacity of the jetty is seen as appropriate for the operations of the island.

3.5.9 Emergency Response Plan

As a means of addressing potential fire hazards, firefighting equipment that meets the requirements of Tourism Regulations and National Fire Code will be developed with all necessary equipment including fire hydrants and fire extinguishers. Services of rescue with all necessary equipment will be made available. An emergency response plan will be developed with details of equipment, human resource and procedures. The following will be considered in the emergency response plan:  Level of protection to be provided;  Equipment - firefighting equipment (fire hydrants, fire extinguishers, etc.), rescue equipment (land and water), communication and alerting systems, oil spill containment;  Response time;  Emergency access and evacuation procedures;  Personnel and training requirements;

3.5.10 Equipment, Machinery and Tools

In the construction phase key activities based on the proposed concept include site preparation, mobilization of materials and equipment, temporary accommodation and services

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 36 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru for labour force, development of water supply, sewerage and power generation facilities, construction of arrival and service jetties, landscaping and demobilization. Machinery and tools used for these activities would be in good condition and used under strict supervision. Heavy vehicles such as excavators, bulldozers and trucks would be kept in designated areas and existing or project specific paths would be used. No additional paths would be created for their movements. Movements on the beach would be restricted or minimized.

The operational phase would not involve the use of heavy equipment. However, the machinery and equipment used during operational phase such as heavy duty washing machines, air-conditioning units, desalination plants, sewerage treatment plant and generator sets would be energy efficient. All air-conditioning units would use HFC or HCFC (RC134a) and refrigerants would be to the requirements of the Montreal protocol (and circulars issued by the Ministry of Environment regarding the Montreal protocol from time to time). Solar water heaters would be used for water heating.

3.5.11 Transport

The heavy transportation involved in the operation of the proposed new resort is considered to be one of the activities that would cause direct impact to environment similar to other such settings across the Maldives. The overall per capita carbon footprint will be very high in all such operations in the Maldives, as the Maldives is highly dependent on light and heavy fuel dependent sea transport system. Guests will be transferred on speed boats and planes while goods and materials will be supplied on . The environmental concerns anticipated are mainly due to contributions to global warming as a result of carbon emissions. The resort will join with the national efforts to minimize country wide carbon emissions as the Maldives is one of the first countries to sign the Kyoto Protocol.

3.6 Tourist Activities and Services

The resort is all about tourist activities and services. The fragile marine ecosystem would be subjected to stress from several tourist activities such as snorkeling, diving and disposal of wastewater and that would be the main concern while the stress on natural resources such as fuel would be an indirect and yet an important concern. With increasing focus on the enforcement of environmental regulations, the resort would have the necessary plans to manage tourist activities and services including adherence to Diving Regulations,

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Desalination Regulations, wastewater disposal guidelines, Solid Waste Management Regulations, HACCP Plans as per the requirements of the Food and Drug Authority, Fire Code, Regulation on the Management and Control of Products with HFC and HCFC and most importantly environmental mitigation measures proposed in the EIA report. Energy and water conservation policies will be implemented. International conventions such as Kyoto Protocol, Montreal Protocol, United Nations Framework Convention on Biological Diversity and other such conventions to which Maldives is party to, will be strictly respected. Protected areas, protected marine life, protected birds and banned exports will be made known to tourists, staff and all concerned.

3.7 Project Duration

It has been estimated that the duration of the construction works would take around one and a half years (18 months) since almost all of the proposed beach villas and some of the back of house facilities buildings have already been completed as part of the previous development efforts. The proposed project is expected to start soon after the EIA and detailed design is approved.

A work schedule will be provided to EPA once it is available.

3.8 Project Inputs and Outputs

The project has inputs in terms of human resources, natural resources and machinery. The main output of the project is Kanbaalifaru developed and operated as a tourist resort. The inputs and outputs are summarized in Table 3-1 and Table 3-2.

Table 3-1: Matrix of key inputs of the proposed project Input resource(s) How to obtain resources Construction workers Contractor’s responsibility Management and maintenance staff Appointed by proponent Construction materials:- timber, cement, thatch Import and purchased where locally available at roofing materials, concrete blocks, electrical cables, competitive prices – Contractor’s responsibility circuit boards, main circuit boards, reinforcing steel bars, river sand, aggregates, telephone cables, PVC conduits, PVC pipes, paint, varnish, thinner, roofing sheets, floor and wall tiles, toilet fittings, diesel, petrol, tar etc Maintenance material Imported or locally purchased Water (during construction) Desalinated water and rainwater Electricity/Energy (during construction) Diesel-based electricity Machinery and equipment Contractor’s responsibility Water treatment chemicals ( e.g. chlorine, anti- Imported or locally purchased scalants, pool chemicals, etc)

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Input resource(s) How to obtain resources Fuel (e.g. diesel, petrol) Locally purchased Fertilizers (e.g. for gardening) Locally purchased or imported Soaps and Detergents (laundry and washing) Locally purchased Cleaning agents (floor cleaning, toilet cleaning) Locally purchased Bleaching agents (laundry washing) Locally purchased Electrical appliances (TV, Refrigerators, Air Locally purchased Conditioners) Communication (phones, fax machines, cables) Locally purchased Insecticides, pesticides, fungicides (pest control) Locally purchased Stationary products (pens, papers, files etc) Locally purchased Kerosene, LPG Locally purchased Diving equipment (snorkeling gears) Locally purchased or imported Water bottles Purchased locally or imported

Table 3-2: Matrix of major outputs Products and waste materials Anticipated Method of disposal quantities Waste oils from machinery Minute To designated landfill once works are over Cleared green waste Small Stockpiled for natural decompose/mulched on site Constructional waste (concrete and cement Considerable Taken to Thilafushi/R. Vandhoo/other debris) designated landfill Used water bottles (PET) Considerable Taken to designated landfill for disposal Sludge (by product of sewage treatment) moderate Sun dried in a drying bed and either used as fertilizers or taken to designated landfill for disposal Wastewater effluent major Used in gardening, landscape, discharged into ocean after treatment Timber, cardboard and scrap metals major Recovered, reused , recycled and any leftovers (construction site waste) taken to designated landfill for disposal Used oil (waste oil), grease minute Reused, or taken to designated landfill for disposal Solid waste (kitchen waste, waste from Major/moderate Taken to Thilafushi/R. Vandhoo/other accommodation blocks, waste from office designated landfill blocks) Bottles moderate Taken to designated landfill for proper disposal Garden waste moderate Stock piled for natural decomposition Hazardous waste (used pesticide bottles, moderate Taken to designated landfill for proper disposal insecticide bottles, health care waste etc)

3.9 Need and Justification

Tourism is the largest economic activity in the Maldives which accounts for 28% of the GDP and over 60% of foreign exchange receipts. However, majority of the tourist resorts are located around Ibrahim Nasir International Airport in Hulhulé. Hence, people from other parts of the Maldives come searching for employment here. As a result there is an enormous concentration of the Maldivian population in this area contributing to negative effects associated with population congestion. If tourist resorts were to be spread out evenly in Maldives, providing employment, people will prefer staying near their homes and hence contribute to reducing population congestion in Malé and nearby islands. Furthermore, this will open opportunities to develop other economic sectors such as handicrafts industry and agricultural sector in other parts of the Maldives, this is truer for Shaviyani Atoll where most

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 39 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru of the employees are in crafting and the related trade industry (Census, 2006). The proposed development of a tourist resort on Kanbaalifaru will add to the state revenue generated from tourism (through bed and land rent and recently introduced goods and services tax) and subsequently help to improve public services and living standards. It will also provide direct and indirect employment and other income generating opportunities and help to address several social issues and help in the overall development of the Shaviyani atoll and the country as a whole.

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14 02

23

10

20

21 07 12

06 11 01 18 16 08 18 16

17

19

34 39 38 37 29 31 30 36 29 26 30 29 32 20 35 33 28 28 27

20

13

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24

LEGEND:

- BUILT/EXISTING STRUCTURES

- PROPOSED EROSION CONTROL/SHORE PROTECTION

KANBALIFARU SITE DEVELOPMENT PLAN

0 3010 50 100

Project Title: Drawing Title: Revisions: Drawn by: Drawing No. : NO. DESCRIPTION DATE ARNOLD BALEDA BELIR SITE DEVELOPMENT PLAN Checked by: Scale: 1:3000M. _ Location: SHAVIYANI ATOLL Discipline: ARCHITECTURAL CONCEPT Date: 18 August 2014 EIA for the Proposed Resort Development on Sh. Kanbalifaru

4 Project Alternatives

4.1 Introduction

This section looks at alternative ways of undertaking the proposed project. There are two basic options: (1) leave the problem as it is (no project option), or (2) take measures to resolve the problem (undertake the project options). If the project were to continue, it would be necessary to take economic, ecological and social aspects of the project into consideration and ensure that these concerns exist within a delicate balance. Neither the economic benefits nor the social and ecological concerns can be avoided. Therefore, it is important to consider all options and ensure that the best available option(s) is/are chosen to solve the issues/problems.

Not all the impacts of a project can be completely prevented, however, with the use of appropriate technology and management measures; the magnitude of most of these impacts can be either reduced or minimized. Nevertheless, the effectiveness of these technology and mitigation measures highly depends on the environmental condition and procedures in which they are applied in the field. On the other hand, there are complex and sophisticated procedures of minimizing environmental impacts by means of alternative methods to some of the activities. Often, alternate means are not economically competent with the extent of the project itself. However, to some of the activities where predicted impacts and its magnitudes on the environment are very adverse, alternate means must be applied considering long-term benefits from use of alternatives, as short-term environmental restorations can become very costly.

The following section describes and evaluates some alternatives in terms of locations and various project activities and methods of construction for the proposed project.

4.2 No project option

It should be noted that the “no project” option cannot be excluded without proper evaluation. In this report this alternative was considered as the baseline against which to evaluate the other options. The no project option takes the following arguments into consideration:  The current bed capacity is sufficient and additional capacity may over-burden existing infrastructure such as the international airport(s).  The island shall be kept in its natural state for the benefit of future generations

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 Hotel development in close-by inhabited islands with potential use of the island for visitor recreation would be more profitable to local communities.

The main advantages and disadvantages of the no-project option are given in Table 4-1.

Table 4-1: Advantages and disadvantages of the no project option Strategy Advantages Disadvantages Additional bed capacity would surpass  Costs related to increasing capacity  Job opportunities would be existing infrastructure of airports and related infrastructure hindered may be avoided  Direct and indirect benefits of the project may not be felt  Loss of national revenue for current and future growth of the industry Island shall be preserved in its natural  Costs related to the proposed  Loss of national revenue and state for the benefit of future development may be avoided economic benefits to local generations  Island’s fragile ecosystem may be communities. protected from potential negative impacts of development Use of island as picnic island for  Direct and indirect economic  Regulation would be almost hotels in nearby inhabited islands may ventures in inhabited islands as a impossible due to lack of ownership create better economic opportunities result of the island and responsibility, therefore, low for locals and keep the island level of environmental protection. environment intact.  Appropriate financing mechanisms do not exist for local entrepreneurs to start up tourism ventures; therefore, economic revenue generated would be low.

The no-project option also needs to be discussed in light of the proposed project. It is believed that a number of environmental impacts will be generated from the proposed development of a tourist resort on Kanbaalifaru. Although there will be no impacts on the environment if the proposed development of the resort does not go ahead, this will eliminate a significant development that has direct linkages with the development of the socio-economic conditions around the project area.

The resort development will bring numerous benefits to the neighboring communities as well as benefits to environmental management of the surrounding area. In terms of socio-economic benefits, the proposed resort will create job opportunities and various small business opportunities to the communities. This will bring more revenue to these communities. The communities around the project location have easy access and connection to Malé as the main mode of transport from these islands to Malé currently is via supply boats from other nearby resorts.

Also, there will be few environmental benefits with the proposed resort since environmental matters will be given important status such as environment-friendly design, technology and practices for environmental protection

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Given the range of benefits that the proposed development of the resort will bring, the consultants find that it would be better to go ahead with the project than not; given appropriate mitigation and management practices are incorporated in the development.

4.3 Alternative Location

As for alternative locations for the proposed development, there are several islands. The closest of these islands is Firunbaidhoo (Figure 4-1), which is located on the south west of Kanbaalifaru. It is a smaller, circular island with dense vegetation. Considering Firunbaidhoo as a medium to high end resort development would be less feasible than Kanbaalifaru given its small size. Furthermore, Kanbaalifaru has added aesthetic advantages over Firunbaidhoo, such as the vast lagoon expanse on its western side. Therefore, Kanbaalifaru is a better choice for the given development in comparison to Firunbaidhoo. Moreover the other two islands near kanbalifaru (Firunbaidho and Eriyadhoo) are declared as environmentally sensitive areas due to the presence of mangroves and therefore would be more susceptible to environmental damage from the development than Kanbaalifaru.

Figure 4-1: Alternative location

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 45 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru

4.4 Alternative Uses of the Island

The island have been used for agriculture in the past under a local system called varuvaa, it has also been used as a picnic island by the neighbouring communities. Nevertheless, the island is currently not used for any purpose and this development is expected to generate direct and indirect revenues to the communities around kanbaalifaru. Therefore it is seen that the tourism venture is the best option for the island.

4.5 Alternatives for Energy Generation

The proposed method of generating energy from diesel generators is considered to be the most reliable means at present. However, given the unstable nature of the world economy, it is important to find sustainable energy sources such as photovoltaic, OTEC, wave or wind energy systems. Wave energy systems, such as the one proposed for Vavvaru may be quite suitable for use in Kanbaalifaru. Deep sea cooling (OTEC) such as that tried in Sonevafushi in 2009 may also cater for about 40% of the energy needs of the proposed development. However, wind turbines would not be suitable due to aesthetics. These systems, however, have reliability and feasibility issues at the present time. Further research in to improved large scale applications is required. Large area is required for photovoltaic systems; however, the Proponent has plans to incorporate photovoltaic system as a hybrid to the proposed diesel generators in support of the carbon neutral goal of the Maldives.

It is better to avoid diesel based systems given their negative impact on the global environment. Diesel generators produce carbon dioxide, suphur dioxide and nitrogen oxides which contributes to global warming that is seemingly affecting global weather or climate system with potential sea level rise due to melting of polar ice caps. However, it shall be noted that the contribution to global emissions from any diesel generators used for the proposed project will be minute. Yet, the cumulative impact needs to be taken into consideration when choosing the best option.

4.6 Alternatives for Water Production

All resorts in the Maldives are required to setup desalination plants. Groundwater is required to be conserved. Therefore, desalination has been proposed for this project too. An alternative to fuel based desalination is a solar desalination plant. There are currently several systems

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 46 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru available for solar desalination; however, these are small scale plants that could be used as backup. The diesel or fuel-based systems have negative environmental impacts while the solar desalination systems have very low environmental impacts. Solar desalination technology may also have high setup costs compared with fuel-based.

The resort could utilize the rainwater harvesting techniques as a complementary method of water input, however it has to be noted that the rainwater that is harvested would not be fit for consumption without prior treatment. For the rainwater harvesting, the roofs of the staff area could be used, where the product water could be treated with methods such as micro and macro filtration, disinfectant through UV and chlorination to remove parasites, pathogens and viruses to give water that could be stored and used for different purposes of the resort.

For desalination, there are two options for raw water: seawater or groundwater. Seawater is taken from a location offshore or from an intake well in the lagoon. Groundwater is not usually taken for desalination. However, since the groundwater aquifer is easily recharged, groundwater is certainly a cheaper source of intake water as the salinity is low and the energy requirement, therefore, is less. This is a recommended means where groundwater is not used for any other purpose. However, groundwater is necessary for transpiration by vegetation. Therefore, the small, superficial groundwater lens must be preserved. Hence, groundwater is best avoided. The use of boreholes that draw seawater from a depth much far below the groundwater lens has the advantage that water is well filtered, therefore, membrane life is longer and the need for large sedimentation tanks is avoided. However, it may be necessary to watch for anaerobic conditions at such depths giving rise to ammonia in the water which could lead to the formation of chloramines after treatment with hypochlorite. However, in the Maldives, reports of ammoniacal smell in raw water in systems where boreholes have been used are rare. Hence, this method is acceptable and has gained interest. The other minor disadvantage is that in case of failure of the borehole within the groundwater lens, there is a tendency that groundwater is drawn into the system. The same applies to ocean intake pipelines, the failure of which could cause salinization of the aquifer. In ocean intakes, impingement and entrainment are also causes for concern. In many resorts fishes get drawn into the pipeline (entrained) and can be found in sedimentation tanks. However, this can be avoided by using footvalves or filters. Therefore, both boreholes and ocean intakes (including lagoon intake wells) are recommended equally.

