ENVIRONMENTAL IMPACT ASSESSMENT Proposed Tourist Resort Development in Aanugandu Falhu (4o18’30.98”N / 73o30’13.65”E) North Male’ ,

July 2019

Prepared for: Promonant Pvt. Ltd. Prepared by: Mohamed Zuhair (EIA01/15) Page | 1

TABLE OF CONTENTS

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1. EXECUTIVE SUMMARY ...... 22 2. INTRODUCTION ...... 28 2.1 BACKGROUND OF THE PROJECT ...... 28 2.2 LEGAL REQUIREMENT ...... 33 2.3 STATEMENT OF NEED AND JUSTIFICATION ...... 33 2.4 EIA BACKGROUND AND RATIONALE ...... 37 2.5 EIA APPROACH, SCOPE AND OBJECTIVE ...... 38 2.6 EIA METHODOLOGY ...... 39 2.7 REVIEW OF RELEVANT STUDIES ...... 39 2.8 EIA TEAM ...... 41 2.9 EIA TERMS OF REFERENCE (TOR) ...... 41 3. STUDY AREA ...... 42 4. PROJECT DESCRIPTION ...... 46 4.1 PROJECT LOCATION ...... 46 4.2 PROJECT PROPONENT ...... 47 4.3 PROJECT OUTLINE ...... 47 4.3.1 Development Scope ...... 47 4.4 KEY ACTIVITIES OF RESORT CONSTRUCTION ...... 48 4.4.1 Activities Undertaken as per Main EIA and EIA First Addendum Approvals ...... 48 4.4.2 New Revised Development Plan ...... 51 4.4.3 Proposed Activities of the New Revised Development Plan ...... 51 4.4.4 Construction of Resort Facilities ...... 65 4.4.5 Area Development Programme ...... 68 4.4.6 Waste Management during Construction ...... 70 4.5 RESORT OPERATIONAL REQUIREMENTS...... 70 4.5.1 Energy Generation ...... 71 4.5.2 Freshwater Production ...... 73 4.5.3 Solid Waste Management ...... 76 4.5.4 Sewage and Wastewater Treatment ...... 78 4.5.5 Landscaping and Pest Control ...... 84 4.5.6 Storage Facilities ...... 84 4.6 PROJECT MANAGEMENT ...... 85

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4.6.1 Project Duration ...... 85 4.6.2 Communication ...... 85 4.6.3 Work Safety ...... 85 4.6.4 Potential Accidents and Management ...... 86 4.6.5 Emergency Plan ...... 87 4.7 PROJECT INPUTS AND OUTPUTS ...... 87 4.7.1 Project Inputs – Construction Phase ...... 87 4.7.2 Project Inputs – Operation Phase ...... 88 4.7.3 Project Outputs – Construction Phase ...... 89 4.7.4 Project Outputs – Operation Phase ...... 89 4.8 ACTIVITIES THAT ARE LIKELY TO CAUSE SIGNIFICANT ENVIRONMENTAL IMPACTS ...... 90 4.9 AFFECTED BOUNDARIES ...... 91 5. LEGAL, POLICY AND ADMINISTRATIVE FRAMEWORK ...... 93 5.1 APPLICABLE LAWS AND REGULATIONS...... 94 5.1.1 Tourism Act of Maldives (Law No. 2/99) ...... 94 5.1.2 Regulation on Protection and Conservation of Environment in the Tourism Industry, 2006 97 5.1.3 Boundary Regulation (2012/R-7) and Amendment (2016/R-94) ...... 99 5.1.4 Fire Regulation (2015/R-43) ...... 100 5.1.5 Maldives Regulation, 2003 ...... 100 5.1.6 Disaster Management Plan for Tourist Resorts ...... 101 5.1.7 Environmental Protection and Preservation Act (Law No. 4/93) and Amendment, 2014 102 5.1.8 Maldives EIA Regulation and Amendment, 2018 ...... 103 5.1.9 Penalty and Liability Regulation, 2011 ...... 104 5.1.10 Uprooting, Cutting and Transportation of Palms and Trees Regulation and Amendment, 2014 ...... 104 5.1.11 Management, Use and Control of HCFC Substances Regulation, 2010 ...... 105 5.1.12 Waste Management Regulation and Amendments, 2018 ...... 106 5.1.13 Dredging and Reclamation Regulation, 2013 ...... 107 5.1.14 Regulation on Desalination Plant, 2002 ...... 107 5.1.15 Dewatering Regulation, 2013 ...... 108 5.1.16 Migratory Birds Regulation, 2014 ...... 109 5.1.17 Regulation on Fuel Handling and Storage (2015/R-160) ...... 109 5.1.18 Waste Incineration Guideline, 2016 ...... 110 5.1.19 National Wastewater Guideline, 2007 ...... 111 Page | 3

5.1.20 Borehole Drilling Guidelines, 2011 ...... 112 5.2 RELEVANT POLICIES ...... 114 5.2.1 4th Tourism Master Plan, 2013 - 2017 ...... 114 5.2.2 National Framework for Development, 2009-2013 ...... 114 5.2.3 3rd National Environmental Action Plan, 2009-2013 ...... 116 5.2.4 Maldives National Strategy for Sustainable Development, 2009 ...... 117 5.2.5 National Solid Waste Management Policy, 2007 ...... 118 5.2.6 National Biodiversity Strategy and Action Plan, 2016-2025 ...... 118 5.2.7 National Climate Change Policy Framework, 2015 ...... 119 5.3 RELEVANT AUTHORITIES ...... 120 5.3.1 Ministry of Tourism, MOT ...... 120 5.3.2 Ministry of Environment, MOE ...... 120 5.3.3 Environmental Protection Agency, EPA ...... 121 5.3.4 Ministry of Defence and National Security, MDNS ...... 121 5.3.5 Maldives Food and Drug Authority, MFDA ...... 121 5.3.6 Maldives Energy Authority, MEA ...... 121 5.4 INTERNATIONAL CONTEXT ...... 122 5.5 PERMITS OBTAINED AND REQUIRED ...... 124 6. EXISTING ENVIRONMENT ...... 125 6.1 DATA COLLECTION METHODS ...... 125 6.1.1 Geophysical Environment ...... 125 6.1.2 Climate Environment ...... 126 6.1.3 Hydrographic Environment ...... 126 6.1.4 Marine Environment ...... 126 6.1.5 Socio-Economic Environment ...... 127 6.1.6 Derivation of Environmental Indicators...... 127 6.1.7 Uncertainties on Data Collection Methods ...... 127 6.2 ASSESSMENTS UNDERTAKEN...... 127 6.3 GEOPHYSICAL ENVIRONMENT ...... 132 6.3.1 Geography and Environmental Setting ...... 132 6.3.2 Coastal Geology ...... 132 6.3.3 Characteristics of Seabed Sediments ...... 133 6.3.4 Topography ...... 134 6.3.5 Seasonal Erosion and Accretion...... 135 6.4 CLIMATE ENVIRONMENT ...... 138 6.4.1 Climatic Setting...... 138 Page | 4

6.4.2 Monsoons ...... 138 6.4.3 ...... 139 6.4.4 Rainfall ...... 141 6.4.5 Sunshine ...... 142 6.4.6 Winds ...... 143 6.5 HYDROGRAPHIC ENVIRONMENT ...... 146 6.5.1 Lagoon Bathymetry...... 146 6.5.2 Currents ...... 147 6.5.3 ...... 148 6.5.4 Waves and Swells ...... 149 6.6 MARINE ENVIRONMENT...... 150 6.6.2 Present Marine Environment Condition...... 155 6.6.3 Marine Protected Areas and Sensitive Sites ...... 161 6.7 SOCIO-ECONOMIC ENVIRONMENT ...... 161 6.7.1 Introduction to North Male’ Atoll ...... 161 6.7.2 Population ...... 161 6.7.3 Housing ...... 162 6.7.4 Health and Education ...... 163 6.7.5 Water, Sanitation and Energy ...... 163 6.7.6 Electricity ...... 163 6.7.7 Infrastructure ...... 164 6.7.8 Waste Management ...... 164 6.7.9 Public Transportation ...... 164 6.7.10 Local Economy ...... 164 6.7.11 Expected Benefits from the Proposed Project ...... 165 6.8 HAZARDS VULNERABILITY ...... 166 6.8.1 Major Natural Hazards ...... 166 6.8.2 Distribution Pattern of Natural Hazards ...... 167 7. ENVIRONMENTAL IMPACTS ...... 169 7.1 METHODS ...... 169 7.1.1 Impact Prediction ...... 169 7.1.2 Impact Significance Analysis ...... 169 7.1.3 Limitations and Uncertainties ...... 171 7.1.4 Justification of the Method Used ...... 171 7.2 EXISTING ENVIRONMENTAL IMPACTS ...... 172 7.2.1 Impacts on ...... 172 Page | 5

7.2.2 Impacts on Land ...... 173 7.3 IMPACT PREDICTION ...... 173 7.4 DESCRIPTION OF IMPACTS ...... 176 7.4.1 Pre-Construction Phase Impacts ...... 176 7.4.2 Construction Phase Impacts ...... 176 7.4.3 Operation Phase Impacts ...... 181 7.4.4 Indirect Impacts...... 185 7.4.5 Cumulative Impacts ...... 186 7.4.6 Positive Impacts ...... 186 7.5 IMPACT ANALYSIS AND EVALUATION ...... 187 8. MITIGATION MEASURES ...... 189 8.1 JUSTIFICATION FOR PREFERRED MITIGATIONS ...... 189 8.2 LIMITATION OF MITIGATIONS ...... 189 8.3 PRE-CONSTRUCTION PHASE ...... 190 8.3.1 Mitigation Measures for Temporary Facilities Development ...... 190 8.4 CONSTRUCTION PHASE ...... 191 8.4.1 Mitigation Measures for Reshaping of Shorelines ...... 191 8.4.2 Mitigation Measures for Coastal Protection ...... 191 8.4.3 Mitigation Measures for Minor Reclamation ...... 192 8.4.4 Mitigation Measures for Landscaping Impacts on Reclaimed Islands ...... 193 8.4.5 Mitigation Measures for Land Excavation ...... 194 8.4.6 Mitigation Measures for Construction Waste Disposal ...... 195 8.4.7 Mitigation Measures for Construction Workers ...... 196 8.4.8 Mitigation Measures for Operation of Construction Machinery on Land...... 196 8.4.9 Mitigation Measures for Operation of Construction Machinery in the Lagoon...... 197 8.4.10 Mitigation Measures for Overwater Structures Construction ...... 198 8.5 OPERATION PHASE ...... 199 8.5.1 Mitigation Measures for Solid Waste Disposal ...... 199 8.5.2 Mitigation Measures for Wastewater and Sewage Disposal ...... 200 8.5.3 Mitigation Measures for Waste Oil Disposal ...... 201 8.5.4 Mitigation Measures for Use of Pesticides and Chemicals ...... 201 8.5.5 Mitigation Measures to Reduce Impacts from Transportation ...... 202 8.5.6 Mitigation Measures to Reduce Impacts from Tourist Activities ...... 203 8.6 OTHER CONSIDERATIONS ...... 205 8.6.1 Reef Rehabilitation Programme ...... 205 8.7 COMMITMENT ...... 205 Page | 6

8.7.1 Rationale ...... 205 8.7.2 Environmental Management Plan (EMP) ...... 206 8.7.3 Emergency Plan ...... 207 9. ALTERNATIVES ...... 209 9.1 NO DEVELOPMENT OPTION ...... 209 9.2 ALTERNATIVE DEVELOPMENT OPTIONS...... 210 9.2.1 Construction Method...... 210 9.2.2 Spun Pile Method ...... 211 9.2.3 Resort Layout ...... 212 9.3 ALTERNATIVE COASTAL PROTECTION METHOD ...... 212 9.3.1 Coastal Protection Design ...... 212 9.3.2 Material ...... 213 9.4 ALTERNATIVE LOCATIONS ...... 214 9.4.1 Alternative RO Intake and Alternative Outfall Locations ...... 214 9.4.2 Alternative Burrow Sites ...... 215 9.5 ALTERNATIVE DREDGING OPTION ...... 216 9.5.1 Use of Cutter Suction Dredger ...... 216 9.6 ALTERNATIVE ENERGY CONSIDERATION ...... 217 9.6.1 Use of Solar Energy ...... 217 10. STAKEHOLDER CONSULTATION ...... 218 10.1 KEY STAKEHOLDERS ...... 218 10.2 STAKEHOLDER CONSULTATIONS...... 218 10.2.1 Methods ...... 218 10.2.2 Summary of Outcomes ...... 219 11. ENVIRONMENTAL MONITORING...... 225 11.1 BACKGROUND ...... 225 11.2 MONITING TYPES ...... 225 11.2.1 Baseline Monitoring ...... 225 11.2.2 Impact Monitoring ...... 226 11.2.3 Compliance Monitoring ...... 226 11.3 MONITORING REPORT ...... 227 11.3.1 Report Format ...... 227 11.3.2 Frequency ...... 228 11.4 MONITORING PLAN ...... 228 11.4.1 Staffing ...... 229 11.4.2 Quality Control Assurance ...... 229 Page | 7

11.4.3 Commitment ...... 230 12. CONCLUSIONS ...... 231 13. REFERENCES ...... 235 14. APPENDICES ...... 237

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LIST OF FIGURES

Figure 1: Project Location and site ...... 14 Figure 2: Resort development concept of Aanugandu Falhu ...... 15 Figure 3: Initial resort development concept of December 2016 ...... 29 Figure 4: Revised resort development concept of March 2018 ...... 30 Figure 5: New revised resort development concept of April 2019 ...... 31 Figure 6: Final revised development concept of June 2019 ...... 32 Figure 7: Direct contribution (left) and indirect contribution (right) of travel and tourism sector to employment (Source: WTTC 2015) ...... 34 Figure 8: Visitor exports and international tourist arrivals (left) and capital investment in the sector (right) (Source: WTTC 2015) ...... 34 Figure 9: Tourism sector contribution to GDP (Source: WTTC, 2015) ...... 35 Figure 10: Monthly tourist arrivals to the Maldives 2013-2017 (Source: MOT 2018) ...... 36 Figure 11: Tourism contribution to GDP, 2013-2017 (Source: MOT 2018) ...... 36 Figure 12: Location and study area of the project...... 43 Figure 13: Study area in various time periods ...... 44 Figure 14: Regional attributes surrounding project area ...... 45 Figure 15: Lagoon reclamation works and temporary setup in early 2018 (Google Earth) ...... 48 Figure 16: Reclaimed islands ...... 49 Figure 17: Temporary setup of labour quarters and storages constructed on both islands ...... 49 Figure 18: Temporary RO plant (left) and power plant (right) ...... 50 Figure 19: Rock boulders brought to the reclaimed island ...... 50 Figure 20: Some sand stockpiles done on the reclaimed islands ...... 50 Figure 21: Temporary facilities plan ...... 52 Figure 22: Reshaping plan of the shorelines on both islands ...... 53 Figure 23: Proposed coastal protection plan for the reclaimed islands ...... 54 Figure 24: Use of headland revetments in newly reclaimed islands in South Male Atoll ...... 56 Figure 25: Design of a typical headland revetment ...... 57 Figure 26: Use of Y groynes for coastal protection along the shore ...... 57 Figure 27: Design of a typical Y groyne ...... 58 Figure 28: Use of offshore breakwaters ...... 58 Figure 29: Design of a typical offshore breakwater section ...... 59 Figure 30: Offshore revetment islets during construction (left) and after construction (right) in a resort ...... 60 Figure 31: Design of offshore revetment islet...... 60 Figure 32: Minor reclamation areas (green) and burrow sites (red) ...... 61 Figure 33: Location of powerhouse and RO plant ...... 71 Figure 34: Borehole and brine/wastewater outfall location and alternative locations ...... 74 Figure 35: Location of the waste management area...... 76 Figure 36: Location of the STP ...... 79 Figure 37: SmartBall leak detection system ...... 82 Figure 38: Direct impact areas (red) and indirect impact boundary ...... 91 Figure 39: Present shorelines of reclaimed islands and lagoon bathymetry ...... 128 Figure 40: Beach profiles and beach marks of East Island ...... 129 Figure 41: Beach profiles and beach marks of West Island ...... 130 Page | 9

Figure 42: Assessment locations ...... 131 Figure 43: Presence of fine sand within the lagoon ...... 134 Figure 44: General topographic condition of east island (left) and west island (right)...... 135 Figure 45: Different developmental stages of the sand bank 2005 (top left), 2008 (top right), 2009 (middle left), 2012 (middle right), 2013 (bottom left), 2016 (bottom right) ...... 136 Figure 46: Natural shoreline adjustments on east island ...... 137 Figure 47: Dynamic conditions on the eastern side of east island (part of existing islet) ...... 137 Figure 48: Erosion on west island ...... 138 Figure 49: Average maximum and minimum (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv) ...... 139 Figure 50: Comparison of max temperature for April 2017 and 2018 (Source: www.meteorology.mv) ...... 140 Figure 51: Comparison of min temperature for April 2017 and 2018 (Source: www.meteorology.mv) ...... 140 Figure 52: Average rainfall (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv) .. 141 Figure 53: Comparison of rainfall for April 2017 and 2018 (Source: www.meteorology.mv) ...... 141 Figure 54: Average sunshine (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv) 142 Figure 55: Comparison of sunshine for April 2017 and 2018 (Source: www.meteorology.mv) ...... 143 Figure 56: The average of mean hourly wind speeds (dark gray line), with 25th to 75th and 10th to 90th percentile bands (weatherspark.com)...... 144 Figure 57: The percentage of hours in which the mean wind direction is from each of the four cardinal wind directions, excluding hours in which the mean wind speed is less than 1.0 mph. The lightly tinted areas at the boundaries are the percentage of hours spent in the implied intermediate directions (northeast, southeast, southwest, and northwest)...... 144 Figure 58: Comparison of winds for April 2017 and 2018 (Source: www.meteorology.mv) ...... 145 Figure 59: Wind frequency chart of Hulhule for April 2018 (Source: www.meteorology.mv) ...... 145 Figure 60: Lagoon bathymetry taken in February 2017 prior to land reclamation ...... 146 Figure 61: Male’ predictions from 17 – 20 July 2019 (www.tidetime.org/asia/maldives/male.htm) ...... 148 Figure 62: Waves occurring along the eastern side of the reef ...... 149 Figure 63: Swells map for North Male Atoll for July 2019 (www.surf-forecast.com ) ...... 150 Figure 64: Reef composition of the lagoon ...... 151 Figure 65: General reef condition at RS1 ...... 152 Figure 66: General reef condition at RS2 ...... 152 Figure 67: General reef condition at RS3 ...... 152 Figure 68: General reef condition at RS4 ...... 153 Figure 69: General reef condition at RS5 ...... 153 Figure 70: Reef fish assessment results from the reef...... 154 Figure 71: Reef composition of the lagoon in 2019 ...... 156 Figure 72: Reef condition at RS1 ...... 157 Figure 73: Reef condition at RS2 ...... 157 Figure 74: Reef condition at RS3 ...... 157 Figure 75: Reef condition at RS4 ...... 157 Figure 76: Reef condition at RS5 ...... 158 Figure 77: Reef fish assessment 2019 ...... 159 Figure 78: Existing tourist resorts (labeled in yellow) in North Male’ Atoll (Source: www.modomaldive.it) ...... 162 Figure 79: Relationship between intensity and frequency of ...... 167 Page | 10

Figure 80: Latitudinal variations of major natural hazards across the Maldives (UNDP, 2008)...... 168 Figure 81: Longitudinal variations of major natural hazards across the Maldives (UNDP, 2008) ..... 168 Figure 82: Present reef condition in the lagoon ...... 172 Figure 83: Erosion on reclaimed islands, western island (top) and eastern island (bottom) ...... 173 Figure 84: Proposed coastal protection (left) and alternative coastal protection (right) ...... 213 Figure 85: Alternative intake and outfall locations ...... 214 Figure 86: Proposed burrow site (green) and alternative burrow sites (red) ...... 215

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LIST OF TABLES

Table 1: Proposed minor reclamation areas ...... 62 Table 2: Proposed burrow site and alternative sites and volume obtained ...... 62 Table 3: Area development programme of Aanugandu Falhu ...... 69 Table 4: Water intake and wastewater outfall and alternative locations ...... 74 Table 5: Waste management equipment ...... 77 Table 6: Project inputs during construction ...... 88 Table 7: Project inputs during operation ...... 89 Table 8: Project outputs during construction ...... 89 Table 9: Project outputs during operation ...... 90 Table 10: Maximum allowable in domestic wastewater discharge into deep sea ...... 112 Table 11: Aanugadu falhu beach profile GPS locations ...... 134 Table 12: Drogue study details (June 2019) ...... 147 Table 13: Drogue study (February 2017) ...... 147 Table 14: GPS coordinate of the reef assessment sites ...... 151 Table 15: GPS coordinate of seawater sampling location ...... 155 Table 16: Seawater analysis results (2017) ...... 155 Table 17: GPS coordinate of SW3 ...... 160 Table 18: Seawater analysis results (2019) ...... 160 Table 19: Population of North Male Atoll in inhabited islands (Source: Preliminary Results of Population and Housing Census, 2014, DNP) ...... 162 Table 20: Impact significance criteria ...... 170 Table 21: Significance rating matrix ...... 170 Table 22: Significance colour scale ...... 170 Table 23: Impact prediction table ...... 175 Table 24: Impact analysis table ...... 187 Table 25: Alternative locations for intake and outfall ...... 215 Table 26: Environmental monitoring plan ...... 228 Table 27: Monitoring aspects during resort operation ...... 229

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ABBREVIATIONS

BOH Back of the House EIA Environmental Impact Assessment EMP Environment Management Plan EPA Environmental Protection Agency EPPA Environmental Protection and Preservation Act GDP Gross Domestic Product GPS Global Positioning System LIT Line Intercept Transect ME Ministry of Environment MWSC Male’ Water and Sewerage Company MSL Mean Sea Level MPA Marine Protected Area MDNS Ministry of Defense and National Security MRC Marine Research Centre MOFA Ministry of Fisheries and Agriculture MOT Ministry of Tourism NEAP National Environment Action Plan NBSAP National Biodiversity Strategy and Action Plan NSSD National Sustainable Development Plan SAP Strategic Action Plan TOR Terms of Reference 4TMP Fourth Tourism Master Plan

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The Project Location and Site

Figure 1: Project Location and site

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The Project Concept

Figure 2: Resort development concept of Aanugandu Falhu

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CONSULTANT’S DECLARATION

I, Mohamed Zuhair, Registered EIA Consultant at the Ministry of Environment of Maldives with the Registration Number EIA 01/15, hereby declare that the statements in this Environment Impact Assessment (EIA) Report for Proposed Tourist Resort Development in Aanugandu Falhu in North Male’ Atoll are true, complete and correct to the best of my knowledge and abilities.

The EIA Report has been prepared in accordance with the Terms of Reference (TOR) approved by EPA on 9 May 2019.

Name: Mohamed Zuhair (EIA01/15)

Signature:

Date: 1 July 2019

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1. EXECUTIVE SUMMARY

i. This is the EIA report prepared for the proposed development of 353 guest room (706 beds) tourist resort on existing reclaimed islands in Aanugandu Falhu in North Male’ Atoll with coastal protection and all supporting infrastructure and services.

ii. Initially Aqua Blue Investments Pvt. Ltd. proposed to reclaim 5 islands and develop a 160-room (320 beds) tourist resort in Aanugandu Falhu based on a concept approved by Ministry of Tourism on 5 December 2016. A total of 15.02ha was proposed to be reclaimed as part of the project. Subsequently an EIA Report for the initial development concept was prepared in February 2017. The EIA was approved by MOT on 16 March 2017. iii. Subsequently, the project proponent decided to revise the entire development concept of the proposed project. In this regard, a revised development concept was approved by MOT on 13 March 2018. The revised project included development of 221 guest rooms (442 beds) in two reclaimed islands having 7.5ha and 4ha. In order to get environmental clearance for the revised development concept of March 2018, an EIA First Addendum was prepared in April 2018. The EIA First Addendum was approved by MOT on 30 April 2018.

iv. Major reclamation works and temporary site setup work initiated upon approval of the EIA First Addendum in April 2018. Reclamation of 2 islands were completed in early 2019.

v. Recently, the proponent again decided to revise the development concept, which was approved by MOT on 4 April 2019. The revised development concept of April 2019 proposed to develop a 353 guest rooms (706 beds) distributed across ‘islands’, which are already reclaimed.

vi. During the process of finalizing the recent redevelopment concept, a sub-lease agreement was signed between Aqua Blue Investments Pvt. Ltd. and Promonant Pvt.

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Ltd. for development of the resort in the lagoon as per the new revised development concept. Hence the project will be taken over by the sub-lessee, Promonant Pvt. Ltd.

vii. The new Project Proponent, Promonant Pvt. Ltd. proposes to develop 353 Rooms (706 beds) tourist resort on existing reclaimed islands with coastal protection of reclaimed islands, all resort facilities, amenities and provision of all necessary services including electricity, water, sewerage treatment, waste management, communication, etc. viii. The resort layout including building sizes, construction methods, infrastructure development, environmental protection measures, as well as the management and operation of the island will conform to the standards and guidelines maintained by relevant government authorities.

ix. During December 2018, the Tourism Act came to a reformulation excluding all provisions related to EIAs in the tourism sector, which was implemented by Ministry of Tourism. The main aim of this reformulation was to streamline all EIAs carried out for all development projects including process and approval to be governed by the Ministry of Environment in accordance with the Environmental Protection and Preservation Act (Law No. 4/93) which is implemented by Environmental Protection Agency (EPA) on behalf of the ministry. Hence, all EIA provisions are implemented by EPA since January 2019 under Environmental Regulations. This EIA is prepared under the new EIA governance implemented by EPA. The EIA Terms of Reference (TOR) was approved by EPA on 9 May 2019.

x. The scope of this EIA is to assess the existing environmental condition of the island and surrounding environment with regards to proposed resort development project including development of resort facilities and amenities as well as operation of the resort, identify potential environmental impacts and propose environmental management and mitigation measures to minimize environmental impacts as well as propose an environmental monitoring plan with appropriate environmental parameters to monitor changes on a regular basis.

xi. Aanugandu Falhu is located at 4o18’30.98”N / 73o30’13.65”E in North Male’ Atoll. It is centrally located in the Atoll at a distance of 11km from Velaanaa International

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Airport. The nearest tourist resorts are Thulhaagiri Island Resort 1.4km west, Paradise Island Resort and Gili Lankanfushi 6km east and Bandos Island Resort 4km south. The nearest inhabited island is found 6.6km east.

xii. Aanugandu Falhu is a small lagoon having 76ha in total area and is formed into a circular shape. A slightly deeper inner lagoon having an approximate area of 27ha is found slightly westwards of the lagoon, hence, shallow lagoon areas having an extent of 365m from inner lagoon slope to the outer reef slope exists on the eastern and south- eastern sides of the lagoon. A small sandbank is formed on the SE shallow lagoon having an area of 0.5ha. However, land reclamation initiated in the lagoon for a resort development project in 2018 which was completed in 2019. Currently the lagoon has two reclaimed islands. xiii. The closest Marine Protected Area (MPA), Banana Reef is located at 8.4km south-east. Other MPAs in the region are Lion’s Head, Kollavaani found 15km on the south. A Sensitive Site (SS), which is a sand bank near Kodhipparu Falhu is found 14km SW of the project site.

xiv. The baseline assessments undertaken 2017 indicate that highest live coral cover recorded was from RS 3 located on the western part of the reef that has a live coral cover of 16%. RS 2 located close to the access channel also have a relatively high coral cover having 11%. The lowest live coral cover was recoded from RS 4 located on the southern side of the reef having only 3%. Sand content was highest at RS 5 site, which probably because of the location of the existing sand bank near the site.

xv. In comparison to the 2017 assessments, live coral cover on all sites in 2019 are recorded to be reduced. In this regard, live coral cover at RS1 reduced from 5% to 1%, RS2 reduced from 11% to 4%, RS3 reduced from 16% to 5%, RS4 reduced from 3% to 2% and RS5 reduced from 6% to 1%. In contrast, rubble content and sand content on all sites were recoded to be increased. This is believed to be as a result of direct impact on the reef from sedimentation resulted from dredging and land reclamation activities undertaken in the lagoon previously. Considerable amount of rubble and fine sediments were observed on all sites.

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xvi. The results of the 2017 reef fish assessments indicate that the reef fish abundance and diversity found from the sites were at an average level. However, RS 3 had more individuals having a total of 107 belonging to 18 different families. RS 4 had fewer number of reef fish having 42 belonging to 10 different families. It was found that the reef fish abundance and diversity increased as the condition of the reef sites were better having increased live coral cover. However, RS 5 also had good reef fish diversity compared to RS 2 and RS 3 with more fish and less live coral cover. xvii. In comparison to the 2017 reef fish assessment, the population structure was observed to be altered owing much to the impacts of sedimentation. Large fishes such as snapper, groupers, travellies and sweetlips recorded during 2017 assessments were found to be absent during 2019 assessments. Generally speaking, the impacts on the reef has breatly affected reef fish abundance and diversity found in Aanugandu Falhu. xviii. Some notable existing environmental impacts have been observed from the lagoon from 2017 baseline to 2019 assessments for the proposed development.

xix. Most of the environmental impacts occur during construction are of short-term and during operation are of long-term in nature. During construction phase, the most significant impacts that will occur are believed to be from minor land reclamation and construction waste disposal. Also, significance of a number of impacts during construction phase has been identified to be moderate such as impacts from construction workers, constructions in the lagoon, reshaping of shorelines and coastal protection. Land excavation has been identified to have negligible impacts as a result of the activity on already reclaimed island.

xx. During the operation phase, although most of the impacts are of long-term in nature, significance of most of the environmental impacts have been identified to be moderate except for disposal solid waste and wastewater into the nearby marine environment, where they have been identified to be major.

xxi. The socio-economic impacts of the proposed development have been identified to be positive. These include, opening of new employment opportunities in close proximity to communities, contribution to improving living standards of nearby communities

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through direct and indirect economic benefits, opening new market opportunity for local products as well as contribution to the local economy from the above in addition to tax and land rent revenue to the national economy. An indirect impact of the project is believed to be as a result of increased completion over natural resources such as diving and areas. xxii. Mitigation of environmental impacts from the proposed project can be developed as early as the project planning phase and pre-construction as well as during the development and implementation period of the project. In this regard, appropriate designing and citing the facility could enhance environment protection even from the start without much financial considerations. Also, as an important mitigation measure, implementation of an Environmental Management Plan during construction and operation stages have been outlined. xxiii. Alternatives to some of the project components such as no development option, alternative development options, alternative locations and other alternative considerations have been identified and evaluated. The development preference for each alternative has also be stated and justified, where considerations have been given to practicality and effectiveness. xxiv. Some key stakeholders have suggested to implement a reef rehabilitation programme as part of the project given that there are some damages on the reef as a result of previous activities undertaken in the lagoon. xxv. Environmental monitoring during both construction and operation stages has be given serious consideration in order to assess the degree and magnitude of environmental changes in the biophysical environment, severity of impacts as a result of the proposed development through impact monitoring as well as to identify if certain aspects of the environment are in compliant with required guidelines and standards through compliant monitoring in addition to baseline monitoring of seawater, reef health, shoreline, , etc. An environmental monitoring programme will be implemented during construction and operation stages of the proposed development and annual reports will be prepared and submitted to the regulator.

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xxvi. With regards to understanding and improving environmental performance of the proposed development, the project has developed an Environmental Management Plan, Code-of-Conduct for Environmental Management as well as an Environmental Monitoring Plan, which will be implemented during construction and operation phases of the development. An environmental monitoring report will be prepared twice a year, which will be submitted to relevant government authorities. xxvii. Although there are a number of environmental impacts from the proposed development, some of which has been identified to be significant such as minor reclamation, generation of solid waste during construction and operation, most of these impacts can be reduced and minimized by implementation various management and mitigation measures. The effectiveness of these methodologies can be documented by implementing a comprehensive monitoring programme. Also, with very positive socio- economic outlook of the project (1064 direct jobs, 190,000 annual tourist arrivals and US$ 3 – 5 Million annual contribution to national economy). it is concluded that the project will bring a number of benefits to the country.

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2. INTRODUCTION

2.1 BACKGROUND OF THE PROJECT

Initially Aqua Blue Investments Pvt. Ltd. proposed to reclaim 5 islands and develop a 160- room (320 beds) tourist resort in Aanugandu Falhu, the lagoon plot located at 4o18’30.98”N / 73o30’13.65”E in North Male’ Atoll based on a concept approved by Ministry of Tourism on 5 December 2016. The details of the 5 islands were as follows;

 Central Island – 7.52 ha of space, housing the main services of the island including the spa and the conferencing facilities.  South Island – 3.96 ha of space, housing additional rooming facilities and housing the water villa wing of the resort.  Retreat Island – 0.9 ha of space, to be developed as a ‘private island’ within the resort which would offer exclusivity to the guests of the island  Picnic Island – 0.51 ha of space, to be used as a ‘virgin sand band’ with no development but for guest excursions.  Staff Island – 2.13 ha of space housing most of the back of the house and staff facilities including staff recreational facilities.

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Figure 3: Initial resort development concept of December 2016

A total of 15.02ha was proposed to be reclaimed as part of the project. Subsequently an EIA Report for the initial development concept was prepared in February 2017. The EIA was approved by MOT on 16 March 2017. Some works including development of access channel and project mobilization initiated immediately. The EIA Decision Statement of March 2017 is attached in Appendix 1.

Subsequently, the project proponent decided to revise the entire development concept of the proposed project. In this regard, a revised development concept was approved by MOT on 13 March 2018. The revised project included development of 221 guest rooms (442 beds) in two reclaimed islands having 7.5ha and 4ha with all support infrastructure and services on each island to be developed as part of the overall resort development.

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Figure 4: Revised resort development concept of March 2018

In order to get environmental clearance for the revised development concept of March 2018, an EIA First Addendum was prepared in April 2018. The EIA First Addendum was approved by MOT on 30 April 2018. The land reclamation of islands having 7.5ha on the eastern side and 4ha on the western side, further project mobilization and some temporary arrangements have been undertaken as per the Decision Statement of April 2018. The EIA First Addendum Decision Statement of 30 April 2018 is attached in Appendix 2.

Recently, the proponent again decided to revise the development concept, which was approved by MOT on 4 April 2019. The revised development concept of April 2019 proposed to develop a 353 guest rooms (706 beds) distributed across ‘islands’, which are already reclaimed. A main component of the revised development concept included coastal protection measures of reclaimed islands, landscaping, development of a harbor on the eastern side island and reclaim a small islet having 0.6ha by the access channel. The new revised development concept labeled already reclaimed islands into 3 islands with Island 1 having approximately 5ha on the western side. The exiting reclaimed island on the eastern side was proposed to be separated by a 10m wide channel and proposed to be labelled as Island 2 and Island 3 and will have an area of

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7.7ha. No further land reclamation was proposed to be carried out in these islands. The desired land areas of 5ha for Island 1 and 7.7ha for Islands 2 and 3 will be obtained from existing sand stockpiles. The small islet proposed by the access channel on the north has been labelled as Island 4, which is proposed to be reclaimed from material obtained from maintenance dredging of the access channel. No development was proposed on Island 4. A harbor was proposed to be developed on the eastern side of Island 2. A connecting jetty between Island 1 and Island 2 will be developed with the arrival jetty and an underwater pavilion.

Figure 5: New revised resort development concept of April 2019

Given that the islands were already reclaimed from previous EIA First Addendum approval, as part of the revised development concept of April 2019, more focus was given for implementation of coastal protection measures by using offshore breakwater, revetment and groynes to ensure that the islands are well protected for the new development.

During the process of finalizing the recent redevelopment concept, a sub-lease agreement was signed between Aqua Blue Investments Pvt. Ltd. and Promonant Pvt. Ltd. for development of

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the resort in the lagoon as per the new revised development concept. Hence the project will be taken over by the sub-lessee, Promonant Pvt. Ltd.

In order to get environmental clearance for the new revised development concept of April 2019, an EIA application was submitted to EPA in May 2019. Given that the resort EIA governance and administration changed from MOT to EPA in January 2019, a fresh EIA was prepared by the new project proponent based on the EIA Terms of Reference (TOR) approved by EPA on 9 May 2019. The approved EIA TOR is attached in Appendix 3.

Some revisions to the development concept of the project have been proposed recently taking into consideration operational aspects as well as coastal protection of the already reclaimed islands. In this regard, the proposed harbor on the eastern side of Island 2 has been proposed to be removed and instead propose construction of a service jetty on the south-eastern tip of Island 1 and changing the initially proposed offshore breakwater system on the southern side of Island 2 to breakwater islets on the same location. Subsequently, revised development concept and revised coastal modification concept have been approved by Ministry of Tourism on 25 June 2019 and 26 June 2019 respectively and are attached in Appendix 4 and Appendix 5.

Figure 6: Final revised development concept of June 2019

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Since EIA TOR was approved on 9 May 2019 before the final revision of the project on 25 June 2019, the proponent requested EPA for a revised EIA TOR. EPA informed the proponent in reply indicating that the proposed changes were minor and that the EIA can be prepared based on the already approved EIA TOR. The letter from EPA to the proponent is attached in Appendix 6.

2.2 LEGAL REQUIREMENT

The EIA Regulation of 2012 and Amendments require all tourist resort development projects to prepare Environmental Impact Assessment (EIA) and obtain necessary development approvals prior to commencement of the project.

In this regard, it is a mandatory requirement for the proposed project to prepare and approve an EIA from EPA before any activity of the project can be undertaken as per the new revised development concept.

2.3 STATEMENT OF NEED AND JUSTIFICATION

Tourism is one of the most important economic activities in the country due to its large contribution to the GDP, national economy and employment that have both direct and indirect benefits. Currently there are 736 tourist establishments including resorts, hotels, guesthouses and safaris with a bed capacity of 41,255 (MOT, 2018).

Tourism generated 48,000 jobs directly in 2014 (32.2% of total employment). This includes employment by hotels, travel agents, airlines and other passenger transportation services (excluding commuter services). It also includes, for example, the activities of the restaurant and leisure industries directly supported by tourists (World Travel and Tourism Council (WTTC, 2015).

By 2025, travel and tourism is expected to account for 52,000 jobs directly, an increase of 0.7% pa over the next ten years (WTTC, 2015).

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Figure 7: Direct contribution (left) and indirect contribution (right) of travel and tourism sector to employment (Source: WTTC 2015) The total indirect contribution of tourism sector to employment (including wider effects from investment, the supply chain and induced income impacts) was 92,000 jobs in 2014 (62.0% of total employment, (WTTC, 2015))

Money spent by foreign visitors to a country (or visitor exports) is a key component of the direct contribution of travel and tourism. In 2014, Maldives generated MVR33,919.5 Million in visitor exports (WTTC, 2015).

