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Appendix 1: Human Rights Watch Letters to Maldivian Government Ministries
Appendix 2: Response from the Maldives Environmental Protection Agency
Appendix 3: Human Rights Watch Letters to the Addu City Council and the Kulhudhuffushi City Council
Appendix 4: Response from Kulhudhuffushi City Council to Human Rights Watch’s Letter dated June 8
The Maldives is one the most vulnerable countries on earth to the consequences of climate change
Its government has been a strong voice in international forums on climate-related issues
its policies at home belie these calls for global action
Dependent on income from international tourism and anxious to expand its islands through reclamation
recent Maldivian administrations have ignored or compromised on national environmental regulations
been unwilling to enact and implement environmental safeguards
and neglected the concerns of local communities while pursuing development projects
This has been harmful to residents already at risk from the effects of changing weather patterns
Maldives government officials say that reclamation is necessary for a country with a growing population and limited land and assert that the planned purposes—harbors
and artificial islands for tourist resorts and guesthouses—are crucial to the nation’s economic development
the government’s failure to enforce environmental protection laws has damaged—sometimes irrevocably—livelihoods from fishing
and other work that is dependent on reefs and wetlands
Poorly regulated development has stripped islands of natural resources and deprived communities of access to fresh water
This report describes how the Maldives government’s failure to consult local communities and to adequately mitigate the impact of reclamation and other development projects has harmed island residents
Our research is based on interviews with residents in the northern Maldives island of Kulhudhuffushi and Addu atoll in the south
They described damage to homes and businesses from worsening flooding
and the substantial loss of income from the destruction of natural resources as a result of development projects implemented without adequate regard for environmental protection.
the government overrode environmental regulators and buried 70 percent of the island’s mangroves to construct a new airport
The loss of the mangroves harmed already at-risk local communities
Five years later the government has still not provided compensation and has pursued other development projects that have damaged the reef
One small business owner described the economic impact
“We used to grow bananas—the trees were torn up for development,” she said
Development to us means imported fruits no one has the money for.”
Satellite imagery comparison between July 7
2022 shows the area impacted by the construction of the Kulhudhuffushi Airport in the Maldives.
Although the Maldives has adopted several laws to prevent such harm
the Environment Protection and Preservation Act mandates environmental impact assessments (EIAs) for all development proposals
many projects are preapproved by the government
the Maldives’ primary environmental regulatory authority
is not independent but operates under the minister of environment
It lacks the resources to carry out monitoring to ensure that projects heed required mitigation recommendations
Climate change is an immediate existential threat in the Maldives
with 80 percent of the islands less than a meter above sea level
and many experiencing acute shoreline erosion
The Maldives government has committed to action on climate change and has sought financial support for adaptation
Countries and institutions providing climate financing should continue to do so but also require the Maldives government to enforce its own environmental protection laws
ensure independent oversight by the Environmental Protection Agency
International climate finance donors should require robust evaluation of reclamation and other development projects for potential harm
and press for implementation of appropriate mitigation measures
Human Rights Watch conducted research into the human rights consequences of development projects on Kulhudhuffushi Island and the southern atoll of Addu between 2019 and 2023
individually interviewing 56 people living on the islands and carrying out group discussions of 7
We also interviewed current and former government officials on these islands and in the capital Malé
We examined environmental impact assessments (EIAs)
photos provided by experts and by local sources
and reviewed local media articles and satellite imagery
Human Rights Watch wrote to the Maldives Ministry of National Planning
Housing and Infrastructure; the Ministry of the Environment
Climate Change and Technology; the Environmental Protection Agency; and the island councils of Kulhudhuffushi and Addu
The responses we received are included in the appendix
The Republic of Maldives is an archipelago comprising 26 atolls and 1,192 islands
It is the lowest-lying and one of the most geographically dispersed countries on earth
Mohamed Nasheed, Maldives’ first democratically elected president, took office in 2008 and highlighted the risks the climate crisis posed to the Maldives.[5] Nasheed was ousted in 2012 and replaced by Abdulla Yameen Abdul Gayoom in 2013
Environmental issues fall under the Ministry of Environment, Climate Change and Technology.[13]
A member of a Malé-based environmental organization told Human Rights Watch:
Governments throughout the world have adopted environmental impact assessments (EIA) as a tool to identify environmental risks associated with development projects. However, despite their widespread use, they often fall short because EIA recommendations are not mandatory and in many places have devolved into box-checking exercises.[19]
Common complaints about the EIA process in the Maldives echo those in other countries: failure to enforce requirements that an EIA be completed before commencing a project; pressure to hasten the timeframe for the EIA; limitations on public consultation; and inadequate monitoring after completion of the project.[20] Another critique of EIAs is their short-term time horizon
and failure to consider the long term—for example
sea-level rise and other effects of climate change that are expected to accelerate as the century proceeds
He said it “will take years for it to become normal
We still haven’t recovered from the [last reclamation] project.”