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4.7 Alternatives for Sewage Disposal

Since the volume of wastewater generated on the proposed resort would be small (below 75m3/day), there is sound argument against wastewater treatment for such small scale operations as treatment is itself an energy intensive process. For such small wastewater systems, deep sea outfalls extending to over 5m off the reef edge is not expected to cause any damage to reef or cause ill-health to swimmers in the nearshore waters. The sea is a huge receiving body providing high rates of dilution (over 500-fold) and good hydrodynamic conditions usually taking the waste away from the point of discharge. Even then, the location of the outfall shall be chosen with care to ensure that wastewater is not disposed into the lee of the island at any given monsoon. Hence, usually the northwest to northeast and southeast to southwest is preferable for the disposal of untreated wastewater.

Nearshore disposal of wastewater is considered inappropriate in the context of the Maldives, especially in islands where groundwater lens is not properly formed due to small size or being too narrow, owing to which sustainable use of the groundwater is restricted. Therefore, in such islands, disposal of semi-treated sewage into the terrestrial environment through sceptic tanks is an alternative to treatment. However, there are existing restrictions for resorts due to regulatory requirements.

In order to minimize the energy-intensive nature of wastewater treatment, it is recommended for Kanbaalifaru, to avoid wastewater treatment and to consider direct disposal to sea or ground, if possible. Although the island is located within the atoll, the reef on the east is subjected to oceanic swells from the channel between Fonadhoo and Eriyadhoo, therefore, the southeastern side or the north-northeastern side of the island is considered appropriate for disposal of raw sewage. Furthermore, due to the narrow nature of the island, the groundwater is quite saline and a proper groundwater lens is not formed, therefore, sewage and wastewater (being primarily domestic in nature) may be disposed into the ground through a properly- designed septic tank system.

The option of disposal to groundwater has few advantages over the proposed treatment and disposal to sea. A lot of freshwater is used for toilet flushing and other non-potable uses. This ends up in the sewerage system. In Kanbaalifaru, where the island has a shallow and slightly saline freshwater aquifer and where the island has young vegetation, it may be ideal to let the plants use all the desalinated water that ends up in the sewerage system as wastewater since

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 48 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru the groundwater will not be used for any purpose and the wastewater effluent would provide nutrients required for the growth of plants.

The disadvantages of this option include the initial capital cost of the septic tanks and slow deterioration of groundwater quality as well as possible future maintenance/cleaning of septic tanks. Treatment using septic tanks does not completely remove coliforms and minerals in sewage; hence, there would be some degree groundwater pollution even though it is greatly reduced by septic tanks. Furthermore, releasing treated water to the ground at one point on the island will not recharge the entire freshwater lens of the island effectively. Therefore, the advantages and disadvantages shall be taken into consideration in taking a decision on this alternative.

Furthermore, in the case of STP, instead of disposing treated sewage to the sea, it could be used for irrigation and toileted flushing. This would require secondary treatment and final wastewater will have to be of superior quality than required for disposal to sea. This will increase cost of STP but reduce RO plant operational cost due to low water demand.

4.8 Shore protection options

Structural protection shall be avoided to the greatest possible extent as it affects the quality of the tourism experience due to the impact on the natural view of the beach. However, due to seasonal erosion, protection may be necessary to retain beach, which is the primary tourist attraction in the Maldives. Therefore, soft shore protection is the best means to achieve shore protection in island resorts. Where regular beach nourishment is possible due to availability of locations from which sand can be pumped, it may be ideal to consider regular sand pumping. However, regular sand pumping has the disadvantage of creating silty conditions downdrift of the fill location as well as sediment re-suspension in the water column impacting the clarity of the coastal water, which the islands of the Maldives are famous for.

In Kanbaalifaru, the eastern side, which is subjected the effects of weakened swells from the channel between Funadhoo and Eriyadhoo, lacks the desired fine sandy beach. The flow around the island diverts from the center of the eastern side with possibly stronger flow on the northern end of the island rather than the southern end of the island. Therefore, it may be necessary to nourish the eastern beaches during the construction phase with some degree of soft shore protection structures since beach nourishment alone are usually short lived. This is

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 49 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru truer for the cases where the beach area is subjected to higher wave action and hence would require to be repeated over time. This would mean that ultimately, the good burrow areas nearby would be cleared and proponent would have to go for burrow areas which are further away from the beach which would have a negative implication on the cost of the nourishment project. Also, for the eastern side, there would be no burrow areas in the vicinity, for which reason if may be important to undertake the beach nourishment operation with shore protection measures during the construction stage in order to avoid operational difficulties in case of beach nourishment during the operational phase. Considering these facts, it is better to use structural protection where it is deemed feasible and necessary. Hence the alternative would be the proposed shore protection plan suggested with the beach nourishment on the eastern side. This can be done during the construction phase, so that shore protection and beach nourishment may be undertaken towards the end of the construction phase after the necessary hydrodynamic data have been collected.

Revetments and seawalls shall not be considered, except unless necessary. However, submerged sills or breakwaters on the eastern side are appropriate options for shore protection. However, breakwaters should be built in such a way that it does not enclose the zone in any way as good circulation is crucial for the water quality of the area.

There are several shore protection materials to choose from and these include proposed rock boulders, geotextile containers (tubes or bags), sheet piling, concrete blocks or tetrapods including core-loc armour units. All these materials are similar in terms of their cost except for geotextile tubes. Geotextile containers involve filling of the containers which create further sedimentation and also are less durable. Sheet piling undertaken in Malé International Airport has shown that there is scour behind the structure leading to distortion of land and possible damage to airstrip as a result of flooding resulting in wave overtopping during rough weather. Tetrapods and rock boulders have shown to be more practicable because they tend to absorb wave energy into the cavities minimizing wave overtopping and scour behind the structure.

In Kanbaalifaru, it has also been observed that the north to north western side of the island does not have an appropriate beach area; therefore beach nourishment could be carried out for this area. However it has to be noted that this area is known to be a place for turtle nesting, according to the previous EIA report, although no signs of turtle nesting in this area has been observed during recent site visits. Yet, whatever alterations to the beach must be brought

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 50 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru about after further studies on the nesting behaviours of the turtles, which includes not carrying out beach nourishment in the turtle nesting season and nourishing the beach with similar beach material that exists naturally on the northeastern side. A study of the beach areas for turtle nesting along with hydrodynamic study may be undertaken during the early phase of construction so that shore protection and beach nourishment can be properly implemented towards the end of the construction phase.

Studies carried out on turtle nesting shows that the impact of beach nourishment affects the nesting rates for two years maximum and returns to normal (Gallaher, 2009) . However, proper prior and post monitoring should be carried out on the nesting sites and if the nesting sites appear to be under stress, the nourishment projects should not be repeated. In addition to this, the lightings used in all the phases of the project in the periphery of the northern beach area is of paramount importance as the lights from the beaches can lead the young hatchlings to landward direction rather than the ocean, which will increase the mortality rate of the hatchlings. Therefore, it is recommended that the lights used near the area to be shielded, lowered, recessed and if possible re-directed as to limit the visibility of the light to the beach area. Furthermore it is also recommended to use low-pressure sodium (LPS) vapor lights wherever applicable as they emit wavelengths to which turtles are least attracted to (Blue peace Maldives).

As a matter of fact, the beach could be left unaltered as turtles are a protected species in the Maldives and its nesting is as an important attraction to the resort as having an extended beach area. Furthermore, the resort could get involved in “ex-situ headstarting” programs in its operational phase as having these turtle nesting sites would give them an upper hand over the others who are involved in similar exercises. Moreover, this would be a green initiative of the resort which would be loved and admired by nature loving tourists, ensuring more repeat visitors. Nevertheless, it is highly recommended that the program should strictly be based on headstarting and not rearing the young ones for extended periods and releasing them into the wild later on.

4.8.1 Existing coastal structures

There are some existing coastal structures in Kanbaalifaru which might possibly be from the earlier investors. It is recommended that these be removed as it will have negative aesthetic impacts and as observed from the field visit, these structures are disrupting longshore drift,

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 51 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru causing erosion on some parts of the beach. Therefore it is highly recommended to remove these structures as soon as possible.

4.9 Preferred alternatives

Given their environmental benefits, it is recommended to consider clean energy technologies for power and water production in the island. However, wind turbines are not recommended as they can have visual impacts. Other systems are considered to have little or low aesthetic impacts, especially solar roofs, which could provide over 50% of the energy needs of the resort.

Based on the principles of “Best Available Technology Not Entailing Excessive Costs”, and given that the proposed location would not be used for recreational purposes, the preferred alternative for sewage disposal would be to pump raw sewage directly via ocean outfall since the volume of wastewater is low, the type of wastewater is predominantly human waste and the ocean provides more than adequate mixing and dilution at the outfall. This also minimizes the cost and energy of the treatment process. Considering the need to mitigate the energy impact of sewage treatment and disposal, it may also be considered appropriate to dispose wastewater into the ground via septic tanks. However, the initial investment cost for a septic tank system may be higher. Therefore, these two alternatives shall be considered against their cost-effectiveness over the long-term.

For shore protection, it is recommended to consider beach nourishment with minimal structural protection. Groynes are cost-effective and expected to achieve the purpose, on the eastern beaches of Kanbaalifaru. Similary, submerged sills may be considered for the eastern side. However, offshore breakwater may be slightly expensive but may be considered depending on the level of beach requirement for the eastern side. Beach nourishment is recommended to be conducted on the eastern and the north to north western side with necessary precautionary measures in relation to the known turtle nesting sites in the northern beaches. Nourishment is deemed important as these areas are prone to erosion.

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EIA for the Proposed Resort Development on Sh. Kanbalifaru

5 Existing Environment

5.1 Introduction

Conditions of the existing environment of the study area were analyzed by using appropriate scientific methods. Field surveys were undertaken to get further understanding of the existing environment of the island. These surveys were carried out during field visit to the island from 1-3 April 2014 and late July 2014 to collect baseline data. Before the trip was undertaken all existing information regarding the site was gathered.

The following components of the existing environment were assessed;  Coastal environment including coastal protection structures, longshore and offshore currents using drogue, and beach profiles  Existing landuse and additional land requirements  Socio-economic aspects  Marine water quality  Marine ecology of the housereef and proposed channel area  Bathymetry of the project sites  Terrestrial flora and fauna

5.2 Methodologies

Conditions of the existing environment of the study area were analysed by using appropriate scientific methods. The environmental components of the study area were divided into marine, coastal and terrestrial resources. The marine environment of the island covered the house reef of Kanbaalifaru. The coastal environment covered the beaches, the beach rock formations and coastal processes including longshore sediment transport, nearshore currents, tides and wave climate. The terrestrial environment covers the vegetation of the proposed coastal structures.

The different methods used in assessing and reporting the conditions of the existing environment of the island are given in the following subsections.

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5.2.1 Location identification

The location of data collection sites have been marked using handheld GPS. Figure 5-26 shows the data collection and sampling locations. Beach profile locations have also been marked by permanent markers or bench marks on site.

5.2.2 Marine Water Quality

Marine water quality was assessed in-situ for most of the parameters using a YSI handheld water quality logger and Hach portable turbidity and TSS meter. Water quality was assessed at different locations within the impact zone. Additionally, Water testing was also undertaken for one other marine location identified as a control marine reef survey location.

All water samples were taken at a depth of 1m from the mean sea level or mid water depth for shallow areas. GPS coordinates of each water sampling location was taken. The samples were analysed for basic parameters.

5.2.3 Coastal processes

Beach profiles at potential impact areas and other areas useful for future monitoring were done using automatic leveling instrument. These levels were done for shore and lagoon areas from the vegetation line.

A purpose built drogue integrated with Trimble Juno GPS was released at selected locations around the island, especially the main impact areas to understand general longshore currents around the island. Several drogues were done around the island. Repetitive long term measurements at the same locations would help to understand the general current patterns that will be used in assessing impacts as well as designing longterm shore protection measures.

Wave and tide data were based on long term wave and tide data available for the nearest airport, Hanimaadhoo Airport.

Long term monitoring of the coastal processes such as beach profiles and currents will be undertaken at regular intervals in order to formulate an appropriate mitigation plan.

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5.2.4 Bathymetry

Bathymetry was done using Sonarmite echosounder. Spot levels had to be taken in the field using a handheld echosounder to determine depth of shallow areas.

5.2.5 Marine Ecology

Marine environmental surveys were conducted to collect data on key environmental components (i.e. the coral reef system) that will be impacted due to the development. Purposes of the surveys are to define and establish marine environmental baseline conditions for impact evaluation during and after the proposed project implementation. Surveys were based on standard marine environmental survey techniques (English, et al 2007) so that they can be repeatedly carried out to monitor and record changes and assess possible impacts on the marine environment from the proposed work activities as well as operation of the facility. These surveys should be continually repeated to assess the short-term and long-term impacts on the marine environment.

5.2.5.1 Coral Reef Surveys

Quantitative surveys were conducted to establish the status of the coral reef system of Kanbaalifaru. Methodologies adopted for these surveys are internationally accepted and widely used to assess the status of coral reefs in the country as well. Photo Quadrates and visual observation of the reef were conducted at the coral reef system. Photo Quadrate technique has been used for objectives ranging from large-scale special problems to morphological comparison of coral communities and studies assessing impacts natural and anthropogenic disturbances.

For the photo quadrates, a measuring tape of 40m was placed on the reef, a set of random numbers between 0 and 40 were selected using MS Excel prior to the set out. Ten photos were taken at random using these numbers and the measuring tape and later analyzed using Coral Point Count with excel extension (CPCe) created and maintained by National Coral Reef Institute, Nova Southeastern University Oceanographic Centre.

Photo Quadrates were conducted at 6 locations of the reef as shown in Figure 5-26. These sites are representative areas within the reef system that can be monitored on long-term basis for assessing magnitude of possible impacts. Some of these areas may be most prone to any

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 56 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru adverse impacts from the proposed work, therefore establishing permanent monitoring sites at these areas is important to assess the impacts.

5.2.6 Socio‐ economic conditions

Socio-economic condition of the atoll was assessed through secondary data sources and the EIA report done in 2008 (Water Solutions 2008).

5.3 Overview of Project Site

Kanbaalifaru is an island formed on its own separate reef which is located approximately four kilometers from the eastern rim of the Shaviyani atoll in close proximity to the southern end of the atoll. It has a vast oval shaped shallow lagoon with a deeper oval shaped section in the center. Judging from the vegetation and soil characteristics, it is believed that the island have been created from a point in the south eastern corner of the reef system and grown into the C- shaped curvature which is broader on the north and narrower on the southern end. The eastern side of the island consists of sand patches while the western side possesses a more continuous sandy beach system. The island does have remnants of its last investment, which consists of about 10 structures in the terrestrial environment and some boulders which is located on the south eastern beach area. As for the existing roads, there are two roads in the north-south direction, one on the western periphery of the island which is about 800 meters and one in the center of about 1000 meters. There is also a road in the east-west direction which is located on the south of the island. Other than the clear roads, the island consists of lush vegetation.

There are varying depths of the lagoon in the western side, with the deepest to be recorded -7.5m from the MSL and the shallowest to be -0.5m from MSL. The eastern side is generally shallower up to the first 90m from the shoreline or so with an average of 1.5m below MSL, and thereafter the lagoon undergoes steeper declines. The island being in the middle of the atoll is subjected to wind generated waves, where the wind generated waves from the west meets the swell waves from the east.

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Figure 5-1: Beach areas on the west (left) and east (right)

Figure 5-2:Some of the existing structures on the island

5.4 Climate

The Maldives, in general, has a warm and humid tropical climate with average temperatures ranging between 26C to 32C and relative humidity ranging from 73 per cent to 85 per cent.