By 2025, international tourist arrivals to the country are forecasted to total 1,657,000, generating expenditure of MVR45,797.1 Million, an increase of 2.7% pa (WTTC, 2015).

Figure 8: Visitor exports and international tourist arrivals (left) and capital investment in the sector (right) (Source: WTTC 2015) Tourism is expected to have attracted capital investment of MVR2,001.5 Million in 2014 (WTTC, 2015).

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The Maldivian economy is reliant on tourism with tremendous direct and indirect contributions to GDP, hence, it is regarded as one of the most important economic activities in the country.

Figure 9: Tourism sector contribution to GDP (Source: WTTC, 2015)

Tourist arrival trends in the Maldives, over the last five years, has been phenomenal. In the five year span from 2013 to 2017 arrivals to the Maldives has been consistent and optimistic. Maldives continues to flow in line with the global growth rate whilst increasing its arrivals, steadily. The five year annual average growth rate of tourist arrival in Maldives from 2013 to 2017 was 7.8% (MOT, 2018). Annual arrival numbers remained above one million since achieving and surpassing one million mark in 2013.

The year 2017 had been an outstanding year for the Maldives, recording an 8% increase in tourist arrivals, outshining the global rate of 6.8%. Nonetheless, monthly results for the year were erratic. The year started in full vigor with January yielding a growth of +15.6%. Tourist arrivals in the months that followed enjoyed different traits. While April (+15.7%), November (+15.2%) and December (+19.7%) were in harmony with the month of January, results for the months of June (+7.8%), August (+8%) and October (+8.9%) had been in line or slightly above the five year average rate of 7.8%. Whereas, July and September recorded weaker performances of +2.5% and +4% respectively. The months of February and May posted a marginal rate of +0.3% each. March recorded a negative growth of 2.1%, reflecting the weaker global performance during the month (MOT, 2018).

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Figure 10: Monthly tourist arrivals to the Maldives 2013-2017 (Source: MOT 2018)

During the last five years, 2013 to 2017, tourism has contributed more than 23% to national GDP. The following figure presents tourism contribution to GDP over the last five years. In 2017, as per the new rebased figures, tourism contributed a total of 15.22 Billion Rufiyaa which was 23% of the total national GDP of the year (MOT, 2018).

Figure 11: Tourism contribution to GDP, 2013-2017 (Source: MOT 2018)

In order to further develop the sector and distribute the benefits throughout the country, the government developed the 4th Tourism Master Plan (4TMP), which highly recognizes development and operation of tourist resorts in throughout the country and increase in total bed capacity to carter for the growing demands of tourism sector. The proposed development will be in accordance with the policy direction of the Plan.

In order to carter for the growing demands of tourists, bed capacity, adequate facilities, services and infrastructure need to be increased in the Maldives. Also, as a result of dramatic increase in tourist arrivals to the country, tourism industry is now subject to diversification. The Fourth

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Tourism Master Plan also gives very high prominence to diversifying the Maldivian tourism product as well as increase in the bed capacity of the country in order to target for various tourist markets.

The proposed tourist resort will add 706 beds to the tourism sector with direct employment of around 1,064 jobs and indirect employment contribution of around 500 jobs. The proposed projects is also expected to contribute over 190,000 annual tourist arrivals to the country, hence is also expected to directly and indirectly contribute US$ 3 - 5 Million annually to the national economy through taxes and land rents. With the positive outlook of the project, it is regarded as an important project for the country and in lne with the government policies on strengthening tourism sector.

2.4 EIA BACKGROUND AND RATIONALE

This EIA is prepared as per the Terms of Reference (TOR) approved by EPA on 9 May 2019. It is a legal requirement under the EIA Regulation 2012 that all toust resort development projects obtain environmental clearance prior to construction and operation the project. As per the above-mentioned regulation, environmental clearance is obtained through approval of the EIA from EPA.

EIA is a process of assessing environmental impacts from development projects, and its key purposes are identifying / evaluating the potential and adverse impacts of proposed development projects on the surrounding environment taking into account environmental, economic and social considerations. For evaluating the impacts of the proposed activities, all activities associated with planning, design, site preparation, construction, operation and maintenance within the proposed project are included.

The aim of this EIA is to ensure that potential impacts are identified and addressed in relation to the proposed development. For this purpose the report has addressed present environmental condition of the reclaimed islands and the lagoon where the proposed development will be undertaken as part of the project.

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2.5 EIA APPROACH, SCOPE AND OBJECTIVE

This EIA Report has been prepared based on information collected from the existing reclaimed islands and the surrounding environment by use of established methodologies, desk research for obtaining relevant secondary data, information obtained from the project proponent, use of guidelines collected from relevant laws and regulations as well as information obtained from previous EIA studies carried for Aanugandufalhu as well as other similar EIAs out in the country and experience of the EIA team engaged in preparing the report.

The primary objective of the EIA study is to safeguard the environment during planning, design, construction and operation of the proposed project activities and associated facilities by mitigating environmental impacts envisaged during various phases of the project and implementing an environmental monitoring programme to quantify the changes in the environmental components as a result of the development.

Specific objectives of the EIA study are to:

 Determine the present environmental conditions of the project area (important to note that the islands have already been reclaimed from previous EIA approval).  Identify, predict and assess environmental impacts that might arise during the construction and operation of the proposed resort project and activities associated with it.  Suggest environmental impact mitigation measures to suit local conditions in order to eliminate or reduce the negative impacts on the environment  Enable the project proponent to comply with environmental rules and regulations and train operating personnel in order to protect the environment.

The scope of the EIA study includes;

 Assessment of the present status of physical, biological and socio-economic components of the environment.  Identify environmental impacts due to the proposed project on environmental components (during the pre-construction, construction and operation phases).  Evaluation of environmental impacts.

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 Propose environmental management and mitigation measures for the impacts identified.  Propose an environmental monitoring programme to be pursued by the project proponent

2.6 EIA METHODOLOGY

The methodology adopted for the environmental impact study consists of the following stages:

 Identification of significant environmental components and assessment of their present status within the study area. This is carried out by site visits to study site-specific environmental conditions at the site.  Prediction of impacts on various identified environmental parameters due to the proposed project. Data relating to the proposed construction activities, resort design and layout, construction and operation waste, production of water and energy, as well as other activities causing environmental impacts through use of a descriptive environmental impact matrix.  Review of relevant EIAs carried out in similar environmental settings as well as other EIAs carried out for the site.  Evaluation of significance of environmental impacts by use of significance analysis method and using colour codes to indicate significance level  Expert judgment and professional opinion have also been used throughout the impact assessment and evaluation process.

These methods are described in detail at the relevant section of this EIA Report.

2.7 REVIEW OF RELEVANT STUDIES

As part of relevant literature review and preparation of the report, the following EIA studies have been reviewed to understand the effects of such development projects on the environment in addition to personal experiences of the environmental consultant who have prepared this EIA Report. These are;

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 Environmental Impact Assessment Report for Tourist Resort Development in Kudafushi Island in prepared by Dr. Mahmood Riyaz & Mohamed Zuhair in 2014.  Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Bodufinolhu Island, ADh Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2015.  Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Aarah Island in Raa Atoll prepared by Dr. Mahmood Riyaz and Mohamed Zuhair in 2015.  Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Uthuruboduveli, Uthurugasveli and Hurasveli in prepared by Mohamed Zuhair and Ibrahim Shakir in 2016.  Environmental Impact Assessment Report for Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2017.  First Addendum to the EIA for Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll prepared by Mohamed Zuhair in 2018.  Environmental Impact Assessment for Proposed Tourist Resort Development in Ruhthibirah, Thaa Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2018.

All these EIAs focus tourist resort developments in uninhabited islands some of which have land reclamation and coastal protection components, hence, have been used as reference and comparison in order to understand the types, degrees and magnitudes of environmental impacts from various development activities in these islands and lagoons. Also, these projects discussed different types of environmental impacts during construction and operation stages of tourist resorts that are most severe as well as identify ways in which these environmental impacts are managed through implementation of a number of mitigation measures that are site-specific and practical.

Resort development in Aanugandufalhu also carried out an EIA and an EIA First Addendum by the former proponent, which also provided vital information on baseline condition before any activity such as dredging and land reclamation at the site was carried out.

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2.8 EIA TEAM

Mr. Mohamed Zuhair, EIA Consultant (EIA01/15) is the team leader, who is a freelance Environment Consultant who has many years of experience in the field of environmental management, assessment and monitoring, implementation of environmental laws and regulations and has involved as lead consultant and a team member in preparing several EIAs in the Maldives including EIAs for tourist resort development, mariculture and agriculture development, harbor development, coastal protection, land reclamation, etc.

Mr. Ibrahim Shakir, Registered Land and Hydrographic Surveyor, who is an experienced Land Survey Consultant who has undertaken a number of land surveys for the purpose of land registration and development, undertaken many hydrographic surveys for development of important facilities such as jetties, harbours, water villas, as well as other water-associated facilities in many islands in the Maldives.

Curriculum Vitae of the Consultants have been annexed to this report.

2.9 EIA TERMS OF REFERENCE (TOR)

The Terms of Reference (TOR) outlining the scope of the EIA has been approved on 9 May 2019 by EPA.

The approved Terms of Reference is attached in Appendix 3.

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3. STUDY AREA

The following figures show relevant information of the project site including its location and key attributes of the surrounding environment including existing tourist resorts, inhabited islands, marine protected areas (MPAs) and enlisted sensitive sites. Planned new tourist resort developments in close proximity are also presented and boundary of the study area used to collect baseline environmental information has been outlined.

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SCALE

0 100 200 Meters

Title: Location Map

Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll Drone image taken by Veshilab Pvt. Ltd. in February 2019 Proponent: Promonant Pvt. Ltd. Figure 12: Location and study area of the project Page | 43

Aanugandu Falhu in 2008 Google Earth image Aanugandu Falhu in 2017 Google Earth image

SCALE

0 250 500 Meters

Title: Study Area Aanugandu Falhu in 2018 Google Earth image Aanugandu Falhu in 2019 Update Google Earth image (During land reclamation) (During final stages of land reclamation) Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll Proponent: Promonant Pvt. Ltd. Figure 13: Study area in various time periods Page | 44

Thulhagiri Island Resort Banyan Tree Vabbinfaru Himmafushi

Angsana Ihuru PROJECT SITE Gili Lankanfushi

Baros Island Resort Paradise Island Resort

Bandos Island Resort

Kodhipparu Malahini Resort

Sand Bank

Banana Reef

Kuda Haa

Project Site Centara Ras Fushi Existing Tourist Resort

Planned Tourist Resort

Ongoing Tourist Resort Development

Inhabited Island SCALE Lion’s Head Sensitive Site Kollavaani 0 2000 4000 Marine Protected Area Meters

Title: Key Attributes

Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll

Proponent: Promonant Pvt. Ltd. Figure 14: Regional attributes surrounding project area Page | 45

4. PROJECT DESCRIPTION

4.1 PROJECT LOCATION

Aanugandu Falhu is located at 4o18’30.98”N / 73o30’13.65”E in North Male’ Atoll. It is centrally located in the Atoll at a distance of 11km from Velaanaa International Airport. The nearest tourist resorts are Thulhaagiri Island Resort 1.4km west, Paradise Island Resort and Gili Lankanfushi 6km east and Bandos Island Resort 4km south. The nearest inhabited island is Himmafushi found 6.6km east (Figures 12 and 14).

Aanugandu Falhu is a small lagoon having 76ha in total area and is formed into a circular shape. A slightly deeper inner lagoon having an approximate area of 27ha is found slightly westwards of the lagoon, hence, shallow lagoon areas having an extent of 365m from inner lagoon slope to the outer reef slope exists on the eastern and south-eastern sides of the lagoon. A small sandbank is formed on the SE shallow lagoon having an area of 0.5ha. However, land reclamation initiated in the lagoon for a resort development project in 2018 which was completed in 2019 (Figure 13). Currently the lagoon has two reclaimed islands.

As Aanugandu Falhu is located in North Male’ Atoll where there are a number of tourist resorts as well as a number of lagoons allocated for similar resort development project on reclaimed land as well as with existing tourist resort and proximity to the international airport, its location is quite prime.

A number of lagoons have been allocated for similar resort development projects are found in the region (Figure 14).

The closest Marine Protected Area (MPA), Banana Reef is located at 8.4km south-east. Other MPAs in the region are Lion’s Head, Kollavaani found 15km on the south. A Sensitive Site (SS), which is a sand bank near Kodhipparu Falhu is found 14km SW of the project site (Figure 14).

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4.2 PROJECT PROPONENT

The project proponent for the new revised development plan for Aanugandu Falhu is Promonant Pvt. Ltd., which is a local company registered for investment and development of the resort in the lagoon. Promonant Pvt. Ltd. has sub-leased Aanugandufalhu from Aqua Blue Investments Pvt. Ltd., who was the previous project proponent and head lease holder.

Following are the details of the Project Proponent

Promonant Pvt. Ltd. 3rd Floor, Aage Building 12H, Boduthakurufaanu Magu Male’ 20094 Maldives Tel: 333 9992, 911 7799

4.3 PROJECT OUTLINE

Following are the key aspects of the revised resort development concept plan (Appendix 4: Final Revised Development Concept, June 2019) that is addressed in this EIA Report.

4.3.1 Development Scope

The development scope of the proposed project involves;

a. Development of temporary facilities b. Final shaping of the islands as per resort development plan c. Coastal protection around reclaimed islands and offshore d. Reclamation of small islet e. Landscaping plan f. Development of Back of the House (BOH) g. Development of guest rooms h. Development of public areas and guest facilities i. Development of utilities services including electricity, fresh water, sewerage treatment and waste management j. Operation of the resort

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4.4 KEY ACTIVITIES OF RESORT CONSTRUCTION

The following section outlines the major components of the development of the proposed tourist resort in Aanugandu Falhu.

4.4.1 Activities Undertaken as per Main EIA and EIA First Addendum Approvals

The main EIA for the proposed project was approved by MOT on 16 March 2017. However, initial project activities started in early February 2018. First, a reef access channel having 75m long and 30m wide and a depth of 3.5m below MSL on the north of the lagoon was made to access the already existing small islet on the eastern rim of the reef. Some temporary setup including labour quarters for the reclamation contractor was made on the existing islet. Land reclamation work on the western side of the lagoon also initiated during this time.

Figure 15: Lagoon reclamation works and temporary setup in early 2018 (Google Earth)

Although some land reclamation works were carried out, it was stopped as the project came to a revision, especially alteration of the land reclamation, changing of burrow site locations and coastal protection components as well as overall development concept of the resort. The project revision was approved by MOT on 4 April 2018. Subsequently, First Addendum to the EIA was prepared by the proponent and approved by MOT on 30 April 2018. The revised project of April 2018 included reclamation of two islands, one on the eastern and the other on the western side of the reef.

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Land reclamation of the two islands as per the First EIA Addendum was completed around March 2019. Throughout the land reclamation, further temporary structures including labour quarters, material storages, powerhouse, RO plant necessary for the construction works of the resort were established mainly on the area where a small islet exist on the eastern side of the reef. Rock boulders having approximately 5,000T for the proposed coastal protection were also brought and piled on the reclaimed islands. Some sand stockpiles having an estimated volume of 20,000m3 were placed on both islands for later use during beach profiling as well as for filling in case of severe erosion of reclaimed islands.

Figure 16: Reclaimed islands

Figure 17: Temporary setup of labour quarters and storages constructed on both islands

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Figure 18: Temporary RO plant (left) and power plant (right)

Figure 19: Rock boulders brought to the reclaimed island

Figure 20: Some sand stockpiles done on the reclaimed islands

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4.4.2 New Revised Development Plan

Towards the end of land reclamation in March 2019, with the engagement of a new project proponent, the entire development concept of the proposed tourist resort in Aanugandu Falhu again came to a reformulation. However, an important consideration was given to the already reclaimed islands with slight adjustments in the shoreline shapes, coastal protection measures including coastal protection around reclaimed islands and offshore protection as well as number of guest rooms, guest facilities, BOH and entire resort layout was reviewed. MOT approved both new revised development plan and coastal protection plan on 25 June and 26 June 2019 respectively. These plans are annexed to this report.

This EIA report is prepared to get environmental clearance for the new revised development plan and coastal protection plan which forms the entire project on development of tourist resort in Aanugandu Falhu.

4.4.3 Proposed Activities of the New Revised Development Plan

4.4.3.1 Development of Temporary Facilities

Although some temporary facilities have been done on the island upon approval of previous EIA and EIA First Addendum, the proponent proposes to construct proper temporary facilities including labour accommodation, stores, powerhouse and RO plant, site office, dining, waste management and temporary jetties on both islands to make the site ready for construction.

The proposed temporary facilities will be undertaken upon approval of the EIA. As there will be a number of construction activities planned throughout the islands, the temporary facilities have been distributed in various locations of the island. However, the facilities such as accommodation will be phased according to the progress of construction activities. Services including temporary powerhouse will have 3 x 125kVA , 1 x 200kVA, 1 x 100kVA and 1 x 20kVA gen sets, RO plants having capacity of 2 x 100 ton per day, 1 x 50 ton per day and 1 x 20 ton per day. Raw sewage from construction labourers will not be released into the marine environment as it will have direct impacts on Aanugadu Falhu reef and nearby reefs, instead a localised septank system will be used on the reclaimed island. This system will be removed once a proper STP is installed on the island.

The following figure outlines the temporary facilities development plan.

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Figure 21: Temporary facilities plan

4.4.3.2 Reshaping the Shorelines

Although the new revised development plan considers exiting reclaimed islands to be developed as the resort, minor reshaping of the islands, particularly shorelines require to be undertaken. Some areas of the island has been slightly extended while other areas have been reduced through natural process of accretion and erosion. The extended areas of the shoreline will be removed in accordance with the required extent by use of excavator, while areas that require extension, particularly, the southern side of Island 2 will be filled with sand sourced from the existing stockpiles.

Immediately after reshaping of the shorelines, coastal protection as proposed in the new revised development plan will be undertaken in order to maintain the shorelines as per the requirement. Details of the coastal protection measures will be discussed later.

Towards the end of the construction period, beach profiling will be undertaken by use of existing sand stocks.

The following figure outlines reshaping plan of the shorelines on both islands. Page | 52

Figure 22: Reshaping plan of the shorelines on both islands

Furthermore, a 10m wide internal channel has been created between Island 2 and Island 3 in order to enhance flow directed towards the island. This will reduce the on the islands as a good flow will be maintained through the internal channel. The sides of the channel will be protected by a revetment. The middle part of the channel will be made circular and will be used as a public area. The depth will be maintained between 0.5m to 1m. Sand excavated from the internal channel will be stockpiled for later use during beach profiling. It is estimated that 4,150m3 of material will be obtained from the internal channel.

4.4.3.3 Coastal Protection

Since the islands are already reclaimed, a number of coastal protection measures have been proposed in order to maintain and protect the islands for long-terms. Both onshore and offshore structures have been proposed.

The following figure outlines the proposed coastal protection plan.

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Figure 23: Proposed coastal protection plan for the reclaimed islands

Justification for Coastal Protection

Since reclaimed areas are newly formed lands, natural adjustments in the shoreline as a result of alteration of the oceanography start occurring, which is the case in the present reclaimed islands in Aanugandu Falhu. This triggers movement of sand from one place to another and in many cases prompting erosion in certain areas of the reclaimed islands. It also depends on seasonal oceanographic conditions such as waves and currents, where erosion may take place in one season and may reverse in the alternating season. Thus, it is essential for newly reclaimed areas to consider coastal protection in order to maintain their desired shapes and sizes.

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Permanent coastal protection has been considered a key element for retaining the reclaimed islands, especially on areas where some rough conditions prevail during SW monsoon. The proposed shoreline protection measures are believed to maintain the islands as the structures will limit sand movement along the shore as well as reduce waves directly approaching the island. Also, these structures are not believed to obstruct any longshore current movement around the islands, which is vital for maintaining the beaches.

While considering coastal protection measures, wide scale applicability and functionality has been greatly considered for similar environmental conditions. It is proposed to use rock boulders in the structures made for coastal protection of the reclaimed islands.

Design Consideration

The coastal protection design parameters have taken into consideration wave energies that ranges between 0.3Hz to 0.127Hz which is commonly found in peripheral reefs in the country (Paul S. Kench, Robert W. Brander, Kevin E. Parnell, Roger F. McLean in 2006). Since the reclaimed island will be inside the lagoon, the strong design parameter consideration is believed to sustain the island on a long-term basis.

Headland Revetments

Headland revetments are onshore structures designed to reduce currents and waves and placed in key areas, particularly tips and corners to reduce erosion and maintain desired shapes of shorelines. It is widely used in reclaimed islands to maintain a desired shape of a particular area of the island.

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Figure 24: Use of headland revetments in newly reclaimed islands in South Male Atoll

Design Details

Following are the design details of the headland revetment structures proposed for the already reclaimed islands in Aanugandu Falhu.

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Figure 25: Design of a typical headland revetment

A total of 12 revetments having varying lengths (43m – 77m) have been prosed around the reclaimed islands including the internal channel between Island 2 and Island 3 as per the new revised development plan. It is estimated that around 2,871 tonnes of rock boulders (400 – 600kg) will be required for the proposed revetments.

Groynes

Grones are also onshore structures extended into the lagoon and constructed perpendicular to the shore. Groynes are also widely used to as an important coastal protection measure in many reclaimed islands and other islands to sustain beaches. It functions as a controller to minimize sand movement along the shore with seasonal sand accumulation. For the purpose of the project, it is proposed to use Y groynes.

Figure 26: Use of Y groynes for coastal protection along the shore

Design Details

Following are the design details of the groynes proposed for the already reclaimed islands in Aanugandu Falhu.

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Figure 27: Design of a typical Y groyne

The length of the proposed groynes are 20m long each in the stem and 10m in length in each arm. A total of 5 groynes on Island 1 and 1 groyne on Island 2 have proposed to be constructed. The groynes will also use 400-600kg size rocks. It is estimated that around 1,125 tonnes of rock boulders will be required for the proposed groynes.

Offshore Breakwaters

Offshore breakwaters are structures constructed in the lagoon parallel to the shoreline in order to reduce the energy of waves and swells directed towards the island. Since the southern periphery of the reef experiences some dynamic conditions including seasonal waves and swells, it is proposed to construct an offshore breakwater to cover the SW side of Island 1.

Figure 28: Use of offshore breakwaters

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Design Details

Following are the design details of the proposed offshore breakwatersto be placed on the southern sie of Island 1.

Figure 29: Design of a typical offshore breakwater section

The total length of the proposed offshore breakwater is 175m, which will be constructed in sections of 25m long. Thus, there will be a total of 7 sections using 400 – 600kg rocks. It is estimated that a total of 1,785 tonnes of rock boulders will be required for the proposed offshore breakwaters.

Offshore Revetment Islets

Similar to offshore breakwater on the SW of Island 1, it is proposed to construct offshore revetment islets on the SE side of Island 2. This system will also have similar functionality as the offshore breakwaters in terms of intercepting incoming waves and swells directly approaching the island.

For these islets, sand fill will be done in a semi contained revetment. The sand fill will be inside the revetment facing the main island while the back will be a rock boulder revetment. The fill area will be vegetated, hence, will have an additional function of increasing aesthetics for the beach villas proposed on the SE side of Island 2.

The gaps between these islets will have an offshore breakwater section (25m long) similar to the breakwater proposed for SW side of Island 1. These sections will reduce pressure towards the gaps between the islets.

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Figure 30: Offshore revetment islets during construction (left) and after construction (right) in a resort

Design Details

Following are the design details of the proposed offshore revetment islets proposed for SE side of Island 2.

Figure 31: Design of offshore revetment islet

It is proposed to construct 5 small islets having 100m each within the lagoon on the SE side of Island 2. The design height of the revetment is proposed to be 1.5m above MSL and sand fill height is proposed to be at 1.4m above MSL. It is proposed to use 400 – 600kg rock boulders in the revetment. It is estimated that around 5,100 tonnes of rock boulders will be required for the proposed offshore revetment islets. The sand fill requirement for the islets are estimated to be 15,574m3 (3,115m3 per islet).

4.4.3.4 Minor Reclamation

Land reclamation of main islands are currently complete as per the main EIA and EIA First Addendum approvals granted by MOT under the previous project proponent.

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However, a minor land reclamation for a small islet (Island 4) by the access channel on the north of the reef and 5 small islets (revetment islets) for coastal protection are proposed to be undertaken as part of the new revised development plan.

The following figure outlines details of these reclamations.

Figure 32: Minor reclamation areas (green) and burrow sites (red)

Locations, Area and Volume Estimates

Following are the locations were minor land reclamation will be carried out and proposed burrow site and alternative burrow sites.

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Area Location Area Height Depth Fill Material (m2) (MSL) (MSL) Volume (m3) Small Islet 4°18'45.79"N 625.17 1.5 -1.0 1,875 (North) 73°30'10.34"E Revetment 4°18'15.13"N 1,038.26 1.5 -1.0 3.115 Islet 1 73°30'15.77"E Revetment 4°18'15.49"N 1,038.26 1.5 -1.0 3.115 Islet 2 73°30'18.04"E Revetment 4°18'16.30"N 1,038.26 1.5 -1.0 3.115 Islet 3 73°30'20.18"E Revetment 4°18'17.39"N 1,038.26 1.5 -1.0 3.115 Islet 4 73°30'21.92"E Revetment 4°18'18.82"N 1,038.26 1.5 -1.0 3.115 Islet 5 73°30'23.26"E Total 17,450 Table 1: Proposed minor reclamation areas

Area Location Area Existing Dredging Volume (m2) Depth Depth Obtained (m3) (MSL) (Seabed) Burrow 4°18'30.84"N 3,472.55 -8.0 -5.05 17,536 Site 73°30'17.26"E Alternative 4°18'34.57"N 3,472.55 -8.0 -5.05 17,536 Burrow 73°30'4.97"E Site 1 Alternative 4°18'43.04"N 3,472.55 -8.0 -5.05 17,536 Burrow 73°30'12.29"E Site 2 Table 2: Proposed burrow site and alternative sites and volume obtained

In order to reclaim the proposed small islet having 0.06ha on the north of the reef as well as reclaim 5 revetment small islets having 0.1ha each on the SE side of Island 2, it is estimated that 17,450m3 of fill material will be required. It is proposed to obtain the required fill material within the inner lagoon of the reef. A burrow site and two alternative burrow sites within the inner lagoon have been proposed. Each site has an existing depth of -8m MSL and it is proposed that the burrow site will require to be dredged at a depth of 5.05m below existing seabed to yield the material required for minor reclamation.

Method of Dredging and Reclamation

Since these are smaller areas proposed to be reclaimed, it is proposed to use 12-inch sand pump in a floating sand barge to undertake the main dredging. In order to reduce spread of sedimentation within the marine environment, it is proposed to pump the required fill material onto the existing reclaimed island (Island 3) or Island 1 (in case alternative of burrow sites)

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and make sand stockpile. Transport required fill material from these sand stockpile either by using tractors and flat-top barges to the desired areas (islets). Direct disposal of fill material will generate sedimentation, hence, has not been proposed for minor reclamation. These islets will also be contained with a physical barrier such as geo-bags, hence, sedimentation can be minimized during infilling of these areas.

Indication of Availability of Fill Material

Since the islands in Aanugandu Falhu have been reclaimed from fill material obtained from the inner lagoon as per main EIA and EIA First Addendum approval, it is believed that there will be sufficient amount of fill material required for the proposed minor reclamations.

Based on the assessments undertaken in the lagoon according to the EIA report, the large inner lagoon area is believed to have more than sufficient sand deposits that can be used for proposed land reclamation. Although the lagoon was not cored to assess the general seabed profile, based on studies undertaken for similar projects (reviewed in this EIA Report) as well as other literature, there is potential that the lagoon will have sufficient fill material in different layers of the seabed profile given that certain areas have already been used as burrow sites within the inner lagoon.

4.4.3.5 Landscaping Plan

Landscaping will be an important component of the proposed project as the reclaimed islands will require landscaping in accordance with the development concept. With regards to implementing landscaping on the reclaimed islands, a proper landscaping concept is needed, which is currently under preparation. However, the following landscaping plan outlines major components that will be undertaken towards implementing landscaping on the reclaimed islands.

Plant Nursery Setup

During the initial stages of land reclamation, a 2,000ft2 area will be allocated for development of a proper plant nursery with all necessary equipment which will be an important source for supplying necessary landscaping plants throughout the construction period of the resort. The main focus of the nursery will be to establish fast growing local plants from sticks such as Magoo, Hirundhu, Dhigga, Kuredhi. Also, an important part of the nursery is to source very young palm trees from various islands which will then be brought to the nursery and planted

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on pots and maintained well for growth. In order to enhance the plant source of the nursery, plant nurseries run by locals and community will be communicated and arrangements will be made for transportation of young plants. Also, cuttings of local ornamental plants will be grown in the nursery which will later be used for landscaping. Dedicated staff will be employed to maintain the nursery on the island.

Local Sourcing

Sourcing mature trees and plants including palm trees have become a sensitive issue recently due to illegal activities including removal and transportation of large amounts of mature trees especially palm trees undertaken towards greening of reclaimed islands. A regulation has been developed under the Environmental Protection and Preservation Act (Law No. 4/93) known as “Regulation on Uprooting, Cutting and Transportation of Trees and Palm Trees” which covers provision of such activities that can be undertaken legally and measures that require to be undertaken towards mitigating removal of plants in the country. If anything happens in terms of removal of mature trees and palm trees outside of this regulation, it is considered as an illegal activity.

Therefore, local sourcing of mature trees and palm trees will be carefully undertaken and will be done in accordance with the Uprooting Plants Regulation.

Following are the key considerations that will be given while sourcing trees locally;

a. Only locally available plants and trees such as Ruh, Funa, Magoo, Dhigga, Hirundhu, Uni, Kaani, Kuredhi, will be used as the main vegetation on the reclaimed islands. b. Trees will be sourced from areas that already have an approved EIA by EPA. Such areas include vegetation removal approval given by EPA for undertaking development project such as airport development, roads development, public facilities development. In this regard, approved EIA Decision Statements will be sought from Councils. c. Proponent will prepare separate EIAs for vegetation removal for approval of EPA for sourcing of trees if there are no EIAs done for a development area. In this case, consent of important stakeholders such as Island Council, community and relevant government agencies will be initially sought prior to preparation of the EIA.

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d. All legal provisions and measures prescribed in the Trees Uprooting Regulation will be implemented. e. The proponent will ensure that trees are planted in accordance with the Uprooting Trees Regulation in replacement of trees transported to the reclaimed islands.

Since a proper landscaping concept of the resort has not be done yet, the exact number of trees required to be planted on the reclaimed islands are currently unknown. However, it is estimated that around 4,500 trees (mixed), 1,200 palm trees and approximately 50,000 plants (for ground cover) will be required for all islands.

Importing

In order to reduce stress on local sources of trees and plants, importing plants from other countries has also been considered as part of landscaping on the reclaimed island. Only plants and trees including ornamental plants that can be easily acclimatized and grown in local conditions will be considered for import. Palm trees will also be considered for import if there are shortages from local sources. Prior written approval from Ministry of Fisheries, Marine Resources and Agriculture will be sought before importing plants to the country. Importing plants and trees will be undertaken in accordance with relevant regulations as well as proper health certificates to reduce risks of diseases.

4.4.4 Construction of Resort Facilities

The following section outlines major facilities that will be constructed as part of the proposed resort development in the lagoon.

4.4.4.1 Guest Accommodation

As part of the proposed project, a total of 353 guest rooms (706 beds) will be developed on the reclaimed islands in Aanugandu Falhu in various categories. These include;

 47 x Beach Villas  6 x Duplex Beach Villas  43 x Deluxe Duplex Beach Villas  13 x Duplex Beach Villas Type 2 (2 Storey)  36 x Water Villas Page | 65

 60 x Duplex Water Villas

Although the proposed resort will be developed on a completely reclaimed islands, a 5m setback from proposed vegetation line in the front areas and a minimum of 2m in between two rooms as well as over 60% of beach areas will be left for guest use as per the tourism regulation will be considered for development of the guest rooms and resort infrastructure.

4.4.4.2 Food Outlets

A number of food outlets have been proposed to be developed on the two reclaimed islands as part of the development, including;

 Food Court (Island 2)  Pool Bar (Island 2)  Main Restaurant (Island 1)  Underwater Pavilion and Dining (Island 1)  Specialty Restaurant (Island 1)  Pool Bar (Island 1)

4.4.4.3 Swimming Pools

Two Swimming Pools will be developed on the two main islands facing the inner lagoon. The swimming pools will have a sun deck and a bar area. Additionally, guest rooms in Island 1 will have small plunge pools.

4.4.4.4 Overwater Spa

A large and a modern overwater Spa Complex having spa treatment rooms, spa relaxation rooms will be developed on the NE side of Island 3 within the lagoon. The main spa area will comprise of a Jacuzzi pool, relaxation area, changing rooms, reception, steam bath area. The treatment rooms will comprise of treatment area, toilets and steam shower area with service facilities. The entry pavilion of the spa will be developed on land close to the treatment and relaxation areas.

4.4.4.5 Underwater Pavilion

An underwater viewing pavilion with a small dining area will be developed on the connecting jetty between Island 1 and Island 2, which will be located close to the arrival jetty and main

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reception on the southern side of the reef. The pavilion will be developed on a separate platform connected to the connecting jetty.

4.4.4.6 Overwater Gym

An overwater gym is proposed to be developed on the north of the water villa wing of Island 3, which will face into the inner deep lagoon. It will be housed with state-of-the-art gym facilities.

4.4.4.7 Club House

A large club house with many facilities and amenities will be developed on Island 3 close to the internal channel, which will be a man public area of the resort.

4.4.4.8 Clinic

A small clinic will be developed for emergency requirements in the middle of Island 2 which will have direct access to BOH and guest facilities. The clinic will provide essential health services on the resort with on-call doctors.

4.4.4.9 Dive School and Water Sports

A dive school and water sports center will be developed on the western side Island 3, which will be located close to each other for easy management. The centers will be housed with most modern facilities for diving and water sports.

4.4.4.10 Boutique and Shop

A boutique and shop will be developed on the NW side of Island 2 which will provide local handicrafts, souvenir as well as some essential goods.

4.4.4.11 Arrival Jetty and Main Reception

A large overwater complex housing arrival jetty, main reception. lobby, etc will be developed in the middle of Island 1 and Island 2 on the connecting jetty facing the inner deep lagoon. The area will be developed separately but connected to the connecting jetty between Island 1 and Island 2.

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4.4.4.12 Water Sports and Dive Centre

A large complex for water sports and will be developed behind the main complex on the island on the western side.

4.4.4.13 Connecting Jetty and Service Jetty

The islands developed as part of the resort will function as one tourist resort. Hence, it is proposed to construct a 600m long jetty on concrete columns on the southern side of Aanugandu Falhu. All necessary services including power, freshwater and STP will be connected from Island 2 to Island 1 by using the connecting jetty.

A service jetty has been proposed on the eastern side of Island 1, which will be primarily used for all services needs of the resort. This jetty is a replacement of a harbour proposed on the eastern side of Island 2, however, based on careful assessment of site conditions, the harbour proposal was taken out in the final revised development concept of June 2019.

4.4.4.14 Back of the House (BOH)

The main hub of the resort with all services facilities and infrastructure will be developed in a large Back of the House (BOH) area that will be located on the eastern side of Island 2. Although the resort will be divided into 4 islands, it will have one dedicated BOH area. Staff Accommodation, Mess Room and Kitchen and Staff Recreation area, all utility services including Powerhouse, RO Plant, Sewage Treatment Plant, Incinerator well as Main Store, Workshop, Laundry, Housekeeping, Fuel Farm, Water Storage, Futsal and Mosque will be located within this area.

There will be no dedicated BOH area on Island 1, however, some Executive Staff accommodation, transformer house and some office buildings will be located on Island 1. All necessary utility services including power, freshwater, sewerage, communication will be connected to Island 2 from the connecting jetty developed between Island 1 and Island 2.

4.4.5 Area Development Programme

The following table outlines the area development programme of all infrastructure and amenities that will be developed as part of the proposed tourist resort.

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Table 3: Area development programme of Aanugandu Falhu Page | 69

4.4.6 Waste Management during Construction

During the construction of the resort, one of the most significant environment issues will be generation of construction waste and disposal. As construction on the islands will be started immediately after EIA approval, adequate measures will be taken to address waste issues during construction phase.

In this regard, a waste collection area will be allocated on Island 1 and Island 2 where all waste will get initially sorted. An important construction waste management strategy will be to reduce waste and reuse all reusable items. With this strategy, residual waste will be minimized. Regular transportation of disposable waste to Thilafushi, which is located closeby will be undertaken to reduce piling up of construction waste on the islands. Some of the food waste will be used as compost for the nursery while others will be regularly transported to Thilafushi.

Provisions outlined in the Waste Regulation implemented by EPA will be strictly followed during construction waste management. In this regard, all waste will be handled carefully and during transportation of waste, containers will be fully covered. No waste will be dumped or disposed on the islands and into the marine environment as it will deteriorate the environmental and aesthetic quality of the resort. All hazardous waste such as waste oil will be transported to Thilafushi in closed containers.

4.5 RESORT OPERATIONAL REQUIREMENTS

Once the proposed resort is fully constructed, it will have a total of 353 guest rooms (706 beds). A guest to staff ratio of 1:1.5 as per the tourism regulations will be required to operate the resort, hence the total number of staff requirement will be 1,064, who will be employed in the resort. Greater emphasis will be given to maintain and effectively manage the environment of the islands as well as the surrounding environment during the resort operation. The following facilities and services will be developed on the islands to make sure that the resort operation will be undertaken effectively.

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4.5.1 Energy Generation

Location

A proper powerhouse for energy generation requirements of the resort will be developed within the BOH area on Island 2. The powerhouse and RO plant house will be located in the same building for easy management as the engineering team will operate both the powerhouse and RO plant.

Figure 33: Location of powerhouse and RO plant

Generator and Powerhouse Details

The primary source of energy generation on the resort will be by use diesel generators. In this regard, a total of 3 x 1250 KVA, 1 x 1000 KVA and 1 x 810KVA generator sets will be installed in the resort. One 810 KVA unit will be used for backup. The powerhouses of the resort will be made with soundproof walls, concrete flooring, bund wall and appropriate roofing as per regulatory requirements and will be located at the BOH area as outlined in Figure 33. Appropriate firefighting equipment in accordance with legal requirement will be kept within and outside of the powerhouses for fire emergencies.

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Cooling System

Air-cooled system will be used in the powerhouse by using desalinated water from the RO plants. The heated water will not be discharged into the marine environment as it will have major impacts on corals and marine organisms. Exhaust heat will be used for production of hot water and will be circulated to staff accommodation buildings.

Fuel Transportation Technique and Volume

The required fuel will be transported to the resort on a regular basis by vessel bowsers from Male’ or elsewhere from the Atoll where fuel is readily available. An underground piped network will be connected to the fuel farm from the service area located on Island 1. Care will be taken during fuelling to reduce potential for oil spills. The service jetty area will have fire extinguishers and boomers in case of fuel related accidents.