The EIA also noted that loss of coconut palm trees would also have a negative impact for the local community
The administration then amended existing regulations to permit reclamation in Kulhudhuffushi’s protected mangrove forest.[37] Work commenced on October 28
Bulldozers buried the island’s mangroves to create the airport
The women of Kulhudhuffushi said that the palm and mangroves’ destruction had cost them income they needed for their children’s schooling among other costs.[44] Others said that the airport had increased expenses. “All the palm trees were also cut down because now we have ‘development,’” one woman said. “We can’t collect wood, can’t fish, can’t get coconuts from the forest. Now we have to buy them.” [45]
Today farmers who depended on the forest said they had not only lost income, but some of them living near the site had lost their homes. “Development has brought some good things, like the sewage system,” one farmer said. “But it should not be by burying coconut palms and mangroves for an airport.”[48]
While some residents who spoke with Human Rights Watch supported an airport, saying it had improved accessibility for people in urgent need of medical attention, others said the money could have been better spent. [49] As one resident put it: “For health care, islands need hospitals, not airports.” [50]
In response to questions from Human Rights Watch, the Kulhudhuffushi City Council also said that n0 measures have been implemented to protect the remaining mangroves on Kulhudhuffushi Island because the EIA had required the developer or ministry to implement the specified measures, but the Ministry of Environment had not provided the necessary resources to do so.[51]
While the airport opened in 2019, other aspects of the project were not completed at the same time. A road that encroaches on the buffer zone was under construction as of June 2023. Environmental activists have complained that the road could damage the ridge and increase flooding.[52]
the land use plan had not been approved and no EIA had been done
the agency ordered a halt to the road construction while it investigated
In a joint letter signed in March 2022, a coalition of environmentalist groups called on the government to halt the project after the EIA found it would bury 21 hectares of corals and 120 acres of seagrass around the Addu Atoll, a UNESCO reserve, and have an adverse effect on the fishing community and diving centers.[63] Addu is renowned as one of the Maldives’ best diving areas because of its diverse lagoon ecosystem
and are essential for fishing larger species like tuna
The Gulhifalhu EIA found that the project could “significantly degrade and suppress the ability of reefs to recover” and decrease fish populations, and that stakeholder consultations had exposed major reservations about the environmental impact.[82] However
the contract for the project had been signed well before the EIA was carried out
The Maldives government has been a strong voice in international forums on climate-related issues
It is a founding member of the Climate Vulnerable Forum that includes nations most severely threatened by climate change
Financing countries and institutions should support climate change mitigation and adaptation initiatives in the Maldives but should also press the government to demonstrate compliance with its own environmental laws through the steps listed below
The report was written by Patricia Gossman
associate Asia director at Human Rights Watch
based on research she carried out between November 2019 and June 2023
counsel for Human Rights Watch’s Asia Division
Three consultants in the Maldives also contributed to the research but have requested to remain anonymous for their own security