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The country receives an annual average rainfall of 1,950mm. There is considerable variation of climate between northern and southern atolls. Table 5-1 provides a summary of key meteorological findings for Maldives. General studies on climatic conditions of Maldives were taken into account during study as local level time-series data are limited for longer periods at the nearest meteorological station.

Table 5-1: Key meteorological information (Maldives)

Parameter Data Average Rainfall 9.1mm/day in May, November 1.1mm/day in February Maximum Rainfall 184.5 mm/day in October 1994 Average air temperature 30.0 C in November 1973 31.7 C in April Extreme Air Temperature 34.1 C in April 1973 17.2 C in April 1978 Average wind speed 3.7 m/s in March 5.7 m/s in January, June Maximum wind speed W 31.9 m/s in November 1978 Average air pressure 1012 mb in December 1010 mb in April

5.4.1 Monsoons

Monsoons of Indian Ocean govern the climatology of the Maldives. Monsoon wind reversal plays a significant role in weather patterns. Two monsoon seasons are observed: the Northeast (Iruvai) and the Southwest (Hulhangu) monsoon. Monsoons can be best characterized by wind and rainfall patterns. The southwest monsoon is the rainy season which lasts from May to September and the northeast monsoon is the dry season that occurs from December to February. The transition period of southwest monsoon occurs between March and April while that of northeast monsoon occurs from October to November.

5.4.2 Temperature

The temperature of Maldives vary little throughout the year with a mean daily maximum temperature of about 32C and mean low of 26C and are rarely below 25C or above 33C. The highest temperature ever recorded in the Maldives was 36.8°C, recorded on 19 May 1991 at Meteorological Office. Likewise, the minimum temperature ever recorded in the Maldives was 17.2°C, recorded at the National Meteorological Centre on 11th April

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1978. The highest recorded temperature for Malé was 34.1C on 16th and 28th of April 1973. The hottest month of the year is usually April reaching a peak around 24 April.

The figure below represents daily average low (blue) and high (red) temperature with percentile bands: inner band from 25th to 75th percentile and outer band from 10th to 90th percentile (source: weatherspark.com) based on the historical records from 1981 to 2011 at Hulhulé weather station.

Figure 5-3: Daily average temperature for Central Maldives with percentile bands.

5.4.3 Rainfall

Annual average rainfall in the Maldives is about 1900mm. There is a marked variation in rainfall across Maldives with an increasing trend towards south. The annual average rainfall in north is 1977mm and for south is 2470mm. The southwest monsoon is known as the wet season with monthly average rainfall ranging from 125-250mm. The northeast monsoon is known as the dry season with average monthly rainfall of 50-75mm.

The following figure illustrates the likelihood that precipitation may occur at some point in the day on a given day, based on the historical records from 1981 to 2011 at Hulhulé weather station (weatherspark.com).

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Figure 5-4: Probability of precipitation at some point in the day for Hulhulé, Maldives

Long term data indicate an average annual rainfall of 2200mm for Kaadedhdhoo. The intensity of rainfall is a concern in the Maldives since intensity is high with low frequency. However, excessive rainfall is not a concern in terms of flooding for Kanbaalifaru since the island is narrow and does not cup towards the middle but rather diverts the runoff towards the shore, especially towards the western side. However, excessive rainfall and subsequent runoff into the western lagoon may deteriorate the lagoon water quality of the western lagoon. However, this impact is not likely since the soil is quite permeable and runoff of material towards the shore is limited.

5.4.4 Wind

Wind has been shown to be an important indirect process affecting formation development and seasonal dynamics of the islands in the Maldives. Winds often help to regenerate waves that have been weakened by travelling across the reef and they also cause locally generated waves in lagoons. Therefore winds are important here, as being the dominant influence on the sediment transportation process (waves and currents). With the reversal of winds in the Maldives, NE monsoon period from December to March and a SW monsoon from April to November, over the year, the accompanying wave and current processes respond accordingly too. These aspects have ramification on the seasonal sediment movement pattern on the islands and also the delivery/removal of sediments from the reef platform/island.

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The two monsoon seasons have a dominant influence on winds experienced across the Maldives. These monsoons are relatively mild due to the country’s location close to the equator and strong winds and gales are infrequent. However, storms and line squalls can occur, usually in the period May to July; gusts of up to 60 knots have been recorded at Malé during such storms.

Wind was uniform in speed and direction over the past twenty-plus monsoon seasons in the Maldives (Naseer 2003). Wind speed is usually higher in central region of the Maldives during both monsoons, with a maximum wind speed recorded at 18 m/s for the period 1975 to 2001. Maximum wind speed recorded in the south was 17.5 m/s during the period 1978 to 2001. Mean wind speed was highest during the months January and June in the central region, while wind speed was in general lower and more uniform throughout the year in the southern region. Wind analysis indicated that the monsoon was considerably weaker in the south (Naseer, 2003). During the peak months of the SW monsoon, southern regions have a weak wind blowing from the south and south-eastern sectors.

Table 5-2: Summary of general wind conditions in Kanbaalifaru. (DHI 1991)

Wind speed Wind Direction (m/s) NE E SE S SW W NW N 1 0.94 0.95 0.96 1.19 1.02 0.97 0.82 0.78 2 2.02 1.95 2.13 1.91 1.81 1.92 1.57 1.46 3 2.30 2.79 2.98 2.74 2.74 2.99 2.31 2.12 4 2.04 2.26 2.75 2.91 2.86 2.90 2.15 1.91 5 1.45 1.97 2.30 2.21 2.98 2.49 1.51 1.27 6 0.54 0.99 1.42 0.94 1.79 2.36 1.02 0.80 7 0.10 0.32 0.74 0.28 0.91 2.04 0.43 1.10 8 0.05 0.06 0.26 0.11 0.52 1.39 0.19 0.04 9 0.01 0.01 0.16 0.01 0.19 0.94 0.10 0 10 0 0 0.05 0 0.04 0.75 0.04 0 11 0 0 0 0 0 0.46 0.01 0 12 0 0 0 0 0 0.07 0.01 0 13 0 0 0 0 0 0.02 0 0

Since most of the proposed components of the resort face the western side of the island, these sites could experience significantly high wind speeds during southwest monsoon and northeast monsoon and transition periods. This means that peak tourism season would fortunately fall out of the strong wind periods. The western side would be usually in the lee of the island especially during the peak tourist season, which is the northeast monsoon.

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Figure 5-5: Windrose diagram based on data from Hanimaadhoo Airport

5.4.5 Waves

Wave energy is important for sediment movement and settlement, and it is also a crucial factor controlling coral growth and reef development. Waves have been attributed to the diversity and the abundance of coral and algal species. These aspects have implications for the type and perhaps the supply of sediments into the island.

Studies by Lanka Hydraulics (1988 & 1989) on Malé reef indicated that two major types of waves on Maldives coasts: wave generated by local monsoon wind and swells generated by distance storms. The local monsoon predominantly generates wind waves which are typically strongest during April-July in the south-west monsoon period. During this season, swells generated north of the equator with heights of 2-3 m with periods of 18-20 seconds have been reported in the region. Local wave periods are generally in the range 2-4 seconds and are easily distinguished from the swell waves.

Distant cyclones and low pressure systems originating from the intense South Indian Ocean storms are reported to generate long distance swells that occasionally cause flooding in Maldives (Goda 1988). The swell waves that reached Malé and Hulhule in 1987, thought to have originated from a low pressure system of west coast of Australia, had significant wave heights in the order of 3 metres.

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In addition, Maldives has recently been subject to earthquake generated tsunami reaching heights of 4.0m on land (UNEP 2005). Historical wave data from Indian Ocean countries show that tsunamis have occurred in more than one occasion, most notable been the 1883 tsunami resulting from the volcanic explosion of Karakatoa (Choi et al 2003). Kanbaalifaru was not affected by the recent tsunami of 26 December 2004.

Kanbaalifaru is exposed to high waves generated by swells from the eastern side in the Northeast monsoon as it is facing the open ocean, namely the Eriyadhoo Kandu and the Fonadhoo Kandu. The wave action on the eastern side is also greater than the western side and thereby its effects could be seen in the beach content as most of the eastern side consists of rocks, rubble and dead corals while the western side has a sandier beach area. In the Southwest monsoon the western side is prone to the much weaker wind generated waves from the atoll lagoon. The overall result of wave influence on the morphodynamics of the island during the NE monsoon might be rapid deposition of sediment with shaping the island also taking place during the NE monsoon as well as the SW monsoon.

Table 5-3: Summary of wave condition in Kanbaalifaru Season Total Long Period Short Period

NE - Monsoon Predominantly from E. High Waves From E Mainly E-NE. High waves from E from E Transition Period 1 Mainly from SE-E From E Mainly from NE-SE

SW - Monsoon From WSW-NNW. Mainly from W. From E Mainly from W Transition Period 2 As SW monsoon From E From NNW-NNE. Higher waves from NE

This aspect of climate will therefore have an effect on the design of any coastal infrastructure and water sports and marine-based activities planned for the resort.

5.4.6 Evaporation Rates and Relative Humidity

Open water evaporation and transpiration from vegetation are very high. The high rates of evaporation and transpiration, especially owing to global warming, may be considered to add further to the evaporation rate and cause sea levels to fall in the future (Morner et al 2004). Evaporation rates are influence by wind, temperature and humidity and level of particulates in the air, studies of pan evaporation rates may yield misleading results as pan evaporation rates

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The figure below represents daily high (blue) and low (brown) relative humidity with percentile bands: inner band from 25th to 75th percentile and outer band from 10th to 90th percentile (source: weatherspark.com) based on the historical records from 1981 to 2011 at Hulhulé weather station.

Figure 5-6: Average daily relative humidity with percentile bands

5.5 Hydrography

5.5.1 Tides

Tides affect wave conditions, wave-generated and other reef-top currents. Tide levels are believed to be significant in controlling amount of wave energy reaching an island, as no wave energy crosses the edge of the reef at low tide under normal conditions. In the Maldives where the tidal range is small (1m), tides may have significantly important influence on the formation, development, and sediment movement process around the island. Tides also may play an important role in lagoon flushing, water circulation within the reef and water residence time within an enclosed reef highly depends on tidal fluctuations.

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Tides are an important factor to be considered in the design of elevation of jetties and water villas from MSL. The following figure shows the tidal variations at Hanimaadhoo International Airport (adapted from Zahir 2008).

+0.73m Highest Astronomical Tide (HAT)

+0.35m Mean Higher High Water (MHHW) +0.31m Mean Lower High Water (MLHW)

0.00m Mean Sea level (MSL)

-0.25m Mean Higher Low Water (MHLW) -0.40m Mean Lower Low Water (MLLW)

-0.81m Lowest Astronomical Tide (LAT)

Figure 5-7: Tidal variations recorded at Hanimaadhoo

5.5.2 Currents

Studies on current flow within a reef flat in Malé Atoll suggests that wave over wash and tides generate currents across the reef platforms, which are also capable of transporting sediments (Binnie Black & Veatch 2000). However, available information suggests that tidal currents are not strong due to small tidal range.

Generally current flow through the Maldives is driven by the dominating two-monsoon season winds. Westwardly flowing currents are dominated from January to March and eastwardly from May to November. The change in currents flow pattern occurs in April and December. In April the westward currents flow are weak and eastward currents flow will slowly take place. Similarly in December eastward currents flows are weak and westward currents will take over slowly.

Studies on current flow process within a coral atoll have shown that waves and tides generate currents across the reef platforms, which are capable of transporting sediments on them. Currents, like waves are also modified by reef morphology. Under low-input wave conditions (0.5m heights) strong lagoon ward surge currents (>60cm/sec) are created by waves breaking at the crest. Studies on current flow across reef platforms have shown that long-period oscillations in water level cause transportation of fine-grained sediments out of the reef- lagoon system, while strong, short duration surge currents (<5sec.) transport coarse sediments

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Data on current speed and direction around Kanbaalifaru was measured on the day of the last field visit. These are given in Figure 5-26. However, spot data taken on a single day would not yield sufficient data to understand coastal dynamics. Therefore, long term monitoring of data will be recommended in the monitoring program proposed for the resort.

Aspects relating to currents have a direct impact on the project, especially in understanding the movement of sediment plumes and the design of coastal protection measures. Therefore, longterm monitoring of currents is important.

5.5.3 Bathymetry

Bathymetry of relevant areas of the site is given in Figure 5-27.

5.6 Water quality

5.6.1 Marine water quality

Water quality was tested at four locations shown in Figure 5-26. The water quality results indicate that the marine water quality is in pristine condition with good levels of dissolved oxygen.

Table 5-4: In-situ water quality results

Parameter Unit Site 01 Site 02 Site 03 Site 04 Site 05 Site 06 Site 07 GPS Location 306085.64E 306518.49E 305986.70E 307127.05E 306720.91E 306957.88E 305796.39E 677637.00N 676786.45N 676668.83N 677065.99N 677742.59N 677535.07N 677081.12N

Temperature oC 28.74 29.63 30.5 29.07 29.25 29.18 29.07 pH 8.13 8.12 8.09 8.12 7.45 7.69 7.74 E. Conductivity uS/cm 53,870 53,210 53,720 53,700 52,900 53,146 53,700 TDS mg/l 35,120 35,250 35,420 35,440 35,351 35,610 35,523 Salinity ppt 35.06 35.12 35.23 35 35.23 35.55 34.97 DO mg/l 7.75 6.64 6.82 7.06 8.1 6.58 7.01 Turbidity NTU 0.54 0.55 0.34 0.72 0.15 0.21 0.12 TSSmg/l0000200

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5.6.2 Groundwater quality

Groundwater quality was tested at the same locations as the previously tested locations. The results are given in the table below.

Table 5-5: Groundwater quality Parameter Unit GW1 GW2 GW3 306812.41E 306887.84E 306902.81E GPS Location 677049.39N 677081.22N 676999.17N Temperature oC 27.96 28.94 28.7 E. Conductivity uS/cm 14420 7218 14340 Total Dissolved Solids mg/l 9375 4703 9320 Dissolved Oxygen mg/l 4.02 3.42 3.75 pH 7.05 7.35 7.13 Nitrates* mg/l 0.32 2.3 0.34 Phosphates* mg/l 0.01 0.02 0.00

* Nitrates and phosphate values are from the 2008 measurements

Conductivity readings were generally high and the lowest reading was at 7218 us/cm which is way above the freshwater mark. Conductivity readings of 2500 us/cm is the cut off limit for freshwater. Nitrate levels measured in 2008 were relatively low but the three locations had variations. Well 2 had the highest reading for nitrates. This high level of nitrates in comparison to the other two wells was found to be attributed to septic tanks and toilets near that well at the time.

5.7 Geology and geomorphology

Kanbaalifaru is a young island with very young vegetation cover and a few coconut palms in relation to the size of the island. This is a coralline island cay formed as a separate natural island and lies within an oval shaped lagoon, 4 km from the eastern rim of Shaviyani Atoll towards the southern end of the atoll.

According to the geological formation, vegetation and soil characteristics of the island it is believed that the island has been created from a point on the southeast corner of the reef system and grown as an elongated semi-circular shingle rampart, in a roughly north-south orientation, on oceanward side of the reef and gradually accretion took place to the lee of the island (westwards). Now the island possesses a morphologically distinct elongated arch or C- shape.

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The northern reef flat is narrower and shallower than the southern reef flat. The northern sand spit or thundi area is exposed to wind-generated wave action during Northeast as well as Southwest monsoons. The southern sand spit appears to be more stable than the northern sand spit. However, there is similar sort of wave overwash or wave topping on this side as for the northern side. Wind-generated waves from the western side meet swell-generated waves or surfs from the eastern side. Kanbaalifaru being in the middle of the atoll lagoon is prone to short-wind-generated waves within the atoll lagoon. The gradually sloping reef on the eastern side also creates tide-related waves or swells with a profound effect on the eastern beaches, especially during the northeast monsoon.

The northeast and eastern coasts are exposed to strong wave action especially during the northeast monsoon, which is the peak tourist season. However, the combination of coral, rocks and beach rock mix along the northeast and eastern coast prevent severe erosion from the island. In spite of this, coral and rocks are gradually being exposed, and the formation of sandy beach is discouraged on this coast except for small, temporarily seasonal patches of coarse sand. The unique topographic features such as to this may pose challenges in the built environment design, as the northeast and eastern ridges would need to remain unaltered as much as possible due to environmental sensitivity.