A detailed design on the underground pipeline as well as a route map has not been done yet, hence was unable to be presented in the report. As this is the beginning stage of the development, such details will be worked out and presented to the authorities while obtaining operation permit of the resort.

As an alternative means to supply fuel to the island, an extended pipeline directly into the fuel tanks can be used for refuelling. However, the practicality as well as safety of such procedure needs to be evaluated before implementation.

It is estimated that 200t for the entire Resort of fuel will be required per load, which is estimated to be 30 days supply.

Emergency Power Supply Plan

In case of power failure, the backup 810kVA generator will be used in the powerhouses for use during emergency.

Fuel Leak Detection

In order to detect leakage in the fuel pipelines, the SmarkBall technology has been proposed for the project. The SmartBall platform is a free-swimming for water, wastewater, and oil and gas pipelines that can complete long inspections in a single deployment. The tool can complete long surveys in a single deployment without disruption to regular pipeline service. It is equipped with a highly sensitive acoustic sensor that is able to locate pinhole-sized leaks. Page | 72

During an inspection, the tool is inserted into a pipeline and travels with the product flow while collecting information about leaks and air pockets. It requires only two access points, one for insertion and one for extraction, and is tracked throughout the inspection at predetermined fixed locations on the pipeline. It is capable of locating very small leaks typically within 6 feet (1.8 meters) of their actual location.

Alternative Energy and Energy Conservation Measures

In order to conserve the energy generated on the resort during operation, various measures and energy efficiency equipment and heat recovery systems will be used. In this regard, energy controls and sensors, auto switches and key cards, low-energy lighting and energy efficient heavy equipment such as air conditioners, freezers will be used to ensure conservation in addition to conducting regular energy audits. Solar energy by use of panels in the BOH for various uses as well as solar water heaters are considered for all guest rooms, which will also add to energy conservation measures implemented by the resort.

4.5.2 Freshwater Production

Location

The freshwater required for the resort will be made from Reverse Osmosis (RO) desalination plants. The RO plant will be located in the middle of the island at the BOH area within the same powerhouse building (Figure 33).

RO Plant Details

The primary source of freshwater will be obtained by use of 3 x 300 ton per day and 1 x 50 ton per day for double pass.

Freshwater will be connected through a piped network laid through the main island (Island 2) and other islands (Island 1 and Island 3) through the connecting jetty and access jetties and sub-connections into all outlets which will be connected to the main water production facility.

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Water Intake and Brine/Wastewater Outfall

The following figure outlines the locations for boreholes huts and alternative brine intake location and outfall and alternative outfall that have been considered the resort.

Alt. Brine Intake

Borehole Outfall

Alt. Outfall Figure 34: Borehole and brine/wastewater outfall location and alternative locations

Water intake for the RO plants will be obtained from 30m deep boreholes, which will be located by the proposed RO plant and alternatively an intake direct from the sea on the western side. The boreholes will be developed according to the borehole guidelines maintained by EPA. The sewage outfall and alternative outfall are located on the SE side of Island 2 as shown in Figure 34.

Locations

Following are the locations of borehole, wastewater outfall, alternative brine intake and alternative wastewater outfall locations in detail.

Detail Location Borehole 4°18'20.66"N / 73°30'23.68"E Wastewater Outfall 4°18'18.55"N / 73°30'28.65"E Alt. Brine Intake 4°18'25.30"N / 73°30'16.17"E Alt. Wastewater Outfall 4°18'15.75"N / 73°30'26.82"E Table 4: Water intake and wastewater outfall and alternative locations

Justification

The main reason for selecting boreholes as the water intake for RO plants is to reduce potential for sediment intake, which will easily damage the RO plant membranes. As the island from the lagoon will be reclaimed for developing the resort and there will be some sediments settled at

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the bottom of the lagoon, hence there is greater risk of flowing this sediment into the RO plants if water is directly taken from the lagoon. Also, the water from the boreholes will be relatively clean and have less biological content due to high filtration underground unlike seawater directly taken from the lagoon, thus will make RO plants more efficient and long lasting.

However, if sulphur is found in the water drawn from boreholes, brine intake line (alternative) will be laid and used as primary intake.

The brine/wastewater outfall is located on the south-eastern side of the resort. The main reason selecting the eastern side and particular locations is that the wastewater will be taken away from the lagoon system during SW and NE monsoons. In this regard, impacts on the marine environment will be greatly reduced from wastewater.

Water Quality Monitoring Plan

As per requirements of Desalination Plant Regulation, a monthly water quality monitoring report from key water outlets including restaurants and discharging location as well as staff areas need to be submitted to EPA. In this regard, the water quality of the outfall as well as quality of intake water from boreholes and quality of product water will be monitored on a monthly basis during the operation of the resort.

During monitoring water samples will be collected from the discharge locations in PET and glass bottles, which will be sent to MWSC or Public Health Laboratory for physical, chemical and biological analysis. Samples will be sent to laboratories before 24 hours of collection time as per requirements of the laboratories.

Emergency Water Supply

Emergency water supply will be carried out by using backup RO plant (a 100t plant) as well as freshwater stored on the islands mainly in the BOH area. Storage facilities that will be installed on the island will be discussed later. Additionally, rainwater will be harvested from the Back of the House area, which will also be stored in tanks, which will also be an alternate water source which can be used during emergencies after appropriate treatment.

Water Leak Detection

In order to detect leakage in the water pipelines, the SmarkBall technology has been proposed for the project. The SmartBall platform is a free-swimming solution for water, wastewater, and

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oil and gas pipelines that can complete long inspections in a single deployment. The tool can complete long surveys in a single deployment without disruption to regular pipeline service. It is equipped with a highly sensitive acoustic sensor that is able to locate pinhole-sized leaks.

During an inspection, the tool is inserted into a pipeline and travels with the product flow while collecting information about leaks and air pockets. It requires only two access points, one for insertion and one for extraction, and is tracked throughout the inspection at predetermined fixed locations on the pipeline. It is capable of locating very small leaks typically within 6 feet (1.8 meters) of their actual location.

4.5.3 Solid Waste Management

Location

In order to address solid waste generated from the resort, a waste management area (Recycle house and incinerator) has been designated at the BOH area. Waste generated on the resort will be regularly transported to Thilafushi.

Figure 35: Location of the waste management area

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Waste Management Equipment

The following waste management equipment will be used on the resort;

Type Capacity Incinerator 1 x 1500kg/day Bottle crusher 1 x 250kg.day Can compactor 1 x 250kg.day Shredder 1 x 1000kg/day Compost bins 5 x 100kg/day Table 5: Waste management equipment

Types and Quantities of Waste Generated

The different types of waste during the resort operation can be divided into inorganic and organic waste. The main types of inorganic waste include paper and cardboard items such as stationary and packaging, glass and plastic bottles, plastic bags, cans and tins, building material, and furniture and will be sorted accordingly. Organic waste will mainly consist of food and kitchen waste and green waste from garden trimmings. The other type of waste that will be generated during the resort operation is hazardous waste, which will mostly consist of batteries, solvents, paints, waste oil, clinic waste and anti-fouling agents that will have high chemical content.

It is estimated that the resort will produce about 40t – 46t of solid waste on a monthly basis.

Method of Waste Management

Both organic and inorganic as well as hazardous waste will be collected daily from the resort and will be taken to the main waste management area, which will be established in close proximity to the staff and back of the house area for easy management. Different types of waste will be initially sorted and contained at the waste management area, which will have proper waste management equipment including bottle crusher, incinerator, compactor and shredder. Compost bins will be used to make compost for conditioning soil of the resort.

The organic waste will be sorted into kitchen and garden waste, while inorganic waste will be sorted into plastics, paper, glass and tins.

Hazardous waste from clinic and waste oil, paints will also be kept in closed containers separate at the waste management area.

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The waste generated on the resort will be carefully managed by use of waste management equipment mentioned before. For instance, all flammable waste will be incinerated, glass bottle will be crushed, aluminum cans and tins will be compacted and most of the food waste and garden waste will be shredded and composted by using a compost bin. The residual waste such as ash from the incinerator, crushed glass and compacted cans as well as hazardous waste in closed containers will be regularly transported to Thilafushi.

Waste Transportation

The residual waste after waste management including ash from incinerator, compacted tins, crushed bottles, food waste not used in the compost bins, hazardous waste will be regularly transported to Thilafushi in Dhoni.

The Dhoni used for transportation of waste will also meet with the requirements of the Waste Management Regulation.

It is estimated that around MVR 50,000 – MVR 60,000 per month as waste transportation cost from Aanugandu Falhu to K. Thulafushi waste disposal area.

4.5.4 Sewage and Wastewater Treatment

STP Location and Justification

The STP on resort will be located at the BOH area close to the waste management incinerator room. The main reason for selecting the locations is for easy management and monitoring of the systems by responsible staff as well as to undertake such activities away from guest areas of the island.

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Figure 36: Location of the STP

Type and Capacity

A Mooving Bed Bio-Film Reactor (MBBR) type purification plant for wastewater treatment will be used. In this regard, the resort will be installed with a 250m3/day capacity plant.

Justification of the System

Technically, the MBBR is an activated sludge process designed to operate under non-steady state conditions. An MBBR operates in a true batch mode with aeration and sludge settlement both occurring in the same tank. The major differences between MBBR and conventional continuous-flow, activated sludge system is that the MBBR tank carries out the functions of equalization aeration and sedimentation in a time sequence rather than in the conventional space sequence of continuous-flow systems. In addition, the MBBR system can be designed with the ability to treat a wide range of influent volumes whereas the continuous system is based upon a fixed influent flowrate. Additionally, SBRs produce sludges with good settling properties providing the influent wastewater is admitted into the aeration in a controlled manner.

This is coupled by the flexibility of a SBR in the treatment of variable flows, minimum operator interaction required, option for anoxic or anaerobic conditions in the same tank, good contact with microorganisms and substrate, small floor space, and good removal efficiency.

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Method of Treatment

The sewage treatment plant that will operate on the resort will be compact in size, have silent operation features with minimal maintenance requirements once properly installed. Although the plant have two stages of aerobic and anaerobic treatment processes, it uses very little energy as it has no rotating parts in the process tanks, which is completely sealed to flies and mosquito and produces very low levels of sludge compared to extended aeration system. The process will be based on a simple mixture of gravity and pumped system. In order to keep the system simple, gravity will be greatly used, which will be collected at lift stations suitably located on the islands.

Sewerage System Design

Currently a sewerage system design for the resort has not been undertaken, hence was unable to be used in the report. However, key design parameters that will be taken into consideration while developing the sewerage system and network are identified below.

The EPA sewerage design parameters have been taken into consideration for the sewerage system. In this regard maximum flow of 1 in 250 as the gravity flow, a minimum velocity of 0.6m/s will be maintained throughout the pipeline and a maximum depth of 2.5m has been considered for laying the pipeline. Additionally, 10% infiltration consideration has been given in the flow rates.

The sewerage system will be designed with pump and lift stations and appropriately networked. Each station will be equipped with its own pumps control panel which will be arranged in such a way to automatically rotate the pump duty after each start / stop cycle. The control system provides manual over ride for emergency situation. In addition to pump stations, grease traps will also be installed within the system.

A central alarming system will be installed on the islands for monitoring each lift station and pump as well as leaks in order to ensure corrective action will be undertaken as soon as a problem persists.

The sewage treatment plant will be designed for the following inlet sewage conditions;

BOD5 275 ppm – 300 ppm

Suspended solids 250 ppm

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Oil and grease 5 ppm

The treated water will have the following outlet conditions;

BOD5 15-20 ppm

Suspended solids 15-20 ppm

The wastewater generally free from oil and grease enters the plant through the solid separation zone. The larger solids having a size of 80mm or more will be separated and taken out before the raw sewage is pumped into the plant. At the solid separation chamber, relatively heavier solid and particles settle at the bottom of the tank, which often takes longer time to degrade biologically. Relatively clear sewage flows to anaerobic digestion chamber. Solid separation chamber together with anaerobic digestion chamber plays an important role in this treatment process that aims to achieve very low amount of sludge production.

The treated water will be disinfected either by UV or another disinfectant to eliminate the bacterial load and will be reused during landscaping. This will assist in recharging the aquifer and in the conservation of freshwater in the resort. The treated water will not be used in wash basins, laundry or for W.C. flushing. Wastewater from areas including guest, staff, laundry and public areas will be connected to the treatment plant. As sludge from the system will not require to be removed frequently, thus, the operation will be undertaken as and well when required within a period of 5 to 10 years.

Dewatering Operations for Pump Stations and Sewer Trenches

With regards to dewatering pump stations and sewer trenches, wellpoint system has been considered. The wellpoint system will consist of a number of wellpoints spaced around pump station and along trench, all connected to a common header, which will be attached to one or more wellpoints. Wellpoint systems are quite suitable in shallow aquifers where water level needs to be lowered no more than 3 – 4m.

The water from dewatering will not be disposed into the sea, instead it will be released into various areas of the reclaimed island so that groundwater aquifer can be maintained.

Before the works for sewerage system begins, a dewatering approval will be obtained from EPA and all the work will be done in accordance with the EPA standards and requirements.

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Discharge Water Quality Monitoring System and Leakage Detection System

As per requirements of Desalination Plant Regulation, a monthly water quality monitoring report from key water outlets including discharging location needs to be submitted to EPA. In this regard, the water quality of the outfall will be monitored on a monthly basis during the operation of the resort.

During monitoring water samples will be collected from the discharge locations in PET and glass bottles, which will be sent to MWSC or Public Health Laboratory for physical, chemical and biological analysis. Samples will be sent to laboratories before 24 hours of collection time as per requirements of the laboratories.

For leakage detection purpose of the sewer network, the SmartBall Technology has been proposed for the project. The SmartBall platform is a free-swimming solution for water, wastewater, and oil and gas pipelines that can complete long inspections in a single deployment. The tool can complete long surveys in a single deployment without disruption to regular pipeline service. It is equipped with a highly sensitive acoustic sensor that is able to locate pinhole-sized leaks.

During an inspection, the tool is inserted into a pipeline and travels with the product flow while collecting information about leaks and air pockets. It requires only two access points, one for insertion and one for extraction, and is tracked throughout the inspection at predetermined fixed locations on the pipeline. It is capable of locating very small leaks typically within 6 feet (1.8 meters) of their actual location.

Figure 37: SmartBall leak detection system

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Outfall Location and Justification

The location of the outfall is outlined in Figure 34.

Although sewage and wastewater will be treated in the resort, a wastewater outfall will be made. The waste water outfall will be connected with brine outfall to have a common outfall for each island, which is believed to have some beneficial effects. In this regard, concentrated brine from RO plant will be diluted with treated waste water before disposal.

The outfall pipeline will be 2 x 120mm diameter HDPE lines appropriately anchored to the lagoon bottom by using concrete . The depth of the outfall will be 5 – 10m deep from MSL and at least 500 - 550m away from the island. A T-head diffuser will be used at the tip of the outfall.

As the wastewater will be treated, the impacts on the marine environment especially to the corals and marine organisms are believed to be very minimal.

Laying the Outfall Pipeline

Approximately 130m of pipeline will be required for development of the outfall. The main work of the pipeline will be joining the pipes, which will be done by mechanical means. The pipeline joining work will start on land and as it moves towards the proposed outfall location, a small barge will be used to transport pipes, joints and anchors, which gets fixed section by section. During the fixing of outfall, scuba divers will join, fix and anchor the pipeline.

Emergency Plan

Emergencies relating to sewerage treatment plant include power and water failure and sewerage treatment plant malfunction. For the purpose of power and water failure, backup generators and backup RO plants will be installed in the island, which will come in use during such emergencies. To overcome system malfunction issues, the sewerage network as well as sewerage treatment plant will be regularly monitored. A bypass system to directly flow sewage into the mains and discharge from the outfall will be available as a backup in case of system malfunction. However, the SBR system proposed for the island uses state-of-the-art modern technology and malfunctions are highly unlikely.

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Rainwater Harvesting

Rainwater will be collected and stored in the resort for use. Designated areas from BOH including roofs of staff accommodation buildings, staff recreation area, mosque and general stores will be used for collecting rainwater, which will be stored in 5 x 5t storing tanks. Rain water will be mainly used for gardening purpose in order to recharge the groundwater of the island.

4.5.5 Landscaping and Pest Control

As far as landscaping is concerned, the reclaimed island requires a landscaping program in order to enhance the environmental condition and greening of the islands. A detailed landscaping plan has been discussed previously. Regular maintenance of the landscaped areas will also be undertaken in order to ensure that environmental quality of the areas are kept intact. Use of chemical fertilizers during landscaping will be restricted. However, use of compost and organic soil conditioning will be undertaken during landscaping maintenance work.

Use of biodegradable pesticides and fungicides will be given importance during the operation of the resort as a means to minimize environmental impacts from pest control. With regards to minimizing potential pests, the following measures will be considered;

 Avoid use of synthetic and chemical pesticides.  Use of biopesticides such as plant extracts such as Neem (Azadiractha indica), wood ash and dried chillies as a means to repelling some insect pests.

Pest control in the resort will be outsourced to a professional company who has vast experience in controlling pests in the Maldives.

4.5.6 Storage Facilities

Freshwater produced by desalination plants will be stored in steel holding tanks before it will be distributed for usage. In this regard, 800 tonnes of freshwater will be stored on the resort in 4 x 200t storage tanks close to the desalination plants. This will be enough for approximately 3 - 5 days freshwater requirements during resort operation, in case for emergency use. Additionally 100t of treated wastewater will be stored for gardening purpose.

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Also, fuel will be stored on the resort close to the power plants at the Back of the House areas. In this regard, 2 x 100t steel storage tanks will be used. This is approximately 30 days requirement of fuel during resort operation. Additionally, around 60 tonnes of petrol will be stored for various uses including for speedboats and water sports motor boats and jetskis.

4.6 PROJECT MANAGEMENT

The proposed project will be managed by the proponent and the following project management measures will be ensured during development phase of the project. Also, contractors will be instructed to strictly follow these measures.

4.6.1 Project Duration

The proposed project development will take 12 months to complete. A detailed project schedule is attached in Appendix 7.

4.6.2 Communication

During the implementation of the project, the proponent will communicate with EPA and MOT and other relevant government authorities with regards to informing details of project implementation works. All communication will be undertaken in written form and will also be communicated with project contractors. A focal point for the project from the proponent will be designated for undertaking all communications on behalf of the proponent.

4.6.3 Work Safety

Work safety will be given importance as it is a regulatory requirement. The contractors will be informed of taking appropriate work safety measures and the proponent will monitor how safety measures are implemented on a regular basis.

The following safety equipment shall be provided to all construction staff, including;

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 Earmuffs  Safety goggles / masks  kits

All major construction sites shall have the following including;

 Firefighting equipment including smoke detectors, fire extinguishers and fire hydrants  Safety nets  Oil booms

The proponent will also ensure that the following general measures are implemented by the contractors, including;

 Construction safety manual  Chemical handling manual  Emergency procedures and contact numbers (general and medical)

4.6.4 Potential Accidents and Hazards Management

In order to prevent fire hazards during the operation of the resort, fire-fighting equipment as identified under the Fire Safety Regulations of Tourist Resorts will be used. In this regard, the following measures will be undertaken including use of fire hydrant, smoke detectors, smoke and fire alarms and fire resistant materials in all buildings, staff training for the identification and reporting of fire hazards, notices in guest and staff units on potential fire risks. Regular testing of automatic fire detection and alarm systems, secure storage of fuels and flammable chemicals will be undertaken. The resort will have notices for fire escape routes and assembling areas clearly marked.

Waste oil from the resort will be appropriately stored in closed container and will be regularly transported to Thilafushi with other waste for final disposal.

Although accidents and natural disasters are unpredictable, the operation of the resort will have appropriate plans for addressing for such issues. In this regard, emergency telephone numbers and procedures in case of natural disasters will be placed in all areas of the resort. Information on country-wide potential natural disasters will be regularly obtained from Maldives Meteorological Services and their threat alert system will be regularly updated in the resort.

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All staff working in hazardous areas or handling heavy objects, power tools or hazardous chemicals will receive supervision and regular training in workplace health and safety matters, including hazard awareness and accident prevention, safe lifting practices, safe chemical handling practices, handling and care of power tools and other electrical or mechanical equipment, use of personal protective clothing and equipment and first aid training and medical emergency procedures, including how to summon medical assistance will be given to all staff.

For severe cases and emergencies, immediate transfer to Male’ and Hulhumale’ hospitals will be undertaken.

4.6.5 Emergency Plan

An emergency plan for accidental spills will be covered during construction and operation phases. These include during construction phase provision of safety equipment in all construction sites and vehicles. For instance, all excavators and barges that will operation in the lagoon will have oil booms to confine oil from an accidental spill and will be collected by skimmer equipment to a container. Also dispersants to breakup the oil and stop mixing with water will be made available at all times at the construction sites.

Also, during operation phase, oil booms, skimmer equipment and dispersants will be made available mainly in the areas easily accessible to the resort such as jetties and public areas in a designated safety area.

4.7 PROJECT INPUTS AND OUTPUTS

Following are the key project inputs and outputs anticipated for the proposed project during construction and operation phases.

4.7.1 Project Inputs – Construction Phase

Input resource(s) Source/type How to obtain resources 1200 Construction staff Foreign 800 / Local 400 Contractors and subcontractors employees Dredging and land reclamation 12” sand pump, gen set, sand barge, Contractors and machinery pipeline, excavator, CSD subcontractors Rock boulders for coastal 10,000 – 25,000 tonnes Imported protection

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Construction material Steel bars, iron, river sand, cement, Locally purchased where aggregate, timber, wood, thatch, available and directly sandwich panel, dry panel, rope, imported if locally electrical and telephone, cables, pvc unavailable pipes, building blocks, tiles, plywood, gypsum board, lysaght roofing material, thatch, paint, varnish, chemicals, thinner, etc Construction vehicles and Machinery mainly used for construction Contractors and machinery including pickup, small purpose subcontractors machinery excavator, concrete machine, cranes Maintenance tool and equipment Maintenance and spare parts and fluids Contractors and required for the machinery subcontractors own machinery Fuel and lubricant for machinery Diesel, Petrol, Lubricants local suppliers/ contractor 3,500L per day Fresh water Desalinated water and rainwater Desalination plant capacity 170,000L per day 20m3, 50m3 and 100m3 of contractor Electricity/ energy during Temporary Diesel generator 200kVA and 100kVA and construction 200kVA diesel generators of contractors Wastewater treatment Temporary Septic tanks Developed locally Electrical appliances/machinery Energy efficient machinery and Purchase locally and import appliances Firefighting and safety equipment Fire pumps, Fire protection system, and Purchase locally Foam fire extinguishers, boots, helmets, masks. Table 6: Project inputs during construction

4.7.2 Project Inputs – Operation Phase

Input resource(s) Source/type How to obtain resources 1064 staff 638 local and 426 foreign Announcements Freshwater supply Desalinated water, rainwater 3 x300m3 and 1 x 50m3 capacity RO plant directly imported and harvested rainwater on the resort Drinking water Mineral water (bottled) 1700 bottles per day locally sourced Energy Diesel generators 3 x 1250KVA and 1 x 1000 kVA and 810kVA gen sets imported Fuel, lubricants Energy generation and maintenance 5,000L per day from local suppliers Waste management Machinery 1500kg incinerator 250kg crusher 250kg compactor 1000kg shredder 5 x 100kg compost bins

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Wastewater management Treatment plant SBR type 300t per day directly imported Maintenance material Timber, wooden shingles for roof, Locally purchased and electrical cables, electrical appliances, imported paint, thinner etc. Communications PABX system, fax machines, email and Local telecom companies internet facilities to all guest facilities, public and BOH area

Transport International airlines, domestic flights, Travel agency and owners sea plane, speedboats sea transport Food and beverages Foreign and local Import and purchase locally (fruits, meat, fish and vegetables, perishables and diary goods, alcohol). Soft drinks and PET bottles Local Purchased locally from producers Laundry chemical Bio degradable detergent, all-purpose Imported and locally sourced cleaners Paper products tissue roll, tissue boxes, hand tissues, Imported and locally sourced guest room paper amenities/ brochures office use paper products Fertilizers Compost and bio fertilizers Imported and locally sourced Firefighting equipment Firefighting system Local suppliers Fuel, Kerosene and LPG Diesel, LPG Gas, Petrol, Lubricants Local suppliers Table 7: Project inputs during operation

4.7.3 Project Outputs – Construction Phase

Outputs (s) Anticipated quantities Disposal method Tourist resort 353 Rooms Guest use Wastewater Approx. 10,000t per month Temporary sewerage and brine network and outfall CO2 Approx. 80MT per month Energy conservation Waste oil Approx. 3t per month Transported to Thilafushi Green waste Small quantities Composting to be used for during landscaping landscaping Construction Waste Large quantities Reusable items reused and residual waste transported to Thilafushi Fuel and lubricant for machinery Minor quantities Transported to Thilafushi Table 8: Project outputs during construction

4.7.4 Project Outputs – Operation Phase

Outputs (s) Anticipated quantities Disposal method Non portable water 10,000T per month Reused for gardening and landscaping toilet flushing, aquifer recharge Portable water 80,000 plastic bottles per month Bulk transport to Thilafushi after compaction

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Sewage and wastewater 17,000T per month treated wastewater reuse for landscaping and gardening CO2 Emission 120MT per month Minimized through energy efficiency measures General Domestic waste 15T per month Sent to Thilafushi Kitchen and organic waste 15T per month Use in composting and some transported to Thilafushi Waste oil and grease 2T per month Incinerated or sent to R. Thilafushi Scrap metal/cans/plastics 8T per month Compacted and sent to Thilafushi Paper and Plastics, packaging 2T per month Sent to Thilafushi waste Glass and plastic bottles 60,000 – 80,000 bottles per month Crushed and compacted and sent to Thilafushi Hazardous waste Less than 1T per month Properly sealed in containers and send to Thilafushi Table 9: Project outputs during operation

4.8 ACTIVITIES THAT ARE LIKELY TO CAUSE SIGNIFICANT ENVIRONMENTAL IMPACTS

Following are the activities that are likely to cause significant environmental impacts to the surrounding marine environment from the proposed resort development project in the lagoon.

 Shoreline adjustments of Island 1, Island 2 and Island 3 (approx. 12,000m2 area)  Dredging of burrow site 3,472.55m2  Minor land reclamations – small islets (5,875m2)  Coastal protection of reclaimed islands onshore and offshore structures  Water villa constructions on Island 1 and Island 3  Spread of sedimentation into the surrounding marine environment from the above activities  Solid waste during construction and operation phases

Hence, the total area directly affected with severe impacts from the proposed project is believed to be over 50,000m2 area. However, depending on the seasonal weather conditions, the impact areas may cover even a greater area.

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4.9 AFFECTED BOUNDARIES

Based on the physical assessments undertaken and data collected from the site, the following figure shows potential environmental impact boundaries especially sedimentation that has been envisaged as part of the proposed development.

A key factor in determining the spread of sedimentation related to shoreline reshaping, coastal protection, dredging and reclamation works was considered to be prevailing wave induced currents, wind induced currents as well as reverse currents during an alternating season. Most direct and significant environmental impacts have been considered within the boundaries of the activity areas of coastal protection, shoreline shaping, excavation, dredging and reclamation and its predicted direct and indirect impact zones.

Figure 38: Direct impact areas (red) and indirect impact boundary

The most direct impacts are expected to occur in most parts of the reef due to activities that generate direct sedimentation while indirect impacts are expected to reach some distances (between 500m – 1,000m). If the sedimentation travel beyond 1,000m on the western side, there is potential to impact Thulhaagiri Resort reef, if the dredging and reclamation works happen in NE monsoon, which is now unlikely. If the works are conducted during SW monsoon, no nearby reef are believed to be impacted even from 1,500m sedimentation distance.

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Overall, environmental impacts on nearby areas such as nearby tourist resorts, ongoing development projects and MPAs are unexpected to occur as sedimentation may not carry into greater distances.

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5. LEGAL, POLICY AND ADMINISTRATIVE FRAMEWORK

The following section addresses the legal, policy and administrative framework for environmental management and some regulatory guidelines and standards relevant for the proposed tourist resort development project to be carried out in K. Aanugandu Falhu.

Also, the section addresses international and regional instruments that the country has acceded with regards to protecting the environment of the country. Some of the relevant international instruments have been outlined.

Until December 2018, EIAs for tourism-related projects including development of new tourist resorts were governed under the Tourism Act by Ministry of Tourism through implementation of the Regulation for Preparing EIA Report for Tourist Resort, Guest House, Tourist Hotel and Yacht Marina Development (Regulation Number 2015/R-157). EIA approvals for tourism sector projects were given by Ministry of Tourism. However, in December 2018, the Tourism Act came to a reformulation excluding all provisions related to EIAs in the tourism sector, which was implemented by Ministry of Tourism. The main aim of this reformulation was to streamline all EIAs carried out for all development projects including process and approval to be governed by the Ministry of Environment in accordance with the Environmental Protection and Preservation Act (Law No. 4/93) which is implemented by Environmental Protection Agency (EPA) on behalf of the ministry. Hence, all EIA provisions are implemented by EPA since January 2019 under Environmental Regulations. This EIA is prepared under the new EIA governance implemented by EPA.

Nonetheless, all tourist resort development projects have to abide by the Tourism Act and various other regulations and guidelines developed towards planning, construction and operation of tourist resorts in the Maldives.

As part of this project, an EIA and First Addendum to the EIA were approved by MOT in 2017 and 2018 respectively and certain aspects of the project including access channel development, dredging and land reclamation and some temporary facility development has been carried out under the previous resort EIA governance implemented by MOT.

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5.1 APPLICABLE LAWS AND REGULATIONS

The most applicable laws and regulations are;

5.1.1 Tourism Act of Maldives (Law No. 2/99)

As part of the proposed tourist resort development in the lagoon, the Tourism Act (Law No. 2/99) and subsequent regulations have to be followed. The Tourism Act recognizes a number of regulations, standards and controls with regard to the development of tourist resorts in an environment friendly manner in the Maldives and is implemented by the Ministry of Tourism. Under the Tourism Act the Ministry has developed important regulatory measures and controls as well as standards including building standards, food and sanitation standards, waste disposal, electricity code, carrying capacity, diving regulation, fire safety standards as well as water sports conduct.

Some of the standards and controls developed under the tourism regulations include;

5.1.1.1 Carrying Capacity Standards

As an important basis for deciding the number of rooms and extent of resort facility development allowed on each resort island, the government has established carrying capacity standards. These are based on several factors including; cutting of trees is controlled so that the natural appearance and façade of the island are maintained and no buildings are allowed to appear above the tree tops, the maximum land area occupied shall not exceed 20% of the total land area. The total development area has been recently changed to 30%.

To preserve the tourist’s perception and image of beach orientation, all guestrooms should be facing the beach, with a minimum of 5m of linear beach available in front of each room. Only 68% of the beach length shall be allocated to guestrooms, 20% has to be allocated to public use and 12% left as open space.

Due to the popularity of water bungalows and overwater developments in the lagoon amongst tourists, they are permitted, provided that equal open space is left on the land for each building developed in the lagoon.

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5.1.1.2 Architectural and Design Controls

The design of tourist resorts are controlled so that they are well integrated into the island environment, use local building materials, such as thatch roofs to the extent possible. The use of coral is restricted and the use of imported building materials is encouraged. Coral and sand mining from the resorts and their house reefs are strictly prohibited.

Hard engineering for dynamic coastlines are discouraged and construction of solid jetties and groynes are controlled and shall only be undertaken after conducting an impact assessment study. Design of boat piers, jetties shall be in such a way that these shall not obstruct the current patterns of the island.

5.1.1.3 Biodiversity Conservation Measures

In order to protect and preserve marine environment a number of measures have been prescribed. Spear, poison and dynamite fishing are strictly prohibited. Net and trap fishing are controlled and confined to certain areas. Removal of shells, juvenile lobsters and lobsters ready to lay eggs are strictly prohibited.

The catching of turtles is strictly prohibited and trade in all turtle products is banned. The commercial exploitation and export of many other marine species are banned. Reef fishing from the resort house reef is also discouraged. Also, as a measure for protecting and conserving marine biodiversity, 35 marine protected areas have been designated and fishing, removal of coral, anchoring and other destructive activities are prohibited.

The Ministry of Tourism recognizes the importance of vegetation in maintaining the natural beauty of the island and there a number of measures in terms of conserving the vegetation of the islands. These include a limit of 30% of the island for development and a setback limit of 5 linear meters from the vegetation line of the island and that no buildings shall appear above the treetops.

5.1.1.4 Food, Water and Sanitation

The tourism regulation also requires the restaurants and kitchens of tourist resorts to be structurally sound, clean and properly maintained. Rat proof ceiling and rodent control mechanisms shall be in place in the kitchens and other food handling areas. Hygienic food handling and cleanliness of staff is also encouraged.

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According to these regulations, safe and adequate water must be made available and water supplies must be clean and well maintained. Drinking water must be sufficiently disinfected to prevent water-borne diseases.

All catch pits and manholes shall be made water-tight and shall not leak. Stagnant waters shall not be left uncovered for mosquito breeding. Tins, bottles and cans that will hold water shall not be left anywhere. The tourism regulation also specifies that the sewage system shall be installed such that pollution of water supplies, beaches, lagoons, and other areas are prevented. It also emphasizes the need of dispose of sewage and wastewater in such a way that it will have minimal or no implications on the environment of the island and surrounding seas.

5.1.1.5 Waste Disposal

According to the regulations issued by the Ministry, garbage from tourist resorts shall be disposed of in a manner that would not cause any damage to the environment.

All tourist resorts are required to have incinerators and compactors adequate in size to burn and compact all waste materials generated from the resort. It is also important to have bottle crushers to crush glass bottles. Those that lack these facilities are not allowed to operate. Plastic or hygienic bags shall not be thrown into the sea and such materials shall be burnt.

These regulations also require sweep cleaning of the entire resort at least once every day. Refuse is required to be disposed in closed containers and disposed of daily. For the purpose of the proposed project, all residual waste will be transported to Thilafushi island for final disposal.

Also, with regards to implementing appropriate waste management measures, including transport of waste from the resort, the Waste Management Regulation of 2013 implemented by Environmental Protection Agency will be adhered to with all its provisions.

5.1.1.6 Dredging, Reclamation and Other Coastal Activities

The Ministry of Tourism does not encourage hard engineering solutions such as heavy breakwater structures, groynes, solid jetties, seawalls and revetments on tourist resorts of the Maldives in order to ensure the natural environmental qualities of the island are maintained.

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5.1.1.7 Construction Practices

All infrastructure development areas in the islands designated for tourist resort developments have to be clearly demarcated and these areas will be inspected by the planning officials of the Ministry of Tourism. The number of mature trees that need to be felled and the vegetation that needs clearing will have to be noted and prior permission is required for any vegetation clearance.

Applicability

The overall development of the resort in the islands have to comply with all the design and operational aspects requirement outlined in the Tourism Act and regulations mentioned. A key aspect for obtaining resort operating licence is that the proposed resort development must comply with the Tourism Act.

5.1.2 Regulation on Protection and Conservation of Environment in the Tourism Industry, 2006

The purpose of this regulation is to protect the environment in the tourism industry and to encourage and facilitate sustainable development of tourism. It is strictly enforced to islands and land areas leased for development of tourist resorts and hotels leased by the Ministry of Tourism.

The key attributes of the Regulation include;

 Protection of the environment during resort construction where the following activities are subject to prior approval of MOT; o Dredging of the lagoon and reclamation of land o Construction on the beach and lagoon o Beach enhancement by pumping sand o Construction of breakwater o Construction of sea wall, revetment and groyne o Dredging of lagoon for safe access o Dredging of reef o Felling trees o Importing and exporting living species o Conducting research of land, sea and lagoon

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o Demolition of a building or facility o Anything that may adversely affect the vegetation or freshwater lens of the island  An environmental impact assessment report prepared in accordance with the Protection and Conservation of Environment Act of Maldives (Law No. 4/93) shall be submitted to the Ministry of Tourism prior to the commencement of any construction project or any activity.  Protected birds or marine living species shall not be caught or kept in cages or other enclosed space in an island or land leased for the development of tourism.  All soils and chemicals used as pesticides and fertilizers imported for use in a tourist resort, Picnic Island, marina or such a place shall be imported after obtaining written permission from the relevant government authority.  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.  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 the Environmental Protection Agency in accordance with the “Regulation on Desalination Plants”, and shall comply with such regulation in the operation of the desalination plant.  Sewage shall be disposed in a manner that is least harmful to the environment.

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 1,000.00 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.

Applicability

Except for the requirement of EIA under the EIA Regulation of the Environmental Protection and Preservation Act (Law No 4/93), all other aspects of the regulation need to be followed as part of the proposed resort development and operation.

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5.1.3 Boundary Regulation (2012/R-7) and Amendment (2016/R-94)

The regulation has been developed under the Clause 15 (haa) of the Tourism Act (2/99) in order to facilitate marking of boundaries within the lagoon of islands leased by Ministry of Tourism for development of tourist resorts, tourist hotels, guest houses and yacht marinas. The Regulation was amended (2016/R-94) in November 2016 to reduce boundaries from 1000m to 500m in all aspects. In this regard, the following measures relating to boundaries have been outlined;

 If a boundary has already been identified in the Lease Agreement, the boundary of the lagoon surrounding the island shall be as outlined in the Lease Agreement.  If a boundary has not been identified in the Lease Agreement, the lagoon of the island extends more than 500m from the vegetation line of the island, the boundary shall be 500m into the lagoon from the vegetation line of the island.  If the reef has less than 500m from the vegetation line of the island, then the boundary shall be up to the outer reef from the vegetation line of the island.  If another island is found greater than 500m within the same lagoon, the boundary of the resort island shall be 500m from vegetation line of the resort island.  If another island is found in less than 1000m within the same lagoon, the boundary shall be the middle point between the vegetation of the resort island and the other island  If there are more than one islands within the same lagoon, a no development buffer of 100m shall be established from the outer boundary.  If an island is reclaimed within a lagoon, the boundary shall still remain as the original boundary outlined for the resort.  If a developer wishes to develop tourist facilities up to 2000m from the resort, the Ministry of Tourism has the authority to decide so with certain conditions.

Applicability

The provision of the above regulation extending boundaries within the lagoon may be not be applicable to the proposed project as the entire lagoon has been leased to the proponent for the development.

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5.1.4 Fire Regulation (2015/R-43)

The Fire Regulation has been developed under the Tourism Act (2/99) for the purpose of implementing preventive measures again fire hazards in tourist resorts as well as to protect tourism investments, human life and goods from fire risks.