Specialist review was provided by Erica Bower
Production assistance was provided by Robbie Newton
digital publications officer; and Fitzroy Hepkins
Special thanks to all those individuals and organizations who aided in our research and who generously shared their time
Human Rights Watch would like to particularly express appreciation to the residents of Kulhudhuffushi and Addu who shared with us their accounts of the impact of environmental damage to their lives and livelihoods
[1] Elizabeth Overton Colton
“The elite of the Maldives: sociopolitical organisation and change,” PhD thesis
London School of Economics and Political Science
http://etheses.lse.ac.uk/1396/ (accessed July 11
[2] Ibrahim Zuhuree
“Evolution of Tourism Industry in the Maldives,” Maldives Economic Review
http://saruna.mnu.edu.mv/jspui/bitstream/123456789/13650/1/Evolution%20of%20tourism%20industry%20in%20the%20Maldives.pdf (accessed July 11
[3] “Transition to Multiparty Democracy,” Economic and Political Weekly
https://www.epw.in/journal/2008/47/editorials/transition-multiparty-democracy.html (accessed July 11
[4] Ibrahim Zuhuree
[5] Maryam Omidi
“Maldives sends climate SOS with undersea cabinet,” Reuters
https://www.reuters.com/article/us-maldives-environment-idUSTRE59G0P120091017 (accessed July 11
[6] Thomas Shipley
“Grand corruption and the SDGs: Selling the country’s future: the island sales scheme in the Maldives,” Transparency International
http://www.jstor.org/stable/resrep20537 (accessed July 25
[7] Human Rights Watch
“’An All-Out Assault on Democracy: Crushing Dissent in the Maldives,’” August 16
https://www.hrw.org/report/2018/08/16/all-out-assault-democracy/crushing-dissent-maldives (accessed July 25
[8] “Maldives former president Yameen gets 11-year jail term,” Reuters
https://www.reuters.com/world/asia-pacific/maldives-court-finds-former-president-yameen-guilty-corruption-2022-12-25/ (accessed July 25
[9] President’s Office
“100 Day Pledges – Environment,” https://presidency.gov.mv/HundredDays/Pledges/4?lang=EN (accessed July 25
[10] “Maldives Public Expenditure Review: Charting a More Resilient and Prosperous Future,” World Bank
https://www.worldbank.org/en/news/feature/2022/08/03/charting-a-more-resilient-and-prosperous-future-for-maldives#:~:text=Maldives'%20economy%20has%20rebounded%20strongly,tourists%20back%20to%20its%20shores (accessed July 25
[11] “The World Bank in Maldives,” World Bank
https://www.worldbank.org/en/country/maldives/overview#:~:text=Tourism%2C%20which%20accounts%20for%20almost,arrivals%20from%20Europe%20and%20China (accessed July 25
[12] Ibrahim Zuhuree
[13] President’s Office
functions transferred to Ministry of Environment
https://www.po.mv/Press/Article/24625 (accessed July 25
[14] Raif Amyl Jalyl
“EPA will become an independent institution: President Solih,” The Edition
https://edition.mv/news/11037 (accessed July 25
[15] See appendix
“Letter to Human Rights Watch from Maldives Environmental Protection Agency,” received June 19
[16] Human Rights Watch interview with officials at environmental group
[17] Human Rights Watch interview with Director General of the EPA
[18] Human Rights Watch interview with former EPA official
[19] Obaidullah Nadeem and Rizwan Hameed
“Evaluation of environmental impact assessment system in Pakistan,” Environmental Impact Assessment Review
https://www.sciencedirect.com/science/article/abs/pii/S0195925508000292 (accessed July 25
“Environmental Impact Assessments in developing countries: We need to talk about politics,” The Extractive Industries and Society
https://www.sciencedirect.com/science/article/abs/pii/S2214790X16302003?via%3Dihub (accessed July 25
[20] Peter Ho