The island in general does not have high ridges as seen in many older islands. Generally, the eastern ridge of the island is higher than the western side and the eastern coast of Kanbaalifaru consists of large coral deposited in a very high-energy condition (storm deposits). The sediment composition of the island grades from coral to rubble to sand from east to west.

Kanbaalifaru island is within an individual separate reef system situated closer to eastern rim in south of the atoll. It is highly exposed to the open sea on eastern side as no shallow reef is formed on the atoll rim on eastern side towards the island. It is also very exposed on western side as the atoll has wide open channels to the open sea. Exposure of the reef system is also shown in the characteristic geomorphology of the reef system. Eastern side of the reef system has wider and gentler reef slope creating extensive surf zone. The reef system of the island is complex in terms of geomorphology. The reef top or reef-flat in northern side is wider. It has a deeper lagoon area in the center surrounded by shallow lagoon. The island is formed in eastern side of the reef system.

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Marine environment of Kanbaalifaru island system encompasses three main attributes. They are the coral reef, the shallow lagoon and the deep lagoon. Distinctive reef areas exist within the reef system. They are the reef slope, reef-flat and patch reefs within the deep lagoon. Geomorphology and biodiversity of each of these reef areas are also significantly different. The shallow lagoon surrounding the island also consists of sandy bottom substrate. The most significant marine environmental attribute in terms of area and biotic environment of the island system is its coral reef system covering approximately 36% of the whole island system. The following figure (Water Solutions 2008) shows area covered by different environmental attributes of Kanbaalifaru island system.

Area of attributes (hectares)

reef slope, land, 14 22 deep lagoon, 24 reef-flat, 35

shallow lagoon, 66

Figure 5-8: Area covered by different attributes of Kanbaalifaru

Reef of Kanbaalifiaru is oval shape and oriented northwest-southeast direction. Maximum linear length (from north to south) and width (from east to west) of the reef system are approximately 1.5 km and 1.3km respectively. Total area of the reef including the reef, lagoon and island is approximately 161 hectares.

The coral reef covers approximately 57 hectares out of which reef slope and reef-flat cover 22 hectares and 35 hectares respectively. The reef slope on eastern and southeastern side of the island is gentler and wider than in other areas. The reef-flat in northern side of the island is wider than in other areas.

The lagoon has two distinctively different lagoon areas. They are deeper lagoon area in the center and a shallower lagoon area surrounding the deeper lagoon and the island. The deeper lagoon in the middle is circular and has a diameter of approximately 500m and covers an area of approximately 24 hectares. Coral patches are found within the deeper lagoon. The shallow lagoon has an area of approximately 66 hectares and consists of sandy bottom.

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5.8 Ecology

5.8.1 Marine Protected Areas and sensitive sites

As per the requirements of the TOR, Marine Protected Areas (MPAs) and ecologically important or sensitive sites such as breeding or nursery grounds for protected or endangered species have been considered. There are no MPAs in the vicinity of the site. However, it shall be mentioned that Kanbaalifaru is known to be one of the best areas for bait and reef which indicates that the area has rich habitats. Furthermore the neighboring islands are considered as environmentally sensitive areas due to the presence of mangroves, however there were no mangroves located in kanbaalifaru based on the observation from the field visit.

5.8.2 Endangered species

No endangered species have been observed during the field visit. However the north western beaches are a known turtle nesting site and it is recommended to monitor the area during construction and operation for more of the endangered and protected species.

5.8.3 Housereef of Kanbaalifaru

The house reef of Kanbaalifaru is well formed with a fair amount of both coral and fish biodiversity. Five different sites, almost same as the previously studies areas, have been studied including two at the proposed water villas.

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Figure 5-9: Different marine habitats and their extent around Kanbaalifaru

5.8.4 Marine Ecological Survey Results

5.8.4.1 Site 1

This transect was located near the northern tip of Kanbaalifaru. Most of the site was covered with sand, followed by rubble and live corals. The live coral made up 25.83% of the area out of which 4.17% are Acropora and 21.67 are Porites species.

Fish surveys undertaken at Site 1 indicate that the site had low abundance and low . The highest abundance was noted for Zigzag Wrasse.

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Table 6: Fish survey results, Site 1

site 1 Common Name Scientific Name Abundance Whitespot Maori Wrasse Cheilinus chlorus 1 Zigzag Wrasse Halichoeres scapularis 3 Black Gregory Stegastes nigricans 1 Four-saddle Grouper (j) Epinephelus spilotoceps 1 Jewel Damselfish Plectroglyphidodon lacrymatus 1

Figure 5-10 : Photos of Site 1

5.8.4.2 Site 2

This transect was on the southern end of Kanbaalifaru. Photo Quadrate survey and assessment of coral reef at Site 2 showed that the reef consisted of 5% rubble and 95% sand. As for the fish diversity, there were no fish located on this site from the survey.

Figure 5-11: Photos of Site 2

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5.8.4.3 Site 3

This transect was on the south western side of Kanbaalifaru, near the reef line. Photo Quadrate survey and assessment of coral reef at Site 3 showed that the reef consisted of 55% rubble, 25% sand, 20% live corals belonging to Porites and Stylophora Species.

Fish surveys undertaken at Site 3 indicate that there were an abundance of Surge Damsel fish followed by Threadfin Dart fish and powder blue surgeon fish. Other than this, there were about 9 different species of fish encountered, making this one of the most fish abundant sites in Kanbaalifaru.

Table 5-7: Fish survey results, Site 3

site 3 Common Name Scientific Name Abundance Surge Damselfish Chrysiptera brownriggii 35 Threadfin Dartfish Ptereleotris hanae 7 Blunthead Wrasse Thalassoma amblycephalum 3 Jansen's wrasse Thalassoma janseni 1 Bullethead Parrotfish Chlorurus sordidus 4 Lined Bristletooth Surgeonfish Ctenochaetus striatus 3 Six-barred Wrasse Thalassoma hardwicke 1 Powder-blue Surgeonfish Acanthurus leucosternon 5 Bird Wrasse Gomphosus caerules 1 Barred Thicklip Wrasse Hemigymnus fasciatus 1 Eye-stripe Surgeonfish Acanthurus nigricauda 5 Bluestriped Sabertooth Blenny Plagiotremus rhinorhynchos 2

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Figure 5-12: Photos of Site 3

5.8.4.4 Site 4

This transect was on the south eastern reef of Kanbaalifaru. Photo Quadrate survey and assessment of coral reef at Site 4 showed that this site consisted of 43.75% live corals and 56.2% rubble. Species of Acropora, Porites and Stylophora were recorded from this area.

Figure 5-13: Benthic cover at Site 4

Fish surveys undertaken at Site 4 indicate that 9 species of fish were encountered in this site. Out of which the most abundant is, Lined Bristletooth Surgeon fish with a count of 94 individuals.

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Table 5-8: Fish survey results, Site 4

site 4 Common Name Scientific Name Abundance Indian Triggerfish Melichthys indicus 2 Powder-blue Surgeonfish Acanthurus leucosternon 2 Lined Bristletooth Surgeonfish Ctenochaetus Striatus 94 Surge Damselfish Chrysiptera brownriggii 4 Green-nose Parrotfish Scarus viridifucatus 2 Bullethead Parrotfish Chlorurus sordidus 5 Jewel Damselfish Plectroglyphidodon lacrymatus 3 Sailfin Tang Zebrasoma desjardinii 1 Yellowhead Butterflyfish Chaetodon xanthocephalus 1

Figure 5-14: Photos of Site 4

5.8.4.5 Site 5

This transect was on the eastern reef of Kanbaalifaru. Photo Quadrate survey and assessment of coral reef at Site 5 showed that the reef consisted of 23.75% corals and the rest were rubble. Species of Acropora and Porites were sited on the area.

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Fish surveys undertaken at Site 5 indicate that this site consisted of about 9 different species of fish. Out of which the most abundant ones are Eye-strip Surgeon fish, Bullethead Parrot fish, Lien Bristletooth Surgeonfish and Green-nose Parrotfish.

Table 5-9: Fish survey results, Site 5

site 5 Common Name Scientific Name Abundance Powder-blue Surgeonfish Acanthurus leucosternon 5 Lined Bristletooth Surgeonfish Ctenochaetus Striatus 6 Green-nose Parrotfish Scarus viridifucatus 5 Bullethead Parrotfish Chlorurus sordidus 10 Dusky Parrotfish Scarus niger 1 Eye-stripe Surgeonfish Acanthurus nigricauda 20 Sailfin Tang Zebrasoma desjardinii 2 Chevron Butterflyfish Chaetodon trifascialis 1 Convict Surgeonfish Acanthurus triostegus 2

Figure 5-15: Photos of Site 5

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5.8.4.6 Site 6

This transect was on the north western reef of Kanbaalifaru. Photo Quadrate survey and assessment of coral reef at Site 6 showed that this site consisted of 16.25% live corals, 60% rubble and 6.25% sponges. Species of Acropora, Porites, Stylophora and sponges were recorded from this area. The fish survey indicated that there were about 6 species of fish located in the area at the time of the survey.

Figure 5-16: Fish survey results, Site 6

site 6 Common Name Scientific Name Abundance Indian Triggerfish Melichthys indicus 2 Sergeant Major Abudefduf vaigiensis 4 Green-nose Parrotfish Scarus viridifucatus 1 Collared Butterflyfish Chaetodon collare 2 Bullethead Parrotfish Chlorurus sordidus 2 Scribbled Filefish Aluterus scriptus 1

Figure 5-17: Photos of Site 6

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5.8.4.7 Site 7

This transect was located on the north eastern side of Kanbaalifaru. Photo Quadrate survey and assessment of coral reef at Site 7 showed that this site consisted of 20% live corals, 40% sand and 40% rubble. There were no fish located for this site.

Figure 5-18: Photos of Site 7

5.8.5 Status of the coral reef

The quantitative assessment of the reef at different locations showed that the shallow reef areas of Kanbaalifaru is in average condition with respect to percentage of live coral cover. The average percentage of live coral cover estimated for the reef was about 21% of the reef benthos. This reef system may naturally have lower percentage live coral cover as it is very exposed to high wave energy, or it may have been an impact of anthropogenic activities. Long-term data of the reef system is needed to establish whether this reef system naturally has low percentage of live coral cover.

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5.8.6 Floral Landscape

Kanbaalifaru has lush vegetation with lots of young trees. The floral landscape is in its natural state except for a few areas where trees have been cleared during the previous development. The vegetation can be considered diverse and representative of many other uninhabited islands of similar nature in the Maldives. However, there are limited varieties of plant species than what is observed in other large uninhabited islands with greater diversity possibly due to the island being narrow and subsequently saline groundwater. There are no terrestrial landscapes of significance or unique in nature. No old trees that may require special efforts for their protection or preservation have been observed.

The landscape could be described as having two major types of vegetation: vegetation on the coast line or vegetation line and inner vegetation. Stark differences can be noticed along the vegetation line and the vegetation on the inside of the island. The main difference is the composition of different tree species along the inside of the island in contrast to the vegetation line. Differences also exists in their diversity along the vegetation line and from inside the island.

As for the description of the floral landscape, the eastern periphery including the southern tip, all the way up to the northern bend of the island is dominated by kuredhi (Pemphis acidula), kaani (Cordia subcordata) and such highly salt-tolerant species, as found on the rim reef side in many other islands. This is followed by magoo (Scaevola taccada) and juvenile dhigga (Hibiscus tiliaceous) and boakashikeyo (Pandanus tectorus) in the inland (western) direction. The center of the island is dominated by magoo (Scaevola taccada) and juvenile coconut, while the southern end is dominated coconut, dhigga (Hibiscus tiliaceous) and kaani (Cordia subcordata). The vegetation on the north consists mostly of kuredhi (Pemphis acidula) while the western periphery is abundant in coconut and magoo (Scaevola taccada). Kanbaalifaru’s flora was assessed as clusters of vegetation while mature coconut trees have been counted along with young coconut palms and marked on the map in Figure 5-28. Figure 5-28 shows a detailed map of the types of vegetation/vegetation clusters in Kanbaalifaru undertaken recently as well as the locations of vegetation transects undertaken by Water Solutions (2007), which is considered accurate, is discussed here.

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Table 5-10: Results of vegetation transect 1 Dhivehi Name Common Name Scientific Name Count Boakashikeyo Wild screw pine Pandanus tectorus 23 Boashi Tree heliotrope Tournefortia argentea 3 Dhivehi ruh Coconut tree Cocos nucifera 19 Kuredhi Iron wood Pemphis acidula 42 Magoo Sea lettuce Scaevola taccada 125 Uni Nit pitcha Guettarda speciosa 4 Halaveli Tassel plant Suriana maritima 32 Dhiggaa Sea hibiscus Hibiscus tiliaceous 132 Funa Alexander Laurelwood tree Callophllum inophyllum 12 Kaani Sea trumpet Cordia subcordata 3 Midhili Country almond Terminalia catappa 2

The dominant species observed in this region was mainly magoo (Scaevola taccada) and boakashikeyo (Pandanus tectorus) See Table 5-10. The highest canopy was recorded for coconut palm (Cocos nucifera), which was observed to be fairly young to mature. The average canopy height of this zone varied between 2 to 4 meters.

Table 5-11: Results of vegetation transect 2 Dhivehi Name Common Name Scientific Name Count Boakashikeyo Wild screw pine Pandanus tectorus 13 Boashi Tree heliotrope Tournefortia argentea 1 Dhivehi ruh Coconut tree Cocos nucifera 3 Dhiggaa Sea hibiscus Hibiscus tiliaceus 1 Hirundhu Sea trumpet Thespesia populnea 11 Kuredhi Iron wood Pemphis acidula 41 Magoo Sea lettuce Scaevola taccada 2 Uni Nit pitcha Guettarda speciosa 3

The vegetation along Transect 2 was found to contain 8 species of trees. The dominant species observed in this transect was mainly kuredhi (Pemphis acidula) and boakashikeyo (Pandanus tectorus). The highest canopy was recorded for Coconut Palm (Cocos nucifera), which was observed to be relatively mature and recording over 8 meters. The average canopy height of this zone varied between 2 to 8 meters.

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Table 5-12: Results of vegetation transect 3 Dhivehi Name Common Name Scientific Name Count Boakashikeyo Wild screw pine Pandanus tectorus 13 Dhivehi ruh Coconut tree Cocos nucifera 17 Funa Alexander Laurelwood tree Callophllum inophyllum 1 Halaveli Tassel plant Suriana maritima 2 Magoo Sea lettuce Scaevola taccada 5 Midhili Country almond Terminalia catappa 1 Uni Nit pitcha Guettarda speciosa 1

The vegetation along this section vegetation line was found to contain 7 species of trees. The dominant species observed in this region was coconut palm (Cocos nucifera) and boakashikeyo (Pandanus tectorus). The highest canopy was recorded for coconut palm (Cocos nucifera), which was observed to be over 8 meters. The average canopy height of this zone varied between 2 to 8 meters.

Table 5-13: Results of vegetation transect 4 Dhivehi Name Common Name Scientific Name Count Boakashikeyo Wild screw pine Pandanus tectorus 2 Dhivehi ruh Coconut tree Cocos nucifera 7 Funa Alexander Laurelwood tree Callophllum inophyllum 8

The vegetation along this section vegetation line was found to contain 3 species of trees. The dominant species observed in this region was mainly funa (Calophyllum inophyllum) and coconut palm (Cocos nucifera). The highest canopy was recorded for funa (Calophyllum inophyllum) which was observed to be over 7 meters. The average canopy height of this zone varied between 5 to 7 meters.

5.8.7 Terrestrial Fauna

Water Solutions (2008) have indicated that the northwestern beach has signs of turtle nesting, however no such tracks or activities were encountered during the recent field visit. Grey herons and crows have been observed, but no other avian species have been observed or heard during recent field surveys. A number of crabs (shore crabs and hermit crabs), lizards and common garden ants were observed in the island.

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5.9 Socio-economic environment of Shaviyani Atoll

Kanbaalifaru is located within Shaviyani (North Miladhunmadulu) Atoll, about 200 km away from Male’ International Airport and 85 km away from the nearest airport, Hanimaadhoo. The island lies towards the centre of the atoll and close to the capital island Fonadhoo.