Important measures outlined in the regulation include;

 All resorts established in the Maldives shall have firefighting equipment installed by a licensed party from Ministry of Defense and National Security (MDNS).  All resorts shall submit a fire safety drawing to MDNS through Ministry of Tourism  A 1m boundary shall be maintained free from anything from the location of firefighting equipment or the fire point  All must shall have at least 2 portable firefighting pumps  In order to understand a fore incident instantly, an automatic fire detection and alarm system shall be installed in all resorts  At least two fire points shall be established in the powerhouse  A fire squad with trained personnel shall be maintained in all resorts  If a fire incident occurs, the firefighting equipment maintained in the resort shall be immediately used and shall be immediately informed to MDNS and Ministry of Tourism

Applicability

All the requirements and provisions of the regulation shall be complied and checked for appropriateness by the relevant authority prior to resort operating permit is granted by MOT. Fire Safety drawings for the proposed two islands in the resort are currently being done, which will be submitted to MOT for final approval.

5.1.5 Maldives Recreational Diving Regulation, 2003

The regulation has been developed under the Tourism Act (2/99) in order to keep recreational diving safe and enjoyable.

Important measures outlined in the regulation include;

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 All dive centers providing services to tourists shall be registered and an operating license shall be obtained  All dive information shall be provided to Ministry of Tourism  License and operating permit for dive centers in the resorts shall be given for 5 years and renewed upon expiry.  The license issued by the Ministry of Tourism shall be displayed in the dive center  All breaches of this regulation shall be fined from an amount not exceeding MVR 100,000.  All divers shall have acceptable training before undertaking diving in the Maldives  All dive activities shall be supervised by the staff of the dive center  The maximum depth for all recreational diving in the Maldives is 30m.  Only no diving is allowed in the Maldives  All dive centers must be equipped with pure oxygen and an emergency plan ready in case of diving related accidents.  All dive related equipment shall be well-maintained.

Applicability

The dive centers proposed in the resort shall be registered and obtain an operating permit under the regulation and all its activities and safety standards shall be in compliance with the regulation. The safety requirements for dive related accidents will be covered in the emergency plan specifically developed for dive operations of the resort.

5.1.6 Disaster Management Plan for Tourist Resorts

All tourist resorts must have a disaster management plan. The plan shall outline how the resort, guests and the staff shall respond to cases of disasters, establish an emergency management team, emergency response for fire, fuel and water shortages, natural disasters as well as other incidents such as food poisoning, death, etc. A good reporting mechanism shall also be established in the resort.

Applicability

Since 2004 Tsunami, all tourist resorts are required to have a disaster management plan outlining the above aspects. During the final inspection done by MOT officials prior to granting

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resort operating license, compliance with disaster preparedness and procedures will be checked and the plan will be only once it is approved by MOT.

5.1.7 Environmental Protection and Preservation Act (Law No. 4/93) and Amendment, 2014

This law and subsequent bylaws now govern the provisions for general environmental management in the country including mainstream development projects requiring EIAs.

The Environmental Protection and Preservation Act of the Maldives, EPPA (Law No. 4/93) provides the basic framework for environmental management including Environmental Impact Assessment (EIA) process in the Maldives, which is currently being implemented by Environmental Protection Agency (EPA) on behalf of Ministry of Environment (ME).

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.

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

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Environment have developed regulations and guidelines concerning the environmental protection in the country.

In 2014, an Amendment came into which stated that the Ministry of Environment shall be responsible for formulating necessary regulations relating to conservation of biodiversity, protection of groundwater, mangroves, swamps and other water bodies, protection of the environment from waste and dangerous gases.

Applicability

The proposed project requires an EIA to be undertaken and approved as per the regulations developed under the EPPA.

5.1.8 Maldives EIA Regulation and Amendment, 2018

Prior to the EIA Regulation for Development of Tourist Resorts, Guest Houses, Tourist Hotels and Yacht Marinas of 2015, the Maldives EIA Regulation of 2012 governed the preparation and approval of EIAs prepared for all development projects.

It outlines a step by step approach to EIA process that is followed towards approving and rejecting an EIA. The regulation also outlines all major requirements to be included in an EIA report. All EIAs must be undertaken by the Registered EIA Consultant.

The EIA Regulation of 2012 was amended in August 2015, which excluded all tourism relevant aspects as well as changes to certain administrative procedures as a result of enforcing a separate EIA Regulation prepared under the Tourism Act.

An Amendment (3rd Amendment) came in 2016 with further details on EIA requirements and designating EPA as the implementing agency of the regulation.

In 19 January 2017, a Fourth Amendment to the EIA Regulation came into force where certain development activities such as maintenance dredging, removal of vegetation from housing plots have an exemption from undertaking EIAs.

Most recently, as per the 5th Addendum (2018), all EIAs undertaken for tourist resort and tourist hotel development has been recalled back to the EIA Regulation.

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Applicability

Since January 2019, all EIAs prepared for development project must follow EIA Regulation 2012 and all its amendments. The EIA approval is now granted by EPA under the EIA Regulation.

5.1.9 Penalty and Liability Regulation, 2011

Under the Environmental Protection and Preservation Act (No. 4/93), the Ministry of Environment and Energy 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.

Applicability

As a result of the proposed development, if the environmental impacts and subsequent damages reaches to an unacceptable level, then provisions of the above regulation could be applied where a fine could be levied by EPA depending on the severity of the environmental damage.

5.1.10 Uprooting, Cutting and Transportation of Palms and Trees Regulation and Amendment, 2014

Cutting down and relocating of mature trees is regulated in Maldives under the By-law on Cutting down, Uprooting, Digging out and Export of Trees and Palms from One Island to Another. In the preamble of the law, made in pursuant to Law No. 4/93, it states the purpose of the law is to educate citizens and developers about the importance of trees including sound management to maintain trees and provide standards for the preservation of trees in the Maldives.

Under the law certain tree are prohibited to remove from island. They include:

 The coastal vegetation growing around the islands extending to about 15m into the island

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 All trees and palms growing in mangroves and wetlands spreading to 15m of land area  All trees in Government designated protected areas  Trees that are being protected by the Government in order to protect species of animal / organisms that inhabit on such trees  Trees / palms those are unusual in nature.

The regulation states that prior permission must be obtained for removal and/or relocation of 10 or more trees or palms. For indiscriminate removal and land clearances and EIA and Decision Note is required. The size of the trees and palms that are allowed to be relocated should have more 15 feet from lowest point to the crown spread for palms and 8 feet from the lowest point to the trunk to tip of the highest branch for trees other than palms. For any palm or tree removed, two palms or trees must be replanted on the island.

The law also states that cutting down and uprooting of the trees shall be made under supervision of the Island Councils and Atoll Councils.

In 2014, 1st Amendment to the regulation came further stating that trees and palms removed to undertake a government project, 6 trees and 6 palm shall be replanted on the island. Also, as part of this amendment, EPA has been designated as the implementing agency.

Applicability

The provisions of the regulation will be applied to the project since large scale landscaping for the reclaimed islands are required where trees and plants are believed to be sourced from other areas of the country.

5.1.11 Management, Use and Control of HCFC Substances Regulation, 2010

The HCFC Regulation is developed under the Environmental Protection and Preservation Act (4/93) towards regulating phasing out of import, use, selling of HCFC substances by 2011 and completely eliminating use of HCFC substances in the Maldives by 2020 through controlling importers, registering importers, establishment of a quota system, control mechanisms for selling, maintenance of import, selling, purchase and service providers statistics.

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Applicability

This is an obligation that has to be met by the Maldives, hence the provisions in this regulation will be adhered to. All air-conditioning and cooling done for the resort will consider HCFC free equipment in order to support the efforts of the country to eliminate HCFC by 2020.

5.1.12 Waste Management Regulation and Amendments, 2018

Waste management Regulation (No. 2013/R-58) is more recent coming into effect on 6 February 2014. The Regulation was gazetted on 05 August 2013. The regulation is provides set of comprehensive guidelines and on collecting, storing, transporting and managing waste as well as management of hazardous waste. The waste management regulation identifies the following areas prohibited from dumping of waste; protected areas under the Environmental Protection and Preservation Act, mangroves, lagoons of islands, coral reefs, sand banks, beaches of islands, coastal vegetated areas of islands, harbors, parks and roads. Additionally, waste management regulation states that those involved in waste management must be permitted by the Environmental Protection Agency.

The regulation has outlined guidelines for waste collection, transportation of waste from land and sea, treating of waste, storing of waste, management of waste yards, landfill and management of hazardous waste. The waste management regulation identifies the following areas prohibited from dumping of waste; protected areas under the Environmental Protection and Preservation Act, mangroves, lagoons of islands, coral reefs, sand banks, beaches of islands, coastal vegetated areas of islands, harbors, parks and roads. Additionally, waste management regulation states that those involved in waste management must be permitted by the Environmental Protection Agency.

With regards to handling and transport of waste on land and sea, the following guidelines have been established. For those who are collecting, handling, transporting, storing, landfilling waste, a permit shall be obtained from EPA. During transport of waste on land and sea, the waste shall be completely covered to prevent odour and spilling. Also, the regulation prohibits importing and burning of hazardous waste. Similar to other waste, hazardous waste shall also be transported in sealed containers.

For all economic development projects, an appropriate site shall be identified for managing waste and waste shall be sorted and clearly labeled.

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The entire provisions outline in the regulation will be strictly followed by the project proponent.

An annual waste management report by the licensed party shall be submitted to the Ministry of Environment.

The regulation has 4 amendments further empowering EPA towards implementing the regulation as well as further details on managing waste from commercial and industrial areas.

Applicability

Waste handling, transportation and disposal outside of the resort boundary as a result of the proposed development and operation of the proposed tourist resort must comply with the provisions of the regulation.

As part of the proposed resort development and operation, the proponent proposes to transport disposable waste to Thilafushi, hence the above regulation and its components will be complied.

5.1.13 Dredging and Reclamation Regulation, 2013

Regulation on Reclamation and Dredging of islands lagoons (Regulation 2013/R-15) came into effect in April 2013. The regulation requires having permission of EPA on projects requiring alternation of the island, either by reclamation or dredging. Specifically the regulation requires producing scaled-maps of the island before and after the proposed intervention. Special provisions have been made on protected and sensitive area restricting changes to the environment of the islands.

Applicability

The proposed resort will be developed on reclaimed islands which is done under EIA approvals from MOT in 2017 and 2018. However, the proposed project has minor dredging and reclamation requirements, hence the provisions of the regulation will be strictly followed. A dredging and reclamation permit will be obtained from EPA before the activities.

5.1.14 Regulation on Desalination Plant, 2002

The regulation addresses key requirements with regards to undertaking seawater desalination and installation of desalination plants in the Maldives including tourist resorts.

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Following are the key outlines’

 Plants production capacity greater than 5t per day shall be registered with EPA.  Seawater required for desalination shall be obtained from sea, lagoon or ground  If seawater is obtained from lagoon and sea, appropriate filtering mechanism shall be available and shall have storing facility of filtered water at least 50% of the plant capacity  If seawater is obtained from well dug on the beach, the well shall be developed as per the guidelines  If water is obtained from the ground, it shall be obtained from boreholes dug beyond freshwater aquifer  The brine shall be discharged into the sea 10m beyond outer reef.  The desalination plant shall be installed slightly higher than ground level  The sound of the desalination plant and within the desalination house shall not exceed 85dB.

Applicability

With regards to obtaining operating license for the proposed tourist resort, the desalination plants installed in the resort will be registered at EPA in accordance with requirements of the regulation.

5.1.15 Dewatering Regulation, 2013

A Dewatering Regulation (No. 2013/1697) under the Maldives Environmental Protection and Preservation Act came into force in December 2013. The main purpose of the regulation is to protect groundwater resources found in the islands from impacts of dewatering, pollution and protect the environment from release of groundwater by dewatering. As per the regulation, a dewatering permit shall be obtained from EPA prior to any dewatering operations required for all development projects. Further, the regulation states that 30m radius boundary shall be considered as impact area from all dewatering operations and any entities within the boundary shall be informed 24hrs before the dewatering operation. EPA approved dewatering signage must be placed during the process of dewatering.

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Applicability

There is no requirement for dewatering from the island as part of the proposed project, hence the regulation is not applicable. However, if there is any requirement for dewatering from any specific area of the islands, the provisions of the regulation will be followed and necessary permit will be obtained from EPA.

5.1.16 Migratory Birds Regulation, 2014

The Migratory Birds Regulation (2014/R-169) developed under the EPPA came into force on 21 August 2014. The main purpose of the regulation is to protect seasonal migratory birds found in the Maldives by prohibiting catching and collection of such birds. Fines between MVR 501 – 50,000 will be levied for catching, trading, caging as well as damaging the nests of such birds. Migratory birds are defined as all birds that are not endemic to the Maldives. All endemic birds are currently protected under the EPPA.

Applicability

No migratory birds will be caught and captured from the resort during construction and operation of the resort as per the regulation.

5.1.17 Regulation on Fuel Handling and Storage (2015/R-160)

The Regulation on Fuel handling and Storage (2015/R-160) has been developed under the 7th and 46th Clause of the “Sifainge Gaanoon 1/2008)” and is implemented by Ministry of Defense and National Security (MDNS).

The main purpose of the regulation is to prevent fair risks and protect human life and goods from such risks, strengthen general awareness on preventive measures during handling of fuel as well as ensure common safety measures during storing and selling of fuels in the country.

As per the regulation, all fuel storing facilities and handling shall be done with all preventive measures including availability of firefighting equipment. A written permit shall be obtained from MDNS prior to storing fuels at any location. A random monitoring will be undertaken by MDNS to ensure such facilities are operated in accordance with the regulations.

The regulation also outlines standards for developing petrol storing facilities and states that such facilities shall be isolated from any other establishment and that proper protective signage

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such as NO SMOKING, NO NAKED LIGHTS, FLAMMABLE LIQUID shall be visible as well as the signage of PETROL shall be visible for people coming from both sides.

Similar to standards of petrol storing facilities, the storing facilities for diesel and kerosene shall also be maintained in accordance with the regulation such as storing in an isolated facility for diesel and kerosene.

Appropriate piping shall be developed from storing facilities to fuel meters or up to the jetty in the case of the islands.

Applicability

With regards to the proposed project, this regulation will be strictly followed as well as required permits will be obtained prior to initiation of operations of the resort. All fuel storing facilities will be properly labeled as required.

5.1.18 Waste Incineration Guideline, 2016

The EPA has developed the Waste Incineration Guideline (WIG) in 2016 primarily to prevent or limit, as far as practicable, negative effects on the environment, in particular pollution by emissions into air, soil, surface and groundwater, and the resulting risks to human health, from the combustion of waste using incinerators.

This guideline applies to all kinds of waste incinerators and will assist the managers and operators of waste incinerators to:

 Identify potential environmental impacts and use appropriate tools to monitor and mitigate any impact that arise from waste incineration.  Maintain the air quality of surrounding area at a standard that has minimal health effects to human and other inhabitants of the area.  Understand the operational health and safety measures.

The key consideration outlined in the WIG include environmental considerations, which outlines requirements for site selection including identifying a suitable site according to prevailing winds to reduce emissions around the site, setting up a buffer of 60m between incinerator and sensitive sites including residential areas, hospitals, schools; setting up of 30m buffer between incinerator and vegetation, setting up a buffer of 30m between incinerator and mangrove/wetland areas. Key considerations for emission control include; removal of Page | 110

halogenated plastics (PVC), pressurized gas containers, active chemical waste, silver salts and photographic/radiographic waste, waste with high heavy metal content. Standard air emission levels are also provided in the guideline as well as properly discharging waste from incinerators.

Also, the guideline outlines key considerations for clinical waste incineration, medical and hazardous waste transportation and standards that needs to be maintained while transporting waste identified under this category.

Important considerations are also given to ash management after incineration process including that such waste shall not be mixed with general waste and shall be transported separately.

Key health and safety consideration outlined in the guideline include use of safety and protective equipment such as gloves, safety footwear, safety glasses by personnel, availability of operation and maintenance manual as well as personnel shall be properly trained to operate the facility.

Applicability

As this is a general guideline, the incinerator installed in the resort and during incineration process as well as transportation of residual waste and transportation of clinical and medical waste will be undertaken in conformity to the guideline.

5.1.19 National Wastewater Guideline, 2007

Although the guideline was developed by Maldives Water and Sanitation Authority (MWSA) in 2007, it is now implemented by EPA. It outlines that storm water shall not be allowed to enter the STP as the quality of storm water differs from general wastewater, placement of screens to avoid solids entering into the system, appropriately discharging wastewater into deep sea, and standards of parameters for general wastewater discharge into the deep sea. This standard is outlined in the following table.

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Table 10: Maximum allowable concentrations in domestic wastewater discharge into deep sea

The guideline also outlines implementing an appropriate monitoring programme to monitor waste water quality which shall include components to be monitored, sample point GPS location, sampling frequency and final waste water quality at the point of discharge and laboratory methods used to analyse data.

Applicability

The above guideline is a general guidelines and provisions set forth in the guideline will be protected and monitoring report done accordingly.

5.1.20 Borehole Drilling Guidelines, 2011

The guidelines outline considerations for drilling boreholes and installation of electric pumps for source water extraction for various water supply development projects including RO desalination. The guidelines are implemented by EPA and outline the following;

The drilling site has to be designated by the client in consultation with Environment Consultant and EPA.

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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.

The volume of drilling fluids, drilling fluid additives, and lubricants used during drilling of a borehole should be recorded.

The in-land borehole depth shall not be less than 30 m. Continue drilling up to 30 m even if the electrical conductivity of discharge water has reached 50-60mS/cm before reaching 30m depth. If electrical conductivity of discharge water at 30 m depth is measured less than 50-60mS/cm, continue drilling until electrical conductivity reaches to 50-60mS/cm.

May use any rotary drilling method and yield estimates shall be made during the course of drilling.

The final design of the borehole shall confirm that pumped raw water does not interact with fresh groundwater aquifer zone. For monitoring purpose, boreholes drilled shall provide water sampling tubes at the interval of 5m from top to bottom.

Pumping test shall be performed to establish the performance and yield of the borehole using a suitable, self-contained, mobile test pumping unit. The method for varying the discharge rate of the pumps will depend on the type of pump used, but the Contractor shall ensure the provision of a suitable means of achieving the range of constant flow rates specified by the Supervisor.

The following aspects including reporting, water sampling and quality testing shall be performed. The testing parameters shall include; pH, E.Conductivity (μS/cm), TDS (mg/l), Chloride (mg/l), Calcium Hardness (mg/l), Magnesium Hardness (mg/l), Boron (mg/l), Phosphate (mg/l), Sulphate (mg/l), Iron (mg/l), Fluoride (mg/l), Ammonia (mg/l) and Lead (mg/l).

Applicability

As the proposed project involves water intake from boreholes for the desalination plants, the provisions outlined in the guidelines will be followed and appropriate approvals will be obtained from EPA.

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5.2 RELEVANT POLICIES

5.2.1 4th Tourism Master Plan, 2013 - 2017

The 4th Tourism Master Plan will be implemented until 2017. The main objectives of the fourth Tourism Master Plan include:

 To increase the number of tourists who visit Maldives from one million to 1.6 million.  To maintain the average number of tourists who visit Maldives to more than 10 per cent annually.  To increase the number of days tourists stay in Maldives from 6.8 days to 7.2 days.  To increase beds from 25,000 to 35,500.  To bring more than one million tourists annually.

If this goes as planned, tourist resorts’ occupancy rate will increase from 73% to 85%.

This Master Plan focuses mainly on increasing the number of tourists who visit Maldives. In order to achieve this, a good transport system is needed, as Maldives is a country which consists of scattered islands throughout the sea. A solution for this, according to the plan, is to develop transport Hubs in various locations of the country.

Applicability

The proposed development of tourist resort in the region is under direct provisions of the 4TMP where increasing tourist beds in outer regions have been identified as an important strategy of the tourism sector development in the country.

5.2.2 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

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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 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 Energy and Environment Protection Agency takes the lead role in implementing the above national policies through various strategies and regulatory measures.

Applicability

Although the Development Framework is currently outdated, important policies with regards to environmental protection are relevant for the proposed development. These include policies on solid waste management and hazardous waste management, and air quality safeguards are applicable for the development.

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5.2.3 3rd National Environmental Action Plan, 2009-2013

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;

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.

Applicability

The action plan is currently outdated, however, some of the key principles such as sustainable development through proper environmental protection and governance as well as inter-sectoral and inter agency co-ordination are applied towards achieving a better environment for the country.

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5.2.4 Maldives National Strategy for Sustainable Development, 2009

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 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.

Applicability

The strategy is currently outdated, however, some of the key principles such as sustainable development through proper environmental protection and governance as well as inter-sectoral and inter agency co-ordination are applied towards achieving sustainable development goals in economic sectors.

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5.2.5 National Solid Waste Management Policy, 2007

As waste management has been identified as a key environmental issue in the Maldives, a National Solid Waste Management for the Republic of 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 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 centers 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. Applicability

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.

5.2.6 National Biodiversity Strategy and Action Plan, 2016- 2025

One of the most recent policy documents that will the quite closely connected with the proposed development will be National Biodiversity and Strategy and Action Plan. The following strategies have been outlined in the NBSAP to be achieved in a span of 20 years; The strategies include

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o Strategy 1 – Strengthen governance, policies and strategies for biodiversity o Strategy 2 – Enhancing communication and outreach through awareness programmes and capacity building o Strategy 3 – Work together globally for biodiversity conservation o Strategy 4 – Ensure sustainable use of biological resources o Strategy 5 – Address threats to conserve biodiversity o Strategy 6 – Strengthen Information Management and Resource Mobilization

Applicability

An important strategy is working together globally for biodiversity conservation and ensure use of biological resources sustainably, where the proposed project will highly recognize and work towards implementing these strategies.

During operation of the resort, the aspects of biodiversity conservation will be strengthened in order to contribute to the national strategy.

5.2.7 National Climate Change Policy Framework, 2015

Recognizing that Maldives is vulnerable to climate change issues, the GOM gives high prominence to integrate climate change vulnerability into development through sustainable development approach. Recognizing this important aspect, a National Climate Change Policy Framework has been developed in 2015 outlining use of climate-friendly technology and the capacity to adapt and mitigate climate change and integrate climate change into sector/or thematic policies and plans.

The Framework outlines the following policy directions;

 Policy Goal 1: Ensure and integrate sustainable financing into climate change adaptation opportunities and low emission development measures;  Policy Goal 2: Strengthen a low emission development future and ensure energy security for the Maldives;  Policy Goal 3: Strengthen adaptation actions and opportunities and build climate- resilient infrastructure and communities to address current and future vulnerabilities;

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 Policy Goal 4: Inculcate national, regional and international climate change advocacy role in leading international negotiations and awareness in cross- sectoral areas in favour of the most vulnerable small island developing states;  Policy Goal 5: Foster sustainable development while ensuring security, economic sustainability and sovereignty from the negative consequences of the changing climate.

Applicability

The proposed resort development also considers development in line with the Climate change framework while implementing low emission and climate friendly technology in the overall development aspect. In this regard solar energy technology will be integrated as part of energy generation in addition to use of state-of-the-art technology for energy saving.

5.3 RELEVANT AUTHORITIES

5.3.1 Ministry of Tourism, MOT

The Ministry of Tourism is responsible for the sustainable development of the tourism sector in the Maldives. Under the Tourism Law various regulations, standards, controls and measures relating to protection of the environment have been developed and are currently being implemented. Important measures include implementation of carrying capacity limits when developing islands as tourist resorts. In this regard, only 20 - 30% of the island shall be used to develop tourist resort infrastructure and facilities. Also, the Ministry of Tourism ensures that appropriate waste management facilities such as incinerators, bottle crushers and compactors and that water production and energy generation methods are environmentally friendly.

5.3.2 Ministry of Environment, MOE

The primary environmental institution in the Maldives is MOE. 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, MOE is responsible for formulating relevant laws and regulations, policies and strategies concerning energy, water and sanitation as well as waste management. Page | 120

5.3.3 Environmental Protection Agency, EPA

EPA is the key regulatory body on environment, which is an autonomous body formed under the umbrella of MOE. It is mandated with implementing the EIA process in the Maldives, implementing the Environment Act and subsequent regulations on behalf of MOE, 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.

The desalination plants that will be used in the resort shall be registered at EPA prior to initiating resort operations, which is a key requirement for obtaining resort operating license.

5.3.4 Ministry of Defence and National Security, MDNS

Certain aspects of tourist resort operations are quite relevant for the work of the Ministry of Defense and National Security. The Ministry is responsible for implementing fuel handling and storing regulation as well as ensuring implementation of fire safety measures in the resorts. In this regard, approvals for fuel handling as well as inspections for ensuring fire safety measures are in place is done by MDNS.

5.3.5 Maldives Food and Drug Authority, MFDA

The MFDA is part of Ministry of Health and it regulates food safety standards in the country. With regards to the proposed project, all food production and outlets shall be designed in accordance with the requirements of MFDA and final approval shall be obtained from MFDA.

5.3.6 Maldives Energy Authority, MEA

The MEA is under the Ministry of Environment and Energy and it regulates the standards for power supply in the country. The approval for operation of the powerhouse is granted by MEA after conducting compliance checks by MEA licensed electricians.

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5.4 INTERNATIONAL CONTEXT

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 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)  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)

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 United Nation Convention to Combat Desertification (2002)  Convention in International Trade in Endangered Species of Wild Fauna and Flora (CITES) 2013

The Maldives is also a key player in formulating and adopting various regional plans and programmes 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 Male’  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 Programme initiated by SACEP  Male’ Declaration on Control and Prevention of Air Pollution and its likely Transboundary Effects for South Asia (1998)

Some of the international instruments that are quite relevant for the private sector engagement include United Nations Framework Convention on Climate Change (UNFCCC) where the country plays an important role in the international area with regards addressing impacts of climate change to the country. Private sector engagement with regards to raising funds for climate adaptation projects as well as implementing activities that offset CO2 is widely undertaken. Implementation of renewable energy projects in the resorts is also undertaken to support government initiatives.

Vienna Convention for Protection of the Ozone Layer and subsequent protocols developed as part of the convention is also an important instrument for the private sector engagement. There is a national target for eliminating use of CFCs in the country and private sector support to switch to non CFC refrigeration and air-conditioning has been identified to be quite relevant for the proposed resort development project.

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5.5 PERMITS OBTAINED AND REQUIRED

Following is the list of permits already obtained for the proposed project of tourist resort development in the Lagoon as well as permits required to be obtained in order to initiate the operation process of the tourist resort.

1. Approval for New Revised Resort Development Concept Master Plan – the final resort concept was approved by Ministry of Tourism on 25 June 2019. 2. Approval for Coastal Modification Concept – Approval for the final coastal modification concept was approved by Ministry of Tourism on 26 June 2019. 3. Approved EIA Terms of Reference (TOR) – the EIA Terms of Reference which outlines the scope of the EIA for the proposed development was approved by EPA on 9 May 2019. 4. EIA Decision Statement – the EIA approval is required in the form of an EIA Decision Statement after review of the EIA. The construction of the proposed project will be initiated once the EIA Decision Statement is issued by EPA. 5. Resort Construction Permit – upon EIA Decision statement, a construction permit will need to be obtained from Ministry of Tourism. 6. Resort Operating Permit - the resort operating permit will be given by Ministry of Tourism upon final inspection of the project which will be given upon meeting with key operational requirements and permits given by various government authorities. These include; i) Registration of Desalination Plants - Environment Protection Agency ii) Permit for Powerhouse Operation - Maldives Energy Authority iii) Fire Safety, Fuel Handling and Storage Permit – Ministry of Defense iv) Fire Safety Measures –Ministry of Defense v) Food Safety Measures – Maldives Food and Drug Authority vi) Dive Center Operation – Ministry of Tourism vii) Disaster Management Plan – Ministry of Tourism

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6. EXISTING ENVIRONMENT

This section outlines the present environmental condition of Aanugandu Falhu (4o18’30.98”N / 73o30’13.65”E), North Male’ Atoll and the surrounding environment where the project is believed to have some impacts as a result of the proposed development.

Given that some works including dredging and land reclamation have been carried out in the lagoon by the previous proponent under EIA approval of 2018, comparison of initial site condition outlined in the initial EIA against present condition of relevant environmental components have been undertaken and presented in this section.

6.1 DATA COLLECTION METHODS

This EIA is based on both qualitative and quantitative data collected from the lagoon, existing reclaimed islands and the surrounding environment as well as from previous EIA studies carried. Where site specific information was not available, secondary information was used.

Following are the key environmental components and the ways and methods used to gather relevant data for the project.

6.1.1 Geophysical Environment

Mostly a descriptive analysis from observations during field surveys as well as published information, drone images, Google Earth maps and information available online from websites were used. It mainly includes geographic setting, geological and topographical information.

A survey was carried out in February 2019 to establish existing shorelines and beach profiles of the reclaimed islands. Temporary benchmarks have also been established.

The section also outlines some historical information, present condition of the reclaimed islands, status of the beaches and other relevant physical information from the site.

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6.1.2 Climate Environment

Site-specific climate information was not available for the lagoon. Climate data from the Maldives Meteorological Services collected from the International and Regional Airports in the country as well as relevant data from websites were used in the general description of the climate environment, which is quite uniform throughout the country. It mainly includes general weather patterns including temperature, sunshine and rainfall.

6.1.3 Hydrographic Environment

Bathymetry – depth assessments were carried out by using echo sounder and a GPS. Echo sounder measurements were corrected and related to the mean sea-level for the area, which was carried out in February 2019.

Currents – drogues and GPS were used to measure currents within and around the lagoon in selected locations, which was carried out in June 2019.

Tides and waves information as well as other oceanographic information was collected from secondary sources and site observations.

6.1.4 Marine Environment

Most of the information on the marine environment was collected from field assessments and observations. These include;

Coral reef health – quantitative assessments on selected locations were carried out including line intercept transects (LITs) and visual observations on these locations. These assessments were used to determine the general reef health of the lagoon including live coral cover and reef fish abundance and diversity which was carried out in June 2019. Data comparison with previous EIA assessments and present condition were undertaken to understand impacts on marine environment from dredging and land reclamation carried out before.

Reef fish – visual reef fish census along the LIT locations in the marine environment was carried out

Seawater – three seawater samples were collected from the lagoon in clean 1.5 L PET bottles in June 2019. Required parameters were tested to understand the present seawater condition.

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Laboratory analysis of the water sample was carried out by MWSC.

6.1.5 Socio-Economic Environment

The relevant socio-economic data of North Male’ Atoll was collected from published information.

6.1.6 Derivation of Environmental Indicators

A baseline assessment on the environmental condition of the lagoon in relation to Aanugadu Falhu development was carried out in February 2017 and certain development activities in the lagoon were carried out in 2018. This EIA compares present site condition with that of the baseline condition.

Commonly used environmental indicators such as coral reef health indicators, water quality indicators have been used during assessments and for future monitoring. More details on the monitoring indicators will be outlined in the environmental monitoring section.

6.1.7 Uncertainties on Data Collection Methods

As most of the data on the surrounding environment was manually collected, human error could be the biggest uncertainty with regards to the data collection methods, however, GPS coordinates have been recorded for future monitoring purposes as well as reduce human error as exact points will be monitored in the future to assess changes as a result of the proposed project development on the islands. Other uncertainty factor could be timing of assessments in the future as some of the environmental conditions such as currents, reef fish populations, changes from season to season. Nevertheless, the methods used in these assessments such as reef transects, drogues, echo sounding, etc are widely used to collect environmental data.

6.2 ASSESSMENTS UNDERTAKEN

The following figures outline main environmental assessments undertaken to establish present condition of Aanugandu Falhu.

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SCALE

0 100 200 Meters

Title: Present shorelines and lagoon bathymetry

Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll Proponent: Promonant Pvt. Ltd. Figure 39: Present shorelines of reclaimed islands and lagoon bathymetry Page | 128

SCALE

0 50 100 Meters

Title: Beach profiles and bench marks (East Island)

Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll

Proponent: Promonant Pvt. Ltd. Figure 40: Beach profiles and beach marks of East Island Page | 129

SCALE

0 50 100 Meters

Title: Beach profiles and bench marks (West Island)

Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll

Proponent: Promonant Pvt. Ltd. Figure 41: Beach profiles and beach marks of West Island Page | 130

RS2

Drogue2

RS1

SW1 Drogue1 Drogue7

RS3 Drogue3

Drogue6

Drogue4 SW3 SCALE SW2 0 100 200 Meters RS4 Drogue5

Title: Assessment locations

RS5 Project: Tourist Resort Development in Aanugandufalhu, North Male’ Atoll

Proponent: Promonant Pvt. Ltd. Figure 42: Assessment locations

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6.3 GEOPHYSICAL ENVIRONMENT

6.3.1 Geography and Environmental Setting

Aanugandu Falhu is located at 4o18’30.98”N / 73o30’13.65”E in North Male’ Atoll. It is centrally located in the Atoll at a distance of 11km from Velaanaa International Airport. The nearest tourist resorts are Thulhaagiri Island Resort 1.4km west, Paradise Island Resort and Gili Lankanfushi 6km east and Bandos Island Resort 4km south. The nearest inhabited island is Himmafushi found 6.6km east (Figures 12 and 14).

Aanugandu Falhu is a small lagoon having 76ha in total area and is formed into a circular shape. A slightly deeper inner lagoon having an approximate area of 27ha is found slightly westwards of the lagoon, hence, shallow lagoon areas having an extent of 365m from inner lagoon slope to the outer reef slope exists on the eastern and south-eastern sides of the lagoon. A small sandbank is formed on the SE shallow lagoon having an area of 0.5ha. However, land reclamation initiated in the lagoon for a resort development project in 2018 which was completed in 2019 (Figure 13). Currently the lagoon has two reclaimed islands.

As Aanugandu Falhu is located in North Male’ Atoll where there are a number of tourist resorts as well as a number of lagoons allocated for similar resort development project on reclaimed land as well as with existing tourist resort and proximity to the international airport, its location is quite prime.

A number of lagoons have been allocated for similar resort development projects are found in the region (Figure 14).

The closest Marine Protected Area (MPA), Banana Reef is located at 8.4km south-east. Other MPAs in the region are Lion’s Head, Kollavaani found 15km on the south. A Sensitive Site (SS), which is a sand bank near Kodhipparu Falhu is found 14km SW of the project site (Figure 14).

6.3.2 Coastal Geology

The of the Maldives rise from 350- 450m depth from an underwater ridge found on the SW parts of the Indian Ocean at a depth of around 4km, which largely owes to coral reef formations over a long period of time. The formations of coral reefs die in time and space, and Page | 132

new reefs grow on top to replace old reef structures to form atoll shapes. The reefs in which the atolls are found serve as the foundation for the islands, which is also the result of reef limestone development within the atoll structures.

It is a small lagoon having only 76ha and is located on the inside of the atoll and is characterized by steep reef slopes, shallow lagoons and slightly deeper lagoon area in the middle and is formed like a ring-shape. The reef is well established all around the lagoon with very distinct reef flat areas having around 50m on the eastern side and undefined reef flat on most of the other areas. The reef flat areas have an average depth of 1m below MSL and the shallow lagoon areas have depths of 0.4m, 0.8m and 1.1m below MSL. A wider shallow area is found on the SE side having approximately 130m. The deeper part in the middle is 10m below MSL and some coral patches are distributed within the area.

Seasonal waves occur along the SE and eastern periphery of the reef as a result of swells that enter into the atoll through the large channel between Paradise Island Resort and Fullmoon Resort. Due to the slated nature of the reef slopes along the SE and eastern sides, swells break into the edge areas forming waves.

Prior to land reclamation in 2018, a small islet was found inside the surf zone in shallow areas of the lagoon, which according to some people was formed immediately after 2004 Tsunami. This islet had an area of 0.5ha before land reclamation. It became part of the reclaimed land on the eastern side of the lagoon.

6.3.3 Characteristics of Seabed Sediments

The depth of the shallow area ranges between -0.4m and -1.1m MSL while the depth of the main inner lagoon ranges from -2m to -10m MSL before land reclamation took place. However, after reclamation, the shallow area of the lagoon depth reduced to less than 1m and depth of the inner lagoon increased to 11m below MSL in most part, indicating that sand was burrowed within the inner lagoon for reclamation.

The sediments mostly comprise of fine to medium size grain material mixed with a rubble content in shallow areas and finer sediments in the slopes inner slopes of the inner lagoon. Fine sediments increased within the lagoon after reclamation.

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Figure 43: Presence of fine sand within the lagoon

6.3.4 Topography

The proposed tourist resort development will take place on the existing reclaimed islands, hence importance was given to establish present topography of these islands.

In order to take the present shoreline of the reclaimed islands, temporary beach marks (TBM) have been established on each island and from where present shorelines have been taken in February 2019. The present shorelines of the reclaimed islands are presented in Figure 39.

Upon establishing the shorelines, beach profiles have been taken around each island. The GPS locations are outlined in the following table. The details of beach profiles for both islands are presented in Figures 40 and 41.

Aanugandu Falhu GPS Coordinate East Island BP 1 4°18'29.75"N / 73°30'20.40"E BP 2 4°18'30.78"N / 73°30'24.09"E BP 3 4°18'23.68"N / 73°30'24.46"E BP 4 4°18'20.56"N / 73°30'22.98"E BP 5 4°18'17.29"N / 73°30'17.10"E BP 6 4°18'17.93"N / 73°30'15.16"E BP 7 4°18'22.02"N / 73°30'17.86"E West Island BP 8 4°18'22.13"N / 73°30'4.66"E BP 9 4°18'24.95"N / 73°30'5.79"E BP 10 4°18'27.18"N / 73°30'2.77"E BP 11 4°18'29.99"N / 73°30'3.16"E BP 12 4°18'30.68"N / 73°30'1.74"E Table 11: Aanugadu falhu beach profile GPS locations

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The average height on the northern part of the eastern island is recorded to be 1.7m above MSL and the southern side is recoded to be on average 2m above MSL. Some areas have sand stocks and are not evenly distributed.

Similar to the western island, most parts on the eastern island are also recorded to be 1.7m above MSL. Towards north, the height reduced to 1.1m, however, increases to 2m towards the northern tip.

Figure 44: General topographic condition of east island (left) and west island (right)

6.3.5 Seasonal Erosion and Accretion

6.3.5.1 Historical Perspective

A small sand bank was found on the SE shallow areas of the lagoon close to the surf area, which is believed to be dynamic that has seasonal patterns in the shape. According some people, this islet was formed after 2004 Tsunami and started to grow over time. It is formed very close to the edge of the reef on the SE side. No prominent erosion was observed, however based on Google Earth images taken in different years, it is indicative that the sand bank development and shape is quite dynamic.

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Figure 45: Different developmental stages of the sand bank 2005 (top left), 2008 (top right), 2009 (middle left), 2012 (middle right), 2013 (bottom left), 2016 (bottom right)

6.3.5.2 Present Condition

Land reclamation encompassing the existing small islet began in 2018 under EIA approval and two islands were reclaimed in early 2019. During the final stages of land reclamation, the project came under revision, hence no major coastal protection works were carried out, given

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that a fresh EIA will be required once the revised project concept is finalized and approved by MOT. A year has not passed after land reclamation of the islands have been completed, hence a complete seasonal cycle covering both NE and SW monsoons cannot be observed. Therefore, a detailed analysis of the islands subject to seasonal erosion and accretion could not be undertaken.