“Limits of the Environmental Impact Assessment (EIA) in Malaysia: Dam Politics
and Conflict,” Sustainability 2020, 12(24)
10467; https://doi.org/10.3390/su122410467 (accessed July 25
[21] Human Rights Watch online interview with EIA consultant “S,” July 18
See also Erika Techera and Madelaine Cannell-Lunn
“A review of environmental law in Maldives with respect to conservation
fisheries and tourism,” Asia Pacific Journal of Environmental Law
https://www.elgaronline.com/view/journals/apjel/22-2/apjel.2019.02.03.xml (accessed July 25
[22] Human Rights Watch interview with former EPA official
[23] Human Rights Watch online interview with EIA consultant “S”
[24] Human Rights Watch interview with EIA consultant “H”
[25] Human Rights Watch interview with officials at an environmental organization in Malé
Human Rights Watch interview with an official at a environmental organization
[26] Human Rights Watch interview with fisherman
See also “Environment impact assessment reclamation project of Hithadhoo
Maradhoofeydhoo and Feydhoo in Addu Atoll Republic Maldives,” Saruna: Digital Repository of the Maldives National University
http://saruna.mnu.edu.mv/jspui/handle/123456789/7711 (accessed July 25
[27] Human Rights Watch online interview with EIA consultant “M”
[28] Human Rights Watch interview with human rights activist
[29] Human Rights Watch interview with EPA Director General Naeem
[30] Ahmed Azaan
“Information Denied: The Government's Tactics to Suppress the Right to Information in the Maldives,” The Maldives Journal
https://themaldivesjournal.com/46727 (accessed July 25
[31] Human Rights Watch interview with Aiman Latheef (Right to information activist) February 12
[32] Human Rights Watch interview with EPA Director General Naeem
[33] Human Rights Watch interview with “Malika,” Maldives
[34] Human Rights Watch meeting with women working in cottage industries
[35] “Edging towards ecocide
Mangrove destruction in Kulhudhuffushi,” Maldives Independent
https://maldivesindependent.com/environment/edging-towards-ecocide-mangrove-destruction-in-kulhudhuffushi-133925 (accessed July 25
“President vows to complete Kulhudhuffushi airport terminal by year-end,” September 22
https://edition.mv/regional_airports_company/7263 (accessed July 25
[36] “Authorities urged to protect Kulhudhuffushi mangrove,” Maldives Independent
https://maldivesindependent.com/environment/authorities-urged-to-protect-kulhudhuffushi-mangrove-141281 (accessed July 25
2023); “Environmentalists cry foul as Kulhudhuffushi airport project begins,” Maldives Independent
https://maldivesindependent.com/environment/environmentalists-cry-foul-as-kulhudhuffushi-airport-project-begins-133763 (accessed July 25
[37] “Environmentalists cry foul as Kulhudhuffushi airport project begins,” Maldives Independent
[38] United Nations Environment Programme
“Maldives Post-Tsunami Environmental Assessment,” https://maldivesindependent.com/files/2015/03/UNEP-Post-Tsunami-Environmental-Assessment.pdf (accessed July 25
[39] “EIA for the airport development project at HAA Dhaal Kulhudhuffushi,” Saruna: Digital Repository of the Maldives National University
http://saruna.mnu.edu.mv/jspui/handle/123456789/4979 (accessed July 25
[40] See appendix
“Response from Kulhudhuffushi City Council.” Received July 3
[41] “The ropemakers of Kulhudhuffushi,” Maldives Independent
https://maldivesindependent.com/business/the-ropemakers-of-kulhudhuffushi-134013 (accessed July 25
[42] Uthema
“Concerns regarding the project to reclaim Kulhudhuhfushi white mud mangrove by the Government of Maldives,” November 7
https://uthema.org/press-statement-07nov17/ (accessed July 25
[43] See appendix
“Response from Kulhudhuffushi City Council.”