The nearest islands of Kanbaalifaru are mostly uninhabited islands including, Eriyadhoo, Firubaidhoo and Ekasadhoo. The nearest inhabited island is, Laimagu and Funadhoo. Kanbaalifaru is also located east within 30 minutes of the previously proposed airstrip at Dhiguvelidhoo. Kanbaalifaru’s location allows it to have a 30minute boat access to about 5000 inhabitants of Shaviyani Atoll.

The total population of the North Miladhunmadulu (Shaviyani) is 11,830, which 5,535 males and 6,295 females. The population was growing at an exponential rate of 0.63 according to the data collected from census 2006. The overall dependency of the ratio is high with 77.3, indicating that the working population is less in comparison to the young and the elderly generations. However, with the new pension scheme in place, the elderly generation would not be as dependent as perceived in data. Nevertheless this is compensated by the increase in the child rearing age as the tertiary education demand in the country is in a steep raise. The atoll has a good overall literacy rate of 96.8 which is not surprising as the Maldives prides itself in having an overall high literacy rate of about 98 which is formidable even in comparison to the neighboring nations. The lower secondary school completion rate is 40.3 while the higher secondary school completion rate is about 0.5, there might be a number of reasons behind the lower rate in relation to the higher secondary education, such as the absence of facilities, lower passing rates, migration to other parts of the country or abroad for further studies and youth becoming more involved in the labor sector without going for further studies.

In the atolls economic sector, there are a total of 4344 citizens employed, with most of them in the manufacturing industry. There are about 1825 craft related trade workers in the Shaviyani Atoll, which is a good thing as the proposed resort development would give them a wider market and a better income for their work. Education, fishing and agricultural industry are the next preferred sectors of employment, with 691 skilled agriculture and fishery workers in total.

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The share of the Shvaiyani Atoll in the national fisheries sector has been declining for a number of years. As of the records published by Ministry of Planning and National Development (2005) the share of Shaviyani Atoll fisheries has declined from 9.2% in 2002 to 5.0 % in 2004.

Table 5-14: Island level Demographic statistics of Shaviyani Atoll (census 2006)

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Table 5-15: Employed population of Shaviyani Atoll (Census 2006)

5.10 Natural hazard vulnerability

The following information on the vulnerability of the islands in the Maldives are taken from published literature such as Developing a Disaster Rick Profile for Maldives by UNDP (2006) as site – specific information on vulnerability of Kanbaalifaru was not available. According to the UNDP (2006) the natural vulnerability of the islands and atolls of the country to potential hazards have been modelled to understand the risk factors of the country.

The disaster risk scenario for Maldives can be described as moderate in general. Despite this, Maldives is among the most severely affected countries hit by the Asian tsunami on December 26th, 2004. Maldives experiences moderate risk conditions due to a low probability of hazard occurrence and high vulnerability from exposure due to geographical, topographical and socio-economic factors.

Following are some of the risks that have been identified and potential areas that may be within the range of risks based on its sensitivity, location, exposure, historic events, etc.

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Figure 5-19: Tsunami hazard zones

Figure 5-19 show that Maldives faces tsunami threat largely from the east and relatively low threat from the north and south. So, islands along the eastern fringe are more prone to tsunami hazard than those along the northern and southern fringes. Islands along the western fringe experience a relatively low tsunami hazard. This map is produced based on the experience of the tsunami in 2004 and also occurrence of historic tsunami events in the greater region where most of the events have identified to have occurred from the Sumatra Region (UNDP 2006).

Besides heavy rains and strong winds during monsoons, hazardous weather events which regularly affect Maldives are tropical storms or ‘tropical cyclones’, and severe local storms. At times, tropical cyclones hitting Maldives are destructive due to associated strong winds that exceed a speed of 150 kilometres per hour, rainfall of above 30 to 40cm in 24 hours and storm tides that often exceed four to five meters (UNDP 2006).

Cyclonic winds sometimes can cause a sudden rise in sea-level along the coast, leading to a storm surge. The combined effect of surge and tide is known as ‘storm tide’. Storm tides can cause catastrophe in low-lying areas, flat coasts and islands such as Maldives.

Maldives is also affected by severe local storms- thunder storms/ thunder squalls. Hazards associated with thunder storms are strong winds, often exceeding a speed of 100 kilometres per hour, heavy rainfall, lightning and hail; they also give rise to tornadoes in some regions.

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In general, thunderstorms are more frequent in the equatorial region than elsewhere, and land areas are more frequently hit by thunderstorms as compared to open oceans. However, thunder storms close to the equator are less violent when compared with those in the tropical regions and beyond. Maldives being close to the equator, thunder storms are quite frequent but less violent here. Strong winds generated by severe local storms generate large wind- driven waves which are hazardous for Maldives (UNDP 2006).

The islands of Maldives are less prone to tropical cyclones. The northern islands of the country were affected by weak cyclones that formed in the southern part of the Bay of Bengal and the Arabian Sea. Figure 5-20 shows the tracks of cyclones affecting Maldives during the period 1877-2004. The number of cyclones directly crossing Maldives is small. Only 11 cyclones crossed the islands over the entire span of 128 years. Most of the cyclones crossed Maldives north of 6.0o N and none of them crossed south of 2.7oN during the period (UNDP 2006).

Figure 5-20: Tracks of Cyclones affecting Maldives, 1877-2004

UNDP (2006) stated that there were 21 cyclonic disturbances within the 500km radius during 1877-2004, of which 15 were depressions with an average wind speed of about 28 knots. The highest wind speed due to cyclonic disturbances that affected the islands during that time was about 65 knots. Figure 5-20 shows the tracks of cyclonic disturbances that passed through the circle with 500km radius.

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Figure 5-21: Tracks of Cyclones passed within the Scan Radius of 500 kilometres

Based on the above information, Maldives is divided into zones with varying scales of cyclone hazards based on based on a qualitative judgment based on the gradient of the storm tracks from north to south.

Figure 5-22: Regions to capture Cyclones passing through Maldives for Hazard Zoning

Figure 5-22 shows the regions used to compute the highest wind speed of each cyclone captured within the region. Majority of the cyclonic disturbances crossed the northern region. The frequency and wind speed decreases from northern region to southern region. Region 1 is not affected by any storm. Thus, Maldives can be divided into three cyclone hazard zones – the northern zone with high cyclone hazard, central zone with moderate cyclone hazard and the southern zone with very little cyclone hazard.

With regards to the storm surge potential, the bathymetry around the Maldives shows that the ocean slope close to the east coast is steeper than the west coast, hence it can be generalized that the eastern islands of the Maldives are vulnerable to higher surge hazard compared to the

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 88 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru western islands. Figure 5-24 shows the bathymetry around Maldives. Figure 5-25 shows storm surge hazard zones based on computed model with maximum pressure drops for 100 year return period and with historical data (UNDP 2006).

Figure 5-23: Three Dimensional View of Bathymetry of Maldives (depth in meters)

Figure 5-24: Storm Surge Hazard Zones with Cyclones Affected

Based on the above figure, it can be said that the north-eastern parts of the country are very vulnerable to storm surges.

Based on historical catalogues of earthquakes in the region, identifying seismic sources based on this historical information and based on numerical models, it was found that except for Seenu, Gnaviyani and Gaafu Atolls, earthquake hazard is low across the country. The probable maximum Modified Mercalli Intensity (MMI) is estimated between 7-8 in Zone 5 (Figure 5-24). This level of MMI can cause moderate to high damages (UNDP 2006).

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Figure 5-25: Maldives Seismic Hazard Zones

It can be summarized that the northern parts of the country are vulnerable to cyclones and storm surges while southern parts of the country are vulnerable to seismic activity. The eastern side of the country is more exposed to potential tsunamis and surges.

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EIA for the Proposed Resort Development on Sh. Kanbalifaru

6 Stakeholder Consultations

The key stakeholders of the project include the City Council, Ministry of Transport and Civil Aviation, Maldives Civil Aviation Authority, Ministry of Environment and Energy, Environmental Protection Agency, Ministry of Housing and Infrastructure, Proponent Contractor and Project Engineers, Consultants and general public. The stakeholders that participated in the Scoping Meeting have extensively discussed on the issues relating to the project. Stakeholder opinions have been gathered during the initial field visit.

6.1 Scoping Meeting

The Scoping Meeting was held on 1 June 2014. The meeting was attended or represented by the following.  Ahmed Murthaza, Director, EPA  Nuzhath Ali, Assistant Environment Officer, EPA  Mohamed Sinan, Assistant Project Officer, Ministry of Tourism  Mariyam Rifga, Assistant Project Officer, Ministry of Tourism  Fathimath Suad, CEO and Director, Kanbaalifaru Development Pvt. Ltd.  Ahmed Zahid, EIA Consultant

The Proponent/Consultant provided a brief outline of the proposed development and identified that an EIA was done in 2008 and approved for the development. The development process was started, but few buildings in the back of the house area including staff accommodation and some utilities buildings have been developed. However, with transfer of lease, a new concept based on the old concept to include the already developed structures has been proposed.

It was identified that there are few mature trees and that the island vegetation is quite young. Yet, vegetation will be preserved to the greatest possible extent and all matures trees will be kept intact. Also, the island has a naturally deep entrance into the natural deep lagoon, serving as a harbour, on the western side. Yet, there may be difficulties in using the harbour during the southwest monsoon, which needs to be considered although the proposed jetty area would be generally calm.

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EPA inquired about beach replenishment and identified that if beach replenishment was to be undertaken borrow and fill areas shall be identified and approval from the EPA sought before the EIA can be approved. The Proponent identified that beach replenishment would be required, especially for the eastern side, and necessary approvals will be sought.

EPA also discussed regarding the environmental infrastructure such as waste, water supply and wastewater disposal. Reference was made to the new Waste Management Regulations and the necessity to ensure that licensed persons take waste from the island.

Following discussions on environmental considerations of the project, the scope of the EIA was finalized. Since the EIA has been approved in 2008, it was identified that there may not be a need to undertake further consultations with the neighbouring community in order to avoid public frustration over unforeseen delays but to consider the previous consultations as appropriate and relevant. The rest of the general requirements for resort EIAs were considered valid for this project and were considered necessary to undertake field investigations in the light of previous locations and data.

6.2 Consultations in the field

As has been considered in the Scoping Meeting, public consultations were avoided during this EIA since the project has been delayed for quite some time. Therefore, consultations undertaken for the previous EIA was considered relevant and is discussed here.

People of Funadhoo and Lhaimagu were mainly engaged in the initial dialogue because of their proximity to Kanbaalifaru. The views about the project have been discussed below.

Most of the people knew that Kanbaalifaru has been selected for resort development and that it has been awarded to the winning bidder. They were not well informed about the nature of the development on the island of Kanbaalifaru. In spite of this, rather than opposing and criticizing the development, they were keener to see a resort developed on Kanbaalifaru. Many of them raised concern over the delay in starting the construction work and some of them were skeptic about the construction and operation of a resort on Kanbaalifaru.

However, most of the people consulted indicate that they expect some direct and indirect benefits from the construction and operation of a resort on Kanbaalifaru. They expressed their

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 97 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru desire to work during the construction and operation of the stage. They also expect the development to create more demand for local produces and products.

On the negative side, some people mainly the fisherman raised their concern for depriving them of fishing and bait fishing from Kanbaalifaru reef and lagoon, especially when Kanbaalifaru has few of the bait fishing areas in Shaviyani atoll.

On the positive side they specifically mentioned about the need to employ more local workers during the construction and operation of the resort. They also indicated the need to use more local produces and products such as coconut, fruits, fish and coconut thatches, roanu (coconut fiber rope) during construction and operation of the resort. Furthermore, they expect an increase of local trade supply and merchandise during construction and operation.

The biggest doubt the public had at the onset of the project was to know that a resort on Kanbaalifaru would ever be developed and if it gets developed the public expects the resort owners and operators to understand the socio-economic situation of the atoll and to act rationally in a socially responsible manner to empower the atoll community by providing education and training for the atoll population. In this regard they specifically mentioned about their desire to see direct assistance towards the development of the health and education sector of the region.

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7 Environmental Impacts

7.1 Introduction

Development projects involving infrastructure development in island environments are believed to generate a series of environmental impacts, of which some can be felt immediately on the surrounding environment while others can be felt continually and can be far reaching. By far and large the most significant environmental impacts are those that are felt on the immediate environment. Terrestrial environment is directly affected from removal of vegetation resulting in loss of habitat. Also coral reef environments are sensitive and highly susceptible to immediate changes that will be incurred from most of the development activities. Therefore, all the development activities must take into consideration the understanding of the environment and changes as well as implications that it will bring about to the environment and surrounding.

The following account describes potential environmental impacts that will be associated with the proposed resort development on Kanbaalifaru both during construction and operational phases of the development.

7.2 Methods and Limitations

The methods used to predict and evaluate the environmental impacts that may be associated with the proposed resort development may not be the most comprehensive methods as they are quite simple prescriptive methods. The main shortcoming of these methods is that only assumptions have been made to predict the impacts which may or may not be accurate. Also, the degrees at which these impacts are either accurate or inaccurate as well as uncertainties and natural variability are the key factors that affect the accuracy of these methods. Nonetheless, the methods used are concise and provide a general overview as well as the range of impacts that can affect the environment. Also, the EIA report has taken into consideration similar studies undertaken in the Maldives as well as expert judgment in identifying the main environmental impacts that may be associated with the proposed airport development.

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7.3 Impact Identification

Impacts on the environment from various activities of the proposed development have been identified through:  A consultative process within the EIA team and the Proponent  Purpose-built checklist  Existing literature and reports on similar developments in small island environments and other research data specific to the context of the Maldives

 Baseline environmental conditions described in Chapter 5.  Consultant’s experience of projects of similar nature and similar settings

A purpose built matrix has been used to evaluate the overall impacts of the proposed project. The impacts of the project have been evaluated according to the following criteria:  Magnitude (or severity): the amount or scale of change that will result from the impact  Significance: importance of the impact. Reversibility is considered part of its significance  Duration: the time over which the impact would be felt  Extent/spatial distribution: the spatial extent over which the impact would be felt  The scales associated with the above criteria are given in the table below.

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Table 7-1: Impact evaluation scale Criteria Scale Attribute Magnitude -3 Major adverse Change caused by impact -2 Moderate adverse -1 Minor adverse 0 Negligible 1 Minor positive 2 Moderate positive 3 Major positive Significance/Reversibility 0 Insignificant Impact implications / 1 Limited implications / easily reversible Reversibility of impact's effects 2 Broad implications / reversible with costly intervention 3 Nationwide or global implications / irreversible Duration 0 Immediate Duration / Frequency of Impact 1 Short term/construction period only 2 Medium term (five years of operation) 3 Longterm/continuous Extent/Spatial Distribution 0 None/within 1m from point of discharge/no affected Distribution of impact party 1 Immediate vicinity/household level/developer/consumer 2 Specific areas within the island/atoll/specific parties 3 Entire island/atoll/nation/all stakeholders

Based on the above scale, an impact matrix was developed for the proposed development to determine the overall impact of the proposed project. This matrix is given in Table 7-2.

An impact potential index was then developed from Table 7-2. The impact potential index table represents a product of the magnitude (M), significance (S), duration (D) and extent/spatial distribution (E) given in the above table. The sum of all key component specific indexes for one activity (i.e. sum by rows) provides the Activity Potential Impact Index (API) and the sum of all activity specific indexes for one key component (i.e. sum by column) provides the Component Potential Vulnerability Index (CPVI) which gives an indication of the vulnerability of each key component to activity related impacts. Table 7-3 represent the impact potential indices for the proposed project.

7.4 Overall Impacts of the Proposed Project

The overall impact of the proposed project is moderately positive due to the strong economic potential of the proposed project. The direct and project specific negative impacts of the proposed project are due to land clearing for buildings (moderate), increased noise and pollutant levels (moderate), construction of water villas (minor), dredging access channel and mooring area (major), dredged material disposal (moderate), beach nourishment (minor), shore protection (minor), installation of outfall pipes from the sewerage system (minor) and

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 101 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru use of reef areas for tourist activities (minor). Negative impacts related to beach maintenance, marine activities (diving, snorkeling, etc), solid waste, sewage disposal, water and energy production are causes for concern both during construction and during operation. They have cumulative and indirect as well as direct impacts. The creation of employment opportunities (direct and indirect) and related economic ventures (direct and indirect), government revenue, ownership and responsibility of taking care of the natural environment of the island and surrounding marine environment as well as the value of property associated with the development are considered as major positive socio-economic impacts of the project.