However, the islands have experienced transitional and beginning of SW monsoon periods where certain degree of erosion and accretion are observed. More than prominent erosion, these are believed to be natural shoreline adjustments given that as a result of reclamation, the local oceanographic condition within and around the lagoon have been altered. Certain areas, particularly tips of the reclaimed islands were observed to be affected by erosion, which inner side of the islands facing inner lagoon were observed to have certain degree of accumulation.

Figure 46: Natural shoreline adjustments on east island

Figure 47: Dynamic conditions on the eastern side of east island (part of existing islet)

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Figure 48: Erosion on west island

6.4 CLIMATE ENVIRONMENT

6.4.1 Climatic Setting

Maldives is located on the equator and therefore experiences monsoonal climate. There are two distinct seasons, dry season (Northeast Monsoon) and wet season (Southwest Monsoon). In these two seasons the temperature varies hardly. Northeast monsoon extends from January to March. Since Maldives consists of small islands and are surrounded by sea, hot days are often tempered by cooling sea breezes and balmy evening temperatures.

6.4.2 Monsoons

Maldives is in the Monsoonal Belt in the North Indian Ocean. Therefore, climate in the Maldives is dominated by south-west (Hulhangu) and north-east (Iruvai) monsoons. The southwest monsoon is the rainy season which lasts from May to September and the north-east monsoon is the dry season that occurs from December to February. The transition period of the south-west monsoon occurs between March and April while that of the northeast monsoon occurs from October to November. These monsoons are relatively mild due to the country’s location on the equator and strong winds and gales are infrequent in the Maldives. However, storms and line squalls can occur, typically in the period May to July. The winds usually get stronger in the south west monsoon especially during June and July. During storms the impact is greater on the northern atolls than the southern atolls.

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6.4.3 Temperature

Throughout the year, temperature remains almost same in the Maldives. However, daily temperature ranges from around 31o in daytime to 23° Celsius in night time. The highest temperature ever recorded in the Maldives was 36.8°C, recorded on 19 May 1991 at Kadhdhoo Meteorological Office. Likewise, the minimum temperature ever recorded in the Maldives was 17.2°C, recorded at the National Meteorological Centre on 11th April 1978.

Figure 49: Average maximum and minimum temperatures (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv)

As can be seen from the above figure, there is very little temperature variation throughout the country. The maximum temperature is between the ranges of 30 - 32oC and minimum temperature is between the ranges of 24 - 27oC.

Most of the field assessments in the lagoon were undertaken in June 2019, however, any secondary data for the months of April, May June for 2019 was unavailable, therefore, temperature comparison for April 2017 and 2018 recorded from the nearest weather station, which is Met Center in Velaanaa International Airport in Hulhule was obtained from Maldives Meteorological Service (MMS).

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Figure 50: Comparison of max temperature for April 2017 and 2018 (Source: www.meteorology.mv)

Figure 51: Comparison of min temperature for April 2017 and 2018 (Source: www.meteorology.mv)

The highest temperature recorded in central part of the Maldives last April was 33 degree Celsius, which was recorded on the 2nd. The minimum temperature recorded in the same area for the last month was 23 degree Celsius and was recorded on the 12th of April. On the other hand, the highest temperature recorded in April 2017 in central part of the country was 33 degree Celsius, which was recorded on the 21st and 23rd. Furthermore, the minimum temperature recorded in the central part in April 2017 was 25 degree Celsius, recorded on the 1st. Figure above shows daily maximum and minimum temperature (2017 and 2018) and average maximum and minimum temperature for the Month of April for central part of Maldives.

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6.4.4 Rainfall

The wet season; southwest monsoon runs from mid-May to November. In this season Maldives experiences torrential rain. The highest rainfall ever recorded in the Maldives with in a 24 hour period was recorded on 9th July 2002 at Kaadedhdhoo Meteorological Office and amounts to 219.8mm of rainfall.

Figure 52: Average rainfall (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv)

As can be seen from the average for the past 15 years, the latter half of the year experiences more rain in the country.

Comparison of rainfall for the month of April 2017 and 2018 was also undertaken in order to understand the general rain pattern of the region.

Figure 53: Comparison of rainfall for April 2017 and 2018 (Source: www.meteorology.mv)

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Last April, central part of the country received a total rainfall of 150 mm. The highest rainfall within 24 hours was recorded on the 18th and amounts to 51 mm of rainfall. The rainfall received in April 2017 was 84 mm less than that of last April. Figure above shows daily total rainfall (2017 and 2018) and daily average rainfall for the Month of April for central part of Maldives.

6.4.5 Sunshine

The fact that the Maldives is located at the equator, Maldives receives plentiful of sunshine throughout the year. The graph below shows the average daily sunshine each station receives throughout the year.

Figure 54: Average sunshine (from 2000 – 2015) in the Maldives (Source: www.meteorology.mv)

The beginning of every year receives about 12 hours of sunshine per day, which drastically reduces as the year moves to the later half beginning from May. This is more or less attributed to increased rain during the second half of the year.

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Figure 55: Comparison of sunshine for April 2017 and 2018 (Source: www.meteorology.mv)

Central part of the country received sunshine for 29 days last April, which amounts to 229 hours 18 minutes. Furthermore, in April 2017 central part of the country received sunshine for 30 days, which amounts to 276 hours 30 minutes. Figure above shows daily sunshine (2017 and 2018) and daily average sunshine for the Month of April for central part of Maldives.

6.4.6 Winds

The average hourly wind speed in Male experiences significant seasonal variation over the course of the year. The following data is taken from https://weatherspark.com/y/107507/Average-Weather-in-Male-Maldives-Year-Round accessed on 20 May 2019.

The windier part of the year lasts for 6.0 months, from May 4 to November 4, with average wind speeds of more than 10.1 miles per hour. The windiest day of the year is June 1, with an average hourly wind speed of 13.4 miles per hour.

The calmer time of year lasts for 6.0 months, from November 4 to May 4. The calmest day of the year is March 28, with an average hourly wind speed of 6.8 miles per hour.

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Figure 56: The average of mean hourly wind speeds (dark gray line), with 25th to 75th and 10th to 90th percentile bands (weatherspark.com).

The predominant average hourly wind direction also varies throughout the year.

The wind is most often from the north for 6.0 days, from March 22 to March 28, with a peak percentage of 35% on March 22. The wind is most often from the west for 8.0 months, from March 28 to November 29, with a peak percentage of 90% on May 24. The wind is most often from the east for 3.8 months, from November 29 to March 22, with a peak percentage of 59% on January 1.

Figure 57: The percentage of hours in which the mean wind direction is from each of the four cardinal wind directions, excluding hours in which the mean wind speed is less than 1.0 mph. The lightly tinted areas at the boundaries are the percentage of hours spent in the implied intermediate directions (northeast, southeast, southwest, and northwest).

Last April, the maximum wind speed in Central part of the country was experienced on the 18th at 18:23 hours from north-north-east at a speed of 32 mph. However, the maximum wind Page | 144

speed in central part in April 2017 was recorded on the 25th at 04:35 hours at a speed of 36 mph from east-north-east. Figure below shows daily maximum wind speed (2017 and 2018) and daily average maximum wind speed for the Month of April for central part of Maldives.

Figure 58: Comparison of winds for April 2017 and 2018 (Source: www.meteorology.mv)

The following figure shows wind rose for Hulhule in April 2018.

Figure 59: Wind frequency chart of Hulhule for April 2018 (Source: www.meteorology.mv)

This is the wind rose for Hulhule based on hourly wind data of the month April 2018. This rose shows that the winds at Hulhule during the period blow from the west and north much of the time. In fact, the spokes in the directions south, south-south-west, south-west, west-south-west,

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west-north-west, north-west, north-north-west and east comprise about 54% of all hourly wind directions. This also shows that the wind rarely blows from different directions.

6.5 HYDROGRAPHIC ENVIRONMENT

6.5.1 Lagoon Bathymetry

A recent bathymetry covering the entire project area was taken in February 2019 and presented in Figure 39. It was recoded that most shallow parts of the lagoon now has 1m below MSL and inner deep lagoon has an average depth of 11m below MSL.

At the time of initial assessments of the lagoon in February 2017 before land reclamation, a lagoon bathymetry was also taken. No drastic changes have occurred except for certain areas with changes in depth due to reclamation.

Figure 60: Lagoon bathymetry taken in February 2017 prior to land reclamation Page | 146

6.5.2 Currents

Wind generated current movement in the lagoon was measured in June 2019 from 7 different locations (Figure 42). These locations were same as the drogue study conducted in February 2017.

The following table outlines GPS locations and details of the drogue study.

Location Speed Heading Drogue 1 4°18'33.40"N / 73°30'23.42"E 0.29m/s 259.8o Drogue 2 4°18'44.03"N / 73°30'9.34"E 0.18m/s 65.70 Drogue 3 4°18'30.96"N / 73°30'1.90"E 0.14m/s 358.3.70 Drogue 4 4°18'17.99"N / 73°30'10.31"E 0.31m/s 36.80 Drogue 5 4°18'17.90"N / 73°30'19.80"E 0.33m/s 280.30 Drogue 6 4°18'26.44"N / 73°30'20.13"E 0.13m/s 3530 Drogue 7 4°18'35.92"N / 73°30'12.74"E 0.21m/s 61.20 Table 12: Drogue study details (June 2019)

It was found that the general current flow was from south to north given that the assessment period was during SW monsoon. Stronger currents reaching 0.31 – 0.33m/s (Drogues 4 and 5) emanated from the southern and south-eastern side of the lagoon. Inside the lagoon had slightly less currents.

The following table outlines details of the drogue study conducted in the lagoon in February 2017.

Drogue Speed Drogue 1 (DS1) 0.24m/s Drogue 2 (DS2) 0.15m/s Drogue 3 (DS3) 0.10m/s Drogue 4 (DS4) 0.12m/s Drogue 5 (DS5) 0.28m/s Drogue 6 (DS6) 0.13m/s Drogue 7 (DS7) 0.19m/s Table 13: Drogue study (February 2017)

According to these assessments, general current flow was westerly due to NE monsoon with slightly stronger currents on the south-eastern side. The highest currents were recorded at DS5 having 0.28m/s located on the south-east by the proposed Central Island. The lowest currents were recorded from DS3 having 0.10m/s located on the western side of the reef. Currents in the middle of the lagoon (DS7) was 0.19m/s. Hence, currents on the eastern side were slightly

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stronger than the other areas. Both studies of 2017 and 2019 suggest that currents in the southern side of the lagoon were recorded to be stronger than other areas.

6.5.3 Tides

Tidal currents as well as oceanic currents mostly emanate from western side of the reef. The exposure of western side of the lagoon to constant channel swells ensure that an immense body of water is constantly flowing across the reef. The currents can be extremely strong in the channels found on the north of the reef system especially during ebb and flow into the atoll.

Current speeds of four knots or more have been recorded in the atoll channels in the country. Oceanic currents are largely influenced by the direction of trade winds and can be of great strengths. Tidal currents which flow according the height of the tide and the direction of prevailing wind are much weaker than oceanic currents.

Like most of the places semidiurnal tides are experienced in the atoll, that is two high tides and two low tides a day. The tide varies from place to place, depending on the location and on the shape and depth of the basin, channels and reefs and also time of the year.

Tide data for the project site was not collected, instead secondary data was used to generalize tidal condition as a reference.

The following figure shows tidal data predicted for 17 – 20 July 2019, taken from www.tidetime.org/asia/maldives/male.tm accessed on 17 July 2019. Male’ is the closest area to the project site where tide prediction was obtained. High tides of over 1.2m at MSL and low tides of 0.25m at MSL are expected during this period.

Figure 61: Male’ tide predictions from 17 – 20 July 2019 (www.tidetime.org/asia/maldives/male.htm)

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6.5.4 Waves and Swells

Site specific data on waves were not collected during the assessments, however, some observations were made to understand the general condition.

Secondary data available on wave studies have been used in the Addendum. Studies on wave climate of the country undertaken by Paul S. Kench, Robert W. Brander, Kevin E. Parnell, Roger F. McLean in 2006 suggested that waves particularly have an increased height, frequency and energy on the outer reefs during SW monsoon than the inner reefs. According to the study wave heights of 0.42m are commonly found on the western atoll rims during SW monsoon. The period of the wave (frequency) ranges between 3s – 8s, depending on the morphology of the reef and the wave energy that carries in such waves range between 0.3Hz – 0.127Hz.

During site assessment period in June 2019, some rough conditions prevailed, hence frequent waves (5 – 9 seconds) were observed mainly on the eastern rim of the reef.

Figure 62: Waves occurring along the eastern side of the reef

No site specific information was also collected on swells around the reef. The closest region where swells data was available was from Male region which has been used as reference. Information obtained from secondary sources indicate that the south-eastern side of North Male’ Atoll generate swells of 1.3m high mostly from SE direction. The swells reduce in height to 0.5m as it enters the atoll, where the reefs play a major role in reducing the heights of the swells. According to the information, swells ranging 1.3m – 2m will be experienced in 59% of the time, while 28% of the time swells ranging 0.5m – 1.3m will occur in July 2019.

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Figure 63: Swells map for North Male Atoll for July 2019 (www.surf-forecast.com )

6.6 MARINE ENVIRONMENT

A baseline marine assessment was undertaken prior to commencement of any work in the lagoon in 2017 as part of the previous EIA for initial development concept. Dredging and land reclamation were the main activities undertaken as part of the previous EIA approval. Since this EIA is prepared for a new development concept for the lagoon, it is important to outline baseline marine environmental conditions as well as present marine environmental conditions for comparison purpose, generally to understand the current status prior to commencement of any development activity under the new development concept.

As part of the baseline marine assessment, 5 reef sites have been established to determine the general reef health in terms of live coral cover, coral composition, reef fish abundance and reef fish diversity. Additionally, 2 sites were established to assess the seawater quality within and around the lagoon. These established sites formed the basis of presenting the current marine environmental condition of the lagoon.

The locations of these sites are outlined in Figure 42.

The following table shows the GPS locations of the reef areas assessed.

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Aanugandu Falhu GPS Coordinate RS1 4°18'38.18"N / 73°30'25.79"E RS2 4°18'46.23"N / 73°30'08.83"E RS3 4°18'32.70"N / 73°29'59.99"E RS4 4°18'15.07"N / 73°30'10.63"E RS5 4°18'15.91"N / 73°30'22.20"E Table 14: GPS coordinate of the reef assessment sites

6.6.1 Baseline Marine Environment Condition

6.6.1.1 Coral Reef

The following figures summarize main findings of the baseline reef assessment carried out from the lagoon in 2017.

Figure 64: Reef composition of the lagoon

The coral reef assessments indicate that highest live coral cover recorded was from RS 3 located on the western part of the reef that has a live coral cover of 16%. RS 2 located close to the access channel also have a relatively high coral cover having 11%. The lowest live coral cover was recoded from RS 4 located on the southern side of the reef having only 3%. Sand content was highest at RS 5 site, which probably because of the location of the existing sand bank near the site.

Similar to many other reefs in the country, the main composition of the lagoon was dead corals covered in algae, rocks, rubble and dead corals, where these have highest cover on all sites assessed.

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In terms of coral diversity found from the live coral cover, Porites family was amongst the highest. It can be said that the live coral composition of the reef was dominated by Porites corals having over 75% cover. Most of the Acropora corals found from the reef was found to be dead, which may be as a result of the coral bleaching event that happened in early 2016.

The following figures show general condition of the reef areas assessed.

Figure 65: General reef condition at RS1

Figure 66: General reef condition at RS2

Figure 67: General reef condition at RS3

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Figure 68: General reef condition at RS4

Figure 69: General reef condition at RS5

6.6.1.2 Reef Fish

Reef fish assessments were also carried out in conjunction with the reef assessments along the same 20m transects on RF sites from the lagoon (Figure 42). Visual reef fish census was done on each transect along a belt having 2.5m on either side of each transect. Fishes encountered along the belt were counted or estimated. Reef fish were recorded at family level.

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Figure 70: Reef fish assessment results from the reef

The results of the reef fish assessments indicate that the reef fish abundance and diversity found from the sites were at an average level. However, RS 3 had more individuals having a total of 107 belonging to 18 different families. RS 4 had fewer number of reef fish having 42 belonging to 10 different families. It was found that the reef fish abundance and diversity increased as the condition of the reef sites were better having increased live coral cover. However, RS 5 also had good reef fish diversity compared to RS 2 and RS 3 with more fish and less live coral cover. Page | 154

6.6.1.3 Seawater

Seawater samples from 2 different locations from the baseline assessment were taken (Figure 42) and tested by the laboratories at MWSC.

The following table shows GPS coordinates of seawater sampling location during baseline assessment.

Aanugandu Falhu GPS Coordinate SW1 4°18'40.40"N / 73°30'12.18"E SW2 5°20'16.70"N / 73°38'55.25"E Table 15: GPS coordinate of seawater sampling location

The following table shows the results of the seawater analysis for the sampling sites, hence baseline condition in 2017.

Perimeter SW 1 SW 2 Clear with Clear with Physical Appearance particles particles pH 8.11 8.15 Salinity 34.51 34.29 Temperature 24.2 24.1 BOD 3 3 0.369 0.375 Nitrate 2.9 3.1 Sulphate 800 300 Phosphate 0.15 0.18 Table 16: Seawater analysis results (2017)

6.6.2 Present Marine Environment Condition

The following section outlines the current marine environmental condition around the lagoon based on observations and assessments undertaken in June 2019. In this regard, baseline marine assessment sites of 2017 were repeated to understand the present condition as well as main findings are discussed.

6.6.2.1 Coral Reef

The following figure shows the results of the reef assessments undertaken on the same sites of 2017.

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Figure 71: Reef composition of the lagoon in 2019

The results of the reef assessment show some dramatic changes to the reef composition. Recent assessments show that live coral cover of the reef currently stands at RS1 1%, RS2 4%, RS3 5%, RS4 2% and RS5 1%. Similar to the 2017 assessments, the reef is dominated by dead coral, dead coral covered in algae, rock and rubble components.

In comparison to the 2017 assessments, live coral cover on all sites in 2019 are recorded to be reduced. In this regard, live coral cover at RS1 reduced from 5% to 1%, RS2 reduced from 11% to 4%, RS3 reduced from 16% to 5%, RS4 reduced from 3% to 2% and RS5 reduced from 6% to 1%. In contrast, rubble content and sand content on all sites were recoded to be increased. This is believed to be as a result of direct impact on the reef from sedimentation resulted from dredging and land reclamation activities undertaken in the lagoon previously. Considerable amount of rubble and fine sediments were observed on all sites. Compared to 2017 conditions, it was also observed that visibility in the reef is greatly reduced which is a direct result of ongoing erosion and subsequent sedimentation around most parts of the reef. No coral bleaching was observed on any of the sites.

The following figures show present condition of the reef on the assessment sites.

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Figure 72: Reef condition at RS1

Figure 73: Reef condition at RS2

Figure 74: Reef condition at RS3

Figure 75: Reef condition at RS4

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Figure 76: Reef condition at RS5

6.6.2.2 Reef Fish

The following figure shows the results of the reef fish assessments undertaken on the same sites of 2017.

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Figure 77: Reef fish assessment 2019

The reef fish population in the lagoon is dominated by grazers including surgeonfish, parrotfish, damsels and wrasses. The highest number of individuals were found from RS3 having 107 belonging to 15 families, while the lowest number of individuals were found from RS4 having 61 individuals belonging to 7 families. This to some extent corresponds to the reef health at sites. However, increased algal content on all sites increased grazers in the reef.

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In comparison to the 2017 reef fish assessment, the population structure was observed to be altered owing much to the impacts of sedimentation. Large fishes such as snapper, groupers, travellies and sweetlips recorded during 2017 assessments were found to be absent during 2019 assessments. Generally speaking, the impacts on the reef has breatly affected reef fish abundance and diversity found in Aanugandu Falhu.

6.6.2.3 Seawater

Seawater quality analysis undertaken during 2017 assessment period were repeated to understand the present condition of seawater at the assessments sites against the baseline condition as well as an additional site (SW3) was established on the SE side of the reef (Figure 42), which is the location for proposed outfall. The locations are outlined in Table 15. The following table outlines the location of SW3. COD testing for seawater is not available from MWSC laboratory. Recent seawater test results are attached in Appendix 8.

Aanugandu Falhu GPS Coordinate SW3 4°18'17.92"N / 73°30'26.52"E Table 17: GPS coordinate of SW3

The following table outlines the results of seawater analysis during recent assessment.

Perimeter Unit SW1 SW2 SW3 Physical Appearance Clear with Clear with Clear with particles particles particles pH 8.20 8.22 8.07

0 Salinity /00 33.85 34.25 34.13 Temperature oC 24.3 24.3 24.2 TDS mg/L 26200 27800 TSS mg/L <5 <5 <5 Turbidity NTU 0.465 0.525 0.421 Nitrate mg/L 3.0 3.5 Sulphate mg/L 500 450 Phosphate mg/L 0.10 0.15 DO mg/L 5.54 5.34 Total coliform MPN 80 120 Faecal coliform MPN 4 10 Table 18: Seawater analysis results (2019)

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The results of the seawater analysis shows that the seawater is in good condition and free from contamination and pollution.

6.6.3 Marine Protected Areas and Sensitive Sites

The closest Marine Protected Area (MPA), Banana Reef is located at 8.4km south-east. Other MPAs in the region are Lion’s Head, Kollavaani found 15km on the south. A Sensitive Site (SS), sand bank near Kodhipparu Falhu is found 14km SW of the project site (Figure 14). The project is not believed to cause any impact on these areas.

6.7 SOCIO-ECONOMIC ENVIRONMENT

6.7.1 Introduction to North Male’ Atoll

North Male’ Atoll is part of administrative Male’ Atoll or having 60 km in length, and around 40 km in width. Male Atoll comprises of North Male’ Atoll and South Male’ Atoll as well as Atoll and Atoll, all of which are geographically separate but grouped as one for administrative purpose.

North Male’ Atoll has only 6 inhabited islands, namely Kaashidhoo, Gaafaru, , Himmafushi, and Thuludhoo. There are 27 tourist resorts and 3 islands designated for tourist resort development. A number of similar lagoons in the Atoll has been designated for land reclamation and resort development, of which have already completed land reclamation phase.

Thulusdhoo island is considered as the atoll capital of North Male’ Atoll. The closest inhabited island to the proposed resort development project in the lagoon is Villimale’, lying 15km south- east.

6.7.2 Population

The following table shows the most recent population record of North Male’ Atoll.

Island Population Kaashidhoo 1865 Gaafaru 1061

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Dhiffushi 1024 1388 Huraa 1142 Himmafushi 1308 Total 7,788 Table 19: Population of North Male Atoll in inhabited islands (Source: Preliminary Results of Population and Housing Census, 2014, DNP)

The resident population of the atoll is expected to more than 7,788 including the resorts and other industrial/commercial islands. According to Preliminary Results of 2014 Census, there are over 13,000 people residing in tourist resorts and other industrial islands in the whole Kaafu Atoll, where more than half of this population is expected to be residing in North Male’ Atoll.

Tourism in the atoll is quite high and is regarded as one of the core tourism zones in the country.

Figure 78: Existing tourist resorts (labeled in yellow) in North Male’ Atoll (Source: www.modomaldive.it)

6.7.3 Housing

According to the Population and Housing Census of 2006, there are 966 total households and living quarters in the atoll. The average household size in the Atoll is 6 persons. Kaashidhoo

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Island has the highest number of households having 277 and Dhiffushi Island having the lowest number of households having only 120.

6.7.4 Health and Education

Kaashidhoo is the largest island amongst the six inhabited islands found in North Male’ Atoll having approximately 280ha, which is also amongst one of the largest islands found in the Maldives in terms of land area. Currently there are 11 schools in the six islands with Kaashidhoo Island having 3 schools, where one of the schools is providing education up to GCE A’ Levels, while 10 schools in other islands including Kaashidhoo is providing education up to GCE O’ Levels. Each island has one Health Service Provider or a Health Center providing necessary health services. All islands have established pharmacies. As all these islands are close to Male’, most people fulfill their health needs by travelling to Male’.

6.7.5 Water, Sanitation and Energy

All six islands have access to harbor facilities and access to 24 hours electricity. However, water and sanitation services on the islands are limited. Only few islands have a planned sewerage network such as Huraa and Thulusdhoo. All islands use rainwater and bottled water as the main drinking and cooking water source. Both water and sanitation facilities are currently being planned by the government and as part of CSR development projects by private parties. Cooking gas is widely used in the Atoll as the main source energy for cooking.

6.7.6 Electricity

Electricity for the three islands is available 24 hours and STELCO provides electricity services in 5 out of 6 islands. Electricity in Himmafushi is provided by Island Community. The installed capacity of generators in Dhiffushi is 280kW, Gaafaru is 230kW, Himmafushi is 1010kW, Huraa is 1046kW, Kaashidhoo is 610kW, Thulusdhoo is 620kW. The oil consumption in Dhiffushi is 203,256L per year, Gaafaru is 252,544L per year, Himmafushi is 516,663L per year, Huraa is 720,000L per year, Kaashidhoo is 379,499L per year and Thulusdhoo is 443,808L per year (MEE, 2013). No information was available for installed capacities in the tourist resorts.

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6.7.7 Infrastructure

All islands have access to harbor facilities and have at least 2 mosques.

6.7.8 Waste Management

All islands have a designated waste management centres (WMCs) developed after the 2004 tsunami through assistance from international donors and as well as government assistance.

6.7.9 Public Transportation

Connectivity to all the inhabited islands of North Male’ Atoll to Male’ is easily. There is an established ferry service to all the islands on a daily basis by the Maldives Transport and Contracting Company (MTCC) since 2010 and a lot of people from these islands are currently using this ferry service. Also, some private parties organize chartered transportation services to all islands, particularly to those islands with a number of guest houses including Thulusdhoo and Dhiffushi.

6.7.10 Local Economy

As all the six inhabited islands found in North Male’ Atoll have easy and daily access to Male’, trade of general goods can be easily undertaken in all the islands. These general trade merchants play a key role in the local island economies and have good establishments such as small general stores to mini marts in almost all islands. There seems to be a good diversity in local economy of these islands. For instance, Kaashidhoo is a known agricultural island where most of the agricultural products are brought to Male’ local market. Gaafaru is generally a fishing village, while Thulusdhoo is the only industrial island with many bottling factories of water and soft drinks as well as a number of leased godowns. Himmafushi has a boatyard for boat repair and servicing and Huraa has an Ice Plant for supplying ice to fishermen. Both Dhiffushi and Huraa has good establishment of tourist shops for selling souvenirs to visiting tourists from nearby resorts on a daily basis.

Tourism is very well established in North and South Male Atolls with 42 operating tourist resorts representing 39.9% share of all the bed capacity in the resort islands found in the Maldives (Ministry of Tourism, 2014). By far, Male’ Atoll has the highest concentration of tourist resorts in the Maldives. Also, there are new tourist resorts in operation and planned such

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as Akirifushi, Kodhipparu, Kuda Bandos, Maadhoo Finolhu, and a number of reefs found in North Male’ Atoll already dedicated for resort and marina development. Most of the inhabited islands located in close proximity to tourist resorts such as Dhifushi, Thulusdhoo Huraa, and Himmafushi already have very good ties and relationships with the resorts. These islands have a number of benefits from the resorts in terms of contributing to development of local economies, human resources development in the hospitality industry as well as contribute to education, health and socio-economic development.

Currently there are a number of guesthouse development projects in all the islands, with Dhiffushi, Kaashidhoo, Thulusdhoo and Gaafaru now highly engaged in new development projects for guesthouses. Kaashidhoo Island already has an approved city hotel development project for 80 beds in a large land area. Gaafaru Council has announced a slipway development project on reclaimed land adjoining with a small reclaimed island found on the southern side of Gaafaru Falhu. A large area in Dhiffushi lagoon is already allocated for a large tourist resort development project. Some social housing development projects are also found on Kaashidhoo and Dhiffushi islands. Also a large number of guest houses already exists in Himmafushi and Huraa Island and more are developing in this two islands.

6.7.11 Expected Benefits from the Proposed Project

The resort development in the lagoon is expected to bring a number of socio-economic benefits to the local communities as well as assist in the overall development of the Atoll. These include direct and indirect benefits including both direct and indirect employment during both construction and operation phases, market for agriculture, fish as well as local handicrafts. Indirectly development of cottage industries and indirect benefits such as development of infrastructure and service facilities are some of the benefits that the communities of the Atoll are expected to obtain as a result of the development of the resort in the Atoll.

In general tourism development in the lagoon will increase the direct employment and training opportunities for the people of Kaafu Atoll and stimulate local economy, through cultivation and providing small business opportunities particularly for the nearby island in Kaafu Atoll.

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6.8 HAZARDS VULNERABILITY

The following information on the vulnerability of the islands in the Maldives are taken from published literature such as Natural Hazard and Physical Vulnerability Assessment Report by UNDP (2008) as site –specific information on vulnerability of the lagoon was not available. According to the UNDP (2008) the natural vulnerability of the islands and atolls of the country to potential environmental hazards have been modeled to understand the risk factors of the country.

6.8.1 Major Natural Hazards

According to the UNDP assessment report, the natural hazards prevailing in the Maldives can be classified into 4 categories. These are;

 Geological hazards i.e. earthquakes and coastal erosion;  Meteorological hazard i.e. tropical cyclones and storms, thunder storms, waterspouts, heavy rainfall, and drought;  Hydrological hazards i.e. floods induced by heavy rainfall, storm surges, waves, udha, and tsunamis;  Climate-related hazards i.e. accelerated sea level rise, sea surface temperature rise, changes in monsoon pattern.

Among those listed above, floods (induced by tsunamis, abnormal swell waves, and heavy rainfall), windstorms, droughts, and earthquake are counted as major natural hazards prevailing in the Maldives.

The general patterns of the major natural hazards prevailing in the Maldives can be well summarised in Figure 79.

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Figure 79: Relationship between hazard intensity and frequency of major natural hazards in the Maldives (UNDP, 2008)

6.8.2 Distribution Pattern of Natural Hazards

The major natural hazards in the Maldives are strictly controlled by their geophysical and climatic settings and show quite different patterns in their distribution, as shown in Figures 55 and 56. Tropical cyclones and correspondingly storm surges and droughts predominantly prevail in the north of the Maldives. In contrast, swell waves and heavy rainfalls are more prominent in the southern and western islands of the Maldives. The southern islands of the Maldives are threatened earthquakes from the seismis zone of Carlsberg Ridge.

There are also longitudinal variations in hazard distribution. The most notable is the occurrence of tsunami waves and their impacts. The eastern rim islands are subject to tsunamis and waves of a higher intensity due to their direct exposure to these hazards, whereas the western rim and atoll lagoon islands are protected by the atoll formation patterns. Impacts of swell waves and udha events are also expected to be highest on the western rim island due to the south westerly and westerly approach of these events. However, their impacts aren’t totally reduced on the eastern rim islands due to the propagation of swell waves through reef passes and fetch within atoll lagoon.

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Figure 80: Latitudinal variations of major natural hazards across the Maldives (UNDP, 2008).

Figure 81: Longitudinal variations of major natural hazards across the Maldives (UNDP, 2008)

Based on the above analysis, it can be said that the proposed lagoon is relatively in a safe zone from major natural disasters due to its location in the central parts of the country (Figure 80).

However, there is potential for Udha and swells generated from the western side in between the western and eastern atoll that may directly enter into the lagoon. Furthermore, a Tsunami generated from the eastern side of the country may impact the development as the Atoll lies on the eastern periphery of the country (Figure 81).

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7. ENVIRONMENTAL IMPACTS

The following section predicts potential environmental impacts from proposed tourist resort development project to be carried out in Aanugandu Falhu (4o18’30.98”N / 73o30’13.65”E) North Male’ Atoll. Once the potential environmental impacts are identified, the impacts are evaluated to identify their significance. In order to identify and analyze environmental impacts, the following methods have been used.

While predicting potential environmental impacts from the proposed project, this section also addresses existing environmental impacts in the lagoon as a result of dredging and reclamation works carried out under previous EIA approvals.

7.1 METHODS

7.1.1 Impact Prediction

The environmental impacts that may be generated as a result of the proposed project is predicted and is distinguished from pre-construction, construction and operation phases of the project. The impacts that may be associated with the proposed development have been predicted by using descriptive . The prediction of environmental impacts also to a great extent incorporated expert judgment and professional opinions of the EIA consultant as well as statements of the EIAs reviewed in this EIA report. Once the impacts are predicted, a detailed description has been given in order to understand the nature and type of impacts.

7.1.2 Impact Significance Analysis

The environmental impacts are assessed in terms of significance. Significance is the function of magnitude of the impact and the likelihood of the impact occurring and the impact magnitude is a function of the extent, duration and intensity of the impact. The criteria used to determine impact significance are summarized in the following table (adapted from Environmental Resource Management, 2008).

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Table 20: Impact significance criteria

Once a rating has been determined for magnitude and likelihood, the following matrix has been used to determine the impact significance.

Table 21: Significance rating matrix

The different ratings of impact significance are then given a colour scale for easily understanding the overall magnitude of the impact. The following colour scale has been used.

Negative Ratings Positive Ratings Negligible Negligible Minor Minor Moderate Moderate Major Major

Table 22: Significance colour scale

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7.1.3 Limitations and Uncertainties

The potential environmental impacts from the proposed project are all predicted, hence there may be variables affecting the accuracy of these impacts due to natural variations such as site conditions and uncertainties in scales and magnitudes. Also the limited time available for undertaking baseline environmental assessments is also key limiting factor in terms of determining the accuracy of the environmental impacts. The assessments were done during one season and impacts are predicted based on these assessments, however, how the magnitudes of these impacts and how they behave in nature during the other season are quite uncertain.

EIA studies undertaken in similar environmental settings and technical experience as well as professional judgment of the EIA team have been used as support while predicting and evaluating these environmental impacts.

Since the environmental, geomorphological and physical oceanography of the islands of the Maldives are unique, the degree and accuracy of the predicted impacts when applied even in other islands of the Maldives in similar project settings, may differ in accuracy, magnitude and significance.

7.1.4 Justification of the Method Used

There are many ways and a number of methods in which environmental impacts that arise from development projects can be assessed and evaluated. The methods used for the purpose of predicting and evaluating the significance of environmental impacts is an accepted and internationally recognized as well as widely used methods throughout the world in a number of development projects. Although it is adapted for the condition of the project by the EIA consultant from Environmental Resource Management, 2008 literature, the approach as well as intended outcomes still remain same.

EIA is a decision-making tool, hence, needs to be understood by both technical and non- technical people. The use of colour codes for determining the significance of each and every impact related to the proposed project in the methods used has been demonstrated to be quite effective, especially with non-technical people.

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7.2 EXISTING ENVIRONMENTAL IMPACTS

As discussed throughout the report, dredging and land reclamation as well as some temporary structures have been undertaken on reclaimed areas as part of initial resort development concept, which was carried upon approval of the initial EIA in 2018 by MOT. After reclamation, no development activities were carried out as the project was under review for a new development concept by a new project proponent.

7.2.1 Impacts on Reef

A baseline for the lagoon particularly for the marine environment was established as part of initial EIA assessments undertaken in 2017. Further assessments undertaken in the lagoon in 2019 for the new development concept show some significant changes in the marine environmental condition, particularly reduced live coral cover and altered reef fish abundance and diversity. Furthermore, deposition of fine sand and rubble in all areas assessed were recorded to be increased revealing that the lagoon is currently affected by dredging and land reclamation.

The details of the present condition and environmental impacts are outlined in Sections 6.6.2.1 and 6.6.2.2.

Figure 82: Present reef condition in the lagoon Page | 172

7.2.2 Impacts on Land

Exiting impacts on land were mostly observed to be erosion of various areas on reclaimed islands. Erosion is mostly affected on northern and southern tips of both islands as well as along the western side of western island and eastern side of eastern island. As a result of erosion, sedimentation within the inner lagoon and outer lagoon has been observed.

Figure 83: Erosion on reclaimed islands, western island (top) and eastern island (bottom)

7.3 IMPACT PREDICTION

The environmental impacts that may be associated with the proposed tourist resort development project in the lagoon are predicted in this section by using a simple descriptive matrix. The following matrix distinguishes the types of environmental impacts that may be associated with various project actions on key environmental components and distinguishes whether these impacts occur during pre-construction, construction or during post-construction and operations period.

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The following table predicts the nature and types of environmental impacts based on the existing environmental condition of the island and the surrounding environment.

ENVIRONMENTAL COMPONENTS AND ENVIRONMENTAL IMPACTS PROJECT Reef IMPLICATION Reclaimed Beach Lagoon ACTIONS Habitat PERIOD islands Shoreline Hydrodynamics Seawater Pollution in Development of Pollution on marine During temporary land due to environment pre-construction facilities waste disposal due to waste disposal Changes in Sedimentation nearshore and negative Alteration of Reshaping of hydrodynamics impacts to reef During existing shorelines around reclaimed habits and construction shorelines islands organisms, turbid seawater Changes in Changes in Sedimentation nearshore Coastal the shoreline and turbid During hydrodynamics protection for natural seawater construction around coastal adjustment seawater protected areas Changes in Sedimentation hydrodynamics and negative Minor due to new land impacts to reef During

reclamation area, direct loss habits and construction of lagoon habitats organisms, and organisms turbid seawater Dead trees and plants on reclaimed Landscaping on During islands due to reclaimed islands construction initial landscaping activities Little to no impacts on During Land excavation reclaimed construction islands Pollution in Reef habitat lagoon damage, Land, soil and Pollution of Construction environment and seawater During groundwater beach waste disposal lagoon water quality construction degradation environment quality deterioration deterioration due to pollution Seawater Land, soil and Pollution in quality groundwater Pollution of lagoon deterioration degradation, During Construction beach environment and due to organic loss of construction workers environment lagoon water waste and aesthetic deterioration sewage quality disposal

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Noise and Construction vehicular During machinery on emissions, air construction land pollution and health risks Sedimentation in lagoon, temporary Construction Minor impacts changes in During machinery in to reef due to hydrodynamics, construction lagoon sedimentation damage to habitats and organisms Sedimentation in lagoon, temporary Overwater Minor impacts changes in During structures to reef due to hydrodynamics, construction construction sedimentation damage to habitats and organisms Pollution in Reef habitat Land, soil and Pollution of lagoon Solid waste destruction, During groundwater beach environment and disposal seawater operation degradation environment lagoon water deterioration deterioration Pollution in lagoon environment and affect lagoon Reef habitat Land, soil and Pollution of Wastewater and water and destruction, During groundwater beach sewage disposal increased seawater operation degradation environment potential for deterioration development of algae in the lagoon Land, soil and Harmful to Harmful to groundwater Pollution of coral reefs, reef Waste oil marine organisms During degradation, beach fish and marine disposal in the lagoon operation harmful to environment organisms, environment biodiversity affect seawater Affect lagoon waters due to Land run-off and Use of pesticides degradation, increased During and chemicals groundwater potential for operation pollution development of algae in the lagoon Damage to lagoon habitats Damage to mostly from coral reefs During Tourist activities diving and mostly from operation snorkeling and diving and water sports snorkeling activities Table 23: Impact prediction table

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7.4 DESCRIPTION OF IMPACTS

7.4.1 Pre-Construction Phase Impacts

7.4.1.1 Development of Temporary Facilities

In order to make the islands ready for construction, several temporary structures, including temporary labour accommodation, stores, powerhouse and RO plant will be developed. During development of these facilities, a great amount solid waste are believed to be generated. These waste mostly comprise of wood, timber, iron, rods, plastic, pipes, cables, etc. If inappropriately disposed on land or in marine environment, it may become a nuisance during resort construction as well as bring some serious environmental impacts both on land and marine environment including pollution and land degradation.