[44] Human Rights Watch interviews with women at council meeting
[45] Human Rights Watch interview with “Fariha,” Kulhudhuffushi
[46] Written response from the Kulhudhuffushi Council to Human Rights Watch
[47] Human Rights Watch interview with Maldives Red Crescent
[48] Human Rights Watch interviews with farmers
[49] Statements made by residents at community town hall
[50] Human Rights Watch interview with environmental activist
[51] See appendix
“Response from Kulhudhuffushi City Council,” received July 3
[52] “Detailed Island Risk and Vulnerability Assessment – HDh
Kulhudhuffushi”,Ministry of Energy and Environment
http://www.environment.gov.mv/v2/wp-content/files/publications/20140629-pub-dirva-hdh-kulhudhuffushi-nov2013.pdf (accessed September 21
[53] Human Rights Watch interview with official at Maldives Red Crescent
[54] Human Rights Watch interview with resident
[55] Human Rights Watch interview with resident Kulhudhuffushi
[56] Human Rights Watch remote interview with members of the Kulhudhuffushi Council
[57] Human Rights Watch remote interview with members of the Kulhudhuffushi Council
2023; Human Rights Watch WhatsApp interview with Maldivian environmentalist
[58]Human Rights Watch interview with official at Maldives Red Crescent
“Coastal flooding and mean sea-level rise allowances in atoll island,” Scientific Reports 12
https://doi.org/10.1038/s41598-022-05329-1 (accessed July 25
2023); “Maldives,” World Bank Climate Change Knowledge Portal
https://climateknowledgeportal.worldbank.org/country/maldives/vulnerability (accessed July 25
“Small Islands,” United Nations Intergovernmental Panel on Climate Change Sixth Assessment Report
https://www.ipcc.ch/report/ar6/wg2/downloads/report/IPCC_AR6_WGII_Chapter15.pdf (accessed July 25
[59] Human Rights Watch interview with officials at Women’s Development Council
[60] Human Rights Watch interview with official at Maldives Red Crescent
[61] Human Rights Watch interview with Ali Nizar
[62] Addu EIA
[63] “Joint Letter to Parliament Speaker Mohamed Nasheed,” Save Maldives
https://savemaldives.net/addu-ecocide/ (accessed July 25
[64] “Maldives Moves Forward with Land Reclamation Project Despite Environmental Concerns,” Yale Environment 360
https://e360.yale.edu/digest/maldives-moves-forward-with-land-reclamation-project-despite-environmental-concerns (accessed July 25
[65] Human Rights Watch interview with former EPA official
[66] Ibid
[67] Human Rights Watch interview with community liaison officer
[68] “Proposed Reclamation Project at Addu City
Maldives,” https://addudevelopment.mv/eia (accessed [DATE])
[69] “Shauna: Land reclamation in Addu will not be stopped,” The Edition
https://edition.mv/news/24104 (accessed July 25
[70] Human Rights Watch interview with Addu City major
[71] Human Rights Watch interview with dive instructor
[72] Human Rights Watch interview with fisherman
[73] Human Rights Watch online interview with EIA consultant “H,” July 18
[74] Human Rights Watch online interview with EIA consultant “H,” July 18
[75] Human Rights Watch interview with official at Maldives Red Crescent
[76] Human Rights Watch interview with EIA consultant “S,” July 21
[77] See appendix
“Response from Maldives Environmental Protection Agency.”