Table 7-2: Impact matrix for the proposed project

KEY COMPONENTS Environment Socio-Economic

PROJECT ACTIVITIES bait live incl. Reefs groundwater and Soil Lagoon/seawater Land/seascape Air/Noise Services and Infrastructure Health and Safety Employment Value Property payer consumer/tax to Costs Construction -1 1 0 -3 1 -2 1 -1 0 2 2 -1 1 1 2 2 2 -2 2 Beach nourishment and shore protection 12 1211113211133213 -1 1 0 -1 0 -1 0 -1 0 2 2 -1 1 1 2 2 2 -2 2 Water villas/over-water structures 11 1131113211333213 0 -12-11-10-10 2 1 2 2 1 2 2 2-11 Land clearance and land structures 332111113131133213 -1 1 -1 0 -1 1 -1 0 -1 0 0 -1 0 1 2 0 -1 1 Machinery and construction equipment 1111111111 1113 11 000000-10110-10 Workforce management 1111 11 Operation -1 0 -1 0 -1 0 -1 0 0 2 2 1 1 0 2 2 -2 1 Brine and wastewater effluent/sludge 31313131 3232 3222 -10-10-11-10-10 2 2-10 1 2-10-21 Solid waste 32313131313232323122 0 -1 1 -1 0 0 -1 1 2 2 -1 0 1 2 2 2 -2 1 Energy/electricity 1111 313232323222 -1 1 0 0 0 -1 0 2 2 -1 0 1 2 2 2 -2 1 Snorkelling, Diving and watersports 31 313232323222 -1 0 0 -1 0 -1 0 -1 1 2 2 -1 0 1 2 2 2 -2 1 Transfers and transport 33 3232323232323222 -100 -10210 22-101222-21 Regular beach nourishment 32 3232 3232323222

KEY: M S Magnitude Significance DE Duration Extent (spatial)

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Table 7-3: Impact potential indices for the proposed project

KEY COMPONENTS Environment Socio-economic TOTAL API

PROJECT ACTIVITIES Reefs incl. live bait groundwater and Soil Lagoon/seawater Land/seascape Air/Noise Services andInfrastructure Health and Safety Employment Property Value payer consumer/tax to Costs Construction Beach nourishment and shore protection -0.02 0 -0.07 -0.02 0 0.3 -0.01 0.07 0.3 -0.15 0.4 Water villas/over-water structures -0.01 0 0 0 0 0.3 -0.01 0.22 0.3 -0.15 0.65 Land clearance and land structures 0-0.22-0.0200 0.070.15 0.07 0.3 -0.04 0.31 Machinery and construction equipment -0.01 0 -0.01 00000.07 0 -0.01 0.04 Workforce management 00000000.01 0 0 0.01 Operation Brine and wastewater effluent/sludge 000000.30.070 0.3 -0.1 0.57 Solid waste 0 0 -0.04 0 0 0.3 0 0.15 0 -0.1 0.31 Energy/electricity 0 -0.01 0 0 -0.04 0.3 0 0.15 0.3 -0.1 0.6 Snorkelling, Diving and watersports -0.0400000.300.150.3-0.1 0.61 Transfers and transport 0000 -0.07 0.3 0 0.15 0.3 -0.1 0.58 Regular beach nourishment 0000.15 0 0.3 0 0.15 0.3 -0.1 0.8 TOTAL CPVI -0.08 -0.23 -0.14 0.13 -0.11 2.47 0.2 1. 19 2 . 4 - 0 . 9 5 4.88

API = Activity Potential Impact Index CPVI = Component Potential Vulnerability Index

The table above indicates that the project has some negative environmental impacts during the construction phase as well as operational phase, which are not as strong as the positive outcomes of the project, as a result of which the total potential impact index for the project is largely positive. Therefore, the project may be allowed to proceed as proposed.

7.5 Project Specific Impacts – Construction Phase

The construction phase of the proposed project involves operation of machineries, vehicles, clearance of vegetation, dredging and minor excavations. This would be carried out by a fairly large work fleet. Hence there will be a considerable amount of social and environmental impacts; both negative and positive. For instance, amongst the potential environmental impacts include loss of valuable habitat for various marine life forms in addition to increased pollution. However, there will be an increase in job opportunities for the locals of the area.

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The major impact in term of area will be felt directly and indirectly on the lagoon and reef flat areas from construction activities of the proposed over-water villas and jetty. This impact will be related to the potential increase in turbidity due to disturbances in the seabed during the construction activities. It is estimated that less than 2% of the shallow lagoon and reef flat area will be impacted as a result of all construction activities of the proposed development. These impacts will be short-term depending on the duration of construction activities.

Indirect impact on the coral reef is estimated at less than 5% area of the whole reef and direct impact will felt on less than 1% area of the reef. Direct impact was estimated for reef entrance channel in the initial EIA report, however, it has been identified that there is no further dredging requirement for the entrance channel. This may be because some dredging may have been undertaken following the approval of the initial EIA report.

Indirect impacts can be reversible over time depending on various natural and human induced factors such as natural rate of reef recovery and magnitude of disturbances from operation of the proposed resort. These can only be assessed through long-term monitoring.

The following subsections include a detailed assessment of impacts from all the components of the construction phase of resort development on Kanbaalifaru.

7.5.1 Temporary facilities, constructional material machinery and workforce

Based on the experience of several projects of this nature that has been undertaken in the region and elsewhere in the Maldives, this project is expected to have minor negative impacts of noise and pollution. During the construction phase, Suspended Particulate Matter (SPM) is expected to be the critical pollutant associated with the construction activity and hauling of material. Additionally, Kanbaalifaru is a habitat subjected to minimal human activities and air pollution. However, given proper mitigation measures are employed, the impacts are expected to be at a minimal level.

The use of diesel as well as petrol in vehicular engines and operation of machines such as trucks and excavators cause emissions of carbon dioxide, sulphur dioxide and nitrogen oxides with fine particulate matter. For the proposed project, carbon emissions are considered to be negligible. However, carbon dioxide being the primary greenhouse gas and the main

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 104 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru contributor to global warming, likely future carbon emissions would be a cause for concern, as the impact cumulatively adds to the global burden of carbon emissions.

There is an unlikely risk of major pollution given that the hazards are well controlled. Usually, in projects involving heavy machinery, fuelling of excavators and other machinery is undertaken manually and it carries the risk of spills. Such spills are not a cause for concern in the case of the construction equipment as fuel prevention measures are in place. The impact on the quality of soil and groundwater is not going to be significant as proper storage facilities will be maintained for construction materials, construction waste and oil and grease.

Construction materials such as cement and fuel for machineries have the potential to damage the marine and terrestrial environment. Both terrestrial and coastal activities can pollute the environment including soil, aquifer and coastal water due to accidental spill of oil and chemicals. Sometimes these materials are thrown into the environment due to absence of appropriate supervision at work sites.

Pollution of the lagoon and reef system can be caused by waterborne and windblown debris escaping from the construction. Reefs also get damaged due to boating activities including mooring, loading and unloading of materials

Waste from the construction and work force will be sorted and separated on site and sent to designated landfill on a weekly basis. Liquid waste may be of concern given the large workforce; however, as they will be properly contained by means of temporary sanitation tanks and later disposed properly using the STP after sewerage system has been established.

The project would not affect social values, norms and beliefs due to the workforce. In fact, there will be very little mixing of the workforce with local populace and workforce would be mainly constrained to the worksite, however there maybe such issues arising between the workers as both foreign and local laborers are expected to take part in the project. Nevertheless, the duration of construction phase being fairly short, the significance of any such impacts would be negligible.

7.5.1.1 Health and Safety

Construction of large development projects such as resorts will involve a large number of construction workforce and a number of risks related to construction activities. Key impacts predicted for the construction workforce is related to health and safety issues. Often in such

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 105 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru construction environments, workers are prone to injuries and diseases. Also, if precautionary measures on health and safety are not taken into serious consideration, the entire operation may be affected as a result of incidents and injuries.

7.5.2 Construction of Sewer Outfall

Construction of sewer outfall would impact to coastal water, lagoon bottom and reef during construction due to suspension and re-suspension of fines while laying and anchoring the pipes. This impact would be minor and short-term. Since treated effluent is disposed to the area at depths of over 10m, it may not be worthwhile considering alternatives to the proposed sewer outfall.

However, if untreated sewage were to be disposed, an ideal location with adequate mixing and not generally used for snorkeling and other activities shall be chosen. In the case of Kanbaalifaru this could be the northern and southern ends. The proposed outfall location at the southeast is considered appropriate since the location would provide adequate dilution and will keep the sludge away from the island and into the deep waters at all times. The alternative location would be the northeast end, which is too far from the proposed sewage treatment plant building, for which reason it is considered inappropriate.

7.5.3 Feed water intake

Feed water for desalination plant is proposed to be drawn from a borehole. Borehole drilling does not have adverse environmental impacts. However, the boring methodology is important. Details of the borehole(s) will be provided to EPA when applying for the registration of desalination plant as they are not available at this stage.

7.5.4 Brine discharge

Brine is discharged in the lagoon. The impact of such small discharges is negligible. Almost all audits and EIA reports carried out in the past indicate that there is no impact of hyper- salinization from brine discharge in the lagoon for such small scale operations.

7.5.5 Arrival and Service Jetty

The proposed arrival and service jetty is a piled jetty with concrete footings buried in the ground. Therefore, there would be minor impacts from the installation of the footings. The

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 106 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru arrival jetty is located towards the middle of the western side, therefore, the impact on sediment transport due to the piles as well as the jetty structure would be almost negligible. The service jetty is located on the eastern side where it is subjected to constant wave action, due to which the sediment does not deposit on this area; therefore no large impact due to sedimentation is envisaged. Furthermore the size, location and capacity of the jetty and the mooring area is appropriate for the functioning of the proposed project.

7.5.5.1 Water villa construction

Some degree of sediment will be released from construction of the proposed water villas on the island.

Some sediment from the excavation to bury footings of columns of the water villas on the north may move towards the reef or reef patches while that for the villas on the south is expected to be even less. The impact is minor and short-lived. Given that the reef flats in both areas have very low coral cover, no major impacts on the reef are expected.

Furthermore, during the operational stages the water villas might actually help to minimize the impact on the shoreline as the several piles act to disperse wave energy to some extent.

7.5.6 Removal of Vegetation

Inland structures are considered to be those within the vegetated area of the island. These include almost all structures except jetties and water villas. Tourist facilities including guest rooms are within the coastal zone while staff facilities and utilities are in the middle of the island where the primary vegetation is found.

Structures such as staff area and facilities, utilities buildings and Mosque would have greater direct impacts on terrestrial flora and fauna than the guest villas and other structures in the coastal zone. The guest villas, Reception Building, Main Restaurant and Coffee Shop are on the coastal area and would impact the coastal vegetation. Coastal vegetation (heylhi) is the second line of defence against strong waves. Therefore, it is important to preserve coastal vegetation and therefore, Tourism Regulations require that all buildings are well behind 15m of coastal vegetation. The proposed design ensures this.

Direct impacts of inland structures will be due to clearing of vegetation, especially mature trees or primary vegetation. Clearing of vegetation is a crucial global issue which needs to be

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 107 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru undertaken carefully considering all means to avoid felling palms and other mature trees. Since the island vegetation is young and the building footprint is small, mature trees can be easily avoided during the setting out of buildings. Therefore, it is recommended to plan buildings as well as walkways to buildings around mature trees during the stakeout and trees are removed only if necessary. Even then, those mature trees that need removal shall be transplanted elsewhere. Furthermore, stake out shall be done with care to minimize unnecessary felling of vegetation of any sort. If any tree requires removal, they would be carefully removed and transplanted elsewhere. Moreover the use of the existing cleared area should be utilized in the best possible manner without clearing more areas unnecessarily.

7.6 Project Specific Impacts – Operational Phase

7.6.1 Pollution

Likely oil and chemical spills from operation of power generation facilities, wastewater treatment and desalination will pollute the air, groundwater and soil. This pollution usually occurs either due to accidental spill or unregulated emissions into atmosphere due to absence of appropriate measures to manage such operations. Key impacts identified include  Contamination of soil from oil and chemical spill  Contamination groundwater from oil, chemical and wastewater  Air pollution due to emissions from powerhouse  Generation of solid waste from accommodation blocks, kitchen/restaurants, office etc  Generation of liquid waste from accommodation blocks, office blocks, restaurants, bars, engine repair and maintenance areas, desalination etc.

Inappropriate handling of solid waste and garbage and its disposal into the surrounding environment can have impacts on the marine environment including pollution of coastal waters and consequential effects on coral reefs and associated reef organisms. The types of solid waste generated during the operation will mainly consist of plastic bags, glass and plastic bottles, cans, tins, paper, wrappings, other discarded litter and possibly human faeces. Such items can have adverse impacts on the marine environment ranging from reduced aesthetic beauty of the surrounding area to degraded water quality as well as potential ecological disturbances. Ecological impacts associated with solid waste disposal into the marine environment include reductions in fish populations due to water pollution, as well as killing corals and other marine organisms by smothering by certain items such as plastic bags.

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Often wastewater gets inappropriately discharged into marine environment during operational phase which cause direct contamination of surrounding water causing degraded water quality. Some of the sources include wastewater from boats that are usually contaminated with oils and fats, cleaning agents, detergents and other chemicals. Most of the wastewater is potential pollutants that can have direct effects on coral reef ecology and has potential to harm and devastate the ecosystem. The proposed project will have very few boats at one given time and discharges would be negligible.

Brine concentrate generated from seawater desalination is not expected to affect the environment. Effects, if any, would be evaluated as part of the proposed monitoring program under this project.

Discharge of treated sewage via marine outfalls is not expected to cause any noticeable impact on the marine environment as the currents and wave action will disperse remaining minerals and coli form content of effluent to surrounding area to suitable levels. Even in case of an STP failure, given the likely quantity and duration of discharging untreated sewage, it is not expected to cause significant impact on the marine environment.

7.6.2 Transport Related Impacts

The use of diesel as well as petrol in vehicular engines and operation of machines cause emissions of carbon dioxide, sulphur dioxide and nitrogen oxides with fine particular matter. Carbon dioxide being the primary greenhouse gas and the main contributor to global warming, likely future carbon emissions would be a cause for concern, as the impact cumulatively adds to the global burden of carbon emissions.

7.6.3 Marine‐ based Activities

The lagoon and reef around the proposed island is pristine and clear, free from direct human influence. However, with the beginning of the resort development and operation these marine based recreational activities would cause damage to reefs and reef ecological system followed by either killing or forcing some fishes to leave the reef environment.

7.6.4 Air, noise and light pollution

The proposed method of using diesel generators for production of electricity needed (including RO plant and other utilities) will release pollutants such as carbon dioxide, sulfur

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 109 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru dioxide and nitrogen oxides to the atmosphere. These emissions in itself will not be significant; but given the cumulative nature this impact is considered minor to moderate.

The increased tourism related activities on the island and surrounding marine environment will undeniably disturb the fauna by means of increased noise levels. As the animals are not used to human, it may stress them; nonetheless, the animals are expected to get used to the increased noise levels and exposure to human in time. Hence this impact is considered as minor. Similarly, during operational phase of the project, lights will be used on the island; this has potential to stress wildlife as well. Though unlikely, it is possible some fauna may abandon the island.

7.7 Socio-Economic Impacts

The socio-economic impacts from the proposed project are positive, in terms of job opportunities and other income generating opportunities. These include opening new market(s) for agricultural products, thatch, handicrafts and fishery products required for the construction, operation and maintenance of the facility.

The proposed tourist resort development on Kanbaalifaru, from the construction and during the operation stage would have few negative but many important socio economic benefits to the people of Maldives in general and the islands close to Kanbaalifaru in particular. Some of the impacts would be direct but many would be indirect due to the creation of economic and employment activities including design consultancy, construction and operational aspects. The socio-economic benefits of the resort have direct and indirect world-wide impacts that last over the life of the resort.