7.4.2 Construction Phase Impacts

7.4.2.1 Impacts from Reshaping of Shorelines

Reshaping of shorelines involve adjusting the existing shorelines in accordance with the final revised development concept of the resort in terms of island shapes as the existing shorelines are slightly different. Reshaping work will involve removal of sand from extended areas and filling of sand to eroded areas by use of excavators and trucks.

This work is believed to bring a number of environmental impacts including permanent changes in the shorelines of the reclaimed islands and as a result localized changes in the nearshore hydrodynamics around the reclaimed islands. Also, during reshaping work, some sedimentation will occur around the areas, which will bring temporary changes to the seawater condition, while some sedimentation may impact the reef. Sedimentation on the reef will further stress the reef from existing condition, which are already suffering from sedimentation impacts from dredging and land reclamation undertaken previously.

7.4.2.2 Impacts from Coastal Protection

Development of headland revetments around the reclaimed islands and development of groynes along the shore are proposed as onshore protection measures while breakwaters on the southern side of the reef are proposed as offshore coastal protection measures, which compose of primary coastal protection measure. The primary purpose of these coastal protection measures Page | 176

is to protect the newly reclaimed islands during both monsoonal seasons where some rough conditions are expected on the southern and eastern side of the lagoon. Also, erosion is currently affecting northern and southern sides of the reclaimed islands, the proposed headland revetments are proposed to protect the corners of the reclaimed islands on the north and south.

A major impact of the proposed coastal protection measure will be alteration of the local currents, which may affect some areas of the reclaimed islands. Also, more currents are believed to divert towards the islands, which will move to and from the reef during both seasons.

Proposed coastal protection involves placement of rock boulders as part of onshore and offshore protection, hence will involve movement of machinery on land and in the lagoon causing some sedimentation, which will affect the seawater and reef habitats and organisms.

7.4.2.3 Impacts from Minor Reclamation

The major reclamation works have been completed under previous EIA approval. However, a minor reclamation works, particularly reclamation of Island 4 (north of lagoon) as well as reclamation of small islets on the south-eastern side of Island 2 as part of coastal protection has been proposed to be undertaken. The required fill material (approx. 17,000m3 plus) is proposed to be obtained from a designated burrow site within the inner lagoon. This will no doubt have significant implications in terms of environmental impacts in the lagoon and reef around the lagoon that are already stressed from previous land reclamation activities.

The process of land reclamation is not free from significant environmental impacts. One of the most significant environmental impacts from proposed land reclamation works in the lagoon will be spreading of sedimentation within the lagoon and the reef. Although as part of the proposed reclamation of the islands, filling will not be undertaken on any part of the reef, hence covering of coral reef areas directly will not be undertaken. However, spread of sedimentation of the reef areas within the lagoon are believed to cause direct damage to corals by smothering due to sediment cover, reef fishes and marine organisms will leave the reef areas affected throughout the duration of sedimentation, increased turbid conditions may decrease coral growth and decrease fish diversity in affected areas.

As there are no major habitats found within the inner lagoon, direct impacts on lagoon habitats will be very minimal. Occasional fishes that come neashore for feeding will change their

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feeding habitats due to heavy exposure of sedimentation within the lagoon. Most direct impact within the lagoon is believed to be alteration of local current patterns as a result of reclamation. More currents are expected to flow towards the middle of the lagoon after reclamation during both SW and NE monsoons. This may affect the reclaimed islands by erosion.

7.4.2.4 Impacts from Landscaping on Reclaimed Islands

The reclaimed islands will require large-scale landscaping to be undertaken as part of the proposed resort development. The area is proposed to be landscaped by means of planting trees from a nursery established at site and bringing some of the mature trees and plants including coconut trees from other areas where EIAs have been approved from relevant government authority. During the process of landscaping, survival rate of such trees and plants may be decreased if appropriate measures are not taken into consideration, hence causing death of most of the trees and vegetation that are newly planted. An important aspect is also given to setup a plant nursery in one of the reclaimed islands in order to supply most of the trees and plants required for initial landscaping purpose.

Also, conditioning of reclaimed land with soil fertilizers may have implications such as impacts from run-off due to bare land. Run-off of chemicals and fetilizers may impact the surrounding environment causing pollution and water quality deterioration. Also, there is potential for increased algal growth in the lagoon environment as a result of immediate nutrient enrichment. As there are vast lagoon areas within the project area, algal growth may soon become widespread.

7.4.2.5 Impacts from Land Excavations

Ground excavations on the reclaimed island for laying foundations of guest rooms, main complex, resort facilities, staff accommodation, services buildings etc will occur during initial phase of construction. The soil excavations from the reclaimed islands are believed to generate very minimal impacts such as affecting development of soil ecology.

7.4.2.6 Construction Waste Disposal

Often construction activities generate large amounts of construction waste and disposal of such waste material into the island and surrounding environment often pollutes the island environment. Disposal of construction material such as cement, concrete, oil, paint, cleaning agents will damage the island as well as will contaminate the groundwater lens that will be Page | 178

developed on the islands. Groundwater pollution negatively impacts the human and natural environment. Potential health risks such as diseases may be associated with groundwater pollution if water is used by the construction workforce. Also, on a long-term basis, groundwater pollution may have negative impacts by deteriorating the flora and fauna of the island that will be established on the islands once reclamation is completed and hinders their development and sustenance during the operation phase.

Also, as the area will be landscaped to some extent with more trees and vegetation, the impacts outlined above will be quite notable and visible and may be difficult to address if initial care is not undertaken. As the island will be developed as a tourist resort, impacts associated with construction waste disposal in the area and in the marine environment will be difficult to deal with if not appropriately disposed. If unattended on a regular basis, the aesthetic value of the hotel area will be diminished.

Additionally, disposal of construction waste into the immediate surrounding marine and coastal environment will pollute the marine and coastal waters as well as will have direct and indirect consequences on coral reefs and associated habitats. For instance, corals, reef fish and other marine organisms may instantly die off or leave these habitats as a result of severe pollution. Certain construction waste such as chemicals and waste oil will have serious impacts on the reef and its inhabitants.

7.4.2.7 Impacts from Construction Workers

A temporary workforce of around 1200 persons will be stationed on the reclaimed islands during the construction phase. As the workforce will be stationed on the islands for the entire duration of the construction phase, noticeable as well as considerable impacts will be generated on the surrounding environment of the islands from their activities.

One of the most important environmental impacts may be generated from improper sewage and waste disposal mechanisms. Raw sewage if disposed into the marine environment may harm the marine environment as a result of contamination, which may cause an increase in coliform levels in seawater, eutrophication and coastal water pollution may be generated. Such impacts may affect the survival of both coral and fish communities found in the reef environment. Additionally, raw sewage if disposed in the ground of the islands may contaminate and pollute the groundwater resources.

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Improper and inappropriate methods of domestic waste such as home and kitchen garbage, construction waste such as cement, iron and concrete as well as other waste such as paints, wastewater and waste oil disposal will impose serious implications on the environment through various negative impacts. The most significant impacts associated with such waste disposal on the island environment range from reduced aesthetic beauty of the of the island, pollution and contaminated groundwater and damage to reef environment, marine pollution to water quality degradation, increased sedimentation and turbidity as well as changes in the reef community structure on a permanent basis.

7.4.2.8 Impacts from Operation of Construction Machinery on Reclaimed Islands

During constructions, a number of construction machinery will be used on the reclaimed islands including loaders, concrete machines, earth moving vehicles, pickups, cranes, etc which may have direct impacts including sound pollution, vehicular emissions and dust, as well as associated health risks to the construction workforce however, it is believed that these impacts will be temporary and restricted to construction period.

7.4.2.9 Impacts from Operation of Construction Machinery in the Lagoon

Heavy machinery such as excavators and barges that may be used in the work activities of the proposed project in the lagoon environment would result in short-term however, negative impact in the lagoon environment as a result of disturbance to the lagoon bottom and lagoon waters. Most notable impacts will be from short-term sedimentation especially in the operations areas mostly during shoreline reshaping, coastal protection construction, minor reclamation, jetties construction, water villa constructions which may bring subsequent changes in seawater quality.

As the shallow lagoon areas of the proposed project does not have significant habitats and live corals, the impacts of sedimentation on corals will be very minimal as the operation areas for these machinery will be confined to the lagoon construction sites only.

7.4.2.10 Impacts from Overwater Construction Activities

The overwater structures to be developed in the proposed resort include connecting jetty construction between Island 1 and Island 2, arrival area and underwater pavilion, service jetty Page | 180

and jetties construction for water villas on the northern side, as well as overwater spa construction on the north-eastern side of the lagoon.

Although some environmental impacts have been identified, primary impact from construction activities will be fairly small. Secondary impacts arising from construction activities will be disturbances to the lagoon bottom and long-term sedimentation and increased turbidity in the lagoon water column due to alteration of current regimes within the lagoon as the tilts for the jetty, water bungalows and restaurant are erected.

Aesthetic value of the lagoon will also be reduced due to the sedimentation and turbidity increase for short-terms. In addition to this, mobilization of equipment and disposal of raw materials in the lagoon area will also have some negative impacts in the locality of the lagoon.

7.4.3 Operation Phase Impacts

7.4.3.1 Impacts from Solid Waste Disposal

Inadequate methods of solid waste disposal during the operation of the resort will generate a number of impacts on individual reclaimed islands of the resort as well as in the lagoon and marine environment. For instance, waste such as garbage, plastic bags, glass and plastic bottles, aluminum cans and other discarded items will contaminate groundwater and soils affecting vegetation, if disposed in the marine environment, will generate marine pollution and seawater quality deterioration in the surrounding area, which in turn will have detrimental impacts on coral reefs as well as on reef fish populations.

Also, such pollution can be seen on the islands as well as washed onto the beaches of the islands if not properly taken care of, thus, the islands will become aesthetically unattractive, which can tremendously affect the prime use of the islands as a tourist resort.

Thus, disposal of solid waste in the islands and marine environments will generate large scale environmental impacts that will be quite difficult to deal with. If immediate actions are not undertaken, the impacts will be permanent and widespread, which may have implications on other areas beyond project boundary. As North Male’ Atoll is prime tourism zone, solid waste disposal will affect other tourist resorts nearby and will diminish the aesthetic quality of the area, which will also have serious implications.

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Solid waste is believed to generate a long-term impact from continuous operation of the resort, pollution within and around and even beyond the project boundaries have been envisaged if appropriate disposal mechanisms are not practiced during the operation of the resort.

Thus, addressing issues with solid waste management during the operation of the resort needs to be taken into serious consideration. Appropriate mechanisms both at point source and disposal areas needs to be implemented.

7.4.3.2 Impacts from Wastewater and Sewage Disposal

There are many sources of wastewater that can be inappropriately disposed into the surrounding environment from a resort islands. Some of its sources include wastewater from the kitchens and laundries that are usually contaminated with oils, cleaning agents, detergents and other chemicals, wastewater from power plants usually have thermal effluents and wastewater from the desalination plant usually have concentrated brine.

Most of the above mentioned wastewater is potential pollutants that can have direct effects on the islands and coral reef ecology in which the whole ecosystem can be potentially harmed. Most of the environmental impacts generated from such sources are difficult to delineate as they are generally not attributed to a single source and are usually felt simultaneously. Some of the environmental impacts of wastewater from kitchens and laundries can be potentially toxic to marine organisms, while power plant waste such as thermal effluents can be potentially harmful and can have deleterious effects on both corals and fish due to immediate increases in water temperatures than their historical temperature maxima. Impacts generated from concentrated saline wastewater from desalination plant can also cause ecological disturbances in reef ecosystems through elevated salinity percentages.

Also, inappropriate methods of sewage disposal into the marine environment can have very significant environmental impacts, however, the impact magnitude depends on certain factors such as volume of effluent, location of the outfall, level of mixing and treatment depending on the nature of effluents. In most tourism development projects, sewage effluent is domestic. As the magnitude of impacts generated from sewage sources highly depend on the above mentioned factors especially in the Maldives where inadequate sewage disposal can have very serious implications on coral reef environment as they are highly susceptible and sensitive.

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One of the most common and significant environmental impacts generated from sewage disposal into offshore waters is eutrophication, an increase in nutrients due to algal blooms. As coral reefs survive in a low nutrient environment, nutrient enrichment caused by eutrophication increases the primary production of the reef through increased populations of benthic algae, which in turn decreases the amount of dissolved oxygen in the water, thus, affecting the survival of both corals and fish populations. Also, increased benthic algae populations caused by eutrophication limits necessary light availability for corals, which may affect their growth, reproduction and overall development. Also effects of eutrophication can be far reaching considering the vast nature of the lagoon in which the proposed project will be developed.

The spatial behavior of such pollution from wastewater sources in the marine environment will be similar to those discussed previously on dredging and reclamation works where large amounts of sedimentation will released into the marine environment and distributed to the surrounding environment in the atoll. However, unlike sedimentation which gradually settles down as it moves, pollution from wastewater could be felt on a longer time frame and could last for the entire duration of the operation life of the resort.

Hence it will be important to address wastewater issues at point sources similar to solid waste discussed above in order to reduce its implications on the environment.

7.4.3.3 Impacts from Waste Oil Disposal

Oil will be mainly stored for refueling purposes as well as to generate electricity in the resort during the operations. Oil spills from the storage may occur from accidents and leakage as well as waste oil generated from the power plant if disposed on the island and marine environment will have serious impacts on the environment.

In terms of biological consequences of such disposals depend on the type of oil, oil dosage, physical environmental factors, prevailing weather conditions, nature of the biota, seasonal factors, prior exposure of the area to oil, presence of other pollutants and type of remedial action.

As far as the proposed project is concerned, disposal of oil waste in the marine environment will contaminate the seawater as well as kill corals and marine organisms when come in contact. The aesthetic quality of the surrounding environment will be greatly damaged and

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prime use of the area as a tourist recreation will be diminished. Additionally, it will take long time for such impacts to be physically removed.

7.4.3.4 Impacts from Pesticides and Chemicals

Considerable amounts of fertilizers used in gardening and landscaping as well as chemicals such as pesticides and insecticides used in pest control can run-off to the surrounding marine environment causing significant environmental implications such as eutrophication. Some of the impacts generated from eutrophication have been previously discussed.

Other considerable environmental impacts generated from fertilizer and pesticides include pollution of groundwater if disposed in the ground, intoxication of both corals and fish from chemical contamination of seawater if disposed in the marine water causing large scale water quality degradation and marine pollution. In most instances, coral reefs can be severely affected, however, the magnitude of some of the impacts depend on both quality and quantity of use.

7.4.3.5 Impacts from Increased Transportation

Intensity of boating activities would be relatively high as the resort starts full operation. Intense boating activities have proven chronically detrimental to marine environment especially coral reefs both resulting from direct and indirect impacts such as physical damage to the benthos especially to corals through anchor damage and littering by boat crew and indirectly through disturbing the lagoon bottoms especially in shallow areas.

Small usually insignificant amounts of oils will be released from operation of boats in and around the arrival areas. Leaching of antifoulants, maybe insignificant given the flushing rates in the boating areas, but will be considered as an issue in the long-term. Boat grounding and anchor damage to the reef are potential risks especially in bad weather conditions and boat operations at night are potential risks.

7.4.3.6 Impacts from Tourist Activities

One of the greatest and highly significant impacts on the marine environment is imposed by tourist activities during the entire operation of the resort, which have both direct and indirect effects. As a large portion of the tourism in the Maldives are marine-based, most of the tourist-

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related activities and its implications on the environment are somewhat foreseen due to the current state of experience and knowledge gained from the past.

Recreational diving and snorkeling are major tourist activities in the resorts. As the reef of the lagoon is fairly small, too many divers can impact the reef, especially corals. Diving in large numbers in the reefs of Maldives is known to damage coral reefs, especially if the divers are inexperienced.

The increased demand for tourist boating can also damage coral reefs by anchorage from diving boats and safaris within the Atoll. The most susceptible corals to anchor damage are those of the branching varieties as they are highly fragile. In addition to physical damage, boats can cause chemical pollution of the reef environment. Corals can resist floating pollutants, but high concentrations of compounds that dissolve easily in seawater are a threat. In addition, tourism development increases demand for souvenir collection, which can lead to commercial collection of large number of marine organisms ranging from shells, corals to reef fish.

7.4.4 Indirect Impacts

North Male’ Atoll has one of the highest number of tourist resorts in the country and developing an additional tourist resort in the atoll will further add pressure on the natural environment. Some of the anticipated indirect impacts from the proposed development include increased completion over diving and excursion areas as well as overcrowding in such areas which has potential carrying capacity issues.

Additionally, a number of lagoons in the atoll have been leased long-term for similar development project involving land reclamation. If most of these projects start, indirect impacts from potential sedimentation during construction as well as marine pollution as discussed previously as a result of increased operation of tourist resorts in the lagoon are likely.

Unlike negative indirect impacts on the environment, the proposed project is believed to have some indirect socio-economic benefits such as creating employment opportunities to work in a nearby area to the families whose members reside in the islands of North Male’ Atoll as well as Male’, Villimale’ and Hulhumale’.

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7.4.5 Cumulative Impacts

Male’ City is found in North Male’ Atoll and a number of socio-economic development projects have recently been undertaken. Some of these projects include Hulhumale Phase 2 reclamation, Bridge Project from Male’ to Hulhule’, development of Industrial Zone in SW areas in Male’, Airport expansion project as well as planned new resort development projects that will be undertaken in nearby lagoons. The magnitude of environmental impacts from already completed projects are not known. Also, once new projects start construction, environmental impacts may not reach the lagoon, however once these projects starts operation, together with the existing resorts that are in operation in North Male Atoll, it is anticipated that there will be tremendous pressure on the natural environment of the atoll including increased transport in the region, increased demand for resources, increased solid and wastewater generation are to name a few cumulative impacts relevant for the proposed development project in the lagoon.

7.4.6 Positive Impacts

There are many ways in which the proposed development in the island will bring socio- economic benefits to the Atoll and the national economy in general. Some of the key beneficial impacts related with the proposed development include;

 Temporary employment during construction stages (at least 1200 jobs)  Permanent employment at the resort during operation stages (around 1059 jobs)  Indirect benefits to families of employees from the atoll during construction and operation of the resort  Support and encouragement to secondary and small-scale businesses such as agriculture, handicrafts, transportation, diving, etc  CSR support to local islands in the Atoll  Opportunity to work in a location close to families  Market for fisheries and local handicrafts  Contribution in terms of taxes and land rents to the national economy

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7.5 IMPACT ANALYSIS AND EVALUATION

The following section analyses and evaluates the previously described environmental impacts in order to identify their significance.

IMPACT SIGNIFICANCE During Construction Phase ACTIVITY/IMPACT EXTENT DURATION INTENSITY LIKELIHOOD MAGNITUDE COLOUR SCALE Temporary facilities development Onsite Temporary Medium Likely Moderate Reshaping of shorelines Local Permanent Medium Likely Moderate Coastal protection Local Permanent Medium Likely Moderate Minor reclamation Local Permanent High Definite Major Landscaping on reclaimed islands Onsite Short-term Low Likely Minor Land excavation Onsite Short-term Negligible Unlikely Negligible Construction waste disposal Local Short-term Medium Definite Major Consctruction wokers Onsite Short-term Medium Likely Moderate Construction machinery on land Onsite Short-term Medium Likely Moderate Construction machinery in lagoon Onsite Short-term Medium Likely Moderate Construction of overwater structures Onsite Short-term Medium Likely Moderate Creation of temporary emplyment (during construction) Local Short-term Medium Definite Moderate

During Operation Phase Solid waste disposal Regional Long-term High Definite Major Wastewater and sewage disposal Local Long-term High Definite Moderate Waste oil disposal Local Long-term Medium Likely Moderate Use of pesticides and chemicals Onsite Long-term Medium Unlikely Minor Increased transportation Local Long-term Medium Unlikely Minor Tourist activities Regional Long-term Medium Definite Moderate Indirect impacts Regional Long-term Medium Likely Moderte Cummulative impacts Regional Long-term Medium Unlikely Minor CSR support to islands Regional Long-term Medium Likely Moderate Creation of employment opportunities (Positive) Onsite Long-term Medium Definite Moderate Marketing of local goods and handicrafts (Positive) Onsite Long-term Medium Likely Moderate Contrubuting to national economy (Positive) Onsite Long-term High Definite Major Table 24: Impact analysis table

The above environmental impact analysis indicates that most of the environmental impacts occur during construction are of short-term and during operation are of long-term in nature. During construction phase, the most significant impacts that will occur are believed to be from minor land reclamation and construction waste disposal. Also, significance of a number of impacts during construction phase has been identified to be moderate such as impacts from construction workers, constructions in the lagoon, reshaping of shorelines and coastal protection. Land excavation has been identified to have negligible impacts as a result of the activity on already reclaimed island.

Also, during the operation phase, although most of the impacts are of long-term in nature, significance of most of the environmental impacts have been identified to be moderate except for disposal solid waste and wastewater into the nearby marine environment, where they have been identified to be major.

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All socio-economic impacts have very positive outcomes that have moderate implications, including CSR support, creation of jobs and marketing of local produce. Additionally, contributing to increased living standard within nearby communities and the atoll in general has been identified to be the most positive impact from the proposed development.

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8. MITIGATION MEASURES

The main purpose of the following section is to outline environmental management and mitigation measures that will be undertaken and followed with regards to minimizing and reducing environmental impacts from the proposed tourist resort development to be carried out in the lagoon on reclaimed islands. Mitigation measures have been addressed for all environmental impacts identified in the previous section.

Environmental mitigation measures during pre-construction, construction and operation phases have been dealt separately.

8.1 JUSTIFICATION FOR PREFERRED MITIGATIONS

The environmental management and mitigation measures outlined in this section have been selected by taking into consideration a number of factors. The most important factor considered in selecting these mitigation measures is that it has been selected based on its practicality. Other factors such as economic feasibility, technical know-how as well as adequacy and continuity played a key role in determining these environmental management and mitigation measures. Although cost was increased in some cases such as during excavation, dredging and

8.2 LIMITATION OF MITIGATIONS

In spite of the measures that will be taken to mitigate against the foreseeable impacts, there is always the possibility of impacts that were not foreseen, or the extent of predicted impact can turn out to be greater than predicted, or the mitigating measures may not be as effective as expected. In order to ensure that such incremental impacts do not suddenly appear without warning, the project will monitor key parameters in the vicinity of the development which can serve as environmental indicators. The area has been surveyed and a baseline have been established at key locations in the lagoon, beaches, reef and seawater. These areas will be

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monitored (using the monitoring program) regularly to provide an indication of impacts before they become too advanced for corrective action.

8.3 PRE-CONSTRUCTION PHASE

8.3.1 Mitigation Measures for Temporary Facilities Development

The main pre-construction activity in order to make the site ready for construction is development of temporary facilities.

The following measures will be undertaken;

 All waste generated from temporary facilities constructed will be taken and sorted at the designated waste management area outlined in the temporary setup site plan.  Any waste will not be disposed into the marine environment.  All items that are reusable will be reused in order to reduce waste that required to be disposed.  Regularly transport disposable waste to Thilafushi.  Regularly clean the island during temporary facilities development.

Key considerations; Consideration Detail Undertake appropriate waste management Reduce waste during pre-construction measures Cost US$4,000/month (waste transportation) Expected benefits Keep construction sites free from waste Expertise Waste management and handling Required Manpower 5 – 10 (labourers) Responsibility Contractor Equipment/Technology Small trucks Timing Pre-construction stage

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8.4 CONSTRUCTION PHASE

8.4.1 Mitigation Measures for Reshaping of Shorelines

A number of environmental impacts have been outlined in relation to reshaping and adjusting the shorelines of the existing reclaimed islands as per new development plan including changes in the nearshore oceanography, permanent changes to the shorelines as well as sedimentation. The following measures will be undertaken;

 Clearly mark areas where shoreline reshaping is required.  Sand removed from extended areas shall be initially taken on land and stockpiled.  Sand required for the areas requiring filling shall be undertaken after closing the area with geobags or any other physical barrier.  Undertake the shoreline adjustment works during low tide and on calm days in order to reduce spread of sedimentation into the lagoon and reef.  Implement proposed coastal protection measures simultaneously as the work progress on shoreline adjustment.  If sedimentation runoff is excessive, immediately stop the work and rectify the issue with additional physical barriers.

Key considerations; Consideration Detail Implement practical mitigation measures to reduce Reduce impacts during reshaping of shorelines sedimentation and immediate coastal protection during shoreline reshaping Cost Approx. US$25,000 – US$50,000 Reduced spread of sedimentation and protection of Expected benefits reclaimed areas Expertise Environmental protection/sediment control Required Manpower 10 - 20 Responsibility Contractor Equipment/Technology Excavator and Jumbo-bags Timing Construction stage

8.4.2 Mitigation Measures for Coastal Protection

Details of the coastal protection measures required for the reclaimed islands as per final resort development concept have been outlined previously. Environmental impacts from the proposed activity has been predicted to be quite similar to that of reshaping of the shorelines in terms of

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type and magnitude. Hence, environmental mitigation measures will also be similar as outlined below.

 Clearly mark all areas and prepare land where coastal protection measures will be undertaken including headland revetments, groynes and offshore breakwater.  Place geotextile layer as the primary protection cover in all headland revetments to ensure sand is protected from erosion and reduce sedimentation.  Undertake the coastal protection works during low tide and on calm days in order to reduce spread of sedimentation into the lagoon and reef.  For all offshore breakwaters and revetment islets, the required material (rock boulders) shall be initially placed in the required areas.  If sedimentation runoff is excessive, immediately stop the work and rectify the issue with additional physical barriers.

Key considerations; Consideration Detail Implement practical mitigation measures to reduce Reduce impacts during coastal protection sedimentation while undertaking coastal protection Cost Approx. US$25,000 – US$50,000 (Emergency) Reduced spread of sedimentation and protection of Expected benefits reclaimed areas Expertise Environmental protection/sediment control Required Manpower 10 - 20 Responsibility Contractor Equipment/Technology Excavator and geotextile mats, geobags Timing Construction stage

8.4.3 Mitigation Measures for Minor Reclamation

A small islet having 0.6ha on the northern side by the existing access channel and 5 small islets having 0.1ha on the south-eastern side of Island 2 has been proposed to be reclaimed from material obtained from the inner lagoon burrow site. The 5 small islets on the south-eastern side of the island will be protected by an outer side rock boulder revetment, which has been proposed to be used as an important coastal protection measure for Island 2.

Following are the key mitigation measures;

 Enclose the proposed reclamation boundaries initially with geo-bags, jumbobags before reclamation works begin.

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 Place additional physical barriers such as silt screens on areas where sedimentation is expected to be greater.  All activities must be undertaken during low tide and on calm days in order to reduce spread of sedimentation into the lagoon and reef.  For reclamation of 5 revetment islets, sand pumped from the burrow site shall be disposed on existing reclaimed islands to make a stockpile.  Only this stockpile shall be used to reclaim the islets.  Only use sand pump to obtain required fill material from the burrow site.  Direct disposal of fill material for the proposed 5 islets from burrow site will not be undertaken as it will release large amount of sediment into the marine environment.  All activities will be carefully and regularly monitored.  If sedimentation runoff is excessive, immediately stop the work and rectify the issue with additional physical barriers.

Key considerations; Consideration Detail Undertake sediment control measures before and Reduce impacts during minor reclamation during proposed ativities Cost Approx. US$100,000 – US$150,000 Reduced spread of sedimentation and protection of Expected benefits reclaimed areas Expertise Environmental protection/sediment control Required Manpower 20 - 40 Responsibility Contractor Sand pump, excavator, geobag, jumbobag, silt Equipment/Technology screen Timing Construction stage

8.4.4 Mitigation Measures for Landscaping Impacts on Reclaimed Islands

Landscaping will be an important activity, which will be required on existing reclaimed lands on each island. Landscaping in the reclaimed lands will consist of planting a mix of large, medium and small trees especially coconut palms, Magoo, Kuredhi, Boashi, Hinrundhu, Dhiggaa, Funa, Kaani, etc. Most of these trees will be transported to the site from EIA approved projects undertaken elsewhere. A key impact during landscaping includes immediate death of some of the trees during transport as well as during the process of planting as the reclaimed islands may not have required groundwater developed at the time of landscaping.

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In order to reduce the impact, the following measures will be undertaken;

 Undertake landscaping as per the requirements of the approved masterplan of the proposed resort in order to reduce the landscaping needs  Condition the reclaimed lands with compost and freshwater especially in required areas as an important initial step  Make available freshwater at the site  Undertake landscaping activity as early as possible in order to provide adequate time for the trees to adapt to the new conditions

Key considerations; Consideration Detail Nursery setup and soil conditioning on reclaimed Soil conditioning and nursery setup on reclaimed land lands Cost Approx. US$ 100,000 (setup cost) Expected benefits Proper landscaping on reclaimed lands Expertise Landscaping Required Manpower 10 - 20 Responsibility Contractor Equipment/Technology Nursery, equipment, compost, freshwater Timing Construction stage

8.4.5 Mitigation Measures for Land Excavation

In order to lay foundations of various resort amenities large amounts of soil will be excavated from the reclaimed islands. Excavations will only be undertaken on proposed building footprints. Rather than transporting the excavated soil out of the island, the soil will be used on the island for various purposes such as leveling, backfilling and landscaping the proposed resort. In this regard, soils excavated will be used on the site itself, which may have fewer impacts on the soil organisms and overall island ecology that is being established.

Key considerations; Consideration Detail Excavations Only in proposed resort buildings footprints Cost 0 Reduced areas for excavations and minimizing Expected benefits associated impacts Expertise Project planning Required Manpower 10-20 Responsibility Contractor Equipment/Technology Project master plan/ small excavator/trucks Timing Construction stage

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8.4.6 Mitigation Measures for Construction Waste Disposal

Disposal of construction waste has been identified as a major environmental impact during resort construction phase. In order to minimize impacts generated from construction waste, pollution and protect the aesthetic quality of the island, appropriate disposal mechanisms will be developed so that environmental integrity of the island can be maintained. Any sort of construction waste will not be disposed in the island or dumped into the immediate marine environment. Waste generated during construction will be initially taken into appropriate locations designated in the islands for waste sorting. These wastes will be sorted into reusable and disposable items. All reusable items will be reused during the construction and disposable items will be transported regularly to Thilafushi island.

Additionally, the following measures will also be undertaken;

 Daily cleaning of the construction sites  Regular collection and transportation to designated waste sorting area on the island  Prohibit disposal of any waste on the island and marine environment  Designated staff for initial waste sorting on the islands  Regularly transport all disposable waste to Thilafushi

A designated area on both reclaimed islands will be created and construction waste generated on these islands itself will be transported to this designated sites on a regular basis. From this area, construction waste will get sorted into reusable items and disposable items. All disposable items will be transported to Thilafushi on a regular basis and all reusable items will be reused.

Key considerations; Consideration Detail Protect environment from construction waste Construction waste management disposal Approx. US$ 100,000 (machinery and Cost transportation) Expected benefits Protection of environment Expertise Waste segregation Required Manpower 10 - 20 Responsibility Contractor, Proponent Equipment/Technology Small excavator, small pickup, wmc area, fencing Timing Construction stage

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8.4.7 Mitigation Measures for Construction Workers

With regards to protecting the island environment during the initial stages of the development, activities of the construction workforce will be closely monitored and will be guided by the Code of Conduct for Environmental Management. Activities such as sand mining from the beaches and coral mining from the lagoon and house reef of the island for construction purposes, disposal of waste on the island and in the marine environment as well as undertaking any unlawful activity on the island will be completely banned.

For the purpose of the proposed development in the lagoon, necessary labour quarters, services will be developed on reclaimed islands where their activities can be easily supervised. A temporary wastewater treatment tank and a desalination plant will be provided to protect island environments during construction.

Project management supervisors will regularly monitor the activities of the construction workers and report directly to the seniors.

Key considerations; Consideration Detail Reduce environmental impacts from workers To protect environment during construction phase Cost US$ 150,000 (setup cost) Expected benefits Protection of environment Expertise Project management Required Manpower 5 - 10 Responsibility Contractor, Proponent Equipment/Technology Code of Conduct, STP and RO plant Timing Construction stage

8.4.8 Mitigation Measures for Operation of Construction Machinery on Land

A large number of construction machinery including excavators, lorries, pickups, cranes, concrete machine, etc will be used on the islands during construction. The most notable environmental impact from the operation of these machinery will be emission of smoke and dust and noise pollution that will affect the overall island environment as well as the construction workers.

The following measures will be undertaken in order to reduce impacts from construction machinery;

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 Use of machinery only when necessary  Regular cleaning and conditioning of the machinery  Restricted machinery operation areas and times

Key considerations; Consideration Detail Reduce environmental impacts from operation of Reduce dust, smoke and noise pollution as well as construction machinery on land protect island from degradation Cost US$ 48,000 (salaries) Expected benefits Protection of environment Expertise Project management Required Manpower 2 x project managers Responsibility Contractor Equipment/Technology Code of Conduct for Environmental Management Timing Construction stage

8.4.9 Mitigation Measures for Operation of Construction Machinery in the Lagoon

The main construction activities in the lagoon from the proposed resort will be construction of connecting jetty between Island 1 and Island 2, arrival area, supply jetty, water villas and overwater spa where foundation works, erection of pillars require use of excavator and barges to be operated in the lagoon. Although no major environmental impacts are envisaged from the operation of such machinery in the lagoon, some minor environmental impacts such as damage to isolated corals and habitats, minor sedimentation, potential oil spills, smoke, dust and noise from these machinery.

The following measures will be undertaken;

 Use of machinery only when necessary  Regular cleaning and conditioning of the machinery  Restricted machinery operation areas and times  Operate machinery on calm days and good weather

Key considerations; Consideration Detail Reduce environmental impacts from operation of Protect marine environment from operation of construction machinery in lagoon construction machinery in lagoon Cost US$50,000 (accidental impact cover) Expected benefits Protection of environment Expertise Project management Required Manpower 3 - 5 Page | 197

Responsibility Contractor Equipment/Technology Code of Conduct Timing Construction stage

8.4.10 Mitigation Measures for Overwater Structures Construction

Construction of jetties will be largely undertaken in the lagoon for some resort facilities including water villas, spa, arrival area supply area, underwater viewing platform. These construction activities will also generate some environmental impacts such as sedimentation, damage to lagoon habitats, changes is local oceanography, etc.

In order to protect the marine environment from the above mentioned construction activities on land, the following measures will be undertaken;

 Sedimentation and siltation resulting from the proposed work activities in the lagoon environment will be minimized and contained within the area by using appropriate techniques such as use of appropriate retention methods and physical barriers  Machinery, equipment and vessels used in the project activities must be in good condition and operated in a manner that they do not pose a risk to the environment.  All work activities will be kept to the minimum period of time to reduce impacts on the environment.  Work will be inspected and supervised in whole lifecycle of the proposed project.  All project activities will be completed within the shortest possible time to minimize negative impacts on the environment.

Key considerations; Consideration Detail Reduce environmental impacts from operation of Protect marine environment from operation of construction machinery in lagoon construction machinery in lagoon Cost 0 Expected benefits Protection of environment Expertise Project management Required Manpower 3 - 5 Responsibility Contractor Equipment/Technology Code of Conduct Timing Construction stage

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8.5 OPERATION PHASE

8.5.1 Mitigation Measures for Solid Waste Disposal

An appropriate waste management system will be established on the island to handle all waste generated from the resort. Garbage disposal will be a key feature of the environmental protection of the island and lagoon/reef. All garbage will be disposed in a 100% environmentally responsible manner. All garbage will be segregated both at the source and at the recycle house. Most garbage will have emanated from domestic functions and thus would consist mainly of food waste, packaging and used appliances. Of these, all the biodegradable waste will be managed on the island, and other recyclables segregated, temporarily stored and dispatched to re-cycling centers periodically.

Remaining material will be incinerated at high temperatures. The primary waste management approach will have the following aspects;

 Dustbins for collection of different types of waste will be placed on the island at various locations including public areas, kitchens and restaurants, etc.  Waste materials that are not segregated at the source will be manually segregated at the recycle house.  Metals, glassware, plastics, paper and organic waste like leaves and twigs will be separated from other materials.  Metals such as tins and cans will be compacted at the recycle house  Glass bottles and other glass items will be crushed using a bottle crusher and will be taken out of the island for final disposal  Paper will be separated from other organic material as it can be more readily recycled into fresh paper.  Green waste such as leaves and twigs will be fed through a shredder and disposed on the ground near trees. This will ensure replenishment of the nutrients in the soil. Moreover, the shredding will accelerate the decaying process.  Other organic waste will be used to produce compost on the island.  Hazardous waste such as used appliances that contain some degree of harmful chemical waste like battery acids and heavy-metals and other chemical and medical waste will be contained in closed containers.

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 All residual waste will be regularly transported to Thilafushi

Key considerations; Consideration Detail Protect island and marine environment from Solid waste management improper solid waste disposal Approx. US$ 250,000 (machinery and Cost transportation) Expected benefits Protection of environment Expertise Waste management Required Manpower 5 - 10 Responsibility Operator, Proponent Incinerator, compactor, crusher, chipper and Equipment/Technology compost bins Timing Operation stage

8.5.2 Mitigation Measures for Wastewater and Sewage Disposal

As wastewater can be potentially threatening to the reef ecosystems by marine pollution, eutrophication, chemical contamination, water quality degradation, hence, it requires to be carefully managed. Wastewater will be managed by use of a sewage and wastewater treatment plant. Pipes of wastewater from kitchens, toilets and other facilities will be connected to the treatment plant. Treated water will be used during gardening and landscaping processes in order to conserve freshwater and reduce loads to the desalination plant.

The sewage problems on the proposed new resort will be dealt by using a high-tech SBR sewage treatment plant for treatment of raw sewage in order to reduce impacts of raw sewage disposal in the marine environment. The sewage treatment plant will have different levels of treatment including chemical and biological treatments. The treated water will be used during gardening processes while the sludge will be first disinfected before it will be discharged. The discharge outfall will be located on the eastern side, which will be placed at 15m depth and 5m away from the outer reef.