[78] See appendix
[79] Ibid
[80] Human Rights Watch interview with EPA Director General Naeem
[81] “Timeline for Case: 3246/Cv-C/2021
Civil litigation to stop the Gulhifalhu Port Development Project
Maldives,” https://miveshi.com/timeline-en/ (accessed July 26
[82] Ministry of National Planning and Infrastructure
“Environment Impact Assessment Report for the proposed Gulhifalhu Port Development Project Phase 1: Dredging
Reclamation and Shore Protection,” April 2020
https://www.gulhifalhu.mv/wp-content/uploads/2021/12/EIA-V1.pdf
[83] Government of India
Bilateral Brief: “India‐Maldives Bilateral Relations,” July 2022
https://mea.gov.in/Portal/ForeignRelation/India-Maldives_2022.pdf (accessed July 26
“Climate Finance Landscape of Maldives,” 2020
https://unfccc.int/sites/default/files/resource/Maldives.pdf (accessed July 26
[84] Anna Åberg
fragility and multilateral climate funds,” Chatham House
https://www.chathamhouse.org/2022/08/conflict-fragility-and-multilateral-climate-funds (accessed July 16
[85] Matthias Garschagen and Deepal Doshi
“Does funds-based adaptation finance reach the most vulnerable countries?” Global Environmental Change
https://doi.org/10.1016/j.gloenvcha.2021.102450 (accessed July 26
2023); “Toolkit to Enhance Access to Climate Finance,” Commonwealth Secretariat
https://unfccc.int/sites/default/files/resource/Toolkit_to_Enhance_Access_to_Climate_Finance_UPDF.pdf (accessed July 26
[86] Human Rights Watch interview with officials at Transparency Maldives February 14
Reclamation Projects Harm Local Island Communities
Human Rights Watch is a 501(C)(3) nonprofit registered in the US under EIN: 13-2875808
Maldivian (Q2, Malé) has launched scheduled flights to Kulhudhuffushi airport
becoming the first carrier to serve the newly opened airport
state-owned Public Service Media has reported
The first flight from Malé was operated on August 9, 2019, using Dash 8-300 8Q-IAA (msn 582), Flightradar24 ADS-B data shows.
The airport became operational in September 2018. However, the launch of scheduled flights was deferred due to the construction of its passenger terminal.
The airport features a 1,200 x 30 metre primary runway.
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Better transport connectivity will mean more people will have better access to jobs as well as schools, hospitals, and other medical services.
MANILA, PHILIPPINES – The Asian Development Bank (ADB) has approved a grant of $9.6 million to the Republic of the Maldives to expand Kulhudhuffushi Harbor, a project expected to benefit the 8,000 people living on Kulhudhuffushi Island as well as 30,000 people living on nearby islands.
At present, Kulhudhuffushi Harbor is used for passenger traffic, cargo transport, commercial fishing, and transport of agricultural commodities. Increasing the capacity of the harbor to cater to 250 vessels per day from the current 150 vessels will improve connectivity in the northern region and enhance access to the services and amenities available on Kulhudhuffushi Island such as housing, secondary education, quality health facilities, and financial services.
For residents of Kulhudhuffushi Island, located around 270 kilometers north of the capital Malé, the project will generate employment supporting construction activities and increase opportunities in the commercial sector.
ADB, based in Manila, is dedicated to reducing poverty in Asia and the Pacific through inclusive economic growth, environmentally sustainable growth, and regional integration. Established in 1966, ADB in December 2016 will mark 50 years of development partnership in the region. It is owned by 67 members—48 from the region. In 2015, ADB assistance totaled $27.2 billion, including cofinancing of $10.7 billion.
Inadequate investment in power grids is holding back developing countries in Asia and the Pacific from embracing the full benefits of an energy transition, including enhanced energy security, the creation of millions of green jobs and the expansion of electricity access.
ADB is a leading multilateral development bank supporting inclusive, resilient, and sustainable growth across Asia and the Pacific. Working with its members and partners to solve complex challenges together, ADB harnesses innovative financial tools and strategic partnerships to transform lives, build quality infrastructure, and safeguard our planet. Founded in 1966, ADB is owned by 69 members—50 from the region.
6 ADB Avenue, Mandaluyong City 1550, Metro Manila, Philippines
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Ruling party says the reclamation project will be inaugurated on November 12 by President Yameen
Council gives permission to cut down trees from the mangrove area ahead of reclamation
EPA instructs the council to stop cutting down trees
Councillor claims the tree-cutting announcement was made due to a “spelling mistake”.
Director General of Regional Airports, Samee Ageel, says the announcement by the council is unlawful and the felling of trees is not allowed as the mangrove is environmentally sensitive and under jurisdiction of the agency
Environment Minister Thoriq Ibrahim signs the decision statement and approves Kulhudhuffushi airport.
Copyright © The Maldives Independent 2025. All rights reserved.