7.7.1 Significant negative socio‐ economic impacts

The development of a resort would mean an end to the reef and bait fishing from the reef and lagoon of Kanbaalifaru and all the other traditional and existing rights and uses of Kanbaalifaru for the general public. Shaviyani Atoll has limited reefs where fishermen can do bait fishing which is crucial for the dolphin friendly pole and line fishing which is done in the Maldives. Furthermore, the atoll community and others would no longer be allowed to visit the island as before and use Kanbaalifaru as a picnic island. Kanbaalifaru, however, is rarely used as a picnic island or by safaris and yachts visiting the area.

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7.7.2 Significant positive socio‐ economic impacts

The negative impacts of the project as mentioned above are expected to be offset by the development and operation of the resort. The atoll community as well as the nation in general would have many benefits from this island being developed as a resort. The socio economic benefits of the combined phase of construction and operation of the resort would include increased public revenue through tax, large number of employment opportunities, opportunities for the expansion of existing businesses, development of new business ventures, easy access to and from Male’ for the local populace and so on.

The population of Shaviyani Atoll has been shrinking due to the outward migration from the atoll to other regions. Migration is linked to the socio-economic well-being of the migrant, and is very much influenced by opportunities and incentives as perceived by the migrants. The Internal Migration Patterns and its Impact in the Maldives (2005) examined the reasons for migration reveal the lack of employment opportunity is one of the driving factors for migration.

The proposed development and operation of the resort will create many employment opportunities. The construction of the resort can create over 400 jobs. The proponent intends to employ as many Maldivians as possible during the construction stage and seeks to contract different components to local parties. The operation of the resort would create more than 150 new jobs, more than 50% of them would be reserved for Maldivians focusing more on Shaviyani atoll and the region. So as a result of this development over 75 new employment opportunities will be created in the Maldives for the Maldivians. The salaries would be based on the market rates for similar jobs with additional benefits.

The creation of new employment opportunities would enhance the quality of life of the families of the employees as they would be able to pay more for basic services and other requirements such as food, clothing, shelter, education, health and alike.

As per the norm, there would be excursion trips to various islands in the atoll especially Funadhoo and Lhaimagu which is expected to create opportunities for the locals to sell their products (mainly handcrafted items) directly to the tourists. This in turn is expected to help the handicraft industry to flourish and national artworks promoted. There will be several attempts of making uses of local produces, products and services during the construction and operation of the resort.

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Furthermore, close proximity of the resort to the nearby inhabited islands in the atoll, especially the capital island, Funadhoo, would provide the opportunity for the employees to commute to Kanbaalifaru. These options would attract locals including women in the operation stage of the development.

The development of tourism product targeted to the luxury travellers may also help to revive the cultural heritage sites in the atoll and the region, including those in the neighbouring Firubaidhoo.

7.8 Uncertainties in Impact Prediction

Environmental impact assessment involves a certain degree of uncertainty as the natural and anthropogenic impacts can vary from place to place due to even slight differences in ecological, geomorphological or social conditions in a particular place. The level of uncertainty, in the case of the proposed development, may be expected to be low due to the experience of similar projects in similar settings in the Maldives. Nevertheless, it is important to consider that there are elements that are new (such as the alternative design) and that there will be uncertainties and to undertake voluntary monitoring as described in the monitoring programme given in the EIA report.

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EIA for the Proposed Resort Development on Sh. Kanbalifaru

Figure 7-32: Summary of socio-economic and environmental impacts Activity Causal Factors Impact Impact Significance Clearing of vegetation for Reduced number of trees on the Loss of vegetation Moderate building areas island Loss of habitats for birds and Low domestic animals Loss of CO2 sinks Low

Water villa construction Sediment movement and Smothering of corals Moderate deposition Loss of habitats for juveniles Low-moderate Increased sediment level in the Low water column

Water and sewerage system – Leaks in the system Groundwater quality deterioration Negligible construction and operation Operation of STP/pumps Atmospheric pollution Negligible

Discharge of chemical and Pollutes soil, water Low wastewater into ground/sea Installation of sewer outfalls Re-suspension of fine Water quality degradation Negligible sediments during installation Impact on corals (reef) Low Waste and wastewater disposal Discharges or accidental spill Marine water pollution Low to including brine of motor oils, lubricants, moderate hydraulic fuels, other chemicals such as antifoulants and paints in vessels and wastewater Machinery and equipment for Heavy machinery operation Local noise and air pollution Insignificant construction and construction Accidental damage from Local damage to reefs Low to operation of barges, etc. moderate Accidents during machinery Oil and waste spillages to Low to and material transport to site oceans/reefs moderate Handling and transport of goods Loading/unloading/movement Dust and air emissions Insignificant and materials of goods Transport Increased risk of accidents Low Cumulative emission Low Recreational activities Use of reef for different Accidental damage to corals Low to activities moderate Construction of the resort Works/activities related to the Direct income to employees Positive project Indirect benefits to employees Positive Indirect benefits to societ/ies Positive Operation of the resort Rent and tax Generates Government revenue Largely Employment Income to local people/expatriates positive Development of related sectors Indirect benefits to society/ies Economic opportunities Social interactions

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8 Mitigation Measures

8.1 Introduction

It is evident that island and coral reef environments are highly susceptible to changes and implications that will bring about from the development of the proposed resort. As described earlier, some impacts are felt largely while others are localized. However, most of the environmental impacts associated with the development of the resort cannot be either reduced or minimized unless effective environmental management and mitigation as well remediation process are well placed accordingly.

The following section describes key environmental mitigation measures that will be undertaken during the construction and operation of the proposed domestic aerodrome.

8.2 Mitigation Measures – Construction Phase

8.2.1 Clearing of vegetation

Since the island vegetation is young and the building footprint is small, few or no mature trees are expected to be removed. Yet, it is recommended to plan buildings as well as walkways to buildings around mature trees during the stakeout and trees are removed only if necessary. Even then, those mature trees that need removal shall be transplanted elsewhere. Furthermore, stake out shall be done with care to minimize unnecessary felling of vegetation of any sort. It has been observed in some resort projects undertaken in the past that areas are cleared without appropriate setting out of building footprint or cleared for the purpose of setting out. This shall be avoided. Unnecessary clearing must be restricted by appropriate supervision and accurate stakeout. If any tree requires removal, they would be carefully removed and transplanted elsewhere with an additional tree. It is to be noted that the felling of trees should be started slow as to allow mobile fauna to relocate themselves.

8.2.2 Waste Management

The recommended waste management plan is aimed to reduce the amount of waste for disposal through the development of outline plans for waste avoidance, material re-use and recycling. Mitigation measures are proposed to alleviate the impacts caused by the excavated materials and residual wastes during their handling, temporary storage on site, transportation

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 115 Consultant: Sandcays EIA for the Proposed Resort Development on Sh. Kanbalifaru and final disposal. Waste management procedures will be implemented to minimize potential impacts to the environment. This may be achieved by consideration and application of the following:  Avoid and/or minimize waste generation wherever practical by altering the site procedures  Maximize the opportunity for reusing/ recycling/ recovering materials and thereby negate/minimize the disposal requirements (e.g. by waste segregation according to type, separation of recyclable materials such as metal, maximize reuse of timber framework wherever possible, utilization of excavated material for filling or landscaping); and  Ensure that all treatment and disposal options comply with all relevant guidelines and standards.

The following practices will be followed to minimize waste generated from construction activities;  Segregate waste materials according to types to facilitate re-use;  Segregate different materials at source as far as practical;  Co-ordinate material deliveries to minimize storage times on site to avoid damage and  Provide training to site staff in waste minimization practices  It will be ensured that construction debris will be reused on site to the maximum extent possible.

The following measures will be implemented to mitigate the likely adverse impacts to the environment.  Stockpile material and sites will be covered to prevent washout and erosion during heavy rainfall.  Dust suppression techniques will be adopted;  Designated areas for stockpiling will be fenced.

A temporary refuse collection facility will be set-up by the contractor and wastes will be stored in appropriate containers prior to collection and disposal.

The waste management plan for construction phase has been summarized in Table 8-1.

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Table 8-1: Waste management plan – construction phase  minimization of waste generation for disposal (via reduction/ re-use onsite);  segregating waste materials according to type to facilitate re-use;  separation of inert construction materials;  co-ordinate material deliveries to site;  training site staff in waste minimization practices;  transport of wastes off site as soon as possible;  maintenance of comprehensive accurate waste records;  use of re-useable metal boarding / signboards;  no on-site burning will be permitted

8.2.3 Human Environment

Considering the nature of work, proper equipment and safety gears will be provided to the workers. To minimize the risks associated with health and safety issues, the project proponent will be responsible to ensure that adequate health care arrangements will be available at the site throughout the construction period. Furthermore the working sites should have clear signage with proper lighting in order to avoid accidents during the works.

In order to prevent the complication of the negative social interactions that may occur during works, the staff should be well aware of the working hierarchy and whom to report if a problem occurs. Furthermore, they should be and made aware of their rights, roles and responsibilities throughout their working period. Finally, there should be sufficient level of supervisor, as such a workforce would comprise of locals and foreigners from different nationalities.

8.2.4 Air

Mitigation measures to minimize emissions from machinery and vehicles related to the project including mobilisation and operational phase include:  Use light fuel (with low sulphur content) as much as possible.  Avoid unnecessary operation of vehicles, machines and boats.  Keep in place appropriate transport management system.

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 Minimize mobilisation by planning the mobilisation. In most of the projects undertaken near cities, several mobilisations happen to not only increase the cost of the project but also the environmental impact. Appropriate planning is the key.  Keep in place appropriate logistic management system.  To mitigate the impacts of dust during construction, appropriate dust control measures shall be in place such as watering work areas to suppress dust.

8.2.5 Marine Environment

During the construction of water villas, any live corals that may be directly impacted shall be transplanted elsewhere. Care should also be taken to minimize sedimentation on the reef when placing water villa footings and columns. Precast footings and columns shall be used and excavator movements shall be minimized. Excavator is preferably moved on barge to minimize sedimentation and if high bed excavators were to be used, they shall move as far from coral reef flat areas as possible. Furthermore if a sand bed is used, then it shall be carefully removed as soon as the work is completed, while proper monitoring is to be conducted on the water quality and the health of the existing corals within the impact area. In addition, the changes in the sediment movement and deposition should be monitored throughout the constructional phase.

Mitigation Measures – Operational Phase

The following sections describe proposed mitigation measures to be undertaken during the operational phase of the proposed resort. A detailed environmental management plan for use during the operational phase of the resort is included in the appendix of this report.

8.2.6 Waste and wastewater

For waste generated from housekeeping, restaurants and storage:  Avoid chemical and oil spills into the environment  Adopt good housekeeping measures  Adopt appropriate waste management practices  Adopt composting as a management method of green waste, given the wide availability of such waste.  Records of waste management shall be kept, especially in the waste transferring stage.

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 Regular workshops and trainings shall be carried out for the workers  Operational controls shall be clearly defined as this is an area where a lot of negative impacts could occur if carried out wrong, or carelessly.  Reviewing the existing waste management practices annually, while bringing out the necessary changes.  Avoid direct discharge of untreated liquid waste (spent oil, kitchen wastewater, sewage) into environment  Build appropriate grease traps at restaurants and kitchen and appropriate drainage systems in engine repair and service areas  Avoid cleaning and washing of oily tools, equipment and parts (e.g. engine parts, machines) on bare ground  Avoid washing unnecessarily, for instance the towels in the guest rooms need not be washed every single day without consulting the guest, but a separate container can be kept where the guest could keep what he/she thinks need to be washed. These are small steps, yet taken in a scale of a year, the effect would be significant.  Avoid open dumping of solid waste

Brine concentrate generated from seawater desalination is not expected to affect the environment. Effects, if any, would be evaluated as part of the proposed monitoring programme under this project.

In order to mitigate the environmental impacts from various activities during the operation of the resort, the following measures need to be undertaken and strictly enforced. These include:  Solid waste collected and transported to Thilafushi under strict supervision and monitoring.  Appropriate solid waste collection facilities shall be placed on the island.  Boat cleaning within the jetty area should be avoided.  Fuelling of boats and vessels within the island lagoon should be closely supervised and monitored.  Bins and similar waste management facilities shall be provided at all appropriate locations around the island.  Avoid discharge of untreated wastewater into marine and terrestrial environment.

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8.2.7 Recreational activities

Marine based water sports activities should be limited as much as possible, as to reduce impact of increased disturbances to marine life forms. There should not be any form of direct contact with these wild life (e.g. hands-on wildlife) and avoid feeding them as to keep them around.

Impacts on marine environment from recreational activities such as snorkeling and diving;  Provide appropriate training to all those engaged in marine recreational activities.  Provide information to tourists as well as staff about the vulnerability of corals, protected species and its associated ecological system.  Put up signs on important locations such as turtle nesting sites for tourists and staff to be mindful of sensitive fauna.  Consider reef restoration or coral propagation programmes at important snorkeling locations.  Regular monitoring of the reef for regeneration or death of corals so that important steps can be taken to minimize or control degradation of the reef.

8.2.8 Air and light pollution

Some areas of the island may be used by turtles for nesting; therefore these areas should be studied and lights close to the beach should be avoided. Additionally, use of this area at night by tourists and staff should be limited and controlled as to minimize disturbing nesting turtles.

Measures to minimize dependency on fossil fuel including use of solar water heating and energy efficient equipment and lighting have already been incorporated in the project. Furthermore, alternative energy such as solar cells should be considered where practical and energy optimization considered depending on power consumption. Energy optimization would include using excess heat from gensets, where heat is the main form of energy and adjusting to energy demand by planning the use of energy intensive equipment during non- peak hours. Further measures include minimizing on air conditioning and using ambient light and natural ventilation would be considered.

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8.2.9 Shore protection

As any nearshore coastal protection measure, the groynes will change the dynamics of the coastline it is applied to. Where some areas would be eroded while in other areas accretion will occur. The amount of accumulation and erosion are greatest closer to the groyne and the effect diminishes with the distance from the groyne system. Moreover in the Maldives it has been noted that the longshore transport is quicker in the south west monsoon in comparison to the north east monsoon. These changes in the shoreline would be the most significant in relation to the groyne system. Therefore a beach nourishment project would minimize these impacts, a beach nourishment plan is proposed in the alternatives section.

A post project sediment budget should be developed for areas immediately downcoast and upcoast of the groynes to establish the extent of any sand deficit or shoaling problems caused by the goyne system. These sediment budgets can be used to determine the extent of beach fill that would be required in the next nourishment project. There would be changes in the current patterns around the groyne field as small eddies and rip current may form around the goryne system. It is important that these changes be studied in order to improve the system over time.

The groyne will be subjected to the weathering effect due to the constant wave action on the shoreline, if the groyne is damaged even partially, it may not serve its purpose and sand may move through the groyne without it being able to retain the desired amount. If this is suspected to be the case, first thing is to make sure whether sand is actually passing through the groyne or around it. According to U.S Army Corps of Engineers, a study could be conducted to clarify whether the groyne has become more permeable than desired. To carry out this study, a dye can be injected into the water updrift of a structure and signs of the dye are sought downdrift of the structure. Wave setup on one side of the structure creates a hydraulic gradient that causes a flow that in turn carries sand through the structure. If permeability is a problem, the dye appears downdrift within minutes of its updrift injection. If the study comes out to be positive, the necessary void sealing works could be conducted without further delay. However it is important to hire an experienced, reliable contractor who would monitor the works and ensure that the structure has been sealed adequately.

Finally there would be some aesthetic impacts due to the groynes, as it might take the natural feel from the white sandy beaches as the theme of the Maldivian tourism is “Maldives always natural”. However, if the given that the groyne field is going to be made with rock boulders which natural stone (rock boulders) this impact is expected to be reduced considerably

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8.2.10 Co‐ corporate social responsibility (CSR)

It is important for such developments to implement the CSR component as it would be beneficial to the proponent as well as the locals. For the proponent, there are many benefits in adopting CSR, some of which are as follows:

 Ease in the operation of the resort due to the enhanced relationship with the neighboring islands.