Key considerations; Consideration Detail Protect island and marine environment from Wastewater and sewage management improper wastewater and sewage disposal Approx. US$ 300,000 (salaries and machinery and Cost spare) Expected benefits Protection of environment Expertise Wastewater and sewerage management Required Manpower 5 - 10

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Responsibility Operator, Proponent Equipment/Technology Sewage treatment plant Timing During operation

8.5.3 Mitigation Measures for Waste Oil Disposal

Inappropriate methods of oil disposal into the marine environment can be potentially harmful to the marine ecosystem. Therefore, tremendous efforts and management measures will be undertaken even at the initial stages of development. The powerhouse has been proposed to be built in an area on the island that is far from the reef as well as with appropriate bund wall, therefore, oil leakage and spills from accidents from powerhouse can be easily detected as early as possible. Also, the power plant will be subject to day to day monitoring to see if there is any leakage and such leakage will be subject to immediate fix.

During transportation of oil and unloading procedures into the resort island, oil will be carefully handled in order to reduce risks of potential spills on the marine environment. The procedures will be very carefully monitored and supervised. However, in case of oil spills, only mechanical methods will be attributed in removing the spills rather than emulsifiers or dispersants, which will leave the residues intact on the reef environment for longer periods.

No waste oil will be discharged into the marine and terrestrial environments, rather, all the waste oil generated from the power plant will be subject to either incineration or transportation to Thifushi is closed containers.

Key considerations; Consideration Detail Protect island and marine environment from waste Waste oil and oil spill management oil disposal and potential spills Cost Approx. US$ 100,000 (equipment) Expected benefits Reduce pollution Expertise Waste oil management Required Manpower 2 - 4 Responsibility Operator, Proponent Equipment/Technology Oil containment equipment / oil booms Timing Operation stage

8.5.4 Mitigation Measures for Use of Pesticides and Chemicals

Although pesticides will be used to control pests, effective methods will be employed and their uses will be subject to appropriate management measures and procedures such as integrated

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pest control measures. Also, in case where other methods are feasible, biodegradable items such as biocides will be replaced with chemical pesticides.

No chemicals will be used during landscaping. Only organic soil enrichment methods such as water conditioning will be used in all areas of the resort.

The following measures will be undertaken;

 Avoid use of synthetic and chemical pesticides.  Use of biopesticides such as plant extracts such as neem (Azadiractha indica), wood ash and dried chillies as a means to repelling some insect pests.  Non-chemical pest management practices will be employed.

Key considerations; Consideration Detail Protect island and marine environment from pest Pest control and chemicals Cost Approx. US$ 50,000 (material and equipment) Expected benefits Controlling pest and diseases Expertise Pest management Required Manpower 3 - 6 Responsibility Operator, Proponent Equipment/Technology Compost, biodegradable pesticides Timing Operation stage

8.5.5 Mitigation Measures to Reduce Impacts from Transportation

All supply boats, dive boats and transfer vessels will be equipped with trash bins within easy reach and sign will be displayed to encourage use of trash bins. Crew members as well as passengers will be made aware of that littering to the marine environment is strictly prohibited. Effluent from toilets will not be discharged while boats are moored, anchored or close to the island. Care will be taken in the refueling process of boats to avoid any spillage of oils. Mooring facilities will be provided to avoid any possible anchor damages to corals and benthic organisms. Code-of-Practice for boating will be formulated and implemented. Environmental awareness of boat crew and passengers will be raised on environment friendly practices.

Mooring buoys will be installed in the reefs used for recreational fishing by tourists to avoid anchor damage. Environment friendly boating practices will be adapted by the recreational fishing boats to avoid littering, oil spillage and any physical/ecological damage to coral reef Page | 202

systems. Logs of fish caught will be maintained. Reefs used for fishing will be regularly cleaned of broken fishing lines and any litter.

Key considerations;

Consideration Detail Protect house reef and surrounding reefs from Mitigation of transport impacts boating activities Cost Approx. US$ 70,000 (equipment) Protection of environment and environment Expected benefits awareness Expertise Marine environment Required Manpower 5 - 10 Responsibility Operator, Proponent Equipment/Technology Floating buoys, signs, lights, bins Timing Operation stage

8.5.6 Mitigation Measures to Reduce Impacts from Tourist Activities

As mentioned previously that one of the largest and most direct impacts on the reef environment are occurred from tourist activities, their activities will be carefully monitored and inspected. The most important aspects in reducing tourist impacts initially will be subject to enforcement of good codes of conduct in all tourist activities.

Diving and snorkeling activities on the house reef of the island will be very closely inspected and supervised. Prior to all diving as well as snorkeling activities, briefing on the importance of environmental protection will be undertaken. Also, as there will be large number of isolated snorkelers on the house reef, they will be initially reminded of the good codes of conduct when acquiring necessary gear.

As one of the most effective means of protecting the environment is strengthening of awareness, environmental awareness programs among tourists and local staff will be regularly conducted through most appropriate means. The diving school will have necessary information on coral reefs and ways in which reefs can be protected from diving and snorkeling activities. This information will be available to tourists and local staff engaged in these activities.

Collection of souvenirs will be prohibited from the house reef and other dive locations as it can have some implications on the reef ecosystem. Therefore, underwater activities will be closely monitored and inspected in order to stop souvenir collections. Large fines will be attributed to

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souvenir collections and also will be subject to other harsh measures in order to eradicate such activities.

Key considerations; Consideration Detail Protect house reef and surrounding reefs Mitigation of tourist impacts from tourist activities Cost Approx. US$ 50,000 (equipment) Protection of environment and Expected benefits environment awareness Expertise Marine environment Required Manpower 3 - 5 Responsibility Proponent Equipment/Technology Awareness material, classes, seminars Timing During operation

As mentioned previously that one of the largest and most direct impacts on the reef environment are occurred from tourist activities, their activities will be carefully monitored and inspected. The most important aspects in reducing tourist impacts initially will be subject to enforcement of good codes of conduct in all tourist activities.

Diving and snorkeling activities on the house reef of the island will be very closely inspected and supervised. Prior to all diving as well as snorkeling activities, briefing on the importance of environmental protection will be undertaken. Also, as there will be large number of isolated snorkelers on the house reef, they will be initially reminded of the good codes of conduct when acquiring necessary gear.

As one of the most effective means of protecting the environment is strengthening of awareness, environmental awareness programs among tourists and local staff will be regularly conducted through most appropriate means. The diving school will have necessary information on coral reefs and ways in which reefs can be protected from diving and snorkeling activities. This information will be available to tourists and local staff engaged in these activities.

Collection of souvenirs will be prohibited from the house reef and other dive locations as it can have some implications on the reef ecosystem. Therefore, underwater activities will be closely monitored and inspected in order to stop souvenir collections. Large fines will be attributed to souvenir collections and also will be subject to other harsh measures in order to eradicate such activities.

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Key considerations; Consideration Detail Protect house reef and surrounding reefs from Mitigation of tourist impacts tourist activities Cost Approx. US$ 60,000 (equipment) Protection of environment and environment Expected benefits awareness Expertise Marine environment Required Manpower 3 - 5 Responsibility Operator, Proponent Equipment/Technology Awareness material, classes, seminars, multimedia Timing During operation

8.6 OTHER CONSIDERATIONS

8.6.1 Reef Rehabilitation Programme

Given that dredging and land reclamation activities undertaken previously in the lagoon has impacted the reef, the proponent proposes to undertake a reef rehabilitation programme in order to support the reef recovery. Some stakeholders including Ministry of Environment and Marine Research Center also suggested to carryout a reef rehabilitation programme. In order to proceed with the programme, the following activities will be undertaken;

 A proper project will be formulated outlining key areas for reef rehabilitation, methods for undertaking reef rehabilitation and project management.  Project approval will be sought from EPA or MRC prior to implementation.  An EMP will be prepared for the project.  Dedicated staff will be hired and budget will be allocated to implement the project.  Project implementation will be regularly monitored and documented.

8.7 COMMITMENT

8.7.1 Rationale

The Proponent recognizes that tourism can only be sustained if the environment of the islands are taken care of and are maintained in a healthy state. Therefore, in order to sustain the tourism

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product as well as maintain a healthy environment, the Proponent is fully committed to protect the environment of the island by applying a number of environmental management and mitigation measures. Early planning by devising an Environmental Management Plan and immediately responding to environmental changes as well as environmental monitoring are the key steps that the Proponent considers highly important and recognizes the importance of implementing the mitigation measures previously identified.

Commitment letter from the Project Proponent is attached in Appendix 9.

8.7.2 Environmental Management Plan (EMP)

An Environmental Management Plan (EMP) has been devised in order to systematically manage the resort’s environmental issues. The essential characteristic of the EMP is that its various components will interact to provide measurable information enabling continual improvements.

By developing and implementing the EMP, the resort will evaluate, manage and reduce the environmental impacts by providing a methodology to integrate environmental management into all areas of resort operation and management in a systematic manner.

The EMP consists of the following actions;

 Establish environment objectives/targets  Implement EMP through an environment management program  Establish EMP procedures in all departments and divisions  Establish environmental performance monitoring and data collection procedures  Internal environment communication, delegation and training  Environment-related communication to visitors  Conduct an EMP audit  Review objectives/targets for continual improvement  Report on environmental performance

8.7.2.1 Main Areas of EMP Application

Since the resort will be protecting the environment at the highest environmental standards, the EMP will be applied to all areas of resort operation including;

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 Solid waste management  Sewage and wastewater management  Power generation and energy conservation  Water generation and water conservation  Conservation of flora and fauna  Environmental mitigation measures for the development  Fire safety and occupational health  Emissions and air quality  Monitor and document environmental performance

8.7.2.2 EMP Implementation

The overall implementation of the EMP will be supported by an environment management team. The environment management team will consist of senior resort management staff and will have representation from all departments to ensure that all environmental issues of the resort operation are identified and addressed in the EMP.

8.7.2.3 Staff Training

All the staff of the resort will be made aware on the EMP and the important role that it plays in improving the environmental condition of the resort. Therefore, staff training with regards to collecting environmental data will be undertaken with regards to effectively implementing the EMP of the resort.

8.7.2.4 EMP Audit

The implementation of this EMP will be audited every two years. The audit will be performed by both internal environment management team and external environmental auditors. The audit reports will be carefully reviewed and efforts and measures will be undertaken to implement any recommendations.

8.7.3 Emergency Plan

An emergency Plan will be developed for the operational phase and will include general guidelines and procedures for the events of fire, labor accidents, and accidental oil and chemical spills, both in land and sea as well as in the events of natural disasters.

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The procedures for spill emergency response will include spills related to accidents during the operations. Firefighting will cover potential fire risks and fire event impacts, good housekeeping, fire watch, firefighting systems and equipment. Staffs involved in the island will be trained to undertake such operations.

For occupational accidents, the procedures will cover first aid, the establishment of the hygiene and safety procedures, and the availability of a medic. There will also be procedures for fire control, and emergency response to labor or occupational accidents. Emergency cases will be transported to the nearest Health facilities. In severe cases, where the patient need to be transported to Male’ or Hulhumale’, immediate transportation arrangements will be made.

An Procedure will be laid in cases of natural disasters, fires, flooding, etc and Emergency Escape Charts with Assembling Points will be placed in all guest rooms, public areas as well as BOH area.

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9. ALTERNATIVES

The following section describes and evaluates some alternatives in terms of locations, methods of environmental protection and construction for the proposed resort development in the lagoon. Also, “No Development Option” has been closely looked at in terms of understanding the opportunity cost of the projects versus no development scenario.

9.1 NO DEVELOPMENT OPTION

It is believed that a number of environmental impacts will be generated from the proposed development of the resort in Aanugandu Falhu. Although no impacts on the environment will be associated if the proposed development of the resort does not go ahead, which will leave the environment as it is now. However, the development of the resort will bring numerous benefits. Some of these benefits include socio-economic benefits as well as environmental benefits. In terms of socio-economic benefits, including creation of over 1059 new job opportunities and CSR support to nearby islands as well as contribute to the national economy.

More to that are some of the direct benefits that a development of a resort will bring to nearby local communities, including tourist visits to these communities can be highlighted and boosting of local economy through development of souvenir shops as well as marketing of local agricultural and fisheries products and handicrafts by the communities to the resort.

Also, the environmental benefits are numerous with the proposed resort since environmental matters will be given important status such as environmentally-friendly design, technology and practices for environmental protection. The resort itself will act as a protected area. There are other important environmental benefits such as protection of reef resources within the house reef, implementation of a reef rehabilitation programme, establishment of an environmental monitoring mechanism as a result of the development and creation of environmental awareness within the resort. Given the range of benefits that the proposed development of the resort will bring to the local and national economy and nearby communities as well as to the environment, the proposed development project has been considered as an important opportunity.

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The proposed resort development project in the lagoon will add 706 beds to the tourism sector with direct employment of around 1064 jobs and indirect employment contribution of around 500 jobs. The proposed projects is also expected to contribute over 190,000 annual tourist arrivals to the country, hence is also expected to directly and indirectly contribute US$ 3 – 5 Million annually to the national economy. With the positive outlook of the project, it is regarded as an important project for the country.

The above positive economic and social outlook of the proposed project will be lost if the option for “No Development” is taken based on environmental implications that the project will have. Also, with the option, further environmental protection and safeguard opportunities will be lost as the principle of the option is “Do Nothing”.

9.2 ALTERNATIVE DEVELOPMENT OPTIONS

9.2.1 Construction Method

Since the development of the resort involves construction of over-water structures such as overwater jetties, water villas, overwater spa, connecting jetty, alternative methods that minimize the environmental impacts have also been considered for all these developments. For instance, all these developments will generate some sedimentation into the marine environment ultimately impacting the marine environment. Alternative means to reduce the sedimentation have been considered.

In order to reduce impacts on marine environment, the concrete columns as well as pad footings for the jetties will be pre-casted on land and transferred to the desired location only during construction. Consideration of pad footings will eliminate need for pile driving and minimize excavation needs within the lagoon, hence will reduce sedimentation during construction of overwater structures.

Although a harbor on the eastern side of Island 2 was initially considered for the new development, based on detailed site evaluation and assessment, the harbor development was eliminated considering environmental and operational implications.

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Development Preference

Unlike undertaking construction of jetty and overwater structure foundation works and pile driving of columns, the preferred alternative is to use pre-cast pad footings and columns in all jetties. This method is believed to generate less environmental impacts than commonly practiced underwater foundation works and excavation for erecting columns, which will generate some sedimentation in the lagoon.

Timing

Prior to initiation of construction of jetties and overwater structures, all pre-casting work for pad footings and columns and column covering will be undertaken on land in a designated area.

Technology

Pre-casting molds and concrete.

Mitigation Measure

In order to mitigate environmental impacts from the preferred alternative construction method, the required pad footings and columns will be transported to the work site as the work progresses in the lagoon for jetty, water villas and overwater spa development. This will reduce potential for breaking pad footings and columns when transported in bulk. Also, the lagoon areas in which the work is undertaken can be kept relatively clean, thus likely pollution can be minimized.

9.2.2 Spun Pile Method

Instead of conventional concrete pad footing and concrete column method, spun pile method has also been looked at as an alternative overwater construction method for jetty, overwater spa and connecting jetty.

Pier pile positions shall be installed over a suitable pile installation platform, whether they be on firm ground or on an elevated staging. Any platform/staging established shall be robust and stable enough to handle weights of piling machine. Piles shall be lifted from its stacked position utilizing its two designated lifting points (especially concrete piles). Canvass padded slings shall be used for spun piles. The toe end of the starter piles shall be pitched/planted to its exact position manually by suspending the pile from its driven end. With the toe position fixed, the

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required pile inclination shall then be adjusted to the required angle while the guide rails and required back supports are firmly secured. Pile driving shall utilise the most suitable hammer for the purpose of driving the type of pile to the set without damage to the pile head. The equipment often required for pile driving include piling rig, 7t hydraulic hammer, 20t mobile crane and welding set.

Spun pile driving has some benefits and drawbacks. Although the method is fast and generates less sediments in the lagoon, pile driving is expensive and vibrations can damage the surrounding environment.

Development Preference

Concrete pad footing and concrete columns are preferred over spun pile driving given that the method is expensive and may lead to some environmental damages of the seabed and surrounding environment as well as the method requires specialized equipment that requires to be sourced out of the country.

9.2.3 Resort Layout

There are a number of possible alternative layouts for the proposed development of the resort, however, consideration has been given to the maximum existing reclaimed island land use and minimal environment impacts on both marine and land environments. The development has considered leaving large areas of the islands without development for greening purpose. All beach villas will have a setback of 10m. Thus, the proposed development has been very much integrated with the existing reclaimed island by giving important consideration during the layout of the new resort in order to as much as possible reduce impacts from the proposed development as well as reduce ecological footprints.

9.3 ALTERNATIVE COASTAL PROTECTION METHOD

9.3.1 Coastal Protection Design

Currently it is proposed to use headland revetments and groynes as the primary coastal protection of the reclaimed islands. It has taken consideration of the existing reclaimed island shapes where minimal shoreline adjustment requirement to be in line with the proposed Page | 212

development concept and effective as well as functional coastal protection has been given preference. Hence, an alternative design in terms of location and method has not been looked for the revetments and groynes.

For offshore protection measures, a rock boulder breakwater has been considered for the southern side of Island 1 and offshore revetment islets (5 islets) have been considered for southern and south-eastern side of Island 2.

For the alternative design, only small islets proposed on the south and south-eastern side of Island 2 has been considered. In this regard, instead of the revetment islets, an offshore breakwater can be considered as shown in the following figure.

Figure 84: Proposed coastal protection (left) and alternative coastal protection (right)

Development Preference

Although the proposed alternative could be a slightly economical alternative compared to the proposed islets, the preference is given for the proposed islets. There are a number of advantages for the islets including stronger protection as well as concealing the view of busy transportation in nearby areas, airport, Hulhumale and Male’ views for the guests of beach villas located on the south-eastern side of the island. These islets are proposed to be vegetated for aesthetic appeal, hence can be easily integrated with the resort.

9.3.2 Material

Currently all coastal protection structures are proposed to be constructed from rock boulders. As an economical alternative, drymix geobag revetments and groynes plastered from outside to conceal the bags has been considered. However, for the offshore structures, this alternative may not be practical given that there are seasonal rough conditions and increased wave

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reflection capacity for plastered structures. As a contrast, wave absorbing capacity of the rock boulders are believed to be quite effective, hence for offshore structures, rock boulders would be more functional than plastered drymix geobags.

Development Preference

Use of rock boulders in the revetments and groynes can be long lasting although slightly expensive than drymix geobag plastered structures. However, guests may not prefer hard structures developed from rock boulders as well as it may not fully integrate with the island environment. Nonetheless, functionality and effectiveness wise, rock boulders may be more practical compared to drymix structures given the high absorbing capacity in dynamic areas. Therefore, rock boulder structures are preferred for the proposed development. Furthermore, the drymix revetment can be used in the internal channel between Island 2 and Island 3 as the area can be less harsh and use of drymix can easily blend with the island environment.

9.4 ALTERNATIVE LOCATIONS

9.4.1 Alternative RO Intake and Alternative Outfall Locations

Currently, it is proposed to source water for the desalination plant from boreholes developed eastern side of Island 2. However, as an alternative, a seawater intake location has been identified. Similarly an alternative outfall location for treated wastewater and brine disposal has been identified as outlined in the following figure.

Figure 85: Alternative intake and outfall locations

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The following table outlines details of alternative locations.

Detail Location Alt. Brine Intake 4°18'25.30"N / 73°30'16.17"E Alt. Wastewater Outfall 4°18'15.75"N / 73°30'26.82"E Table 25: Alternative locations for intake and outfall

Development Preference

Considering the long-term benefits of having the borehole system in terms of avoiding machine clogging and quality of source water, the proposed borehole has been considered for the development. Also, it is proposed that the boreholes will be located close to the RO plant.

With regards to alternative outfall, it is proposed to have the proposed location compared to alterative location on the south-eastern side given that the alternative location requires crossing of the pipeline under a proposed coastal protection structure.

9.4.2 Alternative Burrow Sites

Currently a burrow site for the requirements of minor reclamation involving reclaiming an islet on the northern side of the reef and 5 islets on the south-eastern side of the reef has been proposed on the eastern side of the inner lagoon as shown in the following figure.

Figure 86: Proposed burrow site (green) and alternative burrow sites (red)

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Alternatively, two burrow sites are proposed. One on the western side and the other on the northern side of the inner lagoon. All sites have an area of 3,472.55m2. The fill material requirement for these sites have been estimated to be 17,450m3. In order to obtain this fill material, a dredging depth of 5.05m below existing seabed has been considered. It is proposed to obtain fill material by using sand pumps.

Development Preference

The proposed burrow site has been preferred given that it is located close to Island 3 where sand pumping can be directly undertaken and stockpiled on Island 3 and transferred to the required areas easily rather than pumping directly to required areas which will generate sedimentation within the lagoon.

9.5 ALTERNATIVE DREDGING OPTION

9.5.1 Use of Cutter Suction Dredger

Currently it is proposed to use sand pumps for obtaining necessary fill material for the proposed minor reclamation. In case sand pump are unable to obtain fill material due to increased depth or cannot meet with the volume requirement, cutter suction dredger will be used as an alternative option. However, use of cutter suction dredger has the potential to increase sedimentation in the lagoon unlike sand pumps and its use will be finalized only on an absolute necessary basis.

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9.6 ALTERNATIVE ENERGY CONSIDERATION

9.6.1 Use of Solar Energy

The proponent recognizes the importance of environmental considerations as part of the entire development and has committed to implement environmental mitigation measures throughout the development process of the resort in order to safeguard the environment. Similarly, the proponent will further look at possibilities and economic feasibilities of implanting programmes for generating alternative energy by means of harnessing solar energy. Several buildings at the BOH area of the resort are designed to readily install solar panels which can be plugged into the main grid. This alternative requires further assessment and evaluation.

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10. STAKEHOLDER CONSULTATION

This section outlines the major findings of the consultations undertaken with regards to the proposed tourist resort development project in Aanugandu Falhu in North Male’ Atoll.

10.1 KEY STAKEHOLDERS

The key stakeholders identified as per the TOR of the EIA for undertaking stakeholder consultations include;

1. Ministry of Environment 2. Ministry of Fisheries, Marine Resources and Agriculture (Marine Research Center) 3. Kaafu Atoll Council 4. Ministry of National Planning 5. Ministry of Tourism 6. Ministry of Arts, Culture and Heritage 7. National Disaster Management Authority

10.2 STAKEHOLDER CONSULTATIONS

10.2.1 Methods

All stakeholders were met in person at respective ministries and offices as per requirement of the TOR. Initially, meetings requests have been emailed to the stakeholders. Most of them replied after fixing the meetings while others replied by telecommunication after fixing the meeting. Ministry of Fisheries, Marine Resources and Agriculture requested to meet with Marine Research Center as they are a more relevant stakeholder.

Meeting requests and replies from stakeholders are attached in Appendix 10.

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10.2.2 Summary of Outcomes

Following are the key outcomes of the consultations undertaken with key stakeholders;

10.2.2.1 National Disaster Management Authority

Date: 3 July 2019 Time: 10:00 hrs Type: Meeting at NDMA

Summary;

 Concerned about reef damages from sedimentation from development projects involving land reclamation.  Reclaimed areas to be studied at least for 2 seasons to understand the changes in relation to natural weather patterns before implementing coastal protection measures.  Coral reef mitigation measures to be included and followed on a regular basis.  Identify natural hazards and vulnerability and include in a comprehensive Disaster Management Plan.  Current Disaster Management Plans of the resorts are very simple and requires more technical input to cover all aspects of natural disasters and how to act in case of natural disasters.  Current EIAs cover very general information on natural disasters. A proper hazard identification process needs to be included in the EIAs.  Currently working on a Resort Resilient Programme involving workshops, drills, first aid training, awareness programmes.  Need to strengthen NDMA involvement in national development planning.

Participants

Name Office/Institution/Area Contact Number Mr. Maeed Zahir National Consultant, NDMA 7873692 Mr. Abdulla Rafeeu Asst. Project Officer, NDMA 7787700 Ms. Mariyam Shizna Programme Cordinator, NDMA 9641752

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10.2.2.2 Ministry of Tourism

Date: 3 July 2019 Time: 13:00 hrs Type: Meeting at MOT

Summary;

 The EIA must strictly follow EIA Terms of Reference approved by EPA.  Construction permit must be sought upon approval of the EIA from EPA.  All detailed drawings must be approved from MOT.  Must corporate with MOT regarding monitoring trips to the site.  The development must be undertaken as per the approved development plan, if any changes are brought or plans to be brought, it has to be initially approved from MOT.  The proponent must obtain relevant permits from other government authorities including RO plant registration, power plant operation permit, fire safety, etc.  The EIA Decision Statement must be communicated to MOT while applying for construction permit.

Participants

Name Office/Institution/Area Contact Number Mr. Mohamed Sinan Environment Section, MOT 9685119

10.2.2.3 Ministry of Environment

Date: 8 July 2019 Time: 11:00 hrs Type: Meeting at MOE

Summary;

 No major additional requirements except for the approved EIA TOR  Water and sanitation services must in line with national guidelines  The development requires largescale landscaping, hence, the sources of trees and plants must be from verified and approved sources.

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 Solid waste must be disposed of in accordance with regulatory requirements implemented by EPA.  All major development works involving potential environmental impacts must be carried out during calm weather,  Any potential dive locations within the project area must be documented.  Recommend to undertake a reef rehabilitation programme as an important mitigation measure against environmental impacts from the project.

Participants

Name Office/Institution/Area Contact Number Mr. Ahmed Anwar Asst. Director, Planning and Strategic 3018362 Development, MOE

10.2.2.4 Ministry of Arts, Culture and Heritage

Date: 9 July 2019 Time: 11:00 hrs Type: Meeting at Heritage Department

Summary;

 Main focus of the Heritage Department is on inhabited island historical, cultural and traditional sites.  No historical information on wrecks, artefacts or any other relevant material from Aanugandu Falhu.  Hence, there is no significance in the lagoon and no major concern regarding the project development in the lagoon.  Immediately notify Heritage Department when an artefact is found from the site during development.  Based on historical and cultural significance, if a developer wants a relevant component to be incorporated in the resort development, the Heritage Department will assist technically.  A list of cultural and historical significance sites are available from the department’s website.

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Participants

Name Office/Institution/Area Contact Number Mr. Hassan Mohamed Information Officer, Department of 7497386 Heritage, Ministry of Arts, Culture and Heritage

10.2.2.5 Marine Research Centre

Date: 9 July 2019 Time: 12:00 hrs Type: Meeting at MRC

Summary;

 Currently Maldives is on watch alert for a potential coral bleaching event according to NOAA Coral Reef Watch (Scenarios are attached in Appendix 11).  Hence, coral reefs may be subject to coral bleaching event.  According to the scenarios, the southern part of the Maldives is under watch alert.  It may take between 5 – 8 weeks to come to normal condition.  It is important to maintain baseline data for comparison purpose during and after development.  Relocate live corals to safer areas from construction areas such as water villas.  Consider further reclamation to coincide with the watch alert period to come to normal conditions in order to reduce stress on coral reefs.  Sewage outfalls must be in a location that have high mixing potential and do not return back to the reef or shore.  Monitor sedimentation on the reef.  Undertake a coral rehabilitation programme as part of the development.

Participants

Name Office/Institution/Area Contact Number Ms. Hana Amir Marine Biologist, MRC 7860927 Mr. Ahmed Najeeb Senior Research Officer, MRC 7901147

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10.2.2.6 Ministry of Planning

Date: 14 July 2019 Time: 10:00 hrs Type: Meeting at Ministry of Planning

Summary;

 The ministry is currently developing a national policy on resort development projects involving land reclamation.  The ministry is also currently engaged with MOT in allocating appropriate bed capacities for the country in line with national development priorities.  The ministry is engaged in developing a framework for leased lagoons for tourist resorts that have not yet started work.  Since major land reclamation has been completed for Aanugandu Falhu project, no major concerns with regards to the project development.  Ensure that appropriate coastal protection and environmental mitigation measures are undertaken during project development.  Given that the reefs of the country are currently under stress, it is important to undertake a reef rehabilitation programme.  The source for the coral rehabilitation programme must be documented.  It is important to understand the recovery of coral reefs from stress and how corals behave in stress condition and how stress affects coral growth by communicating with an established institution such as Bikoka University segment established in .

Participants

Name Office/Institution/Area Contact Number Ms. Riyaz Mansoor Deputy Minister, Min. of Planning 3004188 Mr. Anwar Ali Min. of Planning 3004188 Ms. Nafha Aujaz Min. of Planning 3004188 Ms. Fathimath Shaheen Min. of Planning 3004188

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10.2.2.7 Kaafu Atoll Council

Date: 14 July 2019 Time: 13:00 hrs Type: Meeting at Kaafu Atoll Council Secretariat

Summary;

 Council seeks CSR support from such development projects undertaken in the Atoll for socio-economic development of the islands.  The project will bring a number of benefits to the Atoll in terms of employment as well as social and health benefits.  Council is not directly related to the proposed project and do not have information regarding such development projects undertaken in the Atoll.  Given that the lagoon is located close to tourist resorts, there is no information that the lagoon has been used by fishermen for fishing.  There is good support from tourist resorts in the Atoll communities (particularly located close by) development activities through implementation of some assistance programme and projects.  The Council is ready to engage with the project in terms of seeking CSR support for local activities such as Quran competitions, education programmes, training programmes, Atoll-wide recognition programmes, etc

Participants

Name Office/Institution/Area Contact Number Ms. Rauf President, Kaaf Atoll Council 7793121 Mr. Ahmed Firag Zimmadhaaru Veriya, Kaaf Atoll 7811910 Council Ms. Aminath Arushy Asst. Director, Kaaf Atoll Council 7971667

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11. ENVIRONMENTAL MONITORING

11.1 BACKGROUND

Environmental monitoring is the systematic measurement of key environmental indicators over time within a particular geographic area (World Bank, 1999) and it is an important part of the whole EIA. It ensures that how the project has or is impacting the baseline environmental conditions that have been assessed as part of the EIA. It identifies the degrees and magnitudes of the predicted environmental impacts for the project are felt on the environment as a result of project implementation. Thus, it will help in implementing the mitigation measures that are already identified in this report or implement further measures if the impacts are identified to be bigger than anticipated.

11.2 MONITING TYPES

The following monitoring types have been considered for the proposed resort development project in the island;

11.2.1 Baseline Monitoring

The baseline environmental conditions and parameters assessed as part of the EIA will be monitored during construction period and subsequent monitoring will be assessed over time to identify changes in the baseline condition and parameters.

The following aspects will be covered in the baseline monitoring;

 Marine environment including general coral reef health, seawater quality, currents and bathymetry  Shorelines and groundwater quality monitoring to be included in construction monitoring to establish baseline

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11.2.2 Impact Monitoring

The biophysical parameters within and around the project area will be measured during the project construction and operation phases in order to understand environmental changes occurred as a result of project implementation. In this regard, most significant environmental impacts identified from the proposed project (construction waste, operational waste) will be addressed as part of the impact monitoring.

The following aspects will be covered in the impact monitoring;

 Presence of sediments in the lagoon  Seawater quality assessment especially quantifying levels including turbidity and suspended solids  Areas where habitat loss has occurred as a result of the project implementation and changes that are taking place

11.2.3 Compliance Monitoring

This monitoring aspect involving continuous recording of specific environmental quality indicators will be incorporated in the overall environmental monitoring programme to ensure project compliance with environmental protection standards currently maintained or applied in the country.

The following aspects will be covered in the compliance monitoring;

 Seawater quality from desalination plant and sewerage outfall locations  Freshwater quality from key outlets  Annual waste report

The primary aim 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.

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11.3 MONITORING REPORT

A detail monitoring report will be compiled based on the data collected for monitoring the parameters included in the monitoring plan. This report will be submitted to the relevant Government agencies for compliance. 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. In addition, more frequent reporting of environmental monitoring will be communicated among the project proponent, the contractors and supervisors to ensure possible negative impacts are mitigated appropriately.

11.3.1 Report Format

The Environment Monitoring Report will be developed in accordance with the following format;

viii) Introduction ix) Aims and Objectives x) Biophysical Environmental Conditions a. Terrestrial Environment (vegetation, groundwater) b. Coastal Environment (shoreline, erosion, currents, bathymetry) c. Marine Environment (coral reef heath, seawater quality) xi) Comparison with EIA Baseline Data xii) Impact Monitoring a. Ground water and seawater quality b. Sedimentation c. Habitat loss including reef damages xiii) Compliance Monitoring a. Water Quality from Intake, Outfall and Product Water b. Waste monitoring xiv) Conclusion and Recommendations

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11.3.2 Frequency

It is important to ensure that monitoring of the environmental parameters mentioned above will be initiated during construction periods, which will be continued throughout the operation life cycle of the project. In this regard, the following measures will be followed.

 During Construction Phase – Every 3 - 6 months  During Operation Phase – Every 6 months for every operation year for 2 years (in- house capacity will be developed after this period to undertake monitoring programme)

11.4 MONITORING PLAN

The following Environmental Monitoring Plan will be followed during the construction phase of the resort.

Monitoring Indicators Baseline Technique Frequency Approx Requirements Reference Cost (US$) Values Coral cover % live coral cover Baseline EIA Qualitative & Every 3 months 500.00 Quantitative during construction and twice a year thereafter Reef fish Population structure Baseline EIA Qualitative & Every 3 months 500.00 populations quantitative methods during construction Fish census and twice a year in operation Marine water Levels of nitrate, Baseline EIA Laboratory Analysis Every 3 months 200.00 quality phosphate, sulphate, during construction salinity, TDS, TSS, and twice a year turbidity, DO, TC and FC thereafter Groundwater Levels of nitrate, To be Laboratory Analysis Every 3 months 200.00 Quality phosphate, sulphate, established during construction salinity, TDS, TSS, turbidity, DO, TC and FC Beach profiles and Topography To be Standard leveling Every 3 months 1,000.00 shoreline established technique during construction and 6 months during operation Currents Seasonal directions Baseline EIA Drogue technique Every 3 months 200.00 during construction and 6 months during operation Bathymetry Varying depths Baseline EIA Eco sounder survey Every 6 months 1,000.00 during construction and operation

Waste generation Amount of solid waste First Waste census Every 3 months 200.00 generated monitoring during construction report during construction Sedimentation Rate of sedimentation To be Sediment traps Every 3 months 1,000.00 established during construction Table 26: Environmental monitoring plan

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In addition to the above environmental parameters that will be monitored during the resort construction, the following parameters have been added in the monitoring plan during the operation of the resort.

Monitoring Indicators Baseline Technique Frequency Approx Requirements Reference Cost (US$) values Solid Waste and Volume/month Per previous Waste census 6 months 500.00 Hazardous Waste operation year Energy production MW/month Per previous Energy audit 6 months 500.00 and consumption operation year

Water production Tons/month Per previous Water log 6 months 500.00 and consumption operation year

Noise levels dB International Sound measurement 6 months 200.00 Standards Product water Quality Established Quality analysis 6 months 300.00 quality during first from MWSC operational monitoring Shoreline Extent of beach erosion Established Standard leveling 6 months 300.00 monitoring for (length) during first and visual beach erosion operational assessments monitoring Groundwater quality Quality EIA baseline Quality analysis 6 months 300.00 from MWSC Marine Water Quality EIA baseline Quality analysis 6 months 300.00 quality from from MWSC wastewater treatment outfall location Table 27: Monitoring aspects during resort operation

11.4.1 Staffing

Throughout the construction period and first two years of resort operation, the implementation of the environmental monitoring will be outsourced. However, the resort will develop its own capacity during that period by training at least 4 staff to undertake all monitoring requirements of the resort under its Environmental Management Plan.

11.4.2 Quality Control Assurance

In order to reduce uncertainty factor and ensure that the monitoring undertaken is assured with quality control measures, the following aspects will be carefully integrated;

 Monitor exact GPS points outlined in the baseline surveys at all times  Employ technical personnel for all monitoring needs  Increase visual presentation of the conditions and compare as an important aspect of monitoring

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 Repeat surveys if unsure  Ensure monitoring is undertaken as outlined in the Monitoring Plan

11.4.3 Commitment

The proponent recognizes the important of environmental monitoring and commits to undertake the monitoring programme during construction and operation periods.

Commitment letter from the Project Proponent is attached in Appendix 9.

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12. CONCLUSIONS

Following are the conclusions with regards to the proposed tourist resort development works to be carried out in Aanugandu Falhu, North Male’ Atoll.

 Tourism is one of the main economic activities in the country and over one fourth of the economy is contributed by the sector. Development of new tourism projects such as proposed tourist resort development project in the lagoon will bring numerous benefits including adding 706 tourist beds in the atoll, create 1064 jobs and indirect employment contribution of around 500 jobs. The proposed projects is also expected to contribute over 190,000 annual tourist arrivals to the country, hence is also expected to directly and indirectly contribute US$ 3 – 5 Million annually to the national economy. Additionally, the project will contribute to local economies of nearby islands.

 Initially Aqua Blue Investments Pvt. Ltd. proposed to reclaim 5 islands and develop a 160- room (320 beds) tourist resort in Aanugandu Falhu based on a concept approved by Ministry of Tourism on 5 December 2016. A total of 15.02ha was proposed to be reclaimed as part of the project. Subsequently an EIA Report for the initial development concept was prepared in February 2017. The EIA was approved by MOT on 16 March 2017.

 Subsequently, the project proponent decided to revise the entire development concept of the proposed project. In this regard, a revised development concept was approved by MOT on 13 March 2018. The revised project included development of 221 guest rooms (442 beds) in two reclaimed islands having 7.5ha and 4ha. In order to get environmental clearance for the revised development concept of March 2018, an EIA First Addendum was prepared in April 2018. The EIA First Addendum was approved by MOT on 30 April 2018.

 Major reclamation works and temporary site setup work initiated upon approval of the EIA First Addendum in April 2018. Reclamation of 2 islands were completed in early 2019.

 Recently, the proponent again decided to revise the development concept, which was approved by MOT on 4 April 2019. The revised development concept of April 2019

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proposed to develop a 353 guest rooms (706 beds) distributed across ‘islands’, which are already reclaimed.

 During the process of finalizing the recent redevelopment concept, a sub-lease agreement was signed between Aqua Blue Investments Pvt. Ltd. and Promonant Pvt. Ltd. for development of the resort in the lagoon as per the new revised development concept. Hence the project will be taken over by the sub-lessee, Promonant Pvt. Ltd.

 The new Project Proponent, Promonant Pvt. Ltd. proposes to develop 353 Rooms (706 beds) tourist resort on existing reclaimed islands with coastal protection of reclaimed islands, all resort facilities, amenities and provision of all necessary services including electricity, water, sewerage treatment, waste management, communication, etc.

 The final revised development concept and coastal modification of the proposed resort has been approved by Ministry of Tourism on 25 and 26 June 2019 respectively. However, this EIA is based on Terms of Reference approved by EPA on 4 April 2019, with no objection from EPA regarding inclusion of final revised development concept components in the EIA report.