 Enhancing employ recruitment and retention.

 Build the resort’s reputation locally and globally.

 Build positive government, NGO and local relation.

 Get trustable and quality input of local goods.

 Broader scope for island excursions.

 Greater tourist satisfaction from island excursions.

 Enhances the sustainability of the resorts operation as the locals and the government would see higher value in the operation of the resort.

Some methods of implementing these are:

 Employing more locals, specifically from the neighboring islands.

 Introduce local packages with benefits such as lower cost.

 Assisting in the development of the neighboring islands.

 Assisting the locals in situations of distress or natural disasters.

 If the resort develops an educational center, such as a coral laboratory, the students of the neighboring island could visit in order to gain new insight and information.

 Going for the local businesses rather than importing goods such as souvenirs.

 Respecting the norms and the culture of the Maldives in all aspects of its operations.

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Figure 8-1: Summary of mitigation measures Mitigation measures for minimizing impacts of the Implementing Technology/ Cost development responsibility equipment Design Phase  Identify areas for development on land and Project Identify clean Included marine environment. engineer/design technologies such in Project  Clearly identify and mark the areas that engineer/consultant Costs require clearing of vegetation and coral reefs.  Design all development on the principle of cleaner production

Construction  Adoption of early warning mechanism EIA Consultant Choose Included phase through regular monitoring for level of Contractor appropriate in Project suspended solids and /or turbidity during technologies and Costs construction works equipment  Ensure proper and efficient operation  Selection of appropriate development windows (e.g. execute coastal and marine work in low tide)  Monitor suspended solids in water flowing out and spreading  Contain marine and coastal work sites to avoid sediment flow away from work site  Completion of work as soon as possible but by avoiding working at night  Minimized felling of old trees  Replant on another location any old coconut palm removed from work site  Minimize clearing of vegetation  Avoid any spillage into the ground that can contaminate soil and groundwater  Keep sensitive areas protected from damage  Avoid discharge of untreated sewage/wastewater effluent into ocean  Minimize removal or destruction of corals for sewage outfall, coastal protection or any other purpose Operation  Monitor marine water quality, groundwater Developer Included phase quality, beach profiles and shore dynamics, (Proponent), in Project coral reef as well as other aspects at Island Council and Costs designated locations EPA  Ensure enforcement from government regulatory bodies Mitigation measures for mitigating impacts of machinery and Implementing Technology/ Cost equipment responsibility equipment Design Phase  Plan for the use of appropriate equipment. Project engineer Included  Provide appropriate working windows in Project Costs Construction  Ensure proper monitoring of construction Contractor Included phase activities in Project  Establish strict regulations and safety Costs measures for machinery operation  Locate storage area on the island  Provide effective management of fuel handling area and storage of other dangerous substances Mitigation measures for mitigating impacts of waste and Implementing Technology/ Cost wastewater disposal responsibility equipment Design Phase  Design for appropriate solid and liquid waste Project engineer/ Choose Included disposal such as provision of disposal developer appropriate in Project facilities and collection procedures technologies Costs  Establish appropriate mechanism for waste and wastewater management employed with trained and informed personnel.

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Construction  Construction waste must be disposed of Contractor/ developer Included phase appropriately in Project  Construction debris shall not be disposed in Costs the marine environment Operation  Produce and enforce strict regulations for Developer/ Included phase liquid and solid waste disposal from vessels Management in Project in the jetty (arrival) area Costs  Disposal of solid waste including fish waste, wastewater and waste oil disposal other than designated areas shall be prohibited  Fuelling of boats and vessels on sea shall be closely supervised and monitored  Ensure emergency procedures in case of spill out of dangerous substances are in place  Appropriate solid waste collection facilities shall be placed Mitigation measures for mitigating impacts of goods and Implementing Technology/ Cost material handling responsibility equipment Design Phase  Raising awareness and utilizing Project engineer/ Included environmental best practice Consultant/developer in Project  Careful planning to ensure minimal Costs disturbance to access the island Construction  Development shall be carried out in a manner Contractor/developer Included phase it will not affect or minimize the effects on in Project the existing ecological system Costs  Ensure emergency procedures in case of spill out of dangerous substances are in place. Identify clear responsibilities.  Material wasted shall be properly handled and no material shall end up in the marine environment or beach Operational  Produce and enforce hazardous material Developer Implement good Included phase handling and storage procedures housekeeping, in Project  Ensure emergency procedures in case of spill provide training Costs out of dangerous substances are in place. and raise Identify clear responsibilities. awareness  Enforce health and safety procedures at all work sites

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9 Environmental Monitoring

9.1 Introduction

Environmental monitoring is essential to ensure that potential impacts are minimized and to mitigate unanticipated impacts. The parameters that are most relevant for monitoring the impacts that may arise from the proposed project are included in the monitoring plan. These include water quality, sedimentation, shore dynamics, live coral cover and nektonic fauna.

Monitoring would ensure that the proposed activities are undertaken with caution and appropriative care so as to protect and preserve the built environment of the areas in proximity to the site or those areas and environmental aspects affected by the development.

The purpose of the monitoring is to provide information that will aid impact management, and secondarily to achieve a better understanding of cause‐effect relationship and to improve impact prediction and mitigation methods. This will help to minimize environmental impacts of projects in future.

The monitoring plan shall target to measure:  live coral cover and nektonic fauna  the amount of sedimentation on the reef  water quality and visibility  beach profile and hydrodynamic changes  impacts are accurate and mitigation measures taken are effective and  the thresholds are kept within the baseline limits predicted.

9.2 Recommended Monitoring Programme

The annual monitoring programme targeted at monitoring the terrestrial and marine environment of Kanbaalifaru is given in Table 9-1. This programme starts from the onset of the project. In addition, if the project were to be delayed by more than six months from the approval of the EIA report, it is proposed to undertake further assessment of all baseline components covered in this EIA report. The proponent’s commitment to undertake this monitoring programme for at least three years forms part of this report. However, the commitment shall continue with a revised monitoring programme, if necessary.

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9.3 Monitoring Report

A detailed environmental monitoring report is required to be compiled and submitted to the Environment Protection Agency yearly based on the data collected for monitoring the parameters included in the monitoring programme given in this report. EPA may submit the report to the relevant Government agencies in order to demonstrate compliance of the Proponent.

The report will include details of the site, strategy of data collection and analysis, quality control measures, sampling frequency and monitoring analysis and details of methodologies and protocols followed. The report will also include fuel and water consumption data and greenhouse gas emission calculations.

In addition to this, more frequent reporting of environmental monitoring will be communicated among the environmental consultant, project proponent, the contractors and supervisors to ensure possible negative impacts are mitigated appropriately during and after the project works.

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Table 9-1: Annual monitoring programme for Kanbaalifaru

No. Indicator/locations Parameters to be monitored Frequency and duration M1 M4 M7 M10 M12 Total Rate (USD) Total (USD) Marine water quality (outfall location and Water quality: DO, pH, Turbidity, TSS, Hydrogen 1 Every six months 2 2 4 15.00 60.00 control) sulphide, BOD, COD Live coral cover and fish survey - Photo quadrates/LIT 2 Marine life/biodiversity (3 locations) Every six months 2 2 4 35.00 140.00 and fish survey Every three months for one 4 Currents/hydrodynamics (2 locations) Drogue tracks 2222 8 30.00 240.00 year Water quality: temperature, pH, salinity/TDS/EC, 3 Groundwater quality dissolved oxygen, hydrogen sulphide, nitrate, Every six months 5 5 10 200.00 2,000.00 phosphate, total and faecal coliform Air quality at STP, middle of island and 6 Hydrogen sulphide, ammonia (optional) Every three months 3333 12 25.00 300.00 northern end of island (3 locations) Total monthly production (treated effluent and RO plant Daily statistics (regularly 7 Water production data 0 - - product water) collected by resort) Daily statistics (regularly 8 Fuel and energy data Total monthly fuel use, energy production 0 - - collected by resort) 8 Annual Monitoring Report 1 1 770.00 770.00 TOTAL 1,235.00 135.00 1,235.00 135.00 770.00 3,510.00

Note: M indicates Month

Proponent: Kanbaaalifaru Development Pvt. Ltd Consultant: Sandcays Page |125 EIA for the Proposed Resort Development on Sh. Kanbalifaru

10 Conclusions

In conclusion, it appears justified from a technical and environmental point of view, to carry out the proposed project to develop a tourist resort on Kanbaalifaru in Shaviyani Atoll. The main negative impacts of the proposed project are from the construction of the water villas. Vegetation removal is also considered as a moderate negative impact, however, the area is small and there will be minimal removal of large or mature trees due to the absence of mature vegetation in the island. It would be necessary to transplant coconut palms from areas approved for clearing under different housing and other schemes. The impact of sewage disposal is considered minor negative or negligible since sewage will be treated before disposal. Brine discharge into the lagoon has no known negative impacts. Feedwater intake from boreholes is considered normal practice with minor negative impacts and no impacts on groundwater table due to the depth of the borehole.

It is important to note that there may be an environmentally sensitive area, which are the possible nesting sites of marine turtles in the north western beach area or other areas, which shall be understood during the construction phase prior to any beach filling or shore protection works. The options of beach nourishment have been clearly assessed while it would be necessary to reduce the amount of disturbance to these areas in both the construction and the operation phases of the proposed development.

Monitoring of water quality and changes, especially turbidity and total suspended solids and currents (drogue studies) in the area during the construction phase is recommended in addition to a comprehensive long term monitoring programme proposed. Long term monitoring involves monitoring of shorelines, beach profiles, currents, water and energy/fuel consumption data, waste management data and water quality including groundwater quality.

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11 Acknowledgements

The authors wish to acknowledge the work of several people who have contributed to this report. Thanks are also due to those who participated in the different meetings, interviews, discussions although their names have not been specifically mentioned here. Special thanks to the Proponent, Mr. Adam Maniku for his insights and thoughts and Ms. Fathmath Suad for providing necessary information in a timely manner.

The technical team of Sandcays who gathered field data, analyzed the data and presented some of the data in this report are worthy of credit for the important work they did. Thanks to Mohamed Shifaf and Mohamed Shafiu for undertaking field work and assisting in the data processing and field data representation.

The field team wishes to express their appreciation for the assistance from Ahmed Iyaz in the topographic and bathymetric surveys.

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12 References

B. Lapointe, M. Littler, & D. Littler, 1993, Modification of benthic community structure by natural eutrophication: The Belize Barrier Reef, Proceedings of the 7th International Symposium on Coral Reefs, p. 317-328, Guam

Binnie Black and Veatch (2000), Environmental/Technical Study for Dredging/Reclamation Works under the Hulhumalé Project, Maldives

Blue Peace Maldives, Marine Turtles in the Maldives, http://www.bluepeacemaldives.org/saveturtles.htm, accessed 6 July 2014

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13 Appendices

Appendix 1: Terms of Reference

Appendix 2: MoT approved concept drawing

Appendix 3: Commitment letter from Proponent

Appendix 4: Document receipt from Atoll Council

Appendix 5: CVs of Assisting Consultants

Proponent: Kanbalifaru Development Pvt. Ltd. Page | 133 Consultant: Sandcays

Curriculum Vitae of MOHAMED IBRAHIM JALEEL

1. PROPOSED POSITION Research Assistant : 2. NAME : Mohamed Ibrahim Jaleel

3. DATE OF BIRTH : 9 May 1991

4. CITIZENSHIP : Maldivian

5. PERSONAL ADDRESS : V.Edhuruvehi Male’ TELEPHONE NO. : (960)9768999 E-MAIL ADDRESS : [email protected]

6. EDUCATION : General Certification of Education, (GCE) Ordinary Level. In 2007 (Science stream) General Certification of Education, in Advance Level. In 2010 (Science stream)

Currently completing the last year of Bachelor’s Degree on Environmental Management from the Maldives National University.

7. OTHER TRAINING : Graphics designing short course from IBI Took part in lecture series held by IUCN Maldives on various conservation issues and opportunities in the Maldives

8. LANGUAGE & DEGREE OF : Speaking Writing Reading PROFICIENCY English Excellent Excellent Excellent Dhivehi Mother tongue Mother tongue Mother tongue

9. MEMBERSHIP IN CIVIC AND : - PROFESSIONAL SOCIETIES 10. COUNTRIES OF WORK : Maldives EXPERIENCE

11. EMPLOYMENT RECORD :

FROM: Feb 2014 TO: Present EMPLOYER Sandcays Pvt. Ltd. POSITION HELD AND Research assistant. Assisting in environmental research, DESCRIPTION OF DUTIES environmental surveys and monitoring, drafting of EIA/ESIA reports and other documentation.

FROM: 2011 TO: 2011 EMPLOYER Ministry of Health and Gender POSITION HELD AND Child care supervisor (full time). Monitoring and reporting the actions DESCRIPTION OF DUTIES of the child care officers and the needs of the children in Kudakudhinge hiyaa. Carrying out and planning various activities that are necessary for the growth and development of the children. Formulating the annual and the monthly schedule for the children and the child care workers. Attending to emergencies and accidents that FROM: 2011 occur within the kudakudhinge hiya sector. EMPLOYER POSITION HELD AND TO: 2012 DESCRIPTION OF DUTIES Maldives National University Admission and Registration officer. Carrying out the respective works of the admission and registration section of the Maldives National University.

August 2014 Page (1) MOHAMED IBRAHIM JALEEL

12. RELEVANT WORK EXPERIENCE Project Name : Study and EIA for proposed STP for Diggiri Tourist Resort, Client : Dhiggiri Tourist Resort Period : Aug 2014 Time Spent: 1 week to present Position Held : Research assistant Duties : Assisted in surveying activities Project Name : Survey of Ensis RO plant Registration, Hulhumale’ Client : Ensis Pvt. Ltd. Period : Aug 2014 Time Spent: 2 days Position Held : Research assistant Duties : Assisted in surveying activities Project Name : Study and EIA for proposed Resort development project in Kanbaalifaru, Shaviyani Atoll Client : Kanbaalifaru Investments Pvt. Ltd. Period : June 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in the drafting/compiling of the EIA report based on previous work Project Name : Study and EIA for the proposed Water Supply system in HA. Client : Upper North Province Council Period : June 2014 Time Spent: 3 weeks to present Position Held : Research assistant Duties : Assist in the drafting/compiling of the EIA report based on previous work Project Name : As built Survey of B. Kihaadhufaru Resort Client : Ibsun pvt.ltd Period : May 2014 Time Spent: 1 week Position Held : Research assistant Duties : Responsible for the survey equipment, assisted in all surveying activities Project Name : Survey of H.Marvel EIA Client : Adam Saleem Period : May 2014 Time Spent: 1 day Position Held : Research assistant Duties : Assisted in survey of the EIA report based on previous work Project Name : Study and EIA for proposed Coastal protecton of Paradise Island Resort, North Male’ Atoll Client : Diza Travels and Trade Pvt.Ltd Period : April 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in the drafting/compiling of the EIA report based on previous work Project Name : Study and EIA for proposed Resort development project in Maareha, Gaaf Alif Atoll Client : Moving International Pvt.Ltd Period : April 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in the drafting/compiling of the EIA report based on previous work Project Name : ESIA for five schools under Enhancing Education Development Project Client : Ministry of Education Period : February 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in compiling socio-economic profiles of islands and review of ESIA report Project Name : EIA for proposed harbour rehabilitation in Holudhoo, Noonu Atoll Client : Maldives Transport and Contacting Company (MTCC) Period : March 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in the drafting/compiling of the EIA report based on previous work Project Name : EIA for proposed harbour Construction in Dhangethi, Client : Maldives Transport and Contacting Company (MTCC) Period : March 2014 Time Spent: 2 weeks Position Held : Research assistant Duties : Assist in drafting/compiling the EIA report

April 2014 Page (2) MOHAMED IBRAHIM JALEEL

Project Name : EIA for proposed Airport Development at Dh. Client : Reollo Investments Period : March 2014 Time Spent: 4 weeks Position Held : Research assistant Duties : Assist in drafting/compiling the EIA report

13. CERTIFICATION:

I, THE UNDERSIGNED, confirm that to the best of my knowledge, this CV correctly describes me, my qualifications and my experience

Mohamed Ibrahim Jaleel

April 2014 Page (3)