 This EIA has been prepared as per new EIA governance structure where all EIAs relating to tourist resort and tourist hotel development projects has been taken back to be implemented under EIA Regulation from December 2018 by EPA.

 According to biophysical assessments undertaken for this EIA report, certain degree of environmental impacts particularly on coral reef and reef fish were found from the lagoon. In this regard, reduced live coral cover and altered reef fish population structure as a result of direct impacts from previous dredging and land reclamation works undertaken as part of the project have been recorded. Additionally, presence of sediments and an increase in rubble content in the reef have also been recorded.

 Most of the environmental impacts occur during construction are of short-term and during operation are of long-term in nature. During construction phase, the most significant impacts that will occur are believed to be from minor land reclamation and construction waste disposal. Also, significance of a number of impacts during construction phase has

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been identified to be moderate such as impacts from construction workers, constructions in the lagoon, reshaping of shorelines and coastal protection. Land excavation has been identified to have negligible impacts as a result of the activity on already reclaimed island.

 During the operation phase, although most of the impacts are of long-term in nature, significance of most of the environmental impacts have been identified to be moderate except for disposal solid waste and wastewater into the nearby marine environment, where they have been identified to be major.

 Mitigation of environmental impacts from the proposed project can be developed as early as the project planning phase and pre-construction as well as during the development and implementation period of the project. In this regard, appropriate designing and citing the facility could enhance environment protection even from the start without much financial considerations. Also, as an important mitigation measure, implementation of an Environmental Management Plan during construction and operation stages have been outlined.

 Alternatives to some of the project components such as no development option, alternative development options, alternative locations and other alternative considerations have been identified and evaluated. The development preference for each alternative has also be stated and justified, where considerations have been given to practicality and effectiveness.

 Environmental monitoring during both construction and operation stages has be given serious consideration in order to assess the degree and magnitude of environmental changes in the biophysical environment, severity of impacts as a result of the proposed development through impact monitoring as well as to identify if certain aspects of the environment are in compliant with required guidelines and standards through compliant monitoring in addition to baseline monitoring of seawater, reef health, shoreline, oceanography, etc. An environmental monitoring programme will be implemented during construction and operation stages of the proposed development and annual reports will be prepared and submitted to the regulator.

 Although there are a number of environmental impacts from the proposed development, some of which has been identified to be significant such as minor reclamation, generation

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of solid waste during construction and operation, most of these impacts can be reduced and minimized by implementation various management and mitigation measures. The effectiveness of these methodologies can be documented by implementing a comprehensive monitoring programme. Also, with very positive socio-economic outlook of the project and considering the overall importance of the sector to the country and its contribution to the national and local economies, creation of employment opportunities, opening of a large marketing opportunity for locally produced goods, it is concluded that the project will bring a number of benefits to the country.

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13. REFERENCES

Environmental Resource Management, 2008, Solaire Direct Drennan Deir, Rev 2

EIA Regulation (Amended), 2017, EPA

Environmental Impact Assessment Report for Tourist Resort Development in Kudafushi Island in Raa Atoll prepared by Dr. Mahmood Riyaz & Mohamed Zuhair in 2014.

Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Bodufinolhu Island, ADh Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2015.

Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Aarah Island in Raa Atoll prepared by Dr. Mahmood Riyaz and Mohamed Zuhair in 2015.

Environmental Impact Assessment Report for Proposed Tourist Resort Development Project in Uthuruboduveli, Uthurugasveli and Hurasveli in Meemu Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2016.

Environmental Impact Assessment Report for Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2017.

First Addendum to the EIA for Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll prepared by Mohamed Zuhair in 2018.

Environmental Impact Assessment for Proposed Tourist Resort Development in Ruhthibirah, Thaa Atoll prepared by Mohamed Zuhair and Ibrahim Shakir in 2018.Handbook on Compilation of Laws and Regulations on Protecting the Environment of Maldives, 2006, MEEW

Maldives Energy Outlook, 2013, Ministry of Environment and Energy

Maldives National Sustainable Development Strategy, 2009, Ministry of Housing, Transport and Environment

Maldives Tourism Act, 1999, Ministry of Tourism, Arts and Culture

Natural Hazard and Vulnerability Assessment Report by UNDP in 2008, UNDP

Paul S. Kench, Robert W. Brander, Kevin E. Parnell, Roger F. McLean (2006): Wave energy gradients across a Maldivian atoll: Implications for island geomorphology, Geomorphology 81: 1-17

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Preliminary Results, Maldives Census 2016, Bureau of Statistics, Maldives

Regulations on Environmental Impact Assessment, 2012, MEE

Regulation on Environmental Damages Liability, 2011, Ministry of Housing and Environment

Regulation for Preparing EIA Report for Tourist Resort, Tourist Hotel, Guest House and Marine Development, 2015, and its First Amendment, Ministry of Tourism

Statistical Yearbook of Maldives, 2013, Department of National Planning

The Strategic Action Plan, National Framework for Development 2009 – 2013, Government of Maldives

Third National Environment Action Plan – 2009 – 2013, Ministry of Housing, Transport and Environment

Tourism Yearbook, 2018, Ministry of Tourism

World Bank, 1999, Good practices: Environmental Assessment, Operational Manual, GP 4.01, and Environment Department World bank, Washington DC.

World Travel and Tourism Council (2015): Economic Impact 2015 Maldives, Harlequin Building, 65 Southwark Street, London, SE1 0HR, UK www.modomaldive.it www.meteorology.mv www.surf-forecast.com www.tide-time.org weatherspark.com

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14. APPENDICES

APPENDIX 1: EIA Decision Statement of March 2017

APPENDIX 2: EIA Decision Statement of April 2018

APPENDIX 3: Approved EIA Terms of Reference (TOR)

APPENDIX 4: Revised Development Concept of June 2019

APPENDIX 5 Revised Coastal Modification Concept of June 2019

APPENDIX 6: EPA Letter to Proponent on TOR

APPENDIX 7: Project Schedule

APPENDIX 8: Seawater Analysis Report

APPENDIX 9: Commitment Letter from Proponent

APPENDIX 10: Communication with Stakeholders

APPENDIX 11: NOAA Coral Reef Watch Scenarios

APPENDIX 12: Communication with Kaafu Atoll Council

APPENDIX 13: EIA Report Contributors

APPENDIX 14: CVs of Consultants

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APPENDIX 1:

EIA Decision Statement of March 2017

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APPENDIX 2:

EIA Addendum Decision Statement of April 2018

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APPENDIX 3:

Approved EIA Terms of Reference (TOR)

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APPENDIX 4:

Revised Development Concept of June 2019

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APPENDIX 5:

Revised Coastal Modification Concept of June 2019

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APPENDIX 6:

EPA Letter to Proponent on TOR

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APPENDIX 7:

Project Schedule

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APPENDIX 8:

Water Quality Analysis

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APPENDIX 9:

Commitment Letter from Proponent

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APPENDIX 10:

Communication with Stakeholders

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1. National Disaster Management Authority

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2. Ministry of Environment

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3. Marine Research Centre

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4. Ministry of Planning

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5. Ministry of Arts, Culture and Heritage

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6. Ministry of Tourism

7. Kaafu Atoll Council

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APPENDIX 11:

NOAA Coral Reef Watch Scenarios

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https://coralreefwatch.noaa.gov/vs/gauges/maldives.php

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APPENDIX 12:

Communication with Kaafu Atoll Council

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APPENDIX 13:

EIA Report Contributors

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Chapter Consultant Chapter Page Contributors Registration Signature (including data Number collection)

Introduction 28 Mohamed Zuhair EIA01/2015

Mohamed Zuhair EIA01/2015

Project Description 46 Ibrahim Shakir

Legislative 93 Mohamed Zuhair EIA01/2015 (Project Setting)

Mohamed Zuhair EIA01/2015

Existing 125 Environment Ibrahim Shakir

Impact and 169 Mohamed Zuhair EIA01/2015 Mitigation 189

Monitoring 225 Mohamed Zuhair EIA01/2015

Conclusions 231 Mohamed Zuhair EIA01/2015

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APPENDIX 14:

CVs of Consultants

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MR. MOHAMED ZUHAIR

PERSONAL DETAILS

Full Name: Mohamed Zuhair

NIC No.: A-045870

Date of Birth: 18 December 1971

Address (Home): H. Eforniumge (South), 4th Floor, Moonlight Hingun/Lonuziyaarai Hingun, Male’ 20¬023, Rep of Maldives Mobile: (960) 777 6800 Email: [email protected]

Marital Status: Married with 3 children

Languages: English (Professional) Dhivehi (Native)

EDUCATION AND TRAINING

 Master of Applied Science (Natural Resource Management), 2003 , James Cook University, Townsville, Queensland 4811, Australia  Certificate in Integrated Management of Coastal and Marine Protected Areas, 1998, South Asia Co¬operative Environment Program (SACEP) in collaboration with Marine Mark Authority, Male’ Maldives  Certificate in Coral Reef Survey Methods, 1998, IOC¬UNESCO/UNEP/IUCN, Global Coral Reef Monitoring Network (GCRMN) in collaboration with Ministry of Fisheries and Agriculture, Male’, Maldives  Certificate in Seminar to Cope with Climate Change in Asia Pacific Region, 1995, Environment Agency, Japan Weather Association Japan  Certificate in Comparative International Studies, 1994, Bath College of Higher Education, Newton Park, Bath BA2 9BN, United Kingdom  B.Sc (Hons) Combined Studies (Major: Environmental Biology), 1994, Bath College of Higher Education, Newton Park, Bath BA2 9BN, United Kingdom  Certificate in Coral Reef Ecology, Theory and Practice, 1990, International Center for Ocean Development and Ministry of Fisheries and Agriculture, Male’, Maldives

EMPLOYMENT

 Freelance Environmental Consultant (2011 - Present) Provide technical consultancy on environment-related work including development of environmental management plans, preparation of Environmental Impact Assessments (EIA) and environmental monitoring plans, field assessment and environmental analysis of potential development sites, technical input for proposed development projects, as well as assist in project development, etc

 Recent Clients: Hotels and Resorts Construction Pvt. Ltd, Leisure Horizons Pvt. Ltd., Amin Construction Pvt. Ltd., Malahini Holdings Pvt. Ltd., Cocoon Investments Pvt. Ltd., Akirifushi Investments Pvt. Ltd., Hanimaadhoo City Hotel Investments Pvt. Ltd., Mr. Ali Zahir, Coral Tree Maldives Pvt. Ltd., Mr. Hassan Moosa, Mr. Ali Moosa, ABN Pvt. Ltd., Cowrie Investments Pvt. Ltd., Oliva Efficient Holdings Pvt. Ltd., Island Channels Pvt. Ltd., Sandcays Pvt. Ltd., Beachrock Ventures Pvt. Ltd., SAS e Senok JV Pvt. Ltd., Group X Pvt. Ltd., Coastline Investments Pvt. Ltd., Sanken Overseas Ltd.(Sri Lanka), Impiana (Lanuan) Bhd. (Malaysia), Gili Lankanfushi, Waterways

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Maldives Pvt. Ltd., Mahogany Pvt. Ltd., Vashugiri Pvt. Ltd., Premier Equity Manager, Ecolife Maldives Pvt. Ltd., Maldives Marketing and PR Corporation (MMPRC), Scaveola Travel Pvt. Ltd., Ebony Pvt. Ltd., Sunny Holdings Pvt. Ltd. (Singapore), B. Island Council, K. Himmafushi Island Council, Ayada Maldives, Maldives Tourism Development Corporation (MTDC), Dhidhoofinolhu Holdings Pvt. Ltd., Amingiri Holdings Pvt. Ltd., K & V Holdings Pvt. Ltd., Funnels Investment Pvt. Ltd., Mr. Abbas Waheed, H. Finimaage Aage, Male’, Mr. Mohamed Wafir, G. Rangireege, Male’ Hima Holdings Pvt. Ltd. North East Pvt. Ltd., Residency Resorts Male’ Pvt. Ltd., Batch Construction Pvt. Ltd., DAMAS Real Estate, Apollo Holdings Pvt Ltd., Westore Pvt Ltd., INSA Pvt. Ltd., O Blu at Helengeli, Aqua Blue Investments Pvt. Ltd., Indus-Resorts Maldives (Singapore), Sea Cross Maldives Pvt. Ltd., Kandinma Holdings Pvt. Ltd., EyeCare Pvt. Ltd., Champalars Holdings Pvt. Ltd., Thiladhoo Resorts Pvt. Ltd., Hurasfaru Holdings Pvt. Ltd., Naainfaru Holdings Pvt. Ltd., Roxy Maldives Resort and Spa, Vakkaru Resort and Spa (Efzy Holdings Pvt. Ltd.), Kuredu Holdings Pvt. Ltd., Pearl Atoll Pvt. Ltd., MEQ Boatyard Pvt. Ltd., WAPCOS (India), Good Catch Pvt. Ltd., Bathala Island Resort, Seal Maldives Pvt. Ltd., Mr. Mohamed Ibrahim, M. Pink Night, CT @ Thilamaafushi Pvt. Ltd, DXYN IQ Pvt. Ltd.Seahouse Resorts Pvt. Ltd., Ali Bey Maldives Pvt. Ltd., Lodester Marine Limited (London)., Amala Maldives Pvt. Ltd.

 Director General (2009 – 2011) Environmental Protection Agency (EPA), 4th Floor, Jamaaluddin Complex, Nikagas Magu, Male’, Rep. of Maldives

Duties: Overall in charge of the Environmental Protection Agency directly reports to Minister and State Minister. Direct, supervise and technical input to the work of the Sections including Environmental Impact Assessment, Biodiversity Conservation, Coastal Zone Management, Waste Management, Water and Sanitation, Physical Oceanography, Resource Valuation and support to implementation of Environmental Protection Act and subsequent Regulations and develop national Environmental Standards, etc.

 Director General (2008 – 2009) Ministry of Environment, Energy and Water (MEEW), Fen Building, 3Floor, Ameenee Magu, Male’, Rep of Maldives

Duties at MEEW: Overall in charge of the Environment Section of the Ministry of Environment, Energy and Water mainly responsible for general policy direction and technical support as well as office administration, finance and support to personnel and staff recruitment. Also guidance and support to implementation of international environmental conventions and treaties, technical input to national environmental action plan, national sustainable development strategy as well as implementation of national biodiversity strategy and action plan, technical support to National Commission on Protection of Environment (NCPE), support to implementation of environmental projects such as Atoll Ecosystem Conservation Project, Integrated Climate Change Projects, etc.

 Assistant Director General (2007 – 2008) Ministry of Environment, Energy and Water, Fen Building, 3Floor, Ameenee Magu, Male’, Rep of Maldives

Duties: Overall in charge of biodiversity conservation, policy advice and technical guidance on environmental management in the Maldives, guidance on implementation of Environmental Impact Assessment in the Maldives, implementation of international environmental conventions, technical input to national environmental action plan, national sustainable development strategy, etc.

CONSULTANCY WORKS UNDERTAKEN (2015 – PRESENT)

 Environmental Impact Assessment Proposed Tourist Resort Development on Ookolhu Finolhu Island, , Maldives, 2015  Environmental Impact Assessment Proposed Harbour Development in Himandhoo Island, AA Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Tourist Resort Development in Kottafaru Island, Raa Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Harbour Rehabilitation in Thoddoo Island, AA Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Tourist Resort Development in Aarah Island, Raa Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Coastal Protection Measures in Plam Beach Resort and Spa,

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Lh. Atoll, Maldives, 2015  and Sunken Excavator near Havodda Island, GDh. Atoll, Maldives, 2015  Environmental Impact Assessment Coastal Modifications at LUX Maldives, South Ari Atoll, Maldives, 2015  Environmental Impact Assessment Coastal Protection Works in Island, Thaa Atoll, Maldives, 2015  Environmental Impact Assessment Coastal Protection Works in Island, Thaa Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Mixed Use Residential Complexes in Hulhumale’, Maldives, 2015  Environmental Impact Assessment Proposed 11-Storey Building Development at Thulhaadhooge, Male’, Maldives, 2015  First Addendum to Environment Impact Assessment Tourist Resort Development in Akirifushi Island, Kaafu Atoll, Maldives, 2015  Environmental Impact Assessment Proposed Reclamation and Tourist Resort Development in Bodufinolhu Island, ADh. Atoll, Maldives, 2015  First Addendum to Environment Impact Assessment Proposed Coastal Protection, Modification, Maintenance Dredging, Gili Lankanfinolhu, Kaafu Atoll, Maldives, 2015  Environment Impact Assessment Proposed Agriculture Product Development in Hulhudhoo Island, , Maldives, 2015  Environment Impact Assessment Proposed Coastal Protection Works in Island, AA Atoll, Maldives, 2015  Environment Impact Assessment Proposed Mariculture, Hydroponics, Aquaponics and Boatyard Development in Vihamaafaru, AA Atoll, Maldives, 2015  Environment Impact Assessment Proposed Coastal Protection Works in , , Maldives, 2015  Situation Analysis Report Proposed Coastal Modification and Partial Renovation Project, LUX South Ari, ADh. Atoll, Maldives, 2015  Technical Study of Erosion and Coastal Protection Measures Northern side of Island, B. Dharavandhoo, Malrives, 2015  First Addendum to Environmental Impact Assessment: EIA for Coastal Protection Works in Maaenboodhoo, Dhaalu Atoll, Maldives, 2015  Environment Impact Assessment Proposed Tourist Resort Development in R. Filaidhoo Island, Raa Atoll, Maldives, 2015  Situation Analysis Report Proposed Coastal Modification and Partial Renovation Project, LUX South Ari, ADh. Atoll, Maldives, 2015  Technical Study of Erosion and Coastal Protection Measures Northern side of Dharavandhoo Island, B. Dharavandhoo, Malrives, 2015  Second Addendum to the Environmental Impact Assessment Proposed Tourist Resort Development in Akirifushi Island, Kaafu Atoll, Maldives, 2015  Environmental Impact Assessment Tower C of Amin Avenue, Hulhumale’, Maldives, 2016  Environment Impact Assessment Proposed Agriculture, Water Sports and Training Facility Development in Faadhoo Island, Maldives, 2016  Environment Impact Assessment Proposed Tourist Resort Development in Vashugiri Island, , Maldives, 2016  Environmental Impact Assessment Proposed Tourist Resort Development in Sunny Lagoon in South Male’ Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Access Channel and Mooring Area Deepening in B. Fehendhoo Island, Baa Atoll, Maldives 2016  Environmental Analysis Report For Tourist Resort Development in Ethigili Island, Raa Atoll, Maldives, 2016  First Addendum to Environmental Impact Assessment Proposed Coastal Protection Works in Ukulhas Island, AA Atoll, Maldives 2016  Environment Monitoring Land Reclamation Works at Bodufinolhu, ADh Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Tourist Resort Development in Uthuruboduveli, Uthurugasveli, Hurasveli, Meemu Atoll, Maldives 2016  Environmental Impact Assessment Proposed Tourist Resort Development in Maniyafaru Lagoon, South

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Male’ Atoll, Maldives 2016  Environmental Impact Assessment Proposed Beach Nourishment Works at Ayada Maldives, GDh. Mugudhuvaa Island, Maldives, 2016  Environmental Impact Assessment Proposed Beach and Swimming Area Development in K. Himmafushi Island, Male’ Atoll, Maldives, 2016  Environmental Impact Assessment Proposed 11 Storey Building Development at H. Finimaage Aage, Male’, Maldives, 2016  Environmental Impact Assessment Proposed Land Reclamation and Tourist Resort Development in Maavaru Lagoon, North Male’ Atoll, Maldives, 2016  Environmental Monitoring Land Reclamation Works at Akirifushi Island, North Male’ Atoll, Maldives, 2016  Third Addendum to the Environmental Impact Assessment Proposed Tourist Resort Development in Akirifushi Island, North Male’ Atoll, Maldives. 2016  Second Addendum to the Environmental Impact Assessment Proposed Resort Development in Kodhipparu Island, North Male’ Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Aerodrome and Access Channel in the Lagoon near St. Regis Vommuli Resort, Dhaalu Atoll, Maldives, 2016  Environmental Impact Assessment Proposed 20-Storey Rehendhi 5 Building, Male’, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at Hanimaadhoo, HDh. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at Hoarafushi, HA Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Farming Development Project at Aidhoo Island, Baa Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at Villingili, GA. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at , Raa. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at Milandhoo, Sh. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at , Th. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at , Dh. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at , Lh. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Water Production and Distribution Facility at Villingili, GA. Atoll, Maldives, 2016  Environmental Impact Assessment Proposed Tourist Resort Development in the Lagoon Plot 4.155882 / 73.251890, North Male Atoll, 2016  Environmental Impact Assessment Proposed Tourist Resort Development in Amingiri Lagoon, Kodhipparu Falhu, North Male’ Atoll, 2016  Environmental Impact Assessment Proposed 10-Storey Mixed Use Residential Complex in Block D10- 4C, Hulhumale’, Maldives, 2016  Environmental Impact Assessment Proposed Mixed Use Residential Complex in Block C4-3, Hulhumale’, Maldives, 2016  Environmental Impact Assessment Proposed 10-Storey Building with Basement at H. Loveside, Male’, Maldives, 2016  Environmental Impact Assessment Proposed Tourist Resort Development in Dhidhoofinolhu Lagoon, Kodhipparu Falhu, North Male’ Atoll, 2017  Environmental Impact Assessment Proposed Tourist Resort Development in Dhigudhefaru Island, Baa Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Tourist Resort Development in Maarandhoo Island, GA Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Coastal Protection Project at Hulhudhoo Island, , Maldives, 2017  First Addendum to the Environment Impact Assessment Report Proposed Tourist Resort Development in Uthuruboduveli, Uthurugasveli and Hurasveli Islands in Meemu Atoll, Maldives, 2017

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 Environmental Audit Report Powerhouse Registration at Malahini Kuda Bandos, North Male Atoll, Maldives, 2017  First Environmental Monitoring Report Kodhipparu Resort Development Project, North Male’ Atoll, Maldives, 2017  Environmental Impact Assessment Report Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll, Maldives, 2017  Fourth Addendum to the Environmental Impact Assessment Report Proposed Tourist Resort Development in Akirifushi Island, North Male’ Atoll, Maldives. 2017  Environment Impact Assessment Development of Snorkeling Platform at Kandinma Tourist Resort, Dhaalu Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Tourist Resort Development in Kandoogandu and island, Raa Atoll, Maldives, 2017  Environmental Impact Assessment Proposed City Hotel Development in Mandhoo Island, ADh. Atoll, Maldives, 2017  Environmental Impact Assessment Proposed City Hotel Development in Kaashidhoo Island, K. Atoll, Maldives, 2017  Environmental Impact Assessment Proposed 15 Storey Building at H. Dhoovehi, Male’, Maldives, 2017  Addendum to the Environmental Impact Assessment Report Proposed Tourist Resort Development in Akirifushi Island, North Male’ Atoll, Maldives. 2017  First Environmental Monitoring Report Proposed Tourist Resort Development in Akirifushi Island, North Male’ Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Tourist Resort Development in Innhuraa Island, Lhaviyani Atoll, Maldives, 2017  Environmental Impact Assessment Proposed 14 Storey Building at Ma. Alidhooge, Male’, Maldives, 2017  First Addendum to the Environmental Impact Assessment Coastal Protection Works in Kandoodhoo Island, Thaa Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Additional Works at Vakkaru Island Resort, Baa Atoll, Maldives, 2017  Environmental Impact Assessment Proposed Mixed Use Residential Complexes in Blocks C2-1, C2-2 and C2-3 in Hulhumale’ (Hiyaa Vehi Project), Maldives, 2017  First Addendum to the Environmental Impact Assessment Proposed Tourist Resort Development in Bodufinolhu Island, ADh Atoll, Maldives, 2017  Coral Propagation and Reef Rehabilitation Project Proposal Akirifushi Island, North Male’ Atoll, Maldives, 2017  Sixth Addendum to the Environmental Impact Assessment Report Proposed Tourist Resort Development in Akirifushi Island, North Male’ Atoll, Maldives. 2017  First Environmental Monitoring Report Proposed Tourist Resort Development in Filaidhoo Island, Raa Atoll, Maldives, 2017  Environmental Impact Assessment Proposed MEQ Boatyard Development Project, K. Himmafushi Island, Male Atoll, Maldives, 2017  First Environmental Monitoring Report Proposed Tourist Resort Development in Bodufinolhu Island, ADh Atoll, Maldives, 2018  Environmental Impact Assessment Proposed Coastal Modification Works at Kudafunafaru (Noku Maldives Resort), , Maldives, 2018  Second Addendum to the Environment Impact Assessment Proposed Coastal Protection Works in Dh. Maaenboodhoo, Maldives, 2018  Environmental Impact Assessment Proposed 6 Storey Building with Basement Water Tank at Lot 20056 in Hulhumale, Maldives, 2018  Environmental Impact Assessment Proposed Tourist Resort Development in Bodufinolhu Island, Baa Atoll, Maldives, 2018  First Addendum to Environment Impact Assessment Proposed Tourist Resort Development in Aanugandu Falhu, North Male Atoll, Maldives, 2018  Environmental Impact Assessment Proposed Tourist Resort Development in Ruhthibirah, Thaa Atoll, Maldives, 2018  Environmental Impact Assessment Proposed Dredging, Land Reclamation and Coastal Protection for Tourist Resort Development in Maavaru Lagoon, North Male Atoll, Maldives, 2018  Seventh Addendum to the Environmental Impact Assessment Proposed Tourist Resort Development in

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Akirifushi Island, North Male’ Atoll, Maldives. 2018  Environmental Management Plan Proposed Reef Rehabilitation and Development at Muravandhoo Island, Raa Atoll Maldives, 2018  First Addendum to Environment Impact Assessment Proposed Land Reclamation and Tourist Resort Development in Maniyafaru Lagoon, South Male Atoll, Maldives, 2018  Environmental Management Plan Proposed Reef Rehabilitation and Restoration Project Akirifushi Island, North Male’ Atoll, Maldives, 2018  Environmental Impact Assessment Proposed Mixed-Use Multi-Storey Buildings Development at Rasfannu Area, Boduthakurufaanu Magu, Male’, Maldives, 2018

EXTRACURRICULAR

 Registered EIA Consultant (2015) Registration (EIA01/15) at Environmental Protection Agency 3rd Floor, Green Building Male’ Republic of Maldives

 PADI Open Water, Advanced Open Water, Research Diver (1998-¬Present) Sea Explorers Dive School, 2nd Floor, Ma. Thuniveli, Male' 20¬01 Republic of Maldives

RFREES

 Professional Mr. Ibrahim Naeem Director General Environment Protection Agency 3rd Floor Green Building Male’, Maldives Email: [email protected]

 Academic Assoc. Prof. Peter Valentine Head School of Tropical Environmental Studies and Geography (TESAG) James Cook University Townsville, Queensland 4811 Australia Email: [email protected]

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IBRAHIM SHAKIR (SHARK)

Date of Birth: 18 July 1967

Contact Address: Ma Sharky Shark

Koarukendi Magu

Male’ 20-30

Maldives

E-mail: [email protected]

Nationality: Maldivian

Contact no: +9607759695

Qualifications

Associate Diploma of Land information Management Systems

(Surveying) South Australian Institute of vocational Education (1994), Australia

Certificate from the Group Training Course in Hydrographic Survey (international accredited Category B Course) –

Conducted by the Japan International Cooperation Agency under the International Cooperation Programme of the Government of Japan, Tokyo, Japan (1996)

Certificate of participation in Environment Management at Singapore Environmental Management and Engineering Services Pte Ltd (January 2000)

Relevant Experience

Surveying projects

K.Fulmoon 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

K.Velassaru 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

K.Kurumba 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

K.Baros 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

M.Hakuraa Huraa 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

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K.Dhonveli 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

AA.Ehlidhoo 2012 PSM survey to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

N.fushivellavaru 2012 Control and as built survey, after establishing PSM to surveying and land surveying standard to tourist properties of Maldives ref to technical brief 2011.

Gdh.Dhigulaabadhoo Topographic survey and Hydrograhic Survey.

K.Kaashidhoo set-out survey for tourist hotel

B.Vakkaru Topographic survey and Hydrograhic Survey including set-out survey for Back of the house

Laguna Maldives Topographic Survey, Hydrographic Survey, Tree Survey, Set out Survey & Environment impact assessment study.

Konnota Island (Gaafu Dhaal atoll) managed by PCH

Topographic Survey, Hydrographic Survey, Tree Survey and Setout Survey.

Maavelavaru Island (Noonu atoll) managed by Athama Marine

Topographic Survey, Hydrographic Survey and Setout Survey.

Halaveli Tourist Resort (Ari Atoll) / Waterfront Pvt Ltd.

Topographic Survey, Hydrographic Survey, Tree Survey and Setout Survey.

HANDHUFUSHI (Herathere) ADDU Atoll / managed by Yatch tours

Hydrographic Survey of the proposed water villa site

Madoogali Island (Ari atoll)

Topographic survey includes buildings, structures and water villas.

Ariyadhoo Island (North Male’ atoll) / managed by VB

Topographic survey and Hydrographic survey, includes buildings, structures and water villas.

Full Moon Maldives / Universal Enterprises

Topographic survey and Hydrographic survey, includes set-out survey for all buildings, structures and water villas.

Baros island Resort / Universal Enterprises

Topographic survey and Hydrographic survey, includes set-out survey for all buildings, structures and water villas.

Dhigufinolhu island Resort / Universal Enterprises

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Topographic survey and Hydrographic survey, includes set-out survey for all buildings, structures and water villas.

Palm Beach Resort, Lhaviyani Atoll, Maldives

Provided all consultancy work including equipment layout design and procurement analysis for all F&B areas and laundry

Ari Beach Resort, Ari Atoll, Maldives

Topographic survey and Hydrographic survey, includes set-out survey for all buildings, structures and water villas.

Coco Palm Resort, / Sunland Travels, Baa Atoll, Maldives

Provided all consultancy work including equipment layout design and procurement analysis for all F&B areas, Environment design, Water & Waste Management, Project Management and Laundry Design and Layout in addition, the project included the supervision of the installation of the designed system, surveying and instructing the contractors on construction methodology.

Veligandu Huraa, Maafushivaru (Twin island)

Tree survey, including identification of species and their respective locations through out the island, set-out survey for all structures.

Fesdu Fun island / Universal Enterprises

Reef survey, identification of coral species and condition of the reef with regard to coral bleaching, Tree survey including detailed layout of vegetation line and shoreline, set-out survey.

NakatchaaFushi / Huvafenfushi

Topographic survey, Hydrographic Survey, Tree survey, set-out survey for water bungalows and land villas.

Hilton on Rangali / Crown company

Topographic Survey, Hydrographic survey and set-out survey for water villas, land bungalows, current and wave action surveys, tide measurements for the under water restaurant.

Reethi Rah Resort / One & Only

Environment impact assessment study.

Moofushi island Resort

Topographic survey, including vegetation, shore line, High tide and Low tide line and all structures.

Villivaru & Biyadhoo / Ministry of Tourism

Environment impact assessment study for the bidding project includes Plant identification survey, soil contamination survey, Ground water monitoring,

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coral diversity and abundance survey, coastal erosion survey, sediment movement and setting studies, beach profiles and land topography survey.

Mushimas Migilli / Dhoani Migilli

Environment impact assessment study including Harbour development.

Keekimini / Fisheries Project

Environment impact assessment study including, Harbour development and set-out survey for infrastructure development.

Hudhufushi island Resort / Abdul Rauf

Topographic survey and Hydrograhic Survey including set-out survey for all buildings and villas.

Ministry of Health, Malé Maldives

Development of a master plan for the provision of safe, adequate and affordable freshwater for Malé (Maldives) including the designing of processes to harness and distribute water on a commercial basis. Includes study on sustainability of utilizing the freshwater aquifer of Malé as well as utilizing airport runway and a loating collector (shallow lagoon) for rainwater catchments vis-à-vis desalination of seawater.

Hinnavaru island, Lhaviyani Atoll, Maldives

Provision of a wastewater collection and disposal systems for a densely populated island.. Design to overcome the problems associated with a high water table and flat low lying island with limitations for proper gradients.

Maadhoo island, Maldives

Environmental impact study on Harbour Development and Recreational Boating Activity for the Management Kandooma island Resort, Republic of Maldives.

Fuah Mulaku

Hydrographic study and Environment impact study on harbour development and commercial boating activity.

Mirihi island Resort

Hydrographic Study, Land survey / and Environmental impact assessment on harbour Development.

Hebadhoo island Resort

Hydrographic Study and Environmental impact assessment on harbour Development.

Embudhoo Finolhu island Resort / Taj

Hydrographic Study and Environmental impact assessment on harbour Development.

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Shaviyani Atoll (all inhabited islands)

Hydrographic Study and Environmental impact assessment on Harbour Development.

Hulhumeedu island

Hydrographic Study and Environmental impact assessment on Harbour Development.

Kulhuduffushi island Harbour

Hydrographic Study and Environmental impact assessment on Harbour Development.

Dh.Eboodhoo/Olhuveli

Topographic survey and Hydrograhic Survey including set-out survey for all buildings and villas.

Gdh.Gazeera

Topographic survey for resort construction

ADh.Athurugaa

Topographic survey and Hydrograhic Survey

AA.Thundufushi

Topographic survey and Hydrograhic Survey

Ha.Uligamu

Topographic survey and Hydrograhic Survey including set-out survey for buildings.

STO Building

Set-out survey in Male’,Maldives.

Velaanaage office Building

Set-out survey in Male’,Maldives.

K.Giraavaru

Topographic survey for Resort Construction

Ga.Handahaa

Topographic survey and Hydrograhic Survey including set-out survey for all buildings, Beach Villa and Water Villa.

N.Huivani

Topographic survey and Hydrograhic Survey.

N.Minaavaru Page | 292

Topographic survey and Hydrograhic Survey.

Gdh.Baulhagilaa

Topographic survey and Hydrograhic Survey.

Rendheli Island (Noonu atoll) managed by INT Management Pvt Ltd.

Setout Survey of Rendheli Island, Noonu Atoll.

Finolhas Island (Baa atoll) managed by Coastline Maldives

Topographic & Hydrographic Survey of Finolhas Island, Baa Atoll.

Kuramathi Maldives (Ari Atoll) managed by Universal Resorts, Maldives.

Topographic Survey (update the site plan) of Kuramathi Maldives, Ari Atoll.

EIA Projects Participated

Environmental Impact Assessment for Proposed Tourist Resort Development on Ookolhu Finolhu Island, Lhaviyani Atoll, Maldives, 2015

Environmental Impact Assessment for Proposed Tourist Resort Development in Kottafaru Island, Raa Atoll, Maldives, 2015

Environmental Impact Assessment for Coastal Protection Works in Veymandoo Island, Thaa Atoll, Maldives, 2015

Environmental Impact Assessment for Coastal Protection Works in Kandoodhoo Island, Thaa Atoll, Maldives, 2015

Environmental Impact Assessment for Proposed Mixed Use Residential Complexes in Hulhumale’, Maldives, 2015

Environmental Impact Assessment for Proposed 11-Storey Building Development at Thulhaadhooge, Male’, Maldives, 2015

Environmental Impact Assessment for Proposed Tourist Resort Development in Bodufinolhu Island, ADh. Atoll, Maldives, 2015

Environment Impact Assessment for Proposed Coastal Protection Works in Ukulhas Island, AA Atoll, Maldives, 2015

Environment Impact Assessment for Proposed Mariculture, Hydroponics, Aquaponics and Boatyard Development in Vihamaafaru, AA Atoll, Maldives, 2015

Environment Impact Assessment for Proposed Coastal Protection Works in Maaenboodhoo, Dhaalu Atoll, Maldives, 2015

Technical Study of Erosion and Coastal Protection Measures for Northern side of Dharavandhoo Island, B. Dharavandhoo, Malrives, 2015 Page | 293

Environment Impact Assessment for Proposed Tourist Resort Development in R. Filaidhoo Island, Raa Atoll, Maldives, 2015

Environmental Impact Assessment for Tower C of Amin Avenue, Hulhumale’, Maldives, 2016

Environment Impact Assessment for Proposed Agriculture, Water Sports and Training Facility Development in Faadhoo Island, Maldives, 2016

Environment Impact Assessment Proposed Tourist Resort Development in Vashugiri Island, Vaavu Atoll, Maldives, 2016

Environmental Impact Assessment Proposed Tourist Resort Development in Sunny Lagoon in South Male’ Atoll, Maldives, 2016

Environmental Analysis Report For Tourist Resort Development in Ethigili Island, Raa Atoll, Maldives, 2016

Environmental Impact Assessment for Proposed Tourist Resort Development in Uthuruboduveli, Uthurugasveli, Hurasveli, Meemu Atoll, Maldives 2016

Environmental Impact Assessment for Proposed Tourist Resort Development in Maniyafaru Lagoon, South Male’ Atoll, Maldives 2016

Environmental Impact Assessment for Proposed Beach Nourishment Works at Ayada Maldives, GDh. Mugudhuvaa Island, Maldives, 2016

Environmental Impact Assessment for Proposed Beach and Swimming Area Development in K. Himmafushi Island, Male’ Atoll, Maldives, 2016

Environmental Impact Assessment for Proposed Land Reclamation and Tourist Resort Development in Maavaru Lagoon, North Male’ Atoll, Maldives, 2016

Environmental Impact Assessment for Proposed Water Aerodrome and Access Channel in the Lagoon near St. Regis Vommuli Resort, Dhaalu Atoll, Maldives, 2016

Environmental Impact Assessment for Proposed 20-Storey Rehendhi 5 Building, Male’, Maldives, 2016

Environmental Impact Assessment for Proposed Farming Development Project at Aidhoo Island, Baa Atoll, Maldives, 2016

Environmental Impact Assessment for Proposed Tourist Resort Development in the Lagoon Plot 4.155882 / 73.251890, North Male Atoll, 2016

Environmental Impact Assessment for Proposed Tourist Resort Development in Amingiri Lagoon, Kodhipparu Falhu, North Male’ Atoll, 2016

Environmental Impact Assessment for Proposed Tourist Resort Development in Dhidhoofinolhu Lagoon, Kodhipparu Falhu, North Male’ Atoll, 2017

Environmental Impact Assessment for Proposed Tourist Resort Development in Dhigudhefaru Island, Baa Atoll, Maldives, 2017

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Environmental Impact Assessment for Proposed Tourist Resort Development in Maarandhoo Island, GA Atoll, Maldives, 2017

Environmental Impact Assessment for Proposed Coastal Protection Project at Hulhudhoo Island, Addu City, Maldives, 2017

Environmental Impact Assessment Report for Proposed Tourist Resort Development in Aanugandufalhu, North Male’ Atoll, Maldives, 2017

Environmental Impact Assessment for Proposed City Hotel Development in Mandhoo Island, ADh. Atoll, Maldives, 2017

Employment

Managing Director of Beach Rock Investment Pvt Ltd. Ma Sharky Shark, Male’, Maldives.